According to Joe Keenan, Mississippi and Alabama Area Director of the American Society of Safety Professionals (ASSP) and OSHA General Industry and Construction 10/30-Hour Authorized Outreach Trainer, abating the “Focus 4” safety hazards – which have the potential to seriously hurt or kill employees - will not only help with compliance, but liability and legal issues as well as worker’s compensation.
Keenan presented “OSHA's ‘Focus 4’ Safety Hazards: Falls, Caught-In or Between, Struck-By Hazards and Electrocution” webinar, and said that it is important to consider a safety and health management system that contain the following elements: Management commitment and employee involvement; work site analysis; hazard prevention and control; and safety and health training.
Keenan said that “management commitment and employee involvement are complimentary, they go together. Management commitment provides the motivating force and resources for organizing and controlling activities within an organization, and employee involvement, call it the heartbeat of safety, provides the means through which workers develop and express their own commitment.”
Work site analysis involves a variety of examinations to identify not only existing hazards, but also conditions and operations where changes might occur to create hazards. Keenan said that effective management actively analyzes the work and the work site for all hazards to anticipate and prevent harmful occurrences, and it's critical that all hazards, not just the Focus 4, are identified and corrected before an injury can occur.
Another key component of any safety program is an ‘effective management of change procedure,’ or MOC. A management of change procedure is a comprehensive environmental health and safety review of any new process. Keenan mentions the mantra "Find it, fix it." A very simple approach - if the safety hazard is found, it's fixed immediately, or if it can't be fixed immediately, the machine or the piece of equipment, is taken out of service, or tagged out of service and not allowed to be run until it can be fixed properly.
The OSHA Focus 4:
According to OSHA, falls account for nearly one quarter of all seriously disabling work injuries - over 300 000 each year in the United States, and are the leading cause of death in the construction industry. Most fatalities occur when employees fall from open sided floors, and through floor openings. Keenan suggests a comprehensive ‘Fall Protection Hazard Analysis,’ which should be reviewed at least annually with hourly employee and management participation.
Keenan said there are two types of falls: falls-to and from the same level or slips and trips. Both can have serious consequences and need to be taken into account when conducting a job hazard fall analysis. Slips can be caused by slippery surfaces and poor housekeeping such as clutter and debris in aisle ways, etc. In addition to good housekeeping, which is critical, it is very critical too to make sure employees have adequate safety footwear.
Trips can occur when a foot strikes an object or stops forward momentum. Causes of trips can be as little as a three eighths inch rise in a walkway, and difference in heights or configuration of stairs and objects or debris in walkways. OSHA has a standard on stairs that regulates the height, and the angle, and the pitch for this very reason.
Ladder safety is also critical in the “falls-to and from” category. Keenan said to only use ANSI-approved ladders, and never use metal ladders where there is potential for contact with electricity. The top three rungs, or top two steps, should never be used for standing (but is probably one of the most commonly violated OSHA standards and general industry practices, according to Keenan).
Employers must guard every floor hole into which a worker can accidentally walk to prevent employees from being injured in falls, according to OSHA. Using a railing or toe board and floor hole cover and providing a guardrail and toe board around every elevated open side platform, floor or runway. “Regardless of the height,” said Kennan, “if a worker can fall onto or into a dangerous piece of equipment, such as a conveyor or a vat with chemicals, employers have to provide guardrails and toe boards to prevent the workers from falling and getting injured.”
The effects of electricity on the body is the second of the Focus 4 hazards. An electric shock can result in anything from a slight tingling sensation to immediate cardiac arrest. Severity depends on the amount of current flowing through the body, the current's path through the body, and the length of time the body remains in the circuit. Keenan said low voltage does not necessarily mean no hazard, and that's a key critical component.
Measures are listed in milliamps. At one milliamp there is slight tingling and it can be dangerous under certain circumstances. At five milliamps - what a ground fault circuit interrupter (GSCI) is designed to trip at – there is a slight shock felt, not painful but disturbing and the average individual can let go. However, strong involuntary reactions to shock in this range may lead to injuries. Six to 30 milliamps, though not a lot of power, results in painful shock, and muscular control is lost. This is called a freezing current, or "can't let go range." Fifty to 150 milliamps, results in extreme pain, respiratory arrest and severe muscular contractions. Death is possible. At 1000 to 4300 milliamps, death is “most likely,” with ventricular fibrillation similar to what happens in a heart attack, and what an automatic external defibrillator (AED) is designed to correct.
Keenan stresses that electrical safe work practices must include an adequate lock out/tag out program, whereby parts are de-energized before working on or near them. Disconnect circuits and equipment from all electric energy sources. Control circuit devices such as push buttons, selector switches and interlocks may not be used as the sole means for de-energizing circuits or equipment. Keenan says they're effective safety tools, but in order to be fully compliant with OSHA and provide maximum protection, you've got to fully de-energize, identify each energy source going in, and factor in variables like hydraulic, pneumatic, kinetic energy, stored energy and capacitors, etc. Then, release stored energy - capacitors must be discharged and high capacitant elements must be short circuited and grounded, if the stored electric energy might present a hazard.
Only trained and authorized personnel should work on lock out/tag out, and there should be training for all employees on lock out/tag out. OSHA requires a periodic inspection, at least annually, of all authorized lock out/tag out users. Keenan said one commonly overlooked item is the verification of energy isolation, or, actually making sure that what is locked out is locked out. “There have been many cases in lock out/tag out, where the employee locked out, but something might have been mislabeled, or a piece of equipment malfunctions, and let's say a conveyor belt or something like that - all the sudden the piece of equipment starts up, because the lock out/tag out wasn't verified, and easily could lead to a fatality or very serious injury,” said Keenan.
The third hazard is struck by such as falling objects, rigging failure, loose or shifting materials, equipment tip over or malfunction, lack of overhead protection, vehicle and equipment strikes, backing incidents, workers on foot, or flying objects.
Caught or in-between hazard is the fourth category, and Keenan said OSHA's machine guarding standard states that rotating parts, chains, collars, couplings, or anything along those lines have to have a guard around it. If an employee can reach in, under, around or through to the point of operation, it has to have a guard.
“A good preventive maintenance program,” said Keenan, “can go a long way in preventing accidents.”
