$13,494.
That’s how much a single manufacturing safety hazard can cost your business in terms of Occupational Health and Safety Administration fines. We’re talking about 5 figures for just one violation of workplace health and safety laws.
The damage to your bottom line doesn’t end there. Once OSHA has discovered a problem, they’ll give you a deadline. If you don’t fix the issue by that deadline, you could face the same penalty every day things go unaddressed. Oh, and if OSHA determines that you’ve committed a willful or repeat violation, you could be on the hook for 10 times as much: $134,937.
Ouch. Clearly, OSHA is making sure that manufacturing safety hazards hurt in more ways than one.
By the way, this is only OSHA we’re talking about. Don’t forget about other federal regulators, such as the Environmental Protection Agency, or state plans.
And then there are all the costs beyond penalties. Manufacturers that don’t adequately manage their risks can expect to pay hundreds of thousands—even millions—in indirect expenses such as the following:
- workers’ compensation claims from people who have experienced injuries and illnesses
- lost productivity during and after an incident
- lowered workforce morale due to fear and uncertainty around risk areas
- hours of labor spent identifying and fixing the issue
- expenses of cleaning and replacing equipment and machinery that’s out-of-date, damaged, or broken
- legal and compliance fees
Are you doing everything you can to avoid these expenses?
Is your manufacturing risk management and compliance program adequately keeping your workers safe? Don’t wait until someone else—like an OSHA inspector—finds out for you.
The fastest way to measure the strength of your manufacturing safety program is to determine whether you’re at risk for any of the most common OSHA violations.
The Top 5 OSHA Violations in Manufacturing
In 2019, the top 5 most frequently violated OSHA standards in the manufacturing industry were the following:
- Machine Guarding (1910.212, 219)
- The Control of Hazardous Energy (1910.147) AKA Lockout/Tagout
- Hazard Communication (1910.1200)
- Respiratory Protection (1910.134)
- Electrical Wiring Methods (1910.303, 1910.305)
Let’s run down each of these OSHA standards, their risk factors, and how you can prevent a violation at your manufacturing facility:
1. Machine Guarding
OSHA definition: “Employee exposure to unguarded or inadequately guarded machines is prevalent in many workplaces. Consequently, workers who operate and maintain machinery suffer approximately 18,000 amputations, lacerations, crushing injuries, abrasions, and over 800 deaths per year. Amputation is one of the most severe and crippling types of injuries in the occupational workplace, and often results in permanent disability.” (Source)
Simple definition: Industrial equipment poses numerous potential hazards. Machines such as power saws, shears, guillotine cutters, presses, milling machines, fans, conveyor belts, palletizers, and revolving drums can slice, crush, and tear off workers’ body parts. Sometimes, hazards are caused by nip points (also called pinch points)—points where one or more parts (such as gears) rotate. In other cases, machines generate sparks or flying chips that can injure workers.
For these reasons, OSHA requires that certain pieces of equipment have specific protection mechanisms in place. This is what’s known as machine guarding. Examples of machine guarding include barriers, light curtains, and two-hand trips.
Machine guarding typically applies to the point of operation—that is, the location on or near the machine where work is performed. However, many machines need to be safeguarded at multiple points. Additionally, there are plenty of instances where OSHA requires or recommends secondary controls, such as alarms and fences.
Signs You’re at Risk of a Machine Guarding Violation
- You have one or more decades-old machines still in operation.
- You haven’t inspected your machines recently.
- You’re relying on user-built safeguards.
- Employees are working close to hazardous machines.
- Employees aren’t well-trained—or you can’t prove that they are.
- Employees are stressed and/or overworked.
2. Lockout/Tagout
OSHA definition: “The OSHA standard for The Control of Hazardous Energy (Lockout/Tagout), Title 29 Code of Federal Regulations (CFR) Part 1910.147, addresses the practices and procedures necessary to disable machinery or equipment, thereby preventing the release of hazardous energy while employees perform servicing and maintenance activities. The standard outlines measures for controlling hazardous energies—electrical, mechanical, hydraulic, pneumatic, chemical, thermal, and other energy sources.” (Source [PDF])
Simple definition: Some machines can seriously injure or kill workers. These machines are dangerous because they release hazardous energy—in the form of electricity, steam, chemicals, or another kind of power.
Hazardous energy can be released whether the machine is being used or not. This is why it’s important for dangerous machines to be completely shut off before servicing and maintenance. For example:
- A capacitor that hasn’t been properly disconnected could electrocute someone trying to repair it.
- A hydraulic press that hasn’t been de-energized could crush someone.
- A steam valve that hasn’t been bled out could scald someone.
OSHA’s Control of Hazardous Energy standard, usually called the “Lockout/Tagout” standard (or LOTO for short), outlines what workers should do to safely depower dangerous machines. One of the main steps of lockout/tagout is literally locking the machine in the “off” position and adding a tag with the name of the person who carries the key to the lock.
Signs You’re at Risk of a Lockout/Tagout Violation
- You’re lacking detailed, written procedures for one or more machines.
- You haven’t identified every source of hazardous energy in your workplace.
- You’re using the wrong lockout/tagout devices.
- You’re not following all lockout/tagout steps in the correct order.
- Your machinery is old or high-maintenance.
- Your workforce hasn’t been trained properly or consistently.
- You can’t remember your last lockout/tagout audit.
3. Hazard Communication
OSHA definition: “OSHA’s Hazard Communication Standard (HCS) is based on a simple concept—that employees have both a need and a right to know the hazards and identities of the chemicals they are exposed to when working. They also need to know what protective measures are available to prevent adverse effects from occurring. OSHA designed the HCS to provide employees with the information they need to know.” (Source)
Simple definition: The HCS is the way you’re supposed to inform your employees about dangerous chemicals in the workplace. It’s a set of rules that covers labeling and tracking chemicals, as well as employee training on chemicals.
Substances that fall under the HCS include…
- acids
- asbestos
- disinfectants
- glues
- lead, mercury, and other heavy metals
- paints
- pesticides
- petroleum products
- solvents
…and many more. In fact, according to OSHA, “[m]ost chemicals used in the workplace have some hazard potential, and thus will be covered by the rule.” For a full index of chemicals overseen by OSHA, click here.
Under the HCS, the following needs to be in place anywhere workers could be exposed to hazardous substances:
- material safety data sheets (MSDS or SDS for short) for every chemical on the jobsite
- a written hazard communication plan
- comprehensive hazard communication training for all workers who may be exposed to hazardous chemicals
Signs You’re at Risk of a Hazard Communication Violation
- Not all hazardous chemicals are labeled properly.
- You don’t have an adequate written hazard communication plan.
- Your SDS database is incomplete, inaccurate, or out-of-date.
4. Respiratory Protection
OSHA definition: “In the control of those occupational diseases caused by breathing air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors, the primary objective shall be to prevent atmospheric contamination. This shall be accomplished as far as feasible by accepted engineering control measures (for example, enclosure or confinement of the operation, general and local ventilation, and substitution of less toxic materials). When effective engineering controls are not feasible, or while they are being instituted, appropriate respirators shall be used pursuant to this section.” (Source)
Simple definition: Not all air is safe to breathe. The oxygen in a certain environment may contain hazardous fumes, dust, or other contaminants.
Common airborne contaminants include particulate matter (e.g. silica dust), smoke, gases, mists, vapors, and aerosols. These and other contaminants can cause short- and long-term health problems, such as asthma, bronchitis, emphysema, impaired thinking, decreased lung capacity, loss of consciousness, and cancer.
OSHA’s respiratory protection standard outlines how organizations should minimize worker exposure to hazardous air. First, the standard requires employers to assess and minimize airborne hazards if possible. But if controlling the environment isn’t possible or doesn’t provide adequate protection, employers must provide their workers with respiratory devices (usually called “respirators”). The standard lays out which respirators to use—and how to use those respirators—in various situations, along with maintenance, inspection, and medical follow-up procedures.
Signs You’re at Risk of Respiratory Protection Violation
- You don’t have a respiratory protection program in place.
- Your employees aren’t using the right respirators for the right jobs.
- You’re not performing required fit testing.
- You’re not providing medical evaluations at no cost to employees.
- You’re not providing respirators at no cost to employees.
- Your employees aren’t properly trained in respirator use.
- Employees exposed to contaminated air are working long hours and/or not taking enough breaks.
5. Electrical Wiring Methods
OSHA definition: “Many workers are unaware of the potential electrical hazards present in their work environment, which makes them more vulnerable to the danger of electrocution. The following hazards are the most frequent causes of electrical injuries: contact with power lines, lack of ground-fault protection, path to ground missing or discontinuous, equipment not used in manner prescribed, and improper use of extension and flexible cords.” (Source)
Simple definition: Electricity is dangerous. Employees risk electrocution any time they’re working with or around machines that conduct or generate electricity.
Wiring is one of the most common sources of electrical hazards. Why? Because wires are potent sources of electricity that are a) practically everywhere and b) relatively fragile. Wires—particularly flexible wires—cover wide areas, may be misconfigured, and can wear down easily, making hazards difficult to manage.
Examples of electrical hazards include the following:
- torn, frayed, or exposed wires
- tangled and/or overcrowded wires
- loose electrical connections
- substandard insulation
- malfunctioning electrical equipment
- ungrounded equipment
- broken ground connections
- improper use of extension cords and/or power strips
Signs You’re at Risk of an Electrical Wiring Violation
- The wrong wires are being used.
- Wires are misplaced and/or unsecured.
- Electrical equipment isn’t sufficiently guarded.
- Equipment isn’t grounded or insulated.
- You haven’t inspected your electrical systems recently.
- Workers aren’t sufficiently trained on electrical wiring safety.
Protect Your Workers and Bottom Line with Manufacturing Safety and Compliance Solutions from KPA
Manufacturers of all kinds rely on KPA to maximize workforce productivity and minimize risks. Our comprehensive manufacturing safety software, training, and consulting services will keep your workers safe and your business out of trouble with OSHA and other regulatory authorities.
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KPA’s training solutions make it easy for your employees to get the training they need to improve on-the-job performance, ensure regulatory compliance, and reduce costly liabilities. Access a comprehensive library of online and on-site training for the manufacturing industry. Course topics cover critical EHS risk areas, including every OSHA standard here—plus over a hundred more workplace safety and compliance topics. Our Subscription to Safety Platform delivers a complete safety training program designed to help prevent injuries and fatalities in the steel, plastics, and concrete manufacturing industries.
Leverage a Team of Manufacturing Safety and Compliance Consultants
In addition to our software and training, we offer consulting and audit services available on-site or remotely. Call on our team of manufacturing safety experts to identify, track, resolve, and report on issues in compliance with federal and state regulatory requirements.
Manufacturing Safety During COVID-19
As the world adjusts to the “new normal” of working during the COVID-19 pandemic, manufacturing companies need to take the right steps to create and maintain safe workplaces. We’ll help you keep your employees safe and in compliance with OSHA requirements developed to help reduce the spread of the virus. KPA has developed a comprehensive turnkey program to help guide your adjustments while staying safe, productive, and compliant.
Download the COVID-19 workplace safety program datasheet.
Try Out KPA’s Manufacturing Solutions
Ready to create a safer and more efficient manufacturing workplace? See what KPA can do for you. Contact us for a personalized demo.