I recently was asked to conduct a mock OSHA enforcement audit at a printing company with a pressman who had just sustained an amputation of a finger down to the first knuckle. This company was expecting a real OSHA enforcement audit to be conducted in the near future. This company wanted to know how they’d likely fare in a real enforcement audit, and they naturally wanted to fix any things wrong with their safety program and plant implementation.
The good news for this company is that they have the paperwork documentation that proves this newly injured employee, along with other applicable employees at the time, received proper training 2.5 years earlier on the proper and safe method of cleaning printing press rollers. This is called the “Inch Safe Service Method”, and it involves pushing the machine inching button to advance the rollers until they stop and the machine is then in the “stop/safe mode”. With the rollers not moving at all (and no one else being able to make those rollers move), the pressman can then safely clean that one section of the rollers. The above inching process is to be completed repeatedly (always cleaning the rollers when they’re not moving at all) until the rollers have been satisfactorily cleaned.
The bad news for the employee is that he was cleaning the press rollers while they were moving and his hand was pulled into the rollers resulting in the finger amputation. Additionally, a second employee was controlling the inching process with a remote device from about 8-10 feet behind the injured employee, and the one controlling the inching could not even see the hands of the employee who was doing the cleaning.
The news is bad for this company on several different levels:
- A long time good employee is now suffering with his injury and he’ll be out of work for a while.
- It appears that this company may have allowed for some time the cleaning of this press to be accomplished in direct violation of the “inch safe service” method that was taught to all their pressmen in 2011. And, the company was not able to produce any employee Safety Policy Violation write-ups that would prove the company disciplines employees who violate the inch safe service method, or who violate any of the company’s other safety rules.
The damage to the employee’s finger is done, and there are likely OHSA enforcement consequences that are yet to come. Now, I’m sure this company will follow-up their safety training with vigorous supervisor enforcement of all their company’s safety rules.
How are machine rollers being cleaned at your company? Is the “inch safe service method” being correctly used at your company, are your machines being locked-out entirely for safety, or are you allowing your employees to “take a risk” by cleaning moving rollers?
Under the guidelines of the Independent Employee Defense, that can be successfully used when an employee has been seriously injured and OSHA citations have resulted and maybe even a civil injury lawsuit, your company must be able to prove that you have a well devised safety program which is effectively implemented. Effective implementation includes both quality safety training and then proof that your company takes action against employees who violate your safety requirements.
Your supervisors must both be knowledgeable of your safety program and everything it requires of your employees, and they must daily audit their employee’s compliance with your safety rules. Since supervisors should be spending time in their department every single day observing and directing production activities, they should also keep a keen eye out for total safety compliance. Non-compliance should result in at least a Safety Policy Violation Notice write-up being completed and signed by both the non-compliant employee and his/her supervisor.
Some of the key items that should be audited and enforced include:
- Guarding: All machine guards and panels must be kept on the equipment and not open or defeated in any way. Older machines that never had guards for hazardous exposure areas must now be equipped with retrofit guards to ensure the full protection of all employees. Safety air nozzle tips that reduce the pressure being expelled from the tips to 30 psi or less are in use by all employees when blowing off equipment.
- Electrical/Maintenance: Lockout procedures are followed, as per the written procedures posted at each plant machine. Inch safe service is followed for all moving parts clean-ups. All electrical panels are labeled and have 36” clear accessibility to their panel fronts, have all switches accurately labeled, and all switch openings are plugged.
- Hazard Communications/Chemical Safety: The newly required GHS Hazard Communications training must be completed (use DVD and materials supplied by ACS, Inc. in September 2013). MSDS/SDS Book is easily accessible, its’ location known by all employees, with both an updated chemical listing and safety data sheets. Both secondary and original containers have readable OSHA compliant labels, and both hazardous chemical and used rag containers are kept closed.
- Personal Protective Equipment: Employees are wearing PPE as per your company’s written hazard assessment. For instance, employees using solvent soaked rags to clean-up equipment are wearing solvent resistant gloves and either safety glasses with side panels or splash goggles. And all employees operating loud equipment (operating at 90 or more decibels) are wearing ear plugs and/or muffs.
- First Aid: All kits are regularly maintained and kept fully stocked. 15 minute eyewash stations are maintained within 10 seconds (without going through any closed doors) to all potential splash sites including nearby all battery charging operations.
- Forklift/Material Handling: The daily maintenance inspection checklist is completed and maintained. Drivers obey all operating rules, including honking at blind intersections, going slow, and lowering the forks all the way to the floor when exiting the lift truck.
- Fire/Evacuation: Evacuation diagram is posted with the location of your outside emergency employee assembly area clearly indicated. Extinguishers are checked monthly (and noted on the back of each unit’s tag) for having clear access, being fully charged, and having a clearly readable sign overhead. Rag container lids are fully closed, flammable liquids are grounded when dispensing, and propane tanks are stored in a proper wire cage or secured to a wall or post when not in use
President and Certified OSHA Trainer
Assured Compliance Solutions, Inc.