Be Aware Safety Tips

Where We Have Been and Where We Are Headed: Some OSHA Insight

By Laura Helmrich-Rhodes, CSP, Ed.D.

It is difficult to say what might be an important workplace safety subject by the time this issue of Springs goes to print. As I write this, the global number of COVID-19 cases just marked 2 million. It appears the reopening of businesses under best precautions possible may be of greatest interest.

Protecting workers, of course, is in the scope of the Occupational Safety and Health Administration (OSHA). Some are aware that some states administer worker safety them selves through state-run OSHA. Other states rely on federal OSHA and enforcement (for a list of state plans, visit www. osha.gov/stateplans/statestandards).

Federal OSHA has created COVID-19 guidance (and provides materials in Spanish too). In their April 13, 2020, interim guidance memo (www.osha.gov/memos/2020-04-13/ interim-enforcement-response-plan-coronavirus-disease2019-covid-19), area federal OSHA offices are encouraged to protect their own employees and use electronic resources to follow up on non-health care informal complaints. This memo also gives guidance on identifying risk levels. In other words, OSHA is also concerned about their own employees being exposed to COVID-19 and doing what they can to prevent compliance personnel from becoming ill.

Referring to the OSHA (and referenced Centers for Disease Control and Prevention) materials on the OSHA website is the best place to find resources for safe return to or continuing to work under the threat of COVID-19. For example, as I write this, OSHA just published a “Safe Return to Work for Manufacturing” news release, which underscores the importance of seeking guidance from OSHA directly in this fluid situation. The best advice is to check the OSHA website regularly for updates on how to protect employees (www.dol. gov/newsroom/releases/osha/osha20200416).

In the meantime, let’s look at OSHA’s activity during the past year, specifically their interaction with this industry. Data were obtained from federal OSHA based on our North American Industrial Classification System (NAICS), which is a four to six-digit code that arranges businesses based on operations. This number is used for a variety of things including workers’ compensation risk determination. A company may have more than one appropriate NAICS number depending on various operations. The NAICS number for this inquiry was 332613, Spring and Wire Product Manufacturing. Referring to the OSHA (and referenced Centers for Disease Control and Prevention) materials on the OSHA website is the best place to find resources for safe return to or continuing to work under the threat of COVID-19.

The Data

Over the year dating April 16, 2019 to April 16, 2020, there were 10 OSHA visits (this includes both state and federal OSHA data). A total of 17 citations were levied against those 10 companies. Seven of the visits were “partial.” This means they were not “wall-to-wall” inspections. Three of the seven were “referrals.” This means that another agency of some sort alerted OSHA to the need for a Compliance Safety and Health Officer (CSHO) to visit the employer. Potential referrals come from other government offices, such as, wage and hour, environmental protection, and emergency management such as ambulance/fire agencies. Referrals can also come from the media. The data presented does not specify where the referrals originated. Two of the visits were due to employee complaints. Three of the 10 were “planned.” These are often part of local or national emphasis programs (NEP).

Examples of a local or national emphasis program would be amputation prevention, combustible dust explosion prevention or forklift safety. These are developed by a national agenda as well as local needs and driven by injury/fatality data. A

Laura Helmrich-Rhodes, CSP, Ed.D., is an independent regulations compliance consultant to the Spring Manufacturers Institute (SMI). A former member of PA/OSHA Consultation, she is an associate professor in the Safety Sciences Department at Indiana University of Pennsylvania where she teaches graduate and undergraduate classes on topics such as OSHA standards, safety communications, workers’ compensation and human relations. Rhodes is available for safety advice and information. Contact SMI at 630-495-8588 or laurahrhodes@gmail.com.

Total Cases All of Private Industry 2.8

Cases with DART

Cases with Days Away 1.6

0.9

Cases with Transfer or Restriction

Other Recordable Cases 0.7

1.3 Wire and Spring Manufacturing 3.9

2.4

1.1

1.3

1.5

review of fatality and catastrophic events for NAICS 332 revealed that 20 events occurred in the U.S. over the year (April 16, 2019 through April 16, 2020), 17 of which were fatal. Keep in mind that data is not just for wire and spring manufacturing, but a larger category of fabricated metal products. Still, the number is informative and alerts company owners that tragic injuries and deaths are possi ble, and every effort should be made to prevent such occurrences.

According to the Bureau of Labor Statistics, 2018 incident rates of nonfatal occupational injuries and illnesses by industry and case types, 2018 Table 1, Spring and Wire Products Manufacturing incurred the following losses: 3.9 total recordable cases, 2.4 total cases with days away from work with job restriction or transfer, 1.1 cases with days away from work, 1.3 cases with days of job transfer or restriction, and 1.5 other recordable cases. This compares to all of private industry’s 2.8 total recordable cases, 1.6 total cases with days away from work with job restriction or transfer, 0.9 cases with

My Company Data (From the OSHA Summary Sheet Poster)

days away from work, 0.7 cases with days of job transfer or restriction, 1.3 other recordable cases.

The key is to compare company data to the data provided (see work sheet). The information is located on your OSHA Summary Sheet that is posted every April 1. (If you have fewer than 10 employees, you do not accumulate this data but could use multiple years to create your own incident rate). Although these are lagging indicators, it can be informative to an organization with either a newly created formal safety

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program or for a company who is struggling with losses. Some questions have been raised as to the validity of incident rates of very small companies. Again, the answer is in using more data over several years to get a clearer comparison. (For more information on Incident Rates, see “Useful Websites” below.)

The Citations

OSHA’s posted list of most frequently cited standards for Spring and Wire Product Manufacturing (NAICS 332613) covers the period October 2018 through September 2019, with 31 companies incurring 127 citations. These 31 companies paid $542,110 in fines during that period. The most frequently cited OSHA standard was control of hazardous energy (lock out/tagout), at $149,992 in fines paid by nine companies. The costliest fine was machine guarding, with citations at $194,453 (15 citations at 12 companies). Those top citations were followed by hazard communication, respiratory protection and electrical. Others that made the list were walking working surfaces, forklifts, and guarding power transmission portion of equipment (belts, pulleys, gears, etc.).

Based on the above and the advent of COVID-19, employers should be ready to answer questions about what steps are being taken regarding OSHA standards related to respiratory protection, personal hygiene and prevention of infectious disease. If there is a lesson learned as to the source of OSHA inspections, it is to work diligently to communicate with employees so that complaints to the agency do not occur. Active listening and appropriate reaction to employee suggestions and concerns can reduce the need for agency interaction. n

Useful Websites

This website explains incident rates and the calculations for very small businesses:

https://www.osha.gov/laws-regs/ standardinterpretations/2016-08-23

Handling COVID-19 Complaints

https://www.ehstoday.com/covid19/ article/21128804/how-to-prepare-for-covi d19related-safety-complaints

OSHA Recordkeeping Advisor

https://webapps.dol.gov/elaws/OSHARecord keeping.htm

To-Do List

• Look at OSHA.gov Return to Work

COVID-19 requirements • Compare company OSHA data to national average • Review and Update » Crisis/Emergency Action Plan » Visitor Policies » Lockout/Tagout Written

Program and Written Shut

Down Procedures » Machine Guarding » Hazard Communication (inven tory, SDS, labels and update training) » Respiratory protection program

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