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Locking In Safety…

Understanding and implementing OSHA-approved safety measures

Last year the Occupational Safety and Health Administration (OSHA) issued more than $750,000 in citations to the metal fabrication industry for equipment-related safety violations. This includes tool usage and guarding issues, control of hazardous energy (lockout/tagout), and electrical safety. These citations do not begin to account for the total cost to metal fabricating shops when considering associated property damage, medical costs, workers’ compensation and insurance increases, lost work time, and lawsuits that often go along with the citations. To avoid equipment-related incidents, you must understand OSHA requirements and have safety programs in place, including those pertaining to tool safety and machine guarding, lockout/tagout, and electricity.

Tool Safety and Machine Guardingmachineguards

Safe tool usage and machine guarding violations were the most frequent and costly citation areas last year. The first thing that you must do is assess the specific hazards by evaluating each piece of equipment. If the machine is new, determine all points of operation, pinch points, and areas that require protection. Ensure that all required guards are in place, and replace any missing guards before allowing anyone to use the equipment.

If you have an older machine that needs guards, you must first determine if the machine is still made. If it is, contact the manufacturer and ask for information on the current guards supplied with new machines. Purchase or replicate the new guard configurations to provide protection, and discard any equipment that cannot be guarded adequately.

After you have assessed the hazards and have adequate guards on your equipment, you can then develop your safety program. Equipment operators must leave the guards on at all times unless the equipment is locked out. Include in your safety program your policy on removal of guards, including who is authorized to do it, and the required lockout/tagout procedures. Also include discipline for employees who remove or bypass guards.

Next, explain the function and purpose of the guards to each employee. Managers and employees must be familiar with the proper guards so they can recognize when something is missing. Without knowledge of the safety program and the purpose and function of the guards that protect them, employees are more likely to bypass or remove them. Remember that a successful training program is always time and money well spent; studies have shown a $4 to $6 return for every dollar invested in safety and health.

Lockout/Tagout Safety

tagoutFailure to follow safe lockout/tagout procedures also accounted for a significant percentage of citation dollars. An effective lockout/tagout program is especially critical because the type of accident it is meant to prevent typically is severe and can result in crushing, amputation, struck-by, or electrocution injuries. OSHA requires you to identify the practices and procedures necessary to shut down and lock out or tag out machines and equipment; provide locks; and train employees on their role in the lockout/tagout program. Also, conduct periodic inspections to maintain or enhance your hazardous energy control program. The No. 1 citation in this area is lack of an effective written program.

Assess hazards by first identifying the lockout requirements for each piece of equipment used, serviced, and maintained at your facility. All energy sources must be documented, including direct and hidden sources. Documentation must include the hazard posed, the magnitude of danger, any special or unusual conditions, and the correct isolation methods and required devices.

About 95 percent of all lockout/tagout citations involve companies’ failure to have a formal program in place. The energy control or lockout/tagout program must be written and must include your hazard assessment, devices to be used, personnel authorized to perform lockout/tagout, enforcement policy and training methods, and the method for auditing and updating procedures. You must develop written procedures for shutting down and locking out each machine. Except in emergencies, each lock/tag must be removed by the person who put it on, and each employee must have his or her own locks and tags. Make sure your written program accounts for situations when servicing lasts longer than one shift, when contractors are involved, or when a group of employees services a piece of equipment.

The training program must consist of effective initial training and periodic retraining. You must have certification that training has been given to all employees covered by the standard. The training each employee needs is based on the relationship of his or her job to the machine or equipment being locked or tagged out. OSHA identifies three types of employees: authorized, affected, and other.

1. Authorized employees are those responsible for implementing the energy control procedures to perform service and maintenance. They must understand the need for lockout/tagout procedures and be able to recognize hazardous energy sources. They also must have a clear understanding of the means and methods of controlling the various types of energy sources and how to verify that each energy isolation is effective.
2. Affected employees are those who operate or use equipment on which servicing or maintenance is being performed under lockout, or those who work in an area where servicing or maintenance is performed. Affected employees must ensure that they can recognize when a lockout/tagout procedure is being implemented. The goal of this training is simple: Whenever there is a lockout or tagout device in place on an energy-isolating device, the affected employee must leave it alone and make no attempt to operate the equipment.
3. All other employees must be able to recognize when the control procedure is being implemented and understand that they must leave lockout/tagout devices alone and not attempt to energize or operate the equipment.

site-meetingRetraining must be provided whenever there is a change in job assignments, machines, equipment, or processes that present a new hazard; when there is a change in energy control procedures; inadequacies are present in employees’ use of the energy control procedure; or at least every three years.

Periodic inspections must be performed annually on each energy control procedure at your site, and the employer must certify that the periodic inspections have been performed. The certification must identify the particular machine, the date of the inspection, the employees included in the inspection, and the name of the person performing the inspection.

Electrical Safety

An average of one worker dies from electrocution on the job every day. Even low-voltage or low-current shock can cause serious harm or death. All of the equipment in a metal fabricating shop operates on 110 V or more and is capable of causing electric shock, burns, or electrocution.

Check your tools and equipment to ensure that the ground prong is present and that cords are in good condition. OSHA requires that live parts of electrical equipment operating at 50 V or more be guarded against accidental contact. Whenever conduit or electrical equipment is in a location where it could be exposed to physical damage, it must be enclosed or guarded. Junction boxes, pull boxes, and fittings must have approved covers. Unused openings in cabinets, boxes, and fittings must be closed.

Flexible cords are vulnerable because they can be damaged by aging, door or window edge contact, staples or fastenings used to hold them in place, abrasion from adjacent materials that they may contact, and various activities in their proximity. Improper use of flexible cords or use of damaged cords can cause shocks, burns, or fire. Whenever possible, use one of OSHA’s recognized hard-wiring methods. OSHA allows flexible cords to be used only for certain applications.

Check your circuits regularly. An inexpensive tester can tell you if the ground iselectrical-6 connected and can also test your ground fault interrupter (GFI) protection. Your safety program must include policies for grounding systems and electrical shutoff device systems. Develop policies for use of ladders and scaffolding around electrical devices. Extension cords have specific current ratings that must not be exceeded or they can overheat and cause a fire without tripping the circuit breaker. Use a qualified electrician for installation and repair of circuits.

Personnel who are at primary risk of electrical hazards are arc welders, those who work with or around electric power tools and equipment, and maintenance and janitorial staff who are responsible for handling electrical issues at your facility. At lesser risk are all other personnel who work with or around other electrical equipment, including lighting, computers, coffee makers, and so forth. Training must be adequate to the needs of each employee depending on his or her specific tasks.

Employees must understand the built-in safety features of electrical systems, including insulation, ground fault circuit interrupters, double-insulated devices, grounding (both of the circuit and the equipment), guarding of live electrical parts, and fuses and circuit breakers.

Employees also must follow safe work practices, such as de-energizing electrical equipment before inspecting or making repairs, correct usage of flexible cords and extension cords, recognition of damaged electric tools and procedures to remove them from use, how to work safely near energized lines, and use of personal protective equipment.

All lockout/tagout devices (locks and tags) must have four key characteristics:

* They must be durable, meaning that they must withstand the environment for the length of the expected exposure.
* They must be standardized according to color, shape, or size.
* Devices must be substantial enough to minimize early or accidental removal.
* They must be identifiable, clearly identifying the person who applied them and warning of hazards should the machine or equipment become energized.

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December 22, 2008 Posted by | Business, Economy, Education, Health & Safety, OSHA Compliance, Uncategorized | , , , , , , , , , , , , , , , , , , , , , , | 1 Comment

Safety update: OSHA announces fit-test procedures

Fabricators as well as other workers may be required to use respirators to protect themselves from inhaling fumes, particles, or dust when performing cutting, grinding, welding, coating, or painting, especially if they are in contact with chrome-containing stainless steel or coatings, which presents the risk of hexavalent chromium exposure.

In cases such as these, respirators must be provided to protect the health of a worker and be selected on the basis of hazards the worker is exposed to. Employers are responsible for establishing and maintaining an effective respiratory protection program, which includes fit-testing for all employees who are required to use one.

The Occupational Safety and Health Administration (OSHA) is looking at fit-testing again, this time with a proposal to add a new fit-test method to its existing standard. The following is a review of the current requirements.

Current OSHA Fit-test Proceduresresp2

Anyone using a negative- or positive-pressure, tight-fitting facepiece respirator must pass an appropriate fit-test that uses an OSHA-accepted protocol. Fit-testing is required before initial use, whenever a different respirator facepiece is used, and at least once a year thereafter. An additional fit-test is required whenever a change in the wearer’s physical condition, such as facial scarring, dental changes, cosmetic surgery, or a significant change in body weight, could affect respirator fit.

A few basic checks must be performed even before using test protocols. The wearer should check for proper chin placement and strap tension, but be sure not to overtighten the respirator. He should make sure it fits correctly across the nose bridge—a respirator should span the distance from nose to chin—and that it doesn’t slip. Along with evaluating fit and respirator position, the wearer also should perform a seal check. If leakage is detected from a poorly fitting facepiece, he needs to try another size of the same model, or another model of respirator.

The workplace exposure level determines what constitutes an acceptable fit and which OSHA fit-test procedure is required. The two types of fit-test methods are qualitative and quantitative.

Qualitative methods rely on a subjective sensation, such as taste, irritation, or smell, to a particular test agent. These test agents include isoamyl acetate, saccharin, Bitrex®, and irritant smoke. Essentially, the wearer puts on the respirator and enters a test chamber. The test agent is then released, and the wearer must determine whether or not he can smell, taste, or feel the agent inside of the respirator during a series of defined exercises.

Quantitative methods use instruments to measure face seal leakage. These protocols are more complex and thorough because they are not dependent on the wearer observing and reporting the presence of a test agent. These protocols are:

1. Aerosol generated from corn oil, salt, or DEH: The wearer enters a test chamber that is isolated from the outside air. A sampling port or probe is inserted into the respirator, and an instrument is used to create a computer record or strip chart showing the rise and fall of the test agent concentration with each inhalation and exhalation. Whenever the concentration inside the mask exceeds 5 percent for half masks, and 1 percent for full-facepiece respirators, the test subject must be refitted and retested. The fit factor is determined by the ratio of the average chamber concentration to the concentration measured inside the respirator for a series of test exercises.

2. Condensation nuclei counter (PortaCount™). This protocol uses a probe with a special sampling device installed on the respirator that samples the air from inside the mask. A probed respirator is required for each make, style, model, and size that the employer uses. These can be obtained from the respirator manufacturer or distributor. Alternatively, the manufacturer also provides probe attachments (TSI sampling adapters) that permit fit-testing in an employee’s own respirator. A record of the test needs to be kept on file, assuming the fit-test was successful.

3. Controlled negative pressure (Dynatech FitTester 3000). This protocol measures leak rates through the facepiece of negative-pressure respirators. To perform the test, the subject closes his mouth and holds his breath, after which an air pump removes air from the respirator facepiece. The facepiece fit is the leak rate through the facepiece, expressed as milliliters per minute. CNP systems have built-in capability to conduct fit-testing that is specific to a work rate, mask, or gender.

For negative-air-pressure purifying respirators, users may rely on either a qualitative or a quantitative fit-test procedure for exposure levels less than 10 times the occupational exposure limit. An exposure level greater than 10 times the occupational exposure limit requires a quantitative fit-test procedure. Requirements for respirators used to protect wearers from certain airborne contaminants, such as asbestos, have their own special fit-test requirements.

Proposed Fit-test Requirement

OSHA’s current proposal is to include an abbreviated Bitrex qualitative fit-test in its respiratory protection program. This emphasizes that OSHA is again focusing on protection programs in workplaces where respirators are required to ensure employee safety and health.

If you need help with your Fit Testing Program, contact one of our Safety Specialists.

December 10, 2008 Posted by | Business, Economy, Education, Health & Safety, OSHA Compliance, Uncategorized | , , , , , , , , , , , , , , , , | Leave a comment

Revisions to OSHA’s Respiratory Protection

Answering 6 common questions can help in selecting the right respirator
The Occupational Safety and Health Administration (OSHA) recently made some changes to its Respiratory Protection Standard 1910.134. It now includes a table listing the assigned protection factors for all types of respirators. Now is the time for employers and fabricators alike to review respirator programs (or determine if they need one) to ensure that everyone in the workplace is properly protected.

The two types of respirators are air-purifying respirators and supplied-air respirators. Air-purifying respirators filter the air from the immediate work area before it enters the lungs. Supplied-air respirators provide clean air from an air line or tank. Each type comes in several styles, such as those that cover half of the face (mouth and nose area), all of the face (referred to as a full face piece), or a helmet or hood. Respirator selection becomes particularly important with air-purifying, or filtering, respirators because the respirator is cleaning the air rather than receiving supplied fresh air.

Answering six frequently asked questions can help employers simplify the respirator selection process.

1. How Do Respirator Filters Work?resp2

Determining the type of respirator needed, whether it is a supplied-air unit or an air-purifying unit like the one shown above, depends on the APF it is assigned.

Air-purifying respirators work by filtering the air before it reaches the lungs. The pores of the filter are small enough to screen out dust and particles. For chemical fumes and gases, the filter contains absorbents such as charcoal that capture the chemicals before they reach the lungs. Some work situations, such as spray painting, require both dust and chemical removal. Most welding applications generate metal fumes or particulate and require filtering to clean the air.

2. What Factors Determine Which Respirator to Use?

To help determine what respirator to use and how long it lasts, OSHA and the National Institute for Occupational Safety and Health (NIOSH) have developed a rating system for respirators called the assigned protection factor (APF). Another new term—maximum use concentration (MUC)—has also been incorporated into the revised OSHA standard.

3. What Are Assigned Protection Factors (APFs)?resp3

APFs are numbers that indicate the level of workplace respiratory protection that a respirator, or class of respirators, is expected to provide to the user. APFs are used to select the appropriate type of respirator based on the permissible exposure limit (PEL) of a contaminant and the level of the contaminant in the workplace. The APF number is the percentage of the contaminant that will be filtered out of the surrounding air.

4. What Are Maximum Use Concentrations (MUCs)?

The selected respirator must keep exposure at or below the PEL. For each specific respirator, the MUC is the largest concentration of an airborne contaminant that the respirator can handle. The exposure level must be measured using OSHA protocol and compared to the MUC for the respirator selected. If the workplace exposure exceeds the respirator’s MUC, a respirator with a higher APF must be chosen.

5. What Do These Revisions Mean to the Metal Fabricating Industry?

Fabricators may be required to use a respirator to protect themselves from inhaling fumes, particles, or dust when cutting, grinding, welding, coating, and painting. If work is done with stainless steel or with coatings containing chrome, there is the risk of exposure to hexavalent chromium, and a respirator may be required. It is important to determine the level of exposure for each chemical produced or used in the workplace, and then ensure that the protection level of every respirator is adequate for the exposure level.

6. What Constitutes an Effective Respirator Program?

First, all airborne hazards in the workplace must be identified and their levels determined. These levels must be compared to the OSHA PELs.

Whenever possible, general or local welding or other exhaust systems should be used to control dusts, vapors, gases, fumes, smoke, solvents, and mists that may be generated. Hazardous materials should be used only in designated work areas that can be ventilated.

If airborne contaminants are still above safe levels after ventilation and exhaust systems have been applied, fabricators must then use respirators to reduce exposure to an acceptable level. Respirators must be approved for each chemical and specific application by NIOSH. Matching the MUC against the measured airborne contaminants ensures selection of a respirator with adequate protection.

testimonial-ad-2Employers should develop written standard operating procedures for the selection and use of respirators. These procedures include when respirators must be worn and who, specifically, must wear them. Welders required to wear a respirator first must have a medical evaluation to be sure that they can safely breathe through the restricted airflow of the respirator.

Once the doctor determines that a welder is medically fit to wear a respirator, fit-testing must be performed to ensure that the respirator fits the shape and size of the face, thereby ensuring a good seal. OSHA regulations list specific protocol for fit-testing.

Everyone must be trained on the correct use and limitations of their respirators. Respirators must be stored in a convenient and clean location, away from contaminants, and must be regularly inspected and sanitized.

December 1, 2008 Posted by | Business, Economy, Education, Health & Safety, OSHA Compliance, Uncategorized | , , , , , , , , , , , , , , , , , , , , | Leave a comment