America was built on innovation and productivity. For example, Henry Ford is known in American history for his ingenuity in boosting productivity through the assembly line. For more than a century, American industry has been looking for ways to get more production out of the 40-hour work week. Usually this takes place by changing the production process or adding a new piece of machinery to the factory floor.
When you change the manufacturing flow, you need to evaluate how those changes can impact workplace safety. A helpful tool in this evaluation process is the “Job Task, Equipment, Process & Engineering Control Assessment.” It ensures that safety is incorporated into the new machinery operation from the start.
First let’s look at the reason for the change. The assessment form on page 67 identifies the following as reasons to change the process: employee safety, hazard exposure elimination or reduction, production improvements, cost factors, environmental considerations, building changes or additions, equipment replacement, incident trends, and regulatory compliance. Companies may add or change machinery for one or more of these reasons.
Once the reason for the change and the related goals are determined, then the safety auditor decides if the change is permanent, or temporary. This is an important factor in the initial setup, safety program requirements, and what will need to be done to meet the requirements of the Occupational Safety and Health Administration (OSHA). Beyond just the basic installation, managers must consider training, energy sources, placement and equipment securement, permanent barriers, guarding, and administrative and engineering controls.
A safety expert or manager can then identify the hazardous exposures related to the equipment, process or job task. The following list provides a good starting point for your evaluation.
Hazardous Conditions, Areas or Points to Consider
• Pinch Points
• Catch Points
• Blades
• Shaft / Belts / Gears
• Flash / Ultraviolent
• Hot Surfaces
• Severe Temperatures
• Traffic
• Pedestrians / Traffic
• Elevated Height
• Bio-Hazards
• Airborne Particles
• Chemical Hazards
• Heavy Lifting
• Repetitive Motion
• Work Surfaces
• Confined Space
• Electrical
• Suspended Load
• Noise / Decibel Level
Once you have determined the hazards related to the equipment, process, or task, then you can look at ways to provide administrative controls, engineering controls, safety training, and identify the personal protective equipment (PPE) that will need to be provided.
The following is a good example of how this process can work based on a real-world setting. I recently completed one of these assessments when a client wanted to improve a stripping process for a coating line. The initial change incorporated a new dip tank and chemical stripping agent. Through the assessment, it was determined that the stripping agent was a health hazard. The first obvious thing to do was change the chemical stripping agent to an agent that was not a health hazard.
The client tried numerous chemical stripping agents, and found that even the more expensive, and advertised as “Safer” chemicals, performed very poorly in comparison to the more hazardous stripping agent. It was determined that none of the chemicals were completely safe, that the more hazardous stripping agent was required for the process, and that administrative and engineering controls, along with training and personal protective equipment would eliminate or control the hazardous exposure.
Working with the client, we then changed the process, added additional ventilation, provided respiratory protection, improved the PPE, and provided safety training. A Job Hazard Analysis was completed and posted at the area of the job task. This serves as a review for employees and documents the safety measures required when performing this task. Signs were also posted to remind employees of the hazards and to enforce the importance of their responsibilities for reducing the exposures.
This example demonstrates that you cannot always select the safest equipment or chemical for the process, but through administrative controls, engineering controls, process controls and safety training, you can reduce or even eliminate the hazardous exposure. The assessment covered in this article assisted in the identification of the hazards. It was then used as a tool to control or eliminate the exposure.
Your safety committee is a great resource for completing this process. The same form can be used when placing a new saw, conveyor, press, or production line into service. The assessment helps in identification of the hazards, and provides a direction for engineering controls such as; guarding, railing, and fencing. It also assists in identifying administrative controls, signage, PPE, and safety training required to reduce or eliminate the hazards associated with the equipment, process or task.
What Signage is Needed for Employee Safety
Given the prevalence of workplace lawsuits, it is important that companies document and put up signage that provides adequate warnings about workplace dangers. This may be needed for certain activities that some managers consider common sense. For example, you don’t want to remove guards when a machine is in operation or energized.
Signage is a great way to reduce liabilities, and more importantly; remind employees of their responsibilities for their safety. Signs are visual cues that improve hazard awareness. I have heard the argument that posting a hazard sign will actually prove that the company was aware of the hazard prior to the accident, and therefore increases the liability. That would be the case, if you were aware of a hazard, and posted a warning sign, without any attempt to reduce or eliminate the hazard.
In the example given previously regarding the chemical stripping agent, we completed the assessment to identify the hazards, and then utilized administrative controls, engineering controls, and PPE to control or eliminate the hazard. After that, signage was installed to remind employees of their responsibilities for their safety. Granted, posting a hazardous exposure sign in the workplace, without attempt to reduce or eliminate the hazard, will certainly create a liability. We know that you cannot eliminate every hazard. You can guard a saw to reduce an exposure, but a non-attentive person can still place their body parts in the area of the blade.
Both OSHA and insurance companies like signage as a way to improve workplace safety. Many of my clients have signage posted at the entrance point into production areas. Most commonly “Eye Protection Required” or “Hearing Protection Required.”
A sign is only as good as the enforcement and focus behind it. You must enforce the signage, once it has been installed.
Through the years, I have witnessed many employees enter into an area that was posted with PPE requirements without wearing the required PPE. Allowing this practice will prove that you, as the employer, were aware of the risk / hazard, and knowingly allowed employees to endanger themselves. In order to prevent this negligence, your supervisors must abide by the signage, and enforce it, or you’re increasing, instead of reducing your liabilities.
Once again, safety signage is a great way to remind employees of their responsibilities for their own safety. This is especially important when there is a language barrier due to a multilingual workforce. In these cases, you should use signage that is understood by the entire workforce within your workplace. New equipment often comes with warning signage, but quite often the signage is only in English. In these cases, you should add signage that uses every language spoken by your workforce. Don’t just assume that the entire workforce understands the warning signs.
When administrative controls, engineering controls, and PPE haven’t entirely eliminated the hazardous exposure, you should place signage in that area.
Examples of areas / hazardous exposures to use signage:
• Areas of high decibels
• Areas of airborne debris or particles, such as dust, chips, and shavings
• Respiratory hazards of airborne particles of chemicals
• Blades, knives, or sharp tool hazards
• Pinch points on presses
• Catch points on the gears and chains of conveyor in-feeds, and out-feeds.
• Rotating parts, pulleys, and drive shafts
• Oxidizing chemical hazards
• Flammable chemical use and storage
• Compressed gas cylinders
• Slip or trip hazard areas
• Heavy vehicle or equipment traffic zones
• Fall hazards
• Ultraviolet, and infrared radiation exposures
• Electrocution hazards; High voltage and electrical panels
• Safety equipment and PPE requirements associated with a particular area or process
• No smoking areas, such as refueling areas
• Egress areas; Evacuation routes and exits
• Fire suppression equipment
• First aid equipment
In closing, remember these keys for proper use of safety signage. When administrative controls and engineering controls do not eliminate the hazardous exposure, you should apply signage. When the hazard merits posted signage, the signage must be enforced by management. And finally, all signage must be understandable, and in the language or languages of the workforce.
Editor’s Note: Jary Winstead is a safety and workplace training expert. He offers his expertise to a wide variety of industrial companies, including the forest products sector. For more information, contact Jary at safejary@gmail.com or visit www.worksafetyservices.com.
