General Plant Safety Issues Dist

8/2/2019 General Plant Safety Issues Dist

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General Plant Safety Issues

IntroductionThe following section addresses these areas of concern in your facilityand are listed in the order of predominant OSHA violation focus:

Hazard CommunicationEmergency Action Plan/Exits/EgressFire Safety/Eye Washes

Limited/Blocked Access to Disconnect Means

Walking/Working Surfaces/Housekeeping

Electrical Hazards

Hoist Safety

Forklift Safety (PIT)Permit-Required Confined Space

ErgonomicsGeneral Programs/Documentation


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Hazard Communication Purpose

1910.1200(a)(1)

The purpose of this section is to ensure that the hazards of all chemicals produced or

imported are evaluated, and that information concerning their hazards is transmitted

to employers and employees. This transmittal of information is to be accomplished

by means of comprehensive hazard communication programs, which are to include

container labeling and other forms of warning, material safety data sheets andemployee training.

1910.1200(f)(7) Exemption:

The employer is not required to label portable containers into which hazardous chemicals

are transferred from labeled containers, and which are intended only for the immediate use

of the employee who performs the transfer.

The issue that arises when evoking this exemption is when the employees transferring (or

controlling) the material turns away, goes on break or otherwise does not have full control

of the container. Full control of an unlabeled container is very difficult to manage unless it is

truly very small quantities and for immediate use.


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Hazard Communication

ConcernsAreas of concern are:

Lack of numerical/pictorial labeling of individual bottles

Individual containers hand labeled with cryptic information

Unlabeled open 3-5 gallon buckets containing mysterious substance

MSDS signs may mislead employees as to the location of the actual documents

Hazard communication is one of the most often cited violations under OSHA regardless if it

is a State/Federal plan. In 2007 1910.1200 was the #1 cited violation for general industry

at 5931 for a settled value of $1,218,351.00 (CCH, August 2009).

XYZ Foods specific hazard communication program was not reviewed as part of this plant

visit, therefore, gaps in the program are not addressed. Within the scope of this review

container labeling is a issue and observed repeatedly as well as language barriers.Most preferably the numerical category provided using the NFPA 704 or the HMIS system

would enhance the labeling communication as they are numerical /pictorial and easily

identifiable.


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1910.1200(f)(9)The employer shall ensure

that labels or other forms

of warning are legible, in

English, and prominently

displayed on the container,

or readily available in the

work area throughout each

work shift. Employers

having employees who

speak other languages may

add the information intheir language to the

material presented, as long

as the information is

presented in English as

well.

MSDS
http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1910_1200&src_anchor_name=1910.1200(f)(9)http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1910_1200&src_anchor_name=1910.1200(f)(9)


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Recommendations For MSDS

1. Designation of person(s) responsible for obtaining and maintaining the MSDSs;

2. How such sheets are to be maintained in the workplace (e.g., in notebooks in

the work area(s) or in a computer with terminal access), and how employees can

obtain access to them when they are in their work area during the work shift;

3. Procedures to follow when the MSDS is not received at the time of the first

shipment;

4. For producers, procedures to update the MSDS when new and significant health

information is found; and,

5. Description of alternatives to actual data sheets in the workplace, if used.

1910.1200 Appendix E


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Recommendations For MSDS (con)

For any safety and health program, success depends on commitment at

every level of the organization. This is particularly true for hazard

communication, where success requires a change in behavior. This will

only occur if employers understand the program, and are committed to

its success, and if employees are motivated by the people presenting

the information to them.



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Hazardous Communication

1910.1200

NFPA 704 Label HMIS Label

LABEL TYPES

"Hazardous chemical" means any chemical which is a physical hazard or a health hazard.

1910.1200(c)

Container

Labels


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1910.1200(f)(5)The employer shall

ensure that each container of

hazardous chemicals in the workplace

is labeled, tagged or marked with the

following information:

Identity of the hazardous chemical(s)

contained therein; and,

Appropriate hazard warnings, or

alternatively, words, pictures, symbols,

or combination thereof, which provide

at least general information regarding

the hazards of the chemicals, and

which, in conjunction with the other

information immediately available toemployees under the hazard

communication program, will provide

employees with the specific

information regarding the physical

and health hazards of the hazardous

chemical.

Individual Container LabelsMaintenance Room

ADD Proper LABEL


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Individual Container Labels

Maintenance Room

Proper Label Improper Label


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ADD Proper

LABEL

Bakery

1910.1200(f)(5)The employer shall

ensure that each container of

hazardous chemicals in the workplace

is labeled, tagged or marked with the

following information:

Identity of the hazardous chemical(s)

contained therein; and,

Appropriate hazard warnings, or

alternatively, words, pictures, symbols,

or combination thereof, which provide

at least general information regarding

the hazards of the chemicals, and

which, in conjunction with the other

information immediately available to

employees under the hazard

communication program, will provide

employees with the specific

information regarding the physical

and health hazards of the hazardous

chemical.


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Individual Container LabelsAppetizers USDA

Although this appear to be food stuff it is possible for employees to misunderstand the

contend, therefore, it is a good practice to label with material content.

ADD Proper

LABEL

Exemption: 1910.1200(f)(7)

The employer is not required to label portable containers into which hazardous chemicals

are transferred from labeled containers, and which are intended only for the immediate use

of the employee who performs the transfer.


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Zoom Shot

Shells

Although these labels

identify the contents ofthe containerit is not

adequate. The haz com

labeling system must

be uniform and be

readily

identified/recognizedespecially as XYZFoods

has multiple languages

spoken by employees.

It s best to use a

universally recognized

label with pictorialdisplay. This aligns with

1910.1200(f)(9).


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Recommendations For

Individual Containers & Labeling

1. Designation of person(s) responsible for ensuring labeling of

in-plant containers;

2. Designation of person(s) responsible for ensuring labeling of any

shipped containers;

3. Description of labeling system(s) used;4. Description of written alternatives to labeling of in-plant

containers (if used); and,

5. Procedures to review and update label information when

necessary.


Ensure Compliance by:

Consider purchasing a label maker for your hazard communication individual

containers as it will print numerical values for each hazard category and pictorial

icon for the PPE requirement as they help to bridge the language barrier.


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Individual Container Labeling

Post this Guide

Recommendations: utilize NFPA 704 or HMIS labeling and provide labeling stations

strategically place, including this or similar pictorial guide with an audit program and

restocking activities.


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Individual Container Labeling

HMIS Label




Post this Guide


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Individual Container LabelingThis system uses the NFPA

704 label but can be adaptedto HMIS

Holes for mounting2 at the

top and 2 at the bottom

Permanent Marker

Fits in These Slot

Place a stockof labels in

this slot

Price (ea.) $15.39

Brand MASTER

Mfr. Model # S1601





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Emergency Action Plan, Exits & Egress

Emergency action plans (EAP) are required for all business regardless of the size.

1910. 38 was cited as a violation 195 time for a settled value of $78,860.00. The

EAP program was not reviewed as part of this plant visit, however, only three

issues were observed and they were not overt. This is an area of concern due tothe fact that having an issue with exiting a building may lead to a catastrophic

event. Maintenance of exits is a highly cited violation with 1253 issued in 2008 at

a settled value of $565,980.00. This issue is also the primary focus of NFPA Life

Code 101.

Most of the exit doors were appropriately marked. Exceptionin the ammonia

room where the exits were difficult to find due to marking and the poor

lighting.

Additionally several of the interior doors are not identified as Not An Exit.

Purpose of Emergency Action Plan (EAP), exit, & egress is to ensure safe exiting in case

of an evacuation emergency. 1910.34


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EXITS, EGRESS & EMERGENCY ACTION

PLAN (EAP)What is an Egress/Exit?

NFPA 101

A.3.3.161 Means of Egress.

A means of egress

comprises the vertical and

horizontal travel and

includes intervening room

spaces, doorways, hallways,

corridors, passageways,

balconies, ramps, stairs,

elevators, enclosures,

lobbies, escalators,

horizontal exits, courts, andyards.

OSHA 1910.33 Means of Egress

is the way to, through, and

away from and exit.


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EAP, Exits & EgressAn employer who demonstrates

compliance with the exit route

provisions of NFPA 101-2000, the

Life Safety Code, will be deemed to

be in compliance with the

corresponding requirements in

1910.34, 1910.36, and 1910.37.

[39 FR 23502, June 27, 1974, as

amended at 45 FR 60703, Sept. 12,

1980; 53 FR 12121, Apr. 12, 1988;

67 FR 67962, Nov. 7, 2002] CFR

291910.35

Note: 1910.37(a)(1) Exit routes must be kept

free of explosive or highly flammable

furnishings or other decorations.

Well

Identified

Exit


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EAP, Exits & Egress3.3.161* Means of Egress. A continuous and unobstructed way of

travel from any point in a building or structure to a public wayconsisting of three separate and distinct parts:

(1) the exit access,

(2) the exit, and (3) the exit discharge.

4.5.3.2 Unobstructed Egress. In every occupied building or

structure, means of egress from all parts of the building shall be

maintained free and unobstructed. Means of egress shall beaccessible to the extent necessary to ensure reasonable safety

for occupants having impaired mobility.

NFPA 101, Life Code Safety 2009

Exit route means a continuous and unobstructed path of exit travel

from any point within a workplace to a place of safety (including

refuge areas). An exit route consists of three parts: The exit access;

the exit; and, the exit discharge. (An exit route includes all vertical

and horizontal areas along the route.) 1910.34(c)


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EAP, Exits & Egress

1910.37(b)(5) Each

doorway or passage along

an exit access that could be

mistaken for an exit must

be marked "Not an Exit" or

similar designation, or be

identified by a sign

indicating its actual use

(e.g., closet).

Doors may be labeled as Not An Exit or be labeled with the use or purpose of the room

such as closet or janitorial supplies.


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EAP, Exits & EgressAppetizer USDA Affix not An Exit to doors


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EAP, Exits & EgressPackaging

Shells

Label All Doors


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EAP, Exits & Egress

Label All Doors

Ammonia Room


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FIRE SAFETY & EYE WASHES


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Fire Safety/Eye WashesFire Extinguishers

The issues observed are related to the overall employees safety as it relates to OSHA

General Industry standard Subpart L. At XYZ Foods the issues are:

Lack of inspection/testing/maintenance of fire

Lack of documentation of inspection

Fire extinguishes blocked

Eye WashesNFPA/ANSI/OSHA all have various conditions where eyewash (and drench showers)

stations are required and likewise various standards for these safety devices. The

explanation for specifics are not clearly and specifically centrally located. Regardless as

XYZ Foods have eyewashes in the plant they must be maintained and managed.

Fire hazards & eyewash are often cited by OSHA during inspection due to the magnitudeof potential. It is extremely important to align the written program with the plant

practices. For XYZs Foods this is especially true due to the multiple languages spoken by

the employees. Because fire extinguishers are provided there is an assumption of safety

and beyond the OSHA citation issue, having fire extinguishes that are not in readiness

condition, depressurized, or the access blocked could lead to high liability results., This is

highly cited by OSHA and is covered in the NFPA 10 as well as NFPA Life Code 101.


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Fire Extinguishers

NFPA 10 Fire Extinguishers Overall7.1.1 The owner or designated agent or occupant of the property in which the fire

extinguishers are located shall be responsible for inspection, maintenance,

and recharging.

7.1.3 Removing from service for maintenance or recharging shall be replace by a fire

extinguisher suitable for the type hazard being protected and shall be at least

equal rating.

NFPA Specific

Inspection

Examination for obvious damage, corrosion, leakage, or clogged nozzles. NFPA 10 7.2.2.2

Corrective action

When a inspection of any fire extinguisher reveals deficiency in any of the conditions listedin 7.2.2.2 immediate correction action shall be taken. NFPA 10 7.2.3

Removing

Removing from service for maintenance or recharging shall be replace by a fire extinguisher

suitable for the type hazard being protected and shall be at least equal rating. NFPA 101

7.1.3


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Fire Extinguishers & OSHA

1910.157(a)Scope and application. The requirements of this section apply to the placement,

use, maintenance, and testing of portable fire extinguishers provided for the use of

employees. Paragraph (d) of this section does not apply to extinguishers provided for

employee use on the outside of workplace buildings or structures. Where extinguishers are

provided but are not intended for employee use and the employer has an emergency action

plan and a fire prevention plan that meet the requirements of 29 CFR 1910.38 and 29 CFR

1910.39 respectively, then only the requirements of paragraphs (e) and (f) of this section

apply.

1910.157(b)(2) Where the employer has an emergency action plan meeting the requirements

of 1910.38 which designates certain employees to be the only employees authorized to use

the available portable fire extinguishers, and which requires all other employees in the fire

area to immediately evacuate the affected work area upon the sounding of the fire alarm, the

employer is exempt from the distribution requirements in paragraph (d) of this section.

OSHA allows a building without fire extinguishers as stated below if the EAP is to

evacuate the building. However, all insurance carriers and local/state fire agencies

require them in building where visitors/employees o occupants are present. OSHA goes

on to state that if fire extinguishers are provided employers must train designated

employees to use them.


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Fire Extinguisher

Where required by the provisions of

another section ofthis Code,

portable fire extinguishers shall be

installed, inspected, and maintained

in accordance with NFPA10, Standard

for Portable

Fire Extinguishers. NFPA 101 9.7.4.1*

Unsuitable Fire Extinguisher

Discharging Unit

This condition was not simply a one-time

occurrence, it was the general overall

condition.

1910.157(c)(4) The employer shall assure

that portable fire extinguishers are

maintained in a fully charged and

operable condition and kept in their

designated places at all times except

during use.

1910.157(e)(2) Portable extinguishers or

hose used in lieu thereof underparagraph (d)(3) of this section shall be

visually inspected monthly.

(1910.157(d)(3) standpipe replacing fire

extinguishers).


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Fire ExtinguisherUnsuitable Fire Extinguisher

Overcharging Unit

1910.157(c)(4) The employer shall

assure that portable fire

extinguishers are maintained in a

fully charged and operable

condition and kept in their

designated places at all times

except during use.

1910.157(e)(2) Portableextinguishers or hose used in lieu

thereof under paragraph (d)(3) of

this section shall be visually

inspected monthly.

(1910.157(d)(3) standpipe

replacing fire extinguishers).

Where required by the provisions of another section ofthis Code, portable

fire extinguishers shall be installed, inspected, and maintained in

accordance with NFPA10, Standard for Portable



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Fire Extinguisher

BLOCKED

The employer shall provide portable fireextinguishers and shall mount, locate and

identify them so that they are readily

accessible to employees without subjecting

the employees to possible injury. OSHA

1910.157(c)(1)


another section ofthis Code, portable fire

extinguishers shall be installed, inspected,

and maintained in accordance with

NFPA10, Standard for Portable



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Fire Extinguishers Monthly Inspection

1910.157(e)(2) Portableextinguishers or hose used in

lieu thereof under paragraph

(d)(3) of this section shall be

visually inspected monthly.

(1910.157(d)(3) standpipe

replacing fire extinguishers).

InspectMonthly &

Sign-off

This condition was not simply a one-time

occurrence, it was the general overall

condition.


another section ofthis Code,

portable fire extinguishers shall be

installed, inspected, and maintained

in accordance with NFPA10, Standardfor Portable



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Eye Washes

Where the eyes or body of any

person may be exposed to injurious

corrosive materials, suitable

facilities for quick drenching or

flushing of the eyes and body shallbe provided within the work area for

immediate emergency use. OSHA

1910.151(c)

Attach tags, inspect & sign-

off monthly


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Limited/Blocked Access to Disconnect

Means

Disconnect means & electrical panel boxes must be accessible to employees in

cases of emergency shut-down & lockout/tag out procedures. During our

assessment it was observed as a general condition where material was

stored/stacked in front and in close proximity of disconnect means. In bakery area

there were several electrical boxes where yellow painted floor marked the zone ofnot storage and this was generally observed.

In one case the disconnect means was in the off position with no tag (no apparent

LOTO procedure). This is displayed in the first slide following. In & of itself this is

not a violation however, it does communicate misinformation as to the status of

the machine/equipment or device it supplies. It is advisable to communicate with

tags the status of disconnect means or electrical equipment in repair or out-of-service.


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Means Switch in off-positionwithout a locksendsmixed message to

employees including the

disposition of the switch

& machine/device/

operation associated

with it.1910.147(c)(7)(i) The

employer shall provide

training to ensure that the

purpose and function of the

energy control program are

understood by employees and

that the knowledge and skills

required for the safe

application, usage, and

removal of the energy controls

are acquired by employees.


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Means

1910.305(j)(4)(v) The

disconnecting means

shall be readily

accessible. If more

than one disconnect isprovided for the same

equipment, only one

need be readily

accessible.

BLOCKED


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Means

This raised disconnect makes

it impossible for employees to

shut-down its associated

machine/equipment/device

without the aid of a ladder.

Shells

Zoom Angle

BLOCKED


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Means

Dock Area

BLOCKED


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Means

Various Locations

BLOCKED


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Means

BLOCKED

Various Locations


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Means

BLOCKED

Various Locations


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Means

BLOCKED

Various Locations


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Walking Working Surfaces &

Housekeeping

7.5.1.1.1 Where exits are not immediately accessible from an open floor area,continuous passageways, aisles, or corridors leading directly to every exit shall be

maintained and shall be arranged to provide access for each occupant to not less than

two exits by separate ways of travel, unless otherwise provided in 7.5.1.1.3 and

7.5.1.1.4. NFPA 101

7.1.8 Elements of the means of egress that might require

protection with guards include stairs, landings, escalators, moving walks, balconies,corridors, passageways, floor or roof openings, ramps, aisles, porches, and

mezzanines. NFPA 101

Generally the walking working surfaces including housekeeping were acceptable for thetype of operation at XYZs Foods. There were only a few issues under this standard in the

following slides. Most areas were clean & dry.


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Walking Working Surfaces

Aisle Accessway. The initial

portion of an exit accessthat leads to an aisle.

NFPA 101 3.3.11*

A.7.1.8 Elements of the means of egress

that might requireprotection with guards

include stairs, landings, escalators, moving

walks, balconies, corridors, passageways,

floor or roof openings, ramps, aisles,

porches, and mezzanines. NFPA Life Code

101-2009

Add handrails to this side descending to

ensure ease of transition.

1910.23(d)(1)Every flight of stairs having four or more risers

shall be equipped with standard stair railings

or standard handrails as specified in

paragraphs (d)(1)(i) through (v) of this section,

the width of the stair to be measured clear of

all obstructions


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Electrical Hazards

The areas of concern for the electrical hazards are:

Strain relief issues where colored wire is exposed and present a potential shock or

electrocution

Minimal observation of knock-outs missing

One issue of live receptacles/light fixtures were observed

Electrical panel access was limited (addressed in disconnect means).Need for an Arc Flash Analysis

The overall issue of electrical hazards were minimal at XYZs Foods. These issues

will need to be addressed as quickly as possible.


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Electrical HazardsFittings. Connectors used to connect lengths of cable in a run

shall be of a type that lock firmly together. Provisions shall be

made to prevent opening or closing these connectors whileenergized. Strain relief shall be provided at connections and

terminations. OSHA 1910.305(h)(6)

Allneed to ensure

strain relief at

connection point

Various Locations

Acceptable spool:

Unacceptable

transition (no

spool) from source


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Electrical KnockoutsRepair with

Approved Parts

Unused openings protected.

NEC 2008 Article 110.12(A)

Listed (approved parts) for repair

NEC 2008 Article 110.3(B) Listed (approved parts) for

repairs OSHA 1910.303(b)(2)

Tighten Bushing

Fittings. Connectors used to

connect lengths of cable in a

run shall be of a type thatlock firmly together.

Provisions shall be made to

prevent opening or closing

these connectors while

energized. Strain relief shall

be provided at connections

and terminations. OSHA1910.305(h)(6)


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Electrical HazardsRepair with

Approved Parts

XYZs Area


NEC 2008 Article 110.3(B)



Listed (approved parts) for



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Electrical HazardsRepair with

Approved Parts


NEC 2008 Article 110.3(B)



Listed (approved parts) for



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Electrical Hazards

Flexible cords and cables shall be

approved for conditions of use and

location. OSHA1910.305(g)(1)(i)

Care should be taken asnot to use flexible cords

(extension cords) as

permanent wiring.


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Electrical Hazards

Avoid pinch points for

electrical cords


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Electrical Hazards

Arc Flash Analysis needs to

include the user (or at the

box) warning signs that

identify the flash hazard level

and required PPE installed on

every electrical panel.

Consider an Arc FlashAnalysis for the entire

facility


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Hoist Safety

Hoist must be treated as cranes for use, inspection, maintenance, and care. To

do less begs accidents. The major issues for the hoists are:

Lack of disconnect readily accessible & labeled as such

Pendent electrical cables wrapped around hoist hook

Documentation for frequent and periodic inspection (must be compiled &available)

Annual inspection of the hoist by a qualified (or third party) inspector &

documented

Hoist capacity not clearly visible from the floor

Suspended load unattended is a serious violation

This hoist issue is another opportunity for systematic correction. The event of anincident with a hoist is significant due to the load configuration and frequency

of use.


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Hoist DisconnectFollowing the application of lockout or tagout

devices to energy isolating devices, all potentiallyhazardous stored or residual energy shall be

relieved, disconnected, restrained, and otherwise

rendered safe. OSHA 1910.147(d)(5)(i)

At the beginning of each operator's

shift, the upper limit switch of eachhoist shall be tried out under no

load. Extreme care shall be

exercised; the block shall be "inched"

into the limit or run in at slow speed.

If the switch does not operate

properly, the appointed person shallbe immediately notified.

1910.179(n)(4)(i)

Locate a

Disconnect

Means

Ensure Periodic

& Frequent

Inspections

(Document)The employer shall insure that the operator

does not leave his position at the controls

while the load is suspended.

1910.179(n)(3)(x)


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Hoist Safety

Electrical pendent cord

running through the hook. This

practice could cause the

electrical cord to be damaged

and cause a shock or

electrocution if adverse

conditions are present.


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Forklift Safety


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Forklift Safety1910.178(a)(5) If the truck is

equipped with front-endattachments other than factory

installed attachments, the user

shall request that the truck be

marked to identify the

attachments and show the

approximate weight of the truckand attachment combination at

maximum elevation with load

laterally centered.

Note: it is very important toensure positive connection

when using a personnel

working platform
http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1910_0178&src_anchor_name=1910.178(a)(5)http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1910_0178&src_anchor_name=1910.178(a)(5)


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Permit-Required Confined Space

Permit-Required Confined Space (PRCS)

requires:

A written program

Space assessment

Space labeling

Training for entryincluding emergency rescue &

recovery


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Hazardous Material

Caps should be replace on stored cylinders.

This is more predominant in construction

1926 rather than 1910 general industry. It is

simply a good practice.


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Rotating Shafts

Projecting shaft ends. 1910.219(c)(4)Projecting shaft ends shall present a

smooth edge and end and shall not

project more than one-half the diameter

of the shaft unless guarded by non-

rotating caps or safety sleeves.

1910.219(c)(4)(i)

Rotating shaft protrusion hazard

Cover or cut-off shaft ends


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Rotating Shafts

Rotating shaft

protrusion hazard

Cover or cut-off


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ErgonomicsAlthough OSHA does not have a

specific standard that horizontally

addressed ergonomics every

citation is accompanied with a letter

that specifically and clearly

identifies ergonomics as a

significant safety factor. The OSHA

suggestion for ergonomics is based

on systematic change throughout

your plant. Some suggestions are:

Using mechanical devices where

possible such as hoist, lift tables,

caddies, & roll cartsUsing rotation

Performing stretching exercises

Health programs that emphasize

health lifestyles

Combustible Dust/Process Safety


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Combustible Dust/Process Safety

Management

Combustible Dust Publication Date: 03/09/2010 Publication Type: Meeting

Fed Register #: 75:10739-10740 Standard Number: 1910 Title: Combustible

Dust [Federal Register: March 9, 2010 (Volume 75, Number 45)] [Proposed

Rules] [Page 10739-10740] From the Federal Register Online via GPO Access[wais.access.gpo.gov] [DOCID:fr09mr10-24].

Ammonia Refrigerant Mechanical Refrigeration and Air-Conditioning Installations

Aboard Ship. ANSI/ASHRAE 26-1996, (1996). Provides the minimum general

requirements for the design, construction, installation, operation, inspection,

and maintenance of mechanical refrigeration and air-conditioning equipment

aboard ships to permit the safe, efficient, and reliable operation of such systems.

Flour is classified as a combustible dust and requires potential critical incident

management

Ammonia is classified as a hazardous substance and as such must be managed with the

Process Management System under 1910.119

Purpose. This section contains requirements for preventing or minimizing

the consequences of catastrophic releases of toxic, reactive, flammable, or

explosive chemicals. These releases may result in toxic, fire or explosionhazards. 1910.119 Process Management Systems
http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=FEDERAL_REGISTER&src_unique_file=FED20100309&src_anchor_name=1910http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=FEDERAL_REGISTER&src_unique_file=FED20100309&src_anchor_name=1910


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RecommendationOverall your plant is in fairly good condition. The food industry typically have

tremendous housekeeping hazards. Areas that need addressed are listed belowand are listed in the order of typical increased violation dollars of fines:


Emergency Action Plan/Exits/Egress

Fire Safety/Eye Washes

Limited/Blocked Access to Disconnect MeansWalking/Working Surfaces/Housekeeping

Electrical Hazards

Hoist Safety

Forklift Safety (PIT)

Permit-Required Confined Space

Ergonomics

General Programs/Documentation

General Programs/Documentation/


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General Programs/Documentation/

Recommendation

Each of the headings were addressed as if an OSHA inspection was conducting

an inspection. Hazard communication is the most often cited issue, followed by

exit/egress, then fire safety. It is noteworthy to clarify that housekeeping is the

first view an inspector sees in the plant, however, this is after the initial review

of documentation including all programs.

The focus of an OSHA inspection is dictated by the reason of the visit butCompliance Officers will certainly look at the programs first. Once the

programs, and of course, the recordkeeping is reviewed their motivation is to

discover the obvious and to look deeper into the disconnects. Disconnect here

is defined as the gaps between the written program, the practices and what

the Compliance Officer observes. Alignment is key. Align your written programs

to your practices, and your employees behavior. Your most difficult task is todiscover these gaps.

General Plant Safety Issues Dist

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