At this time, all dairy processing plants should have some sort of safety audit process in place to continually evaluate safety compliance in the facility. These safety audits are commonly conducted by the safety manager, safety committee members, area supervisors or other safety trained individuals, as well as an outside safety consultant on occasion. The purpose of the safety audit is to ensure the safety practices in the safety program and as prescribed by OSHA regulations are being implemented in the work processes, as well as to identify compliance items for corrective action. Failure to follow appropriate safety procedures creates increased hazards for employees and the potential for workplace injuries, and, in the event of an OSHA inspection, could result in citations with an increasing financial penalty.
The intent of this article is to provide companies with insight into some of the more common safety audit findings at a dairy processing plant from years of auditing experience. The article will also point out some of the most common OSHA citations and how they match up with the more common safety audit findings. Communicate these common safety findings to your safety auditors and see how your company matches up. Here are some results:
1. A Log of Recordable Injuries (29 CFR 1904) must be maintained and updated within seven days of any recordable incident. It is even more important now to accurately track OSHA recordables, as your company is likely now required to submit the OSHA 300A log summary annually to OSHA.
2. Personal Protective Equipment (29 CFR 1910 Subpart I), such as protective gloves, safety glasses, protective shoes, respirators, hearing protection, etc., must be used, maintained and stored properly. Also, each facility must have a written certification of PPE hazard assessment that specifies the tasks/ jobs and the required PPE. (Note: The Eye/Face Protection and Respiratory Protection standards are the No. 10 and No. 4, respectively, top OSHA citation for 2018.)
3. Confined Space Permits (29 CFR 1910.146) must be completed for all confined space entries and the completed permits must be reviewed and maintained for one year following entry. These are typically related to tank/ silo entries, as well as potentially some filling/packaging equipment.
4. Equipment-Specific Lockout/Tagout Procedures (29 CFR 1910.147) must be developed and written for most all machinery and equipment in the facility (with some exceptions) and these procedures must be reviewed/updated periodically (usually annually). (Note: The Lockout/Tagout standard was the No. 5 top OSHA citation for 2018.)
5. Eye Wash and Shower Stations (29 CFR 1910.151) should be inspected (and documented) weekly per the American National Standards Institute and located within 10 seconds/55 feet travel distance from any corrosive chemical hazard.
6. Fire Extinguishers (29 CFR 1910.157) must be tested annually (with tag) and visually inspected on a monthly basis (documented).
7. Powered Industrial Trucks/Fork Trucks (29 CFR 1910.178) must be inspected (documented) on every shift prior to initial use. (Note: The Powered Industrial Trucks standard was the No. 7 top OSHA citation for 2018.)
8. Machine Guarding (29 CFR 1910.212) must be in place around any machine or equipment to protect the employee from hazards created by a point of operation, ingoing nip points, rotating parts, flying chips and sparks, and these guards should be maintained in place and routinely inspected. (Note: The Machine Guarding standard was the No. 9 top OSHA citation for 2018.)
9. Electrical (29 CFR 1910 Subpart S) panels must be labelled with their magnitude and what they control, free for unobstructed access (e.g., 3 feet), free from openings
into the electrical (i.e., spacers, knock outs, etc.) and
closed when not in use.
10. Stainless Steel Welding (29 CFR 1910.1026) could result in employee exposure to hexavalent chromium and OSHA mandates that at least baseline hexavalent chromium air
monitoring is conducted to verify employee exposure below the OSHA standard.
11. Bloodborne Pathogens (29 CFR 1910.1030) requirements are applicable to any company that provides first aid/CPR or medical training to employees that are responsible (e.g., first aid team) to provide these services in the workplace in the event of an emergency.
12. Hazard Communication (29 CFR 1910.1200) requires that all companies maintain a current chemical inventory and safety data sheets for all these chemicals with all OSHAUpdates MSDSs now replaced with SDSs. (Note: The Hazard Communication standard was the No. 2 OSHA top citation for 2018.)
Challenge your safety auditors to focus on the more common safety audit findings and the top OSHA cited standards.