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Management Trends

The Top 10 Traps in OSHA Compliance

by Renée Varella

November-December, 2008
Print finisher and long-time safety consultant Bill Effron recalls the days when presses manufactured in the 1960s featured open belts and pulleys – something he said would be as unsafe "as giving liquid nitroglycerin to a child" by today’s OSHA standards. Equipment manufacturers and workplaces have come a long way since passage of the Occupational Safety and Health Act – resulting in everything from higher employee productivity to rebates on workers’ compensation. "Putting a safety plan in place definitely pays benefits," said Effron, president of ALCO Print Finishers in Tulsa, Okla. "Since putting our plan in place we’ve gone three years without a lost-time injury."

Common dangers in the finishing industry include exposure to hazardous chemicals; slips, trips, and falls; cuts; back injuries; strains; and sprains, noted David Wise, safety services manager at Sentry Insurance of Stevens Point, Wis. He urges companies not to become complacent about worker safety. "OSHA will target the most hazardous workplaces; however, OSHA also will respond to employee complaints regarding a condition that poses serious physical harm," Wise said. "Companies that establish an effective safety program are able to minimize or control hazards, reduce the frequency and severity of accidents, and avoid OSHA penalties."

"Safety doesn’t happen overnight," acknowledged Phyllis Felsinger, vice president of Safety Connections, Inc., a safety advisory company based in Sheboygan, Wis. "It’s all about the process: Do what you say, and say what you do," she said. "If your expectation is that everything is done with safety in mind (safety first), your company will be world class, which equates to happy, motivated employees; efficient and productive processes; quality products; satisfied customers; and a profitable bottom line." Below, you’ll find the most common OSHA pitfalls for the print finishing industry, along with guidance on how to create a safer workplace.

‘The Big 10’

According to Wise, the top 10 standards that produce OSHA violations in the commercial printing industry are

  1. Hazard Communication. Includes providing employees with information and training on hazardous materials in use in your facility. It also covers proper labeling and other forms of warning, and maintenance of material data safety sheets on the premises.
  2. Control of Hazardous Energy (lockout/tagout). Involves procedures and practices in place to protect employees from unexpected startup of machines or equipment or unexpected release of energy while performing maintenance or service.
  3. General Requirements for All Machines (i.e., guarding requirements).
  4. Powered Industrial Trucks. Covers the inspection, maintenance, and operation of the material handling equipment and also is required training for operators.
  5. General Requirements for Electrical Systems.
  6. Flammable and Combustible Liquids. Covers proper storage and handling of these materials.
  7. Respiratory Protection. Covers the use of respirators in the workplace.
  8. Mechanical Power-Transmission Apparatus. Covers guarding requirements for power transmission belts, flywheels, shafts, pulleys, gears, etc.
  9. Guarding Floor and Wall Openings and Holes.
  10. Wiring Methods, Components, and Equipment for General Use. Includes permanent and temporary wiring, electrical fixtures, extension cords, and electrical panels.

Once you assess the problem areas in your workplace, Wise encourages you to act on the OSHA-related requirements that specifically apply to the industry, including the following:

  • Establishing a safety and health program
  • Ensuring safe operating procedures and employee training
  • Establishing a hazard communication program covering storage and handling of hazardous materials
  • Flammable liquid storage and handling
  • Walking and working surfaces
  • Machine guarding
  • Electrical wiring and fixtures
  • Powered industrial lift trucks
  • Personal protective equipment
  • Medical services and first aid

The key, Wise said, is to establish a safety program that provides policies, procedures, and practices that enable employees to recognize and be protected from job-related safety and health hazards. "Some key elements of such a program include management commitment and employee involvement, a workplace assessment of hazards, an ongoing self-inspection program, and an assessment of risk factors that contribute to repetitive trauma," he said.

"To ensure OSHA compliance, conduct an audit of your operation with respect to key OSHA-related items," Wise added. "The OSHA Small Business Handbook contains information and checklists that can provide employers guidance in evaluating their operation." The tool is available online at the OSHA web site, www.osha.gov. Wise noted that employers can get assistance in setting up a safety program and in assessing OSHA compliance from their workers’ compensation insurance carrier or from OSHA consultation services. (For a consultation service available to members of the Foil Stamping & Embossing Association, see the box on page 46.)

Make Training a Priority

Effron said that although ALCO Print Finishers does more proactive safety training than it did several years ago, he noted there’s always room for improvement. His next project is to revise the company’s safety manual – and then retrain on it. "If you buy a program and just put it on the shelf, that’s worse than not buying it at all," he said.

Felsinger agreed that companies often have written safety programs in place, but then fail to practice, enforce, or train to the material. "Or the company may follow best practices verbally, but there are no written programs to support the processes," she said. She noted that proper safety training is one of the important dimensions that companies often overlook, leaving employees without any understanding of how to follow appropriate procedures. "In addition, enforcement of safety policies is the greatest hurdle for business, because conflict is tough."

Her advice is to get involved with local and state safety councils or such federal programs as STAR or VPP (Voluntary Protection Program), in which management, labor, and OSHA establish cooperative relationships at workplaces that have implemented a comprehensive safety and health management system. "Take safety classes, attend seminars, and then share your knowledge with everyone at your company," she said. "It’s important that people understand not only the rule but why there is a rule."

Effron handles annually required safety training – covering hazard communication to lockout/tagout to bloodborne pathogens – at ALCO by scheduling the training for 10 a.m. on, say, Dec. 15 and ordering in a nice catered meal to be ready at noon. "That way, employees go to training in the morning but know they’ll get a Christmas lunch afterward," he said. "Questions and answers usually spill over into lunch." Throughout the year, Effron frequently visits with employees about facility and equipment issues, observes operators at work, and investigates problems. In addition, he schedules periodic inspections, equipment maintenance checks, and forklift driving tests, devoting a total of six to eight hours a year to hands-on safety. "When it comes to training classes, have employees sign in (to create a permanent record), and then have fun," Effron advised.

You can even designate one or two employees as your company’s ‘safety champions,’ Felsigner said: "Provide these workers with the resources and knowledge about OSHA compliance and empower them to ‘Get ’r done!’ " She also recommends that you conduct mock OSHA inspections and educate any independent contractors. "Make everyone from top management to the janitor accountable for safety," she added. "Measure results, communicate successes and failures, and celebrate routinely."

If you need any additional incentive to make safety a priority in your company, Effron offers an example of real world consequences for companies using coated and laminated paper. Between October 2007 and September 2008, Federal OSHA made 26 citations, conducted four inspections, and assessed $17,738 in penalties (SIC 2672, Coated and Laminated Paper, Not Elsewhere Classified).

"Remember, effective safety programs demonstrate ‘good faith’ on the part of the employer, which can lead to penalty reduction if a violation is discovered," Wise said. "Failure to act on OSHA violations can result in increased penalties that can be substantial."

Other Issues

The 10 most cited OSHA violations listed above address only a fraction of the safety concerns in the graphic finishing industry. For example, Felsinger noted that the Environmental Protection Agency requires that a foil stamping/embossing company follow stringent storage time frames for waste, have in place the necessary permits, and train employees in proper handling and processing of waste. The OSHA web site also covers issues related to a stamper’s or embosser’s use of hexavalent chromium and combustible dust. And although Effron noted that OSHA is about worker safety, not environmental safety, he pointed out that a health-related scare in the printing industry could put the environmental concerns associated with printing on the radar screen of regulators.

In addition, if your state has an OSHA-approved state program, your workplace is subject to state occupational safety and health regulations that may have more stringent or supplemental requirements. In that case, Effron’s advice is to search the www.osha.gov site for federal law, then go to one of your state university’s safety web sites and do a side-by-side comparison to determine the actions your company must take.

Want to Learn More?

The sources interviewed here recommend these resources for OSHA-related information:

  • "All About OSHA," a handbook on how OSHA operates, employer and employee rights, and what to expect during an inspection. Available electronically or by mail at www.osha.gov.
  • OSHA Small Business Handbook, featuring suggestions from small business employers and small business trade organizations across the U.S. and improved industry checklists. Available electronically or by mail at www.osha.gov.
  • Compliance Assistance Quick Start, a guide featuring the major OSHA requirements and materials for businesses with less than 250 employees. Visit www.osha.gov/dcsp/compliance_assistance/quickstarts/index.html.
  • OSHA audit information for the printing industry (go to www.osha.gov and select "P" in the Site Index along the top of the home page, then open the "Printing Industry" or "Printing Industry eTool" link).
  • Graphic Arts Coalition (GAC), an alliance of the Printing Industries of America/Graphic Arts Technical Foundation, Specialty Graphic Imaging Association, Flexographic Technical Association, and Gravure Association of America that provides resources to help protect employees’ health and safety. Go to www.osha.gov/dcsp/alliances/gac.
  • Local safety councils (visit the National Safety Council’s web site at www.nsc.org for links in your area).
  • American Society of Safety Engineers, a national trade association that features tips, safety resources for purchase, and current safety news. Visit www.asse.org.
  • American Conference of Governmental Industrial Hygienists, an occupational and environmental health organization that explains how to design ventilation systems and measure airborne carbon, noise, etc. Go to www.acgih.org.
  • State and private universities (most major universities feature safety and health programs, including the safety engineering program at Oklahoma State University, ehs.okstate.edu, and the Occupational & Environmental Safety Office at Duke University, www.safety.duke.edu).
  • Your insurance carrier (for safety publications and available services).

The Real Bottom Line

Wise noted that in focusing on the cost of OSHA penalties and the need for compliance to avoid that expense, employers may be losing sight of the real benefits of establishing an effective safety program: improving company profitability. "Accidents are a symptom of operational error, usually stemming from inadequate training, inadequate maintenance, inadequate tools for the job, or poor workstation layout," he said. "An effective safety program can result in identification and control of factors that not only prevents employee injury but can lead to solutions that improve overall operations and productivity."