Page 14 - OHS, September 2024

FACILITY SAFETY
Some Things to Consider in Facility Safety Programs
Facility safety programs are essential for identifying, managing and mitigating various hazards, ensuring compliance and integrating safety into broader management processes.
BY GREG ZIGULIS
People with facility management responsibilities want to be sure they are doing the right things to ensure safety compliance while also effectively managing their other obligations. And they often ask, “What should we be do-
ing?” Some might even wonder if facility safety should really be a priority issue. The real hazards are mostly from operational pro- cesses, right? Wrong!
There are many aspects and nuances to facility safety. For exam- ple, there can be hazards to workers who maintain facilities. There can be hazards stemming from the presence, absence or state of physical structures, passageways and things related to general oc- cupant and visitor safety. And yet other facility hazards can come from ongoing operations like the movement and loading of fork- lifts, facility traffic and warehouse considerations.
Let’s discuss the identification of hazards and requirements, some general considerations and a few items that deserve special attention.
Ways to Approach Facility Safety Issues
First of all, how can someone know what to pay attention to and what requirements apply?
Technical answers regarding OSHA requirements depend upon the industry the organization is in, the exact processes and opera- tions in place, tasks performed by workers, locations of work and other factors. There can be hazards for which there is no specific OSHA standard but for which an employer is obligated to protect workers from under the OSH Act’s general duty clause (or state equivalents), section 5(a)(1). This requires employers to provide a work environment free from recognized hazards that could cause death or serious physical harm.
Organizations should have processes to identify what hazards might exist, what OSHA regulations apply, and what hazards could be newly created. Do you see things that, if something doesn’t go right, might cause someone to get hurt?
To learn about frequent OSHA citations, one can search the osha.gov website using NAICS (North American Industry Clas- sification System) codes.
One can find focused safety checklists on the web and start learning more about what might apply. Many State OSHA program websites have excellent information and checklists. Trade publica- tions often discuss hazards, impending regulations and trending issues. Some companies offer inspection and auditing software that can be tailored to your situation. There are also online subscrip- tions that provide checklists, technical information, discussion fo- rums and other services.
Information available through artificial intelligence (AI) driven searches is getting better. At least one service is geared for use by safety professionals. However, even for-fee AI searches generate incorrect information and must be checked.
Not all hazards or risks are addressed by specific OSHA stan-
dards. Consider referencing safety-related consensus standards; these can provide excellent information. Some are built into (in- corporated by reference) OSHA regulations, although usually not the current version.
ANSI/ASSP Z590.3, Prevention through Design (Guidelines for Addressing Occupational Hazards and Risks in Design and Re- design Processes), is a good standard to know about. It provides a comprehensive approach to the integration of safety into the design and redesign of workplaces, tools, equipment, machinery, substances and work processes.
Consensus occupational health and safety management sys- tems (OHSMS) standards use systems approaches and describe a management framework that people can learn from. They describe processes for hazard identification, assessment of risk and other things. OHSMSs, if adopted, can provide “the glue” between oth- erwise stand-alone safety procedures.
Common Facility Safety Considerations
OSHA regulations apply to persons working in facility safety or facility maintenance just as they do for persons working in the rest of an organization. Obviously, the exact standards that apply de- pend on where people work and what they are doing, but the point is that just because someone has less visibility or a high skill level, does not mean that OSHA does not apply.
This includes requirements pertaining to things like 29CFR1910.147, the control of hazardous energy (lockout/tagout), and many others.
Special Attention
That said, there are some hazards that can center around facility management and facility maintenance functions that require at- tention. Some examples:
Working alone and remotely. Some tasks can result in isolated and hazardous work, such as climbing and work at elevation, or other processes with extra risk when performed alone. Without monitoring or communication with others, bad things happen that might not be discovered until too late.
Contract employees and temporary workers. Some processes
12 Occupational Health & Safety | SEPTEMBER 2024
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