Page 24 - OHS, November/December 2021

OSHA TOP 10
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adequate protection against the particular hazards for which they were designed, are reasonably comfortable when worn under the designated conditions, fit snugly and do not unduly interfere with the movements of the wearer and are durable and capable of being disinfected and easily cleaned.
Workers cannot be protected from the hazards to their eyes and face unless they are actively wearing PPE the entire time they areexposedtopotentialhazards.Inordertoensurethatworkers are most likely to continue to wear eye and face protection for the duration of their shift, be sure to ask for employee feedback. Understand why workers may feel the need to get a break from their PPE. Is it because the lenses fog? Perhaps the fit is not comfortable on the bridge of their nose or back of their ears. Take time to listen to those who are interacting with this PPE the most and find ways to compromise—it could be the difference in your worksite having an injury-free day.
Fall Protection—Training Requirements
Now on to number seven: Fall Protection—Training Requirements (29 CFR 1926.503), our second construction industry standard in the Top 10 Most Frequently Cited Standards list so far. The preliminary data showed that the violations for this standard in fiscal year 2021 fell to 1,666 from the 1,932 violations the previous year.
According to the standard, an employer shall assure that each employee has been trained by a competent person qualified in the following areas:
■ The nature of fall hazards in the work area;
■ The correct procedures for erecting, maintaining, disassembling and inspecting the systems to be used;
■ The use and operation of guardrail systems, personal fall arrest systems, safety net systems, warning line systems, safety monitoring systems, controlled access zones, and other systems;
■ The role of each employee in the safety monitoring system when this system is used;
■ The limitations on the use of mechanical equipment during the performance of roofing work on low-sloped roofs;
■ The correct procedures for the handling and storage of equipment and materials and the erection of overhead protection;
■ and the role of employees in fall protection plans.
The standard also says that when an employer has reason to believe that an employee who has already been trained does not have the understanding and skill required to complete their job safely, the employee can be asked to retrain. Retraining is sometimes required by the standard. The circumstances in which this is necessary include changes in the workplace that render the previous training obsolete, changes in the fall protection systems or equipment, or inadequacies in the affected employee’s knowledge or use of fall protection systems that indicate the employee has not retained the requisite understanding or skill.
Control of Hazardous Energy (Lockout/Tagout)
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produced fabricated products, plastic products and food.
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The sixth most frequently cited standard according to the Under the standard, each SDS should have the following headings
24 Occupational Health & Safety | NOVEMBER/DECEMBER 2021 www.ohsonline.com
Kapust said that OSHA was finding that manufacturing plants were not adequately training their workforce in lockout/tagout (LOTO), properly implementing LOTO devices or periodically inspecting their LOTO devices. Kapust also mentioned that many companies were cited for lacking any semblance of a hazardous energy control program.
In the standard, OSHA requires employers to establish a program consisting of energy control procedures, employee training and periodic inspections to ensure that energy to machinery is properly shut off before a worker attempts to perform maintenance.5 Here’s the key essentials to any LOTO program:
Machine-Specific Procedures. Lockout programs should list each machine under it’s program and detail the steps needed to shut down, isolate, block and secure equipment. This machine- specific procedure should also include steps to replace, remove and transfer lockout/tagout devices.
Training & Audits. Based on the preliminary data from Kapust, training seems to be one of the reasons why many companies end up getting cited under 1910.147. Training should include OSHA requirements, along with specific program elements and machine-specific procedures. Employees should be trained based on three categories:
■ Authorized employees who perform the lockout on machinery and equipment for maintenance
■ Affected employees who do not perform lockout requirements but use the machinery that is receiving maintenance ■ Other employees who do not use the machinery but are in
the area in which a piece of equipment is receiving maintenance Lockout/Tagout Devices. It is of the utmost importance that you use proper lockout devices to keep employees safe. There are a wide variety of products available to fit machinery, switches, pipes, circuit breaker switches, fuse boxes and more. Be sure to spend time finding the right devices for the machinery under
your program.
Hazard Communication
At number five, we have the Hazard Communication Standard, general requirements (29 CFR 1910. 1200.) The preliminary data shows there were 1,947 violations, which is quite the decrease from the amount in fiscal year 2020 when the standard was number two overall in the list with 3,199 violations.
According to Kapust, employers really struggled with some of the key components of the standard which include having a written Hazard Communication program, providing key information in employee training, having safety data sheets (SDS) readily available or having all pertinent information on the SDSs.
According to the standard, employers should obtain or develop a safety data sheet for each hazardous chemical they produce or import. Employers need to have a safety data sheet in the workplace for each hazardous chemical that they use as well.