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Production: Practicing Safe Operations and Compliance in Your Facility
We’ve all done it at one time or another: taking that shortcut or bypassing safety measures to get the job done. Production demands can make us do some unsafe things, often with disastrous results.
I’ve investigated fatal accidents as well as minor scratches and scrapes in the workplace. Most often accidents are the result of equipment failure due to improper maintenance, employees taking shortcuts, or simply a lack of training both in processes and on equipment.
We tend to frown when our regulatory agencies pass through our facilities, but in truth it can be a good thing and keep us honest. Safety should be a primary focus at our properties. We owe it to employees to provide a safe workplace and adequate training on equipment they work with.
Several years ago, I investigated a fatal workplace accident in which the employee bypassed safety measures in order to make the job easier. Unfortunately, the minutes he would have saved cost him and his family quite a bit more.
Where to Start
If your company is one of the few that doesn’t require pre-employment drug screening, I’d advise you to change that policy immediately. I certainly don’t want to work alongside someone on a machine who is impaired and your employees shouldn’t have to either.
I’ve seen employees start-up inserters before others get their hands clear of the machine because they weren’t paying attention, impaired or not. Unless you practice safety in your shop on a daily basis you’re headed for trouble.
When there is an accident in production, even a minor scrape, it should be thoroughly investigated. Step one is getting employees used to reporting accidents. Obvious as this sounds many people are either too embarrassed to report minor accidents, or figure it’s so minor that it’s not worth reporting. Then, a week later, when it’s swollen up the size of a beach ball, it’s a different story. At this point, we have issues with workers comp claims, drug testing after an accident, and what could have been a very minor situation turning into a nightmare.
Of course, the best way to avoid accidents is to take measures to avoid them on the front-end. Setting up safety committees, safety inspections by third party vendors, safety meetings, safety reviews, training and certification, equipment inspections, personal protective equipment, the list goes on.
Let’s start with setting up a safety committee. It’s a challenge to find members who are sincerely interested in doing the work. I’ve found that many employees prefer to let you know what’s unsafe around the building, as long as they don’t have to be part of the solution. Select someone from each department to sit on your committee, someone who truly cares and wants to make the workplace safer. Because often members don’t work directly in production, expect discussions about designated smoking areas, clear paths through editorial, extension cords, etc. in addition to production related safety. Although these can be important to overall safety in your building, most accidents happen in production and this is where the focus should be.
Depending on the size of your operation, meeting monthly or even quarterly should do it. Keep accurate notes on safety issues discussed and responsibility, what has been accomplished since the last meeting, outstanding issues, what goals have not been met, and go over any accidents since the last meeting.
Management may also want to contract third-party vendors to monitor safety. Most of these vendors are up to speed on OSHA regulations, state laws, and can save quite a bit of time and expense trying to put together an in-house committee.
Understanding the Need and Benefits of PPEs
Hopefully, you have a hearing protection policy in your production area.
Many companies measure employee’s hearing at the start of employment and then annually thereafter. This establishes a baseline and issues can be addressed effectively with annual testing. As well as protecting our valued employees, in today’s “litigation happy” environment, this is an extra measure of protection for the organization.
OSHA measures noise exposure on decibels over time. NIOSH (National Institute for Occupational Safety and Health) recommends that all workers remain below 85 dBA for eight hours to minimize occupational noise induced hearing loss. Basically, the louder your production area is the shorter employees should be allowed to be subjected to it and the longer your employees are in the area measures should be taken to reduce noise. Many areas of production may not require hearing protection, in other areas it’s a must. It’s a tough thing to understand and many newspapers bring in outside help to ensure compliance. I’ve brought in insurance carriers in the past to take measurements. First, it’s usually free, and second, they’re happy to help because it reduces their exposure as well.
As a side note, management should “practice what they preach.” I’ve seen publishers, directors and department managers hanging around in production areas for hours without hearing protection. If you expect your employees to work safe, you should set a good example.
Of course the easiest way is to just avoid problems in the first place by offering personal protective equipment or PPEs and requiring their use in all areas of production.
Noise protection. Hearing protection comes in two basic forms: in-ear and over ear. In ear protection, typically foam plugs, and over the ear headsets both come in various dBA ratings. The choice usually comes down to what the operator feels most comfortable wearing.
Respiratory protection. PPE can vary in this area as well, from SCBA (self-contained breathing apparatus) to a simple dust mask. It really isn’t often that we need air-supplied respirators in our business, but on occasion if you’re cleaning ink tanks or are exposed to any form of potentially hazardous material, refer questions to your local county hazardous materials division before even starting such a project. Common dust masks (referred to as respirators) are measured by the percentage of airborne particles they filter. They typically come in N95, N99 and N100 categories, depending on the degree of desired protection. Normally, a mechanical filter respirator (dust mask) is all that is needed when blowing out dusty equipment, inserting machines, compressors, etc.
Eye protection. As important as preserving your sight may be, I’ve observed employees doing more crazy things without eye protection than I have any other safety offense. No harm in grinding a burr off a metal bushing; it only takes five seconds, so who needs eye protection for such a quick job, right? Same deal working around parts washers and press solutions. Train your employees’ right and be firm when they bypass safety requirements.
Check your eye wash stations frequently. Keep the caps clean and in place. Check the function, run the water (or solution) and check signage. Maintain a clear path to the unit and make sure everyone knows the location.
Additionally, from a production standpoint, the general eyesight of your press operators is critical. Accurate registration and color matching is essential in printing. Consider implementing requirements for general vision and color blindness testing for your press crew.
Hand protection. Employ common sense here. If you’re handling skids/pallets, use heavy leather gloves to avoid splinters and cuts; if you’re using solutions, ink, etc. use basic Nitrile disposable gloves. Be sure to have employees check for Latex allergies first and if one exists, use only a latex free glove.
Although it may seem obvious, be sure your employees understand how to use PPEs. How to remove soiled gloves without contamination, how to snuggly fit a mask, the right eye protection for the job and how to properly fit ear protection.
Safety Data Sheets
If an accident occurs, or an employee simply wants to know what type of chemicals/solvents they are coming in contact with, or if an outside agency (Fire, OSHA) wants more information, MSD sheets (now referred to as SDS or Safety Data Sheets) are simply your best insurance.
You are required (and should want to) keep an SDS on almost every product in your shop, from WD40 to blanket wash, penetrating oil, ink, etc. A complete master of all MSD sheets should be kept in a central place within your facility, that everyone is trained and aware of. In addition, keep a complete copy in each area of production in case someone from one area needs information on another area outside their immediate scope. Make certain that everyone knows the location of your booklets and that they are easily accessible to fire departments, local agencies and employees 24/7.
It is also important to stay current on MSD sheets. Never allow a chemical to come into your facility before you have an SDS and have added it to your booklets. Most sheets are now available through the vendor website and can be downloaded and printed before the product arrives.
New Requirements for Globally Harmonized System Training
Starting June 1, 2015, all chemical container labels were required to include pictograms, signal words, hazard and precautionary statements, product identification and supplier identification. OSHA required all affected employees receive training on this new labeling system and SDS policies.
The primary changes to the HazCom standard that apply to newspaper production areas are that SDS now are standardized with a 16-section format to achieve similar standards throughout the world and chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category.
Lock Out/Tag Out Programs and Equipment
OSHA’s new standard states that if more than one person is involved in LOTO activity, certain steps need to be taken to guarantee the safety of all involved. One member of the group should be designated as the leader to coordinate the actions of the others. The leader needs to know the hazard exposure levels of each of the employees under his watch.
Each employee involved in the operation must attach his own lock to the lockout device. A group hasp, lock box, or other effective means must be used to accommodate this. Each employee shall have the only key to their lock and only they can remove their own lock.
Be certain to have proper kits on hand to comply with OSHA LOTO requirements.
Kits should be displayed in an area easily accessible 24/7 by all employees and training sessions should be conducted on at least an annual basis. New employees should not be allowed to start work until properly trained in all MSDS and LOTO standards.
Forklift Training and Certification
Most of our production areas have forklifts, electric pallet jacks or clamp trucks in operation on a daily basis. In some shops, individuals who don’t even quality for a driver’s license are allowed to operate a piece of equipment that can kill. We’ve all heard the horror stories and seen the videos. I’m familiar with one case in which an individual with a known medical issue was allowed to drive a forklift, right off the end of a dock.
It is our responsibility to the company, the individual and coworkers to properly train and at the least internally certify operators.
Your company should have at least one trainer who is qualified to instruct others. If you do not have this in your organization, seek third-party assistance. Each individual operating a lift should be required to watch a video and pass a written test. There are many online companies who provide excellent videos and tests you can purchase.
The qualified trainer should sit through the video with employees annually (and all new employees upon hire) to answer any questions, pausing the video at opportune times. Afterward, a written test should be completed by each attendee and a standard should be met.
I have had employees who score 100 percent on the written test that you wouldn’t want to be in the same room with when they start up a forklift. Book smart doesn’t always mean you’re going to have a safe operator.
The final step should be an actual driving test. Explain the controls in detail; don’t assume that just because the driver may have operated a fork truck at a previous job that the controls were the same. Set-up in a safe area; go through a driving “test” yourself in front of the employee to familiarize them with the operation. When it’s their turn, have the driver show that they understand the lift, tilt, side-lay and associated controls before putting the unit in gear. Once you’re comfortable with their basic ability, have a predetermined test in which they pick-up product (pallets or paper rolls) and convince you that they are able to safely operate the equipment. As a final test, have them run through a written safety check of the unit.
Other Areas in Production
Periodic equipment inspections, detailed/documented vehicle inspections, air compressor checks, press guards, pinch point awareness, electrical disconnects, gas and water shutoffs, pressroom maintenance to avoid slips and falls, soiled rags in U/L approved containers, spill prevention and containment, mitigation and abatement, emergency response, CPR, First Aid, AED operation, emergency coordinators, lazar inspection of electrical panels for hot spots, fire/sprinkler systems, etc.
There are simply too many safety related areas to cover in detail here. I believe accident prevention and safety is best achieved through proper training, providing the right equipment and the use of common sense. We create the opportunity for accidents to occur through our action. We also have the ability to prevent accidents by doing our jobs, following procedures, training our employees, maintaining equipment, following established safety guidelines and not taking unnecessary chances.
It’s a simple fact that most, if not all accidents, are avoidable.