Once upon a time, checking off a box on an inspection checklist may have been enough for companies to determine that their safety equipment and machinery – as well as their safety processes – were in order. That doesn’t cut it anymore.
Over the years, safety and health audits have become more thorough, with employers using the results to rid the workplace of hazards before incidents occur. Audit activity accelerated after OSHA was established in 1971. Many employers determined that if they did not conduct inspections of the workplace, OSHA would do it for them, adding citations, fines and a big chunk of management time to the costs or the corrections.
Employers gradually have realized that a well-conducted safety audit provides a host of tangible and intangible benefits, including identifying and eliminating safety hazards, reducing lost-time injury and illness rates and improving employee morale, just to name a few. As a result, they increasingly have taken an all-encompassing approach to their safety audits.
Including vital workplace equipment and maintenance data in the audit, as well as conducting a job safety analysis, will help companies identify equipment and process issues, according to one safety expert.
“It’s not just about what you do [with audit information], it is about how you set it up,” asserts Paul Esposito, vice president of the Annapolis, Md.-based ESIS Global Risk Control Consultants. In other words, he says, are you asking the right questions on your audit?
The Before and After Conundrum
According to Esposito, what happens before an audit lays the groundwork for what happens afterwards. He says it is vital that companies do their homework before coming up with an inspection checklist. Employers should have a firm grasp on the regulations to determine how often an inspection is needed. In addition, it also is necessary to look at injury and illness data to determine problem areas requiring special attention during audits. Such an analysis can help employers come up with the right questions to ask on the inspection checklist.
Moreover, employers should be cognizant not only of how often they conduct their equipment and maintenance inspections, but also if inspectors are finding issues, if the problems are getting fixed and if the people performing the inspections are signing off on the right things. If the preliminary data isn’t done, then the audit won’t be successful, he states.
“When doing an audit, you want to continuously ask the question, ‘What is my data telling me?’ before taking action,” Esposito says. “If you don’t do the data, you can’t answer your question.”
Robert Adams, senior manager for the Princeton, N.J.-based ENVIRON International Corp., agrees that the preliminary work is very important, but says it is just as important for an employer to develop internal mechanisms to ensure that the action items identified during the audit are tracked to their completion. This often is where breakdowns in the auditing systems are found, Adams adds.
“Somewhere in that process, there has to be a check where the end of the process is marked as completed or showing that alternate action needs to be taken,” Adams asserts.
One way to ensure that an action item is being followed through is to assign responsibility for that item to an individual or group. According to Adams, this is how the process should work: A piece of defective equipment is tagged and set aside. The inspection findings are recorded and an employee will be assigned the responsibility of ensuring corrective action is taken by a certain date. A more senior-level manager will follow through to determine that the responsible person completed his or her task in a timely manner.
Monitoring PPE
Sometimes, one of the best things companies can do is to partner with the agency responsible for ensuring occupational safety and health regulations are followed. Eric Ajax, vice president of the Fridley, Minn.-based manufacturing company E.J. Ajax & Sons, says that partnering with Minnesota OSHA (MNOSHA) has been “one of the very best things we have been able to do.”
Since 1990, E.J. Ajax voluntarily has worked with MNOSHA Workplace Safety Consultation to identify and correct workplace hazards as a step toward the company’s goal to be the safest stamping facility in the country. The partnership also has prompted E.J. Ajax to achieve OSHA SHARP status – a safety recognition program for smaller employers – as a result of working together to put systems into place as well as identifying and eliminating current or future safety hazards.
Ajax says one of the reasons why the company boasts 17 years without a lost-time incident and 5 years without an OSHA-reportable incident is because management and employees are thorough in making sure that all their equipment is in order.
For instance, they are diligent when inspecting their two first aid kits. One is a first-responder bag that has all the essentials and more – an automated external defibrillator, a respirator, CPR supplies, full bandages, etc. That equipment is sealed and only is used in the case of emergency and is inspected once a year. They also have a couple of first aid stations that have the basics such as small Band-Aids, ointment and aspirin, for what Ajax calls “minor nuisances.” These are maintained on a weekly basis, he says.
When it comes to monitoring and replacing personal protective equipment (PPE) – work boots with full metatarsal protection, safety glasses, ear protection and elbow-length Kevlar gauntlets for workers who handle sharp metal pieces – E.J. Ajax leaves it up to the employees’ discretion. There are no questions asked when new equipment is requested and no added cost for the employee.
“We trust our employees to know when a piece of PPE is getting worn out,” Ajax says. “We have such a great accord here and employees understand that it’s important to be wearing them, when they are the most effective.”
One Size Does Not Fit All
When speaking about equipment audit policies, Adams notes that there is no “one-size-fits all” policy. This couldn’t be better exemplified than when comparing equipment and maintenance audits at E.J. Ajax to Houston-based drilling contractor Parker Drilling.
Unlike E.J. Ajax, Parker Drilling has written corporate procedures that stipulate the minimum replacement criteria for PPE, according to the company’s director of Global QA/HSE, Casey Davis. If a manager notices that something is awry with a respirator or some other type of PPE during daily inspections, it immediately is replaced, he says.
“We find this is beneficial for long-term planning and procurement and can help us prepare for new project startups and employee training when we know the maximum length that the PPE can be used for,” Davis asserts.
Making sure that PPE is at its full-functioning capacity is critical for Parker Drilling, because the company specializes in high-pressure/high temperature remote drilling operations in environmentally difficult locations. Because employees could be working in the middle of the desert, in the middle of the jungle or in other extreme artic conditions, they rely on specialized forms of PPE – mostly in the form of fall protection equipment – that are unique to their industry.
“Because we actively work at heights in derricks and masts that are 100+ feet and moving vertical tubular, we use a unique, double-redundant lifeline system that allows total mobility of the worker, yet provides positive suspension and restraint in the elevated work position,” Davis says.
Monitoring PPE that is in use is not usually too much of an issue, according to Adams. The real problem lies with PPE that is in storage, he says. There are employers who think that because a type of protective equipment is bagged and stored, it doesn’t need to be inspected. Equipment that is stored for a long period of time could begin to degrade and get damaged, Adams points out.
“You want to make sure that when PPE comes out of storage to be used, that it’s still functioning and it does what it is intended to do,” he says. “You don’t want to pull out a Tyvex suit and find out there are holes everywhere.”
Machine Guarding and Lockout/Tagout
Don’t stop the audit when all PPE is determined to be in good shape. Move on to machinery out on the shop floor. When it comes to auditing equipment, one of the first places Adams examines is machine guarding; this is an area where he sees “a lot of potential for people to get injured.”
There are several questions companies should ask when inspecting equipment, such as checking the equipment’s overall condition, determining what machine guarding controls are in place and checking on the frequency of the equipment’s maintenance schedule. Even basic housekeeping around the machinery is important to examine, says Adams, as machinery tends to be messy. He says he has come across machine areas that have hydraulic fluid splattered everywhere and if these areas aren’t cleaned up, they can pose a hazard to the people working near them.
“I even look to see if the machine is being modified from its original design or construction and whether its modifications have any impact on the machine, its operations and potentially on someone’s health and safety,” Adams adds.
Because the metal-stamping industry is one where amputations average one a month nationwide, Ajax says an employer’s priority is to focus its efforts on auditing and following up on issues pertaining to high-hazard issues, such as guarding, as well as the history of the equipment.
“There is certain equipment in our plant that are more prone to needing more maintenance than others,” he explains. “Because there are literally hundreds of amputations that take place each year nationwide, we must be diligent about safety here.”
For instance, E.J. Ajax requires a daily comprehensive inspection on hoists, which are used to pick up thousands of pounds of steel, as well as fork lifts and power presses. In addition, the company commissions an external service and maintenance company to come every quarter to check the brakes of the fork trucks, the hydraulic lines and every part in the power presses.
E.J. Ajax also takes great care in making sure its employees are aware of the company’s lockout/tagout programs. The machines used at E.J. Ajax are large punch presses, huge machines that have, according to Ajax, “a tremendous amount of stored energy, lots of gravity and electrical hazards to deal with.”
From the moment new employees are hired, the company provides lockout/tagout training. Knowing that is not enough, company management, while conducting monthly audits, reminds each employee of the procedures for lockout/tagout. In addition, management has posted on every machine the step-by-step process to de-energize it and to ensure it it stays that way.
At Parker Drilling, the company has implemented what it calls an “integrated permit to work management system.” All risks and all simultaneous operations are viewed as part of a coordinated operations approach to controlling work activities. Davis says the system is unique to the drilling contractor industry.
On a rig, Davis could have employee teams performing electrical isolation, confined space tank entry and hot work all within 50 feet of each other. “You can see why we have had to take an integrated approach to the safe-work authorization process,” he states.
The Overlooked Areas
Despite the best efforts of employers to ensure every nook and cranny has been inspected, there tend to be areas that get overlooked, such as changing the saline solutions in portable emergency eye wash stations. Although the solution carries an expiration date, Adams notes he has seen instances where the solution remains in the eyewash station 4 months after it has expired.
He also notices that maintenance of general issues, such as lighting, is something that companies tend to take for granted. Despite the fact that emergency lighting has to be checked on a routine basis, Adams says he has visited plants where workers would be hard-pressed to find their way out during a power outage.
Which is why company management at Wilmington, Del.-based Dupont has adopted an approach that according to Robert Krzywicki, Dupont Safety Resources’ workplace safety practice leader, is foolproof: Ask the workers themselves.
Auditing Equipment and People
According to Krzywicki, a study Dupont conducted during the early 1990s showed that 96 percent of the company’s injuries were caused by unsafe acts and 4 percent were caused by unsafe conditions. As a result, when conducting their audits, Dupont places the onus on their workers’ behavior.
“As opposed to going out and inspecting and auditing ‘things’ or conditions, our observations, when doing inspections, tend to focus more on people,” Krzywicki explains.
This is not to say that Dupont doesn’t perform equipment inspection; they do. But Krzywicki says that as employees or supervisors are doing their daily or weekly equipment and maintenance audits, they also observe how people use the equipment and inspect the equipment at the same time.
For instance, if auditors are inspecting scaffolding, they talk to the employees on the scaffold and ask them if they inspected the apparatus before using it. In the event the auditors notice there is a problem with the scaffold that the workers missed, they automatically bring the workers down until that scaffold is fixed or replaced. In the process, the auditors investigate why the workers weren’t aware of the problem and take steps to ensure the situation doesn’t happen again.
“With any equipment used in the workplace, it is partially the responsibility for the user to inspect it to make sure it’s safe to use, whether it’s a scaffold, portable lifting equipment, hand tool, etc.,” says Krzywicki. “If this becomes a trend, we would look to incorporate more education and training.”
There even have been instances when talking to workers about their workplace behavior has driven companies to change their policies. This is exactly what happened at Dupont.
Krzywicki recounts a situation that happened a couple of years ago. He was walking through the plant and noticed an instrument mechanic who was not wearing his safety glasses like he was supposed to. Krzywicki reminded him to wear his glasses and the worker thanked him and put them on.
Hours later, Krzywicki passed by the same area and saw that the employee again wasn’t wearing his safety glasses. After Krzywicki talked to him and built a level of trust, the worker confided that he didn’t wear the glasses because they were scratched and impaired his vision. The reason why he didn’t get a new pair was because at that time, workers were supposed to pay for their second pair of glasses if the first ones they received were lost or damaged.
“So what was dragging his behavior was our policy that forced him to buy a second pair of glasses,” Krzywicki says. “We ended up changing our policy after that.”
According to Krzywicki, engaging with workers while conducting audits is beneficial because it not only allows the company to take action on the items that need to be fixed, but it also allows the company to examine the root causes of certain issues.
“Much of what we learn comes from what people tell us as much as or more than what we see with our eyes,” says Krzywicki.