BOS 3525 Unit II Assignment

Unit II Assignment

BOS 3525 Legal Aspects of Safety and Health

Columbia Southern University

Unit II Assignment

The actions that will be outlined below will mostly consist of administrative and work practice controls. These guidelines outline how our company will address the findings that were initially highlighted by the Compliance Officer during the walk-around at our facility. These measures will be the initial actions taken, and may evolve and expand once they have been applied within the facility. The recommended policy and procedure changes will take place without delay to make sure the discovered violations are rectified and prevented from occurring in the future. The issues will be addressed in the same order that they were found by the Compliance Officer.

The initial violation that was discovered was the heave haze that was present in welding area. To address this violation the following actions will be taken:

1. Contact an outside industrial hygienist (IH) or third-party agency to conduct new air quality tests.

2. Contact the air ventilation manufacturers to confirm that the ventilation equipment is in working properly, and meets the appropriate required needs that are outlined in the air quality analysis from the IH.

3. Replace or repair any equipment that is in need of action.

The next violation that was discovered was employees with full beards wearing a half-mask air-purifying respirators. This specific violation could have been a quick-fix situation, by having the employees cease operations immediately and shave their beards. To ensure this violation isn’t repeated the following actions will be put into effect to address the violation:

1. Any and all workers that are in the Respiratory Protection Program (RPP) will be required to maintain a clean shaven face when reporting for work.

2. A refresher RPP training will be completed for all personnel assigned.

3. RPP workers that arrive to work without being clean shaven will be disciplined about the violation and sent home with no pay for that day.

4. All personnel assigned to the RPP will now have a RPP sticker on their hard hat identifying them as such.

The next two violations involved the use of emergency eyewash in locations where employees where using chemicals that could be injurious to the eyes, and no emergency eyewash was present and an eyewash was present in another area of the plant that was covered in dust, and there was no indication of recent operation or inspection. Both of these violations will be addressed together. The following actions will be taken to address the highlighted violations:

1. The company safety representative will conduct an inspection throughout the workplace looking for hazards that require the use of an eyewash station.

2. Eye wash stations will be installed in every area identified as meeting the criteria of need.

3. Eyewash stations that are previously installed will require inspection to ensure they meets the required standard.

4. The safety representative will conduct and document monthly inspections of the eye wash stations to prevent any further issues.

The next problem that was discovered was workers not wearing proper personal protective equipment (PPE) in the form of chemical protective gloves while utilizing a chemical that could be absorbed through the skin. This is another violation that could have been corrected on the spot, by having the employee(s) don the proper PPE available at the workstation. The following actions will be applied to prevent the discovered violation from occurring in the future:

1. Use the SDS sheets on file and develop and deliver a chemical/PPE awareness training for all personnel in the facility.

2. Disciplinary action will be taken if an employee is seen handling a chemical, and not wearing the suitable PPE.

The next two violations discovered involved Lock Out/Tag Out (LOTO). The first was a situation of no LOTO being utilized, and the second was there wasn’t a written LOTO program available during the inspection. The following actions will be applied to prevent the discovered violations in the future:

1. Build and employ a LOTO program.

2. Ensure all personnel are trained on the new LOTO program.

3. Supervision will deliver LOTO duties to the affected personnel in the morning meetings and ensure proper dissemination throughout the worksite.

4. Precise isolation processes will be written for all equipment that requires LOTO to ensure all energy sources are de-energized.

The next discovered violation was welding operation were performed near flammable materials, and no fire watch was present. This was another quick fix situation that could have been corrected on the spot by getting a welder who is trained in fire watch to help by working as the fire watch person. To ensure this violation isn’t repeated the following actions will be put into effect to address the issue:

The next violation that was discovered was no record of training for fork truck drivers. To ensure this violation isn’t repeated the following actions will be completed to tackle the issue:

  • Require a permit for all welding operations or hot work tasks that will be within 35 feet of a flammable material.
  • The area needing a permit will require a trained fire watch person on duty.
  • The permit will be approved by the worksite supervisor for the assigned area and also be signed by the area fire watch person.
  • If there is not a trained fire watch person available, all jobs in that area will be suspended until one is available.
  • Re-training will be conducted for all employees that perform hot work job tasks.

1. Contact an outside training agency to train and certify all of our fork truck drivers.

2. Create a documentation process/file to ensure or records are current and up to date on who is trained to use the equipment.

3. Hold a meeting with all personnel notifying them that only trained personnel are allow to operate the fork trucks.

4. Post written notifications throughout the worksite notifying personnel to not use fork trucks unless they are trained and certified.

The next discovered violation was extension cords were stretched across walkways. This violation could have been corrected on the spot by installing a cord protector over extension cords on the walkway. To ensure this violation isn’t repeated the following actions will be completed tackle the issue:

The next violation discovered was three containers were present in the plant with no label present on any of the containers. The following actions will be applied to prevent the discovered violation from occurring in the future:

  • The safety representative will conduct and document monthly inspections of the walkways to ensure there are no extension cords that are in walkways, if found they will have cord protectors installed over them immediately.

1. Have the IH complete an analysis on the containers to verify the contents present in the container.

2. Inspect all of the containers in the facility for proper labeling. Contact the manufactures for any labels that need to be replaced.

The final violation that was discovered was an employee could not locate the SDS for the chemical they were using when prompted to by the Compliance Officer. The following actions will be applied to prevent the discovered violation from occurring in the future:

1. Inspect the entire workshop and make sure all chemicals have a SDS sheet.

2. Compile all SDS sheets and create an electronic folder where all employees have easy access to the list of SDS sheets in the workplace.

3. Compile all SDS sheets and print hardcopies and place in a central area that employees have easy access to.

4. Train all employees on how to access both the hard copy and the electronic SDS sheets.

5. Make sure there are SDS sheets for any new chemicals coming into the facility and that they are updated in the folders.

The modifications listed herein will have to occur immediately to make sure we are 100% compliant throughout this facility. Management will hold out-brief meetings every day to review the planned course of actions listed above and track them to completion.

References:

Occupational Safety and Health Administration. (2016). Field operations manual. Retrieved from https://www.osha.gov/OshDoc/Directive_pdf/CPL_02-00-160.pdf

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