Conducting Health & Safety Audits that Protect Employees & Business

1. Conducting Health & Safety Audits that Protect Employees & Business American Society of Safety Engineers (ASSE) Professional Development Webinar

2. INSTRUCTOR David Regelbrugge, CIH, CSP Senior Manager – Environmental Health & Safety ENVIRON 333W. Wacker Drive, Suite 2700 Chicago, IL 60606 312-288-3850 www.environcorp.com dregelbrugge@environcorp.com

3. INTRODUCTION • Why conduct safety audits in the workplace? • Protect employees • The silence of the boardroom • Death in a confined space • Protect business • Significant increase in OSHA citation costs

4. OBJECTIVE • You will be able to: • Identify the basic steps and procedures in a safety audit and inspection • Applies to general industry

5. Introduction Six steps to conduct a safety inspection • Initial research • Opening meeting and walkthrough • Review written programs & records • Detailed walkthrough • Review findings • Follow-up

6. Step 1: Initial Review

7. Initial Review • Prior to arriving on site • Two types of audit • 1. Formal • Software/Company’s own audit form • OHSAS 18001 • Comprehensive • Time consuming • 2. Informal • Walkthrough type audit • Extensive experience required • Only identifies deficiencies

8. Initial Review • Prior to arriving on site (cont.) • Send pre-audit questionnaire • Review data on the facility • Visit the companies web site • Review OSHA Stats • www.osha.gov/oshstats/index.html • Establishment search • Assist in identifying past concerns • Limited

9. Initial Review • Formal & Informal Audits • Checklist available? • Commercial software & checklist • South Carolina OSHA (http://www.scosha.llronline.com/) • Search “Checklist” • South Carolina Department of Labor, Licensing and Regulation.mht • genind.pdf

10. Step 2: Opening Meeting & Walkthrough

11. Opening Meeting & Walkthrough • Initial Meeting & Walkthrough • Meeting • Become familiar with the people and processes • Walkthrough • General conditions and cleanliness • PPE worn when necessary • Signage • Confined space, electrical, asbestos materials, etc. • Noise • Hearing protection worn • Fall protection • Railings where needed-toe boards • Screens over skylights • Fork truck usage • Load handling • Parking with forks resting on the floor

12. Step 3: Review Records & Programs

13. Review Records & Programs • OSHA 300 Log / 300A • Information on serious accidents & injuries • Review the last 5 years • Look for: • Excess injuries (e.g., serious cuts, foreign body in eye, etc.) • Cumulative trauma disorders (CDT’s/Ergonomics) • Sprains & strains to the wrist, elbow, shoulder, back, etc. • Insurance claims • First-aid logs (if available)

14. Review Records & Programs • Accident investigation forms (if available) • Root cause analysis performed? • True follow-up or simply filling out forms • Poor follow-up: • “Employee need to pay attention” • “Employee was careless” • “Employee needs to be more careful” • Good follow-up: • Photographs taken • Multiple groups involved including injured employee • Root cause identified and corrected

15. Review Records & Programs • Common written programs that may be needed • Hazardous materials (asbestos, lead, etc.) • Emergency Action/Spill Response Plan • Fire Protection Plan • Personal Protective Equipment (PPE) hazard assessment • Respiratory Protection Plan • Confined Space Program • Bloodborne Pathogens • Hearing Conservation Program • LOTO • Hazard Communication

16. Review Records & Programs • Hazardous Materials • Asbestos • Lead • Hexavalent Chromium • Benzene • Cotton dust • Others…

17. Review Records & Programs • Emergency Action/Spill Response Plan • What to do in the event of an emergency • Fire, flood, earthquake, severe weather, work place violence, etc. • Should include evacuation maps • May include additional emergency information • Fire extinguisher use • Spill response etc. • Training/drills?

18. Review Records & Programs • PPE Hazard Assessment • All task reviewed • Must be written • Information on how workers will be protected must be described • Safety glasses, steel toed shoes, gloves, respirators, hearing protection, etc. • Signed • Training

19. Review Records & Programs • Respiratory Protection Program • Voluntary use • Appendix D distributed to employees • Mandatory use • Written program available • End of service life change cycle developed • Fit testing • Medical • Annual training

20. Confined space program Site survey performed If confined spaces are on site Permit vs. Non-permitted determined If permitted spaces present Labeled appropriately Entry procedures developed Permits Entry equipment Non-entry rescue Equipment available Training Annual rescue Review Records & Programs

21. Review Records & Programs • Bloodborne Pathogens • Is first aid administered at the facility • Could employees be exposed to bodily fluids • If yes • Written Exposure Control Plan • Annual training • Hepatitis B vaccination offered • Denials documented

22. Review Records & Programs • Hearing conservation program • Noise study completed • Employee exposures above 85 dBA (Dose of 50%) • If yes • Hearing protection available • Audiometric testing performed • Annual training conducted • Exposures > 90 dBA (Dose of 100%) • HP must be worn • Employer investigated administrative and/engineering controls

23. Lock-Out/Tag-Out (LOTO) Regulates the isolation of hazardous energy Electrical, mechanical, pneumatics, gravity, etc. General requirements Written program available Specific energy control procedures (ECPs) available for each piece of equipment Employees must be trained Annual audit performed and documented Review Records & Programs

24. Review Records & Programs • Hazard Communication • Written program available • Inventory of hazardous material completed • MSDSs management • Labeling addressed • Training provided • Requirements of standard & hazards • addressed • Specific hazards addressed

25. Step 4: Detailed Walkthrough

26. Detailed Walkthrough • What to look for: • Unsafe conditions • Unsafe acts

27. Unsafe Conditions House keeping Exits Electrical Fall Protection Stairs Ladders Machine guarding Flammable Storage Fire Protection Emergency showers & eyewashes Material handling Detailed Walkthrough

28. Detailed Walkthrough • General house keeping • Walkways clean, dry and clear • Work materials picked up

29. Detailed Walkthrough • Exits • Well marked & lit • Aisle ways to exits • At least 36” wide • Unobstructed • Unlocked • Open outward

30. Detailed Walkthrough • Electrical • Training • Authorized employees trained • Transforms & Sub-station • Protected • By fence wall etc. • Warning signs present • Electrical wiring • Unexposed • Junction boxes covered • Knock outs in place or blanks installed • GFIs present outdoors & in wet locations

31. Detailed Walkthrough • Electrical (Continued) • Extension cords & plugs • Condition • No splices • Extension cords not to be used for fixed equipment • Not to pass through walls, windows, or doors • Ground on cords intact • Electrical panels • Labeled • Covered • Disconnects label • Area in front of panel unobstructed with at least 36” of clearance

32. Fall Protection All floors openings and platforms 4 feet above ground must be guarded Rails commonly used Standard rail consist of a top rail (42” above surface), mid-rail (21” above surface) and toe board (4” above surface) Rail must withstand at least the minimum 200 pounds top rail pressure with a minimum of deflection Detailed Walkthrough Image credit: MSHA.gov

33. Detailed Walkthrough • Fall Protection (Continued) • If railings or other means are not feasible to protect employees a fall restrain system must be use. • Full body harness with suitable lanyard and anchor • Training

34. Detailed Walkthrough • Stairs • Carry a load of five times the normal live load anticipated • See 29CFR1910.24 for rise and tread dimensions • Angles to the horizontal of between 30 deg. and 50 degrees • Handrails available • Stable • Clean, dry and clear • Emergency escape stairwells • Flammables materials must not be stored here • Emergency lighting and/or illumination required

35. Ladders Fixed Permanently attached Cage required if > 20 feet Broken if > 30 feet Plat forms or ladder climber safety device Rungs must be clean and in good condition Detailed Walkthrough

36. Detailed Walkthrough • Mobile ladders and stairs • Clean and in good condition • Stops/pads present and in good condition • Don’t stand on two top rungs or steps • Non-conductive • Must extend 3’ beyond upper landing for leaning ladders • Use 4 to 1 rule for positioning for leaning ladders • Count number of rungs from ground to top and divide by four, this is how far the bottom of the ladder should be placed away from the wall Image credit: OSHA

37. Machine guarding General rule of thumb “If employees could be caught in or struck by, it should be guarded” A few examples of items that must be guarded: Shafts, belts, chains, pulleys, flywheels, moving arms, rotating cylinders, conveyor belts, etc. Moving parts must be completely guarded i.e., employees can’t reach around, go under, etc. Detailed Walkthrough Image credit: 8020guarding.com

38. Detailed Walkthrough • Machine Guarding (Continued) • If guards can be opened • Must be interlocked • Guards come in all shapes and sizes • Guards must be replaced after maintenance • Guards must be secure • Employees will over ride guards

39. Machine Guarding (Continued) Conveyor machine rollers that cannot be completely guarded must have an emergency pull stop Detailed Walkthrough Image credit: Rockfordsystems.com

40. Detailed Walkthrough • Flammable Storage • Small quantities of flammables (generally less than 55 gallons) • Store in a flammable storage cabinet • Large quantities of flammable materials (>55 gallons) • Stored in a flammable storage room • General requirements for flammable storage room: • Constructed of non-flammable materials • Ventilated – at 6 air changes an hour • Measures in place to contain spills • Explosion proof electrical fixtures • Fire suppression system in place • When dispensing grounding & bonding must be used • “NO SMOKING” posted • A more complete description is available in 29CFR1910.106

41. Fire protection Fire extinguishers must be strategically placed throughout the work area Should be clearly identified Documented inspections Monthly Annually Employees expected to use fire extinguishers must be trained in their use Detailed Walkthrough Image credit: OSHA

42. Detailed Walkthrough • Emergency eyewashes & showers • Must be located in areas where strong acids, bases or other hazardous chemicals are used. • Located within 10 feet or 10 seconds’ of travel time • Unobstructed path • Inspected monthly • document • Tempered water • Able to flush for at least 15 minutes

43. Material handling Aisles Remain open and clear Walkways marked Fork trucks operators trained and licensed. Fork truck inspections completed daily Drivers use horns Trucks equipped with lights & back-up alarms Loads handled and stacked properly Load ratings on mezzanines Speed?? Detailed Walkthrough

44. Unsafe acts Infinite Human behavior can be unpredictable Be on the look out at all times If an unsafe act is observed ask questions Detailed Walkthrough Image credit: Microsoft

45. Review Findings • At the end of the audit • Sit down with client and review finding • Solutions should be offered for any deficiencies found • Client should not be surprised when final report/audit is issued Image credit: Microsoft

46. Step 6: Follow-up

47. Follow-up • All items identified in the initial audit/inspection should be tracked to identify when they have been corrected • Time frame • Weeks or months after the original audit • Responsibility should be assigned at the plant level

48. Conclusion • Effective auditing can reduce injuries and citations, thereby reduce operating costs • Best of all, everyone goes home healthy

49. Questions?

50. YOUR FEEDBACK IS IMPORTANT! Please remember to complete the ONLINE session evaluation form.The link will be sent via email at the end of the day, or you may visit one of ASSE’s Cyber Centers to access the evaluations through SafetyNet .