In a recent webinar hosted by insurance and risk-management expert John Schumacher, senior vice president of insurance agency Assurance, participants received a highlight of OSHA safety guides and procedures.
While not meant to be a complete training guide, the webinar revealed the most common OSHA citations and how they can be prevented.
OSHA is looking for specific things within a recycling facility, according to Schumacher, especially administrative records that show the company has a written safety program and has documented safety training.
Inspectors will also look for personal protective equipment, and they’ll look to see whether it’s being properly used. A hazard assessment is also important. For example, does the company have a written policy stating why workers must wear reflective vests inside the materials recovery facility (MRF)? Or why workers must wear safety glasses? Schumacher said these forms and guides are easily found on the internet.
Violations related to respiratory protection are some of OSHA’s most common citations. Schumacher recommended an evaluation by an industrial hygienist, who can decide whether people should be wearing respirators. OSHA inspectors will look to see if the respirators fit properly and if employees have been shown how to use them correctly. This all needs to be documented, he said. Even if a hygienist determines workers don’t need to wear masks, but they want to, they must be shown how to wear them.
Lockout and tagout issues are the most significant safety program a recycling facility can have, said Schumacher. Related injuries are severe and can even lead to amputation or death. If it can move, it can hurt you, Schumacher said, and lockout/tagout is needed. OSHA inspectors will look for proof of annual training, equipment-specific procedures and a written program. The most common reason for a citation in this area is because a facility isn’t using a specific lock for a lockout. A standard padlock used to secure a gym locker or shed won’t cut it.
In addition to the written lockout/tagout training, Schumacher recommended documenting every time the procedure is used, no matter how many times a day it happens. For example, an employee at a single-stream MRF might have to go onto the screen several times a day to remove material clogging the system. That should be documented every time.
Machine guarding is something else OSHA inspectors will look for in a recycling facility. Basically, are workers protected from putting their hands into a moving machine? Schumacher provided several examples of how this can easily be avoided, including by installing a safety rail to prevent someone from falling onto a conveyer belt, or preventing people from reaching up and hitting overhead equipment by guarding all machinery that is 10 feet off the ground or lower. Schumacher said 10 feet is industry best practice – the OSHA rule is seven feet – but other safety experts agree that going beyond the minimum is necessary.
Finally, OSHA inspectors will look at air quality and noise levels. Dust is a primary concern, especially in electronics recycling facilities where there is the potential for heavy metals in the air.
Consequences and benefits
Schumacher said OSHA fines can easily add up and hurt a company’s bottom line. For example, if a facility is cited for contaminants in the air, each contaminant found is a separate fine, possibly equaling hundreds of thousands of dollars.
Schumacher added that a company’s reputation is also at risk during OSHA investigations, which means it is best to always be ready for inspections. A company has 15 days to respond to any violations, but, in the meantime, OSHA will publish a press release, said Schumacher. While OSHA likely does it with the intent to promote safety, a retraction is never issued if the violation is eliminated or changed.
OSHA can show up at anytime if there is imminent danger to employees, a severe injury or death, or a worker complaint or referral from another entity. Inspectors can also show up anytime OSHA is conducting a targeted inspection. As Schumacher points out in the webinar, facility managers have the right to turn OSHA inspectors away. But, he stressed, they will return with a warrant.
In the end, Schumacher said, it’s best to treat safety proactively. He recommended reaching out to an insurance carrier or a third-party consultant for advice. He said safety not only leads to increased well-being among employees, but it can also lead to insurance savings and profits for the company.