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  • OT Seeking Safety Program and Training Advice

    I work for a small company of about 30 people (not including temps), about half of which work in the office. We manufacture small foam consumable products for listening devices, i.e. in ear earphones, hearing aids, etc.
    So out in production we primarily cut and punch foam. Most everything is done on automated equipment which is well guarded, but we do have a handful of manual presses, by that I mean 4-ton pneumatic presses with anti-tiedown controls. We usually have 6 people in packaging and shipping, and about 8-10 in manufacturing. The only on the job injuries we have had were lacerations from changing the blade on one of our bandsaws with a razor sharp blade. The two instances required stitches and were the result of not using proper PPE.
    I should mention that we also have a lab that is used for foam development, so we do have a few hazardous chemicals in house. The lab is restricted to engineers.

    I am the machine design/automation/R&D engineer and am responsible for all of the production equipment. About a year ago I was asked to be the safety officer and implement a safety program consisting of safety training and regular safety meetings. I started out by having monthly meetings where I would cover a topic like press safety or eye protection, and also conducted formal Hazcom training. It has been a struggle to continually find topics for safety meetings and the meeting format never felt like a good fit. Recently I've abandoned the traditional safety meetings and instead sit in on the monthly production meeting and try to give a little spiel and open discussion.
    I also implemented a Near-Miss program but haven't seen the level of involvement that I had hoped for. Part of that is due to English as a second language for a handful of employees.
    I'm struggling now to find good topics to cover in our meetings, and how to have a better safety program. It seems awkward to constantly recycle the same topics.

    Any resources, opinions or personal experiences would be very helpful.
    Thanks!

    Tadd

  • #2
    Don't know where you're located, but does you state labor office or local community colleges or Vo-Techs offer safety training? Having someone else do training might involve money changing hands and might not be an option, but they might be a source of ideas or materials. State Labor Commissioners usually have a vested interest in OSHA compliance and might help.
    .
    "People will occasionally stumble over the truth, but most of the time they will pick themselves up and carry on" : Winston Churchill

    Comment


    • #3
      You may have to go zero-tolerance for awhile.

      Wear PPE or lose job.

      That's how it was for awhile at Old Job.


      Enforce the rules across ALL stratas, new, seniority, leaders, friends... make sure everyone is engaged in the process.


      For example, buy two sets of cut-resistant gloves and make policy that changing any sort of blade requires the use of these gloves. Anyone caught changing the bandsaw blade without the gloves gets walked out for two days without pay, next violation is permanent firing.

      Same thing with the safety features on your presses, and with any other machines you work with. Enforce it for ear-plugs, glasses, shoes... whatever it takes.

      Oh and make darn sure you have a basic lockout tagout program in place and that your shop-floor workers at least KNOW you have the program.

      "Lockout? Oh yeah that's the thing Mr. Turbotadd does when the machines breaks down" This is a better answer than "Lockout? What the **** is that how would I know I just work here."

      Feel free to PM me we can bounce ideas back and forth.
      "The Administration does not support blowing up planets." --- Finally some SENSIBLE policy from the Gov!

      Comment


      • #4
        There are consulting firms that specialize in safety programs, but as you may expect they are expensive. A less expensive, but possibly equally effective, is to hire a professor from a near by college/university who is a safety expert.

        Finally, one of the cheapest and often overlooked source of safety training is your workman's comp insurance company. They have a vested interest in reducing your accident rate and typically will help set up a safety program for free.

        Comment


        • #5
          I may be out on a limb here, but isn't being designated 'safety officer' a big legal deal under OSHA? From what I have heard/read, if things go south in a hurry, they want to know who the safety officer is, and what he taught and enforced, as you may end up being sued or worse because you taught something wrongly or did not enforce something you should.
          Management passes on these responsibilities to a 'safety officer' so they can have somebody else to blame when neccessary - this isn't being paranoic, at least I hope not, but I would look into your actual legal position and responsibilties before you go much further.
          While you see the workers lack of interest in your safety programs as just that - perhaps you should be doing the classes in the 'other language', or some lawyer will be able to blame you for an accident because 'obviously you knew that they didn't understand what you were talking about'
          I would be happy if lawyers became extinct, but until that glorious day - we have to take their parasitical thinking into account. And as many here will attest, it's always a positive program until the accident happens, then managment can turn on a dime - but I hope yours wouldn't be like that :-)
          Richard in Los Angeles

          Comment


          • #6
            You could always start your talk with a nice photo, like so (Warning, Highly GRAPHIC):

            http://www.google.com/imgres?hl=en&s...9,r:1,s:0,i:79


            Then ask them to describe how such an injury might happen, and how to prevent it...


            hth,

            doug

            Comment


            • #7
              Lots of good advice so far.

              I wasn't in the safety department. However, my job was highly involved with it. I wrote confined entry procedures, and lock out/tag out procedures, probably close to 150 in all. All of it was passed on to my superiors for approval (CYA). MSHA actually came out and helped us make a few safety videos, that we shared with the industry.

              I would suggest you follow RPM22's advice and determine your "legal responsiblity", if you ask the company reps and they indicate you're not on the hook for anything. MAKE SURE YOU GET IT IN WRITING WITH SIGNATURES! Also make sure you are properly compensated for your responsibilities.

              25 years ago when the mining industry first started requiring PPE, it was impossible to get the guys to wear it. I suggested that we start a "rewards" program. Each crew/shift was broken up into teams. If anyone got hurt, near miss, safety violation, etc., then the whole crew lost their points for that month. At the end of the year they got a gift catalogue and based on how many points they had they could "buy" different items. If they got all their points for the whole year, they got a "bonus" also. It took just a couple of write ups and the crews started "policing" their co-workers, peer pressure made a huge difference. In just a few months, everyone was wearing PPE, and the "rewards" program really didn't cost any more than paying for injuries, workmans comp, emergency room visits, etc.

              After that program ended we would have safety "dinners". We would reach so many hours without a lost time accident and the employees would receive a gift (knife, jacket, etc.) Management would call in a caterer and help cook steaks, etc. We would serve the employees and thank them for their efforts.

              good luck,
              Ken

              Comment


              • #8
                Originally posted by RPM22 View Post
                I may be out on a limb here, but isn't being designated 'safety officer' a big legal deal under OSHA? From what I have heard/read, if things go south in a hurry, they want to know who the safety officer is, and what he taught and enforced, as you may end up being sued or worse because you taught something wrongly or did not enforce something you should.
                Management passes on these responsibilities to a 'safety officer' so they can have somebody else to blame when neccessary - this isn't being paranoic, at least I hope not, but I would look into your actual legal position and responsibilties before you go much further.
                While you see the workers lack of interest in your safety programs as just that - perhaps you should be doing the classes in the 'other language', or some lawyer will be able to blame you for an accident because 'obviously you knew that they didn't understand what you were talking about'
                I would be happy if lawyers became extinct, but until that glorious day - we have to take their parasitical thinking into account. And as many here will attest, it's always a positive program until the accident happens, then managment can turn on a dime - but I hope yours wouldn't be like that :-)
                Richard in Los Angeles
                Hi,

                I did the safety officer thing for many years. Unless you do something egregious, like recommend licking your fingers before sticking them in the light socket, the final responsibility rests on management. And OSHA will go after them to hang, before allowing them to bargain penalties down to light slaps on fingers or a strongly worded reprimand. As long as you keep some semblance of accurate paperwork, there is little to no liability for the "safety officer".

                As far a subjects go, you can cover almost anything that maybe relevant. Everything from basic lockout/tag out to pertinent hazmat. Other suitable subjects you can cover are fire/weather emergencies and plant evacuation, to plant house keeping, trips and falls, proper lifting, forklift safety, to poor weather driving and other seemingly mundane subjects. The list can be endless. But all you really need are a dozen or so subjects that are important to your company. And each session only needs to take maybe 10 minutes. And yes you will repeat subjects. This shows consistent training.

                I personally would tell you that formal safety meetings are the best method. Use a signed in roll call for attendance and a subject to be covered header. Place this in a file for proof that you do have a company wide safety program and that employees do attend. Such a file will satisfy OSHA. Informal undocumented commentaries do not.

                As far as gaining compliance, I like the candy and carrots method myself. It takes a bit more effort perhaps, but lays down a better foundation to build on. Still occasionally, a club is needed. In the dozen or so years I did the safety thing I only had to fire one person for repeatedly breaking safety rules.

                On the other hand, I have always had the best threat. Which is - Always think before you do. Because if you do get hurt, I will be the first trained medical personnel to work on you.......Do you really want that?

                dalee
                If you think you understand what is going on, you haven't been paying attention.

                Comment


                • #9
                  Often I will turn to one or another of the employees. "Jose,I have run out of topics.How about you running this safety meeting."
                  They always come up with an idea or topic that I had overlooked. It also builds their confidence and self esteem when they out fox me.

                  Comment


                  • #10
                    As for the legal deal........ I am no lawyer, but.....

                    I strongly doubt that the company can take "Joe Schmo" (or in this case, you), designate him as "safety officer", and duck responsibility. Not without "Joe" having training, certifications, etc, etc.

                    Unless "Joe" can be shown to be a "trained safety professional", then management "knew, or should have known" that "Joe" was not qualified to operate the safety program, and so management will continue to bear the responsibility that would otherwise fall on "Joe" (if any). "Joe" will have no more responsibility than the machine operator who causes an accident from sheer lack of training.... which is minimal.... the lack of training gets the blame, and management gets the blame for that.

                    If you walk someone in off the street, no matter what their training, and get them to stamp/seal drawings, they bear no responsibility for resulting failure unless they are a registered professional engineer who is qualified and recognized as capable of doing that. (Other than a possible fraud conviction).

                    Same with "Joe", assuming he is not complicit in some sort of fraud....
                    1601

                    Keep eye on ball.
                    Hashim Khan

                    Comment


                    • #11
                      Properly training people on how to use a fire extingusher is a good topic. I have seen several small fires on worksites where people were cluelees on how to use a fire extingusher properly. If you have access to a rechargeable water extingusher it works great as a traing aid so every person can use it and be familiar with the proper use and operation.

                      Comment


                      • #12
                        Originally posted by J Tiers View Post
                        As for the legal deal........ I am no lawyer, but.....

                        I strongly doubt that the company can take "Joe Schmo" (or in this case, you), designate him as "safety officer", and duck responsibility. Not without "Joe" having training, certifications, etc, etc.
                        I'm no lawyer either, but I'd agree with that. Even with the certifications, I believe the final buck stops at the top.

                        The health and safety manager at a place I once worked was always very clear about this. He always said that the first provisions of OSHA regulations would state that ultimate responsibility for employee safety rests with owners and senior management. they were simply not permitted to shirk responsibility for a serious accident by saying "that was Joe Schmo's job" because they ultimately make the call as to who does that job and how they do it and that they creat the environment that either promotes employee safety or does not. OSHA takes the position that if Joe S. was not doing his job, they should have known and dealt with him to avoid a dangerous situation.

                        He was so vocal about this because he was required to issue safety procedures and policies that were to be reviewed and/or updated annually and signed by management. He did this and annually would submit the documents for review and approval from the top managers and owners. Every year the owners and managers would simply not reply, nor sign them. So he made it common knowledge that the leadership avoided signing those documents, and that that provided them no protection from legal responsibility. He would quote chapter & verse from the applicable OSHA regs saying as much.

                        It was an interesting place to work sometimes.

                        Comment


                        • #13
                          It is likely similar to legal advice......

                          If you copy something recklessly, you may be liable for penalties for copyright violations, as well as having to pay the copyright holder for the use.

                          If you get legal advice, and the advice is that you are n no danger of copyright violation, then you are still liable for the usage fee, but according to the legal advice I have been given, the exposure to penalties is much less. Similarly for patent infringement.

                          Essentially, when the government makes you dependent on a registered professional for advice, then the results of you in fact depending on the professional's advice must not be the same as if you willfully and recklessly went ahead without getting advice. The professional must "hold you harmless" to some extent, bearing the responsibility himself. You are "not qualified" to evaluate the advice you received, and went ahead in good faith based on the advice of a qualified person....so no argument of "knew or should have known" ought to prevail against you.

                          If you get someone who is NOT a qualified professional to advise you, then you knew, or should have known, that the person was not qualified, and the onus is back on you. You are regarded as qualified to determine if the professional has the qualifications, which is generally a license from the state.
                          1601

                          Keep eye on ball.
                          Hashim Khan

                          Comment


                          • #14
                            Originally posted by J Tiers View Post
                            As for the legal deal........ I am no lawyer, but.....

                            I strongly doubt that the company can take "Joe Schmo" (or in this case, you), designate him as "safety officer", and duck responsibility. Not without "Joe" having training, certifications, etc, etc.

                            Unless "Joe" can be shown to be a "trained safety professional", then management "knew, or should have known" that "Joe" was not qualified to operate the safety program, and so management will continue to bear the responsibility that would otherwise fall on "Joe" (if any). "Joe" will have no more responsibility than the machine operator who causes an accident from sheer lack of training.... which is minimal.... the lack of training gets the blame, and management gets the blame for that.

                            If you walk someone in off the street, no matter what their training, and get them to stamp/seal drawings, they bear no responsibility for resulting failure unless they are a registered professional engineer who is qualified and recognized as capable of doing that. (Other than a possible fraud conviction).

                            Same with "Joe", assuming he is not complicit in some sort of fraud....
                            Hi,

                            That's why I said there is little to no liability for a safety officer and final responsibility rests with management. All course material has to be approved by the appropriate managers. In a small company, this will most likely be the owner/s. Not that they are in much danger of any legal consequences either.

                            As a former safety officer and a fire fighter, I will tell you that is not a good idea to train the general workforce to fight fires in the workplace. And extinguisher training will imply that to OSHA. It is OK to perhaps train some employees, (like supervisors/leadpersons), to be designated to be so trained. But even then it could be risky for the company from a liability standpoint. I know extinguishers are probably hanging everywhere in the plant. But there can be a big difference in the legal ramification of having something and actually using them. Stupid I know, but often times true.

                            dalee
                            If you think you understand what is going on, you haven't been paying attention.

                            Comment


                            • #15
                              Thanks to all for your responses. Dalee, I agree the formal safety meeting is the best method, and when I had done them in the past I had handouts and sign-in sheets. Maybe the thing I've been hesitant to accept is that topics will be recycled.
                              I am lucky to work for a small company free of all the politics that come with the larger ones, and the Senior Management group is great. Our Director of operations has a lot of experience with plant safety and is the primary "enforcer" of the rules.

                              Thanks again,

                              Tadd

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