Fix Common Compliance Issues

Proper PPE training and use is one of the four safety issues most frequently encountered in manufacturing facilities.

By Vince Plank, CSP, Safety Management Group

Throughout my years as a safety professional, there are specific compliance issues that are found at almost every manufacturing facility. Those issues usually lie in the production or operations departments and the maintenance shop. Here are the four I encounter most often: 

Guards on bench/pedestal grinders: Since the abrasive wheel is continuously diminishing due to use, the work rest and tongue guards must be routinely adjusted to maintain the required spacing. The work rest must be kept within 1/8 in. of the abrasive wheel and the tongue guard must be maintained within 1/4 in. of the abrasive wheel. To keep the grinders in compliance, employees should be trained on these guarding requirements, a poster with the dimensions can be posted near the grinder, and a bench-grinder safety gauge should be installed for employees to check the spacing before use.

Interlocking machine guards: Smaller manufacturing facilities often lack the resources of a full-time occupational safety and health professional, and this can lend to unsafe practices. One of these practices is opening an interlocked machine guard and relying on the PLC logic to perform service or maintenance. Servicing and maintenance activities are specifically defined by OSHA and require de-energization and isolation of energy sources using energy-isolating devices such as disconnects, circuit breakers, and valves. OSHA does not allow the use of push buttons, selector switches, emergency stop buttons, or interlocked guards for service and maintenance activities.

PPE assessment: Many facilities provide and require specific PPE to be worn by all or certain employees. When hazards are present that require the use of PPE, a hazard assessment must be performed and certified. Employees must also receive training on when PPE is necessary; what type is necessary; how to properly don, doff, adjust, and wear the items; PPE limitations; and the proper care, maintenance, useful life, and disposal of the PPE.

Pre-shift inspections for forklifts/powered industrial trucks: Examinations must be performed at least daily on forklifts. While OSHA does not require documentation of pre-shift forklift inspections, it is a best practice to require such documentation. I have been involved with many OSHA inspections and, if the scope of the inspection involves injuries from a forklift, OSHA has requested documented inspections. We’ve all heard the saying, “If it’s not documented, it didn’t happen.” This is one of those instances where it’s a best practice to document the inspection process. EP

For more information, visit osha.gov.

Vince Plank is a Safety Advisor at Safety Management Group, Indianapolis, IN, (safetymanagementgroup.com). He is a Certified Safety Professional with almost 20 years of occupational safety and health experience in general industry and construction. Contact him at VincePlank@safetymanagementgroup.com.