The acquisition of new equipment is like opening a new gift. Everyone is excited about what it can do, how it works, and how it will help the business. Sometimes in the eagerness to get it installed, running, and tested, organizations skip over checking from a safety assessment perspective.
Best case scenario, safety considerations are done prior to bringing new equipment into a plant; however, ‘new’ equipment can mean a used piece of equipment that may have been acquired in haste or in situational circumstances. It’s important to review all safety considerations prior to using an unfamiliar piece of equipment. Each scenario will have its own set of things to check off but a good rule of thumb to remember is: ‘If something is new, be sure to review.’ A good practice is to have an established checklist that can be utilized during the acquisition and utilization process.
Some things to consider with newly acquired equipment are as follows:
- Machine Guarding – Are all guards installed and working properly? Are there unguarded pinch points, laceration hazards, or electrical concerns? Do all mechanical, fixed, and electronic parts work properly? Has a ‘gotcha stick’ been used to check if physical guarding is up to date?
- Training – Have operators and maintenance mechanics been advised on operational and maintenance tasks and any associated hazards? Has a JHA/JSA been established for this new operation? Is manufacturer support available for questions? Are there any affected employees and have they been advised on changes in safety measures such as noise or fumes?
- Energy Required – Have LOTO documents been created to isolate all forms of energy equipment uses, such as electrical, pneumatic and mechanical? Does the increased load on the breaker box create any NFPA or NEC considerations?
- Administrative – What is the PM schedule? Have PPE requirements been evaluated and posted? Are there any industrial hygiene considerations that need to be re-evaluated, such as noise or dust? Are there operators that need to be added to health and safety programs, such as hearing conservation or respiratory fit testing?
- Other Considerations – Are there environmental concerns? What about critical failure analysis?
The primary point of any checklist or inspection is to ensure that we capture any problematic concerns. Each piece of equipment will have its own unique set of criteria, but the discipline in taking the time to evaluate safety, training, and any potential impacts is critical to a responsible business model.
Tuesday, January 22
Forklifts are the most dangerous piece of equipment in general industry. OSHA reports that forklifts are responsible for roughly 85 fatalities and 35,000 serious injuries each year. While most of these injuries are due to improper use, some can be attributed to a faulty condition or poor maintenance. Of all the compliance related violations issued in recent years, powered industrial trucks are in top 10.
When it comes to compliance, two critical things to keep track of are training and inspections.
- Inspections – OSHA requires pre-operation inspections (1910.178(q)(7)).
- Keep a record of pre-op examinations for critical things such as:
- Tires: no significant damage and all lugs are present on wheels
- Warning devices, such as horn and lights, are all working properly
- Lifting mechanisms are free from deficiencies
- Seat and seat belt are present and working properly
- Power is maintained properly, such as fluids for LPG engines, and batteries are kept in working order
- All brakes work properly
- Checklists are often just a paper copy left with the forklift that the operator fills out prior to use and is filed periodically. However, some newer models have an option that prompts an electronic checklist prior to starting and stores it as a record. Rental fleets may offer this option.
- Training is the most important thing when it comes to forklift safety as operator competency can have a significant impact on your safety record.
- Periodically review operator needs for training and ensure the required refresher evaluation is done every 3 years. (1910.178(I)(4)(iii))
- Have a skill matrix for your operators on which equipment they are authorized to operate.
- All equipment will require competency training to see who can operate what
Wednesday, January 23
When it comes to environmental considerations, the amount of compliance related information can be intimidating; however, we can simplify the number of inspections and checklists by asking ourselves “Do we do anything that can potentially impact the environment and should it be something we need to keep an eye on?”. Most environmental inspections are obvious through legislation for your operating license, but checklists and inspections play an important role in environmental compliance. Some examples are:
- Storm Water / Soil – Most facilities will have storm water permitting that determine whether or not there is a potential to release organic or inorganic materials into the natural environment during a rain event. A ‘Notice of Intent’ means that the facility has the potential to expose these materials to rainwater and must be periodically inspected for such exposure. Check with your local jurisdiction for details on what compliance your facility should follow.
- Air Permitting / Emissions – Some facilities may need to report emissions with regards to particulate matter such as having a dust collector on site. Some may need to report VOC’s with regards to an output of machinery or processes. These are often permitted by federal, state, and local authorities and require periodic review and record keeping. Checklists can be used to monitor visual evidence of unauthorized emissions that may result from leaks, defective controls, or filtration. Resources within your community can help you determine thresholds and what needs to be checked. The important practice with ANY permit is to make sure you can back up your compliance with documentation.
- Waste Storage / Shipment – When it comes to waste storage and shipment, there are a number of things to consider. The most important is OSHA’s HAZCOM standard. Are chemical storage areas established and communicated with local fire authorities? Is everything properly stored in accordance with regulations? Is every container properly labeled and are Safety Data Sheets available for chemicals being stored on site or shipped? Has your waste been evaluated by the state or local authorities and registered? Checklists and inspections can provide valuable information on your waste storage scenario and best practices.
- Other Permits – These are usually operation specific and can have a wide range of requirements depending on federal, local, and state authorities. Having a central document or dashboard can create visibility on which permits are required, the purpose of the permits, the dates they cover, and when payments are due. This can act as a checklist to periodically review on administrative compliance to permitting for your operation.
Thursday, January 24
Depending on your operation, there are a number of opportunities to check your workplace’s condition. Since inspections are required, checklists demonstrate that inspections are taking place.
Some inspections are mandatory but some may have been adopted by the company as a best practice. Some examples of mandatory inspections might be the following:
- Fire Extinguishers / hoses
- Cranes and lifting devices such as slings
- Emissions equipment
- Machine guarding
Other inspections that help facilitate a safer workplace may be things that have some regulation tied to them for safe practices or that the corporate office has recognized as necessary hazard preventions such as:
- Emergency lighting and exit routes
- Preventative Maintenance routines
- Ladders and Stairs
- Electrical panel obstruction
- General Safety
Friday, January 25
Types of Checklists and who should perform them
- Ongoing – Supervisors and operators conduct these types of inspections as part of their daily job responsibilities. Such inspections should identify hazardous conditions or out of compliant tolerances. Frequency varies but the primary purpose is to ensure that the equipment or area is safe for use on an ongoing basis and that minimum safety conditions are met.
- Pre-operational – Operators should perform this type of checklist whenever they intend to use a piece of equipment. In the case of new or unfamiliar equipment, an engineer or technician is best suited to review the equipment’s functions to ensure that all items required for start-up are accounted for and in safe working order.
- Periodic – Depending on the type of inspection, a pre-determined schedule is established either through regulation, manufacturer, or facility decision. The important thing to remember here is in maintaining the discipline so that they can serve your workplace in keeping your employees safe. Having a list of facility inspections and their schedules is a good practice in keeping the information centralized for your team to operate from.
It’s important to define when an inspection is to be done, how it’s done, and who does it. Safety Action Teams can be a tremendous resource for doing inspections. It’s good to form a cross functional group for inspections so that different perspectives are presented and bias is reduced. Training is important so that inspectors know what to look for.
The need for inspections is a good opportunity to expose employees to additional development through acquired knowledge and experience. Supervisors are responsible to see that any corrective action from inspections is followed up on and management should commit to the resources required to see that the health of the organization is routinely checked up on with an active inspection culture.