An Analysis of Fall Protection Hazard’s at Auburn’s Briggs & Stratton Facility
Briggs & Stratton, Auburn, AL. M.I.S.E. Project: INSY 7980 September 21, 2009
Department of Industrial and Systems Engineering
Committee Members:
Dr. Jerry Davis Dr. Robert Thomas Dr. Rich Sesek Dr. Chip Wade
Presented By: Omar Whitfield This report is for training/educational purposes only. 2
TABLE OF CONTENTS
ACKNOWLEDGEMENTS……………………………………………….3
EXECUTIVE SUMMARY………………………………………………..4
INTRODUCTION…………………………………………………………5
METHODOLOGY………………………………………………………..11
RESULTS………………………………………………………………….12
COST JUSTIFICATION………………………………………………..21
COUNTERMEASURES………………………………………………….26
DISCUSSION AND CONCLUSION…………………………………28
REFERENCES…………………………………………………………….32
APPENDIX A: JHA WORKSHEETS OF VARIOUS FALL HAZARDS AT BRIGGS & STRATTON
APPENDIX B: MISE PRESENTATION
APPENDIX C: APPLICABLE FEDERAL OSHA STANDARDS
APPENDIX D: SUGGESTED LIST OF ALL RECOMMEDED DEVICES NEEDED TO COME INTO COMPLINACE WITH ALL APPLICABLE OSHA STANDARDS.
This report is for training/educational purposes only. This report is for training/educational purposes only. 3
Acknowledgements
I would like to express my deepest gratitude to my Lord and Savior, Jesus Christ, for giving me the necessary fortitude to continue through contentious times when my faith began to waiver and giving me the strength to keep moving forward to my ultimate academic goals.
I would like to thank my mother who has always given me continued support throughout my collegiate career. Her support has been paramount in all things I have been able to accomplish. Her support was essential to me going on to have a successful collegiate career instead of being just another statistic.
I would like I would like to thank Dr. Jerry Davis, Dr. Robert Thomas, Dr. Richard Sesek, and Dr. Chip Wade for your patience as advisors, your actions and words of encouragement have been essential to my success during my time here at Auburn. I would like to thank Scott Walker, Safety Engineer at Briggs & Stratton, for taking me under his wing and showing me so much about how to be an excellent safety professional. Hopefully, the opportunity I was given to work at his facility to conduct my project will make Auburn’s Briggs & Stratton’s Auburn facility a safer place. With his commitment I was able to create a better final product.
Lastly, I would like to give thanks to everyone who was involved with me receiving my NIOSH fellowship and Graduate Teaching Assistant support. Without this support my success at Auburn University would have not existed.
Special thanks to: LuAnn Sims, Dr. Alice Smith, Dr. Richard Sesek, Tamela Hall, Mary Drennen, Gabe Allen.
This report is for training/educational purposes only. This report is for training/educational purposes only. 4
Executive Summary During my time of employment at Auburn’s Briggs & Stratton facility my primary responsibility consisted of identifying and addressing fall protection hazards at the facility. Causes of fatal falls can include unstable working surfaces, misuse of fall arrest equipment and systems and human error due to lack of training (Smith,
2006). A primary concern of the Safety Engineer at the facility was the presence of potential fall hazards that exist which could seriously injure personnel in addition to being in violation of applicable Occupational Safety and Health Administration
(OSHA) standards. When addressing fall protection hazards, the most common techniques include engineering controls, administrative controls, and use of personal protective equipment (PPE). Engineering controls involves the concept of controlling a hazard at its source. This includes designing the workstation to eliminate potential hazards or at the least, reducing them. Administrative controls on the other hand do not eliminate the hazard but rather reduce the employee’s exposure to the hazard. A typical example of this includes additional relief workers, exercise breaks, and the rotation of workers. A last result to reduce employee exposure to hazards is the use of PPE. Notable fall protection PPE that is commonly used in industry consists of safety harnesses, lifelines, safety nets, and lanyards just to name a few. The author wants to stress the importance of wearing PPE as a last resort. The primary focus of any safety professional should always be to engineer the hazard out. My goal at
Briggs & Stratton was to walk the production floor to identify all fall protection hazards within the facility. Once I identified all of these hazards, I would then create a “hybrid” Job Hazard Analysis (JHA) Form tailored for use at Briggs & Stratton which would identify the hazard and provide a recommendation on how to address the hazard. OSHA defines Job Hazard Analysis as a technique that focuses on job tasks as a way to identify hazards before they occur (OSHA Job Hazard Analysis, 2002). In
This report is for training/educational purposes only. This report is for training/educational purposes only. 5 total there were 34 hazards identified, which the site’s Safety Engineer agreed needed to be addressed. A more detailed description of these hazards can be found in Appendix A. Hopefully this report should assist the site Safety Engineer in addressing potential fall protection hazards within the facility and bring them into better compliance with all applicable Federal OSHA standards (Appendix C).
Introduction
Since the inception of the OSH Act, which the United States congress passed in December of 1970, the rate of occupational injuries and illness has seen a steady decline. During the U.S. industrial revolution, some estimates suggested that there were nearly 85 to 90 deaths per 100,000 full time employees that have worked each year. Roger L. Brauer, the author of Safety and Health for Engineers estimates that the current number is closer to 35 deaths per 100,000 full time employees which is a significant reduction and is mostly due to the passage of the OSH Act. OSHA estimates more than 6,000 accidental deaths and nearly 10 million disabling injuries occur each year in the U.S. (Brauer, 2006). Falls from elevation contribute a great deal to these statistics. In 2007 alone, the Bureau of Labor Statistics listed falls as the second leading cause of workplace fatalities with 847. Fall hazards from elevated levels are present at almost every job site and the Briggs & Stratton Auburn facility is no exception. Any surface on which there is walking and working could present a potential hazard. OSHA has a few standards, which deal with the aspect of fall protection. OSHA Fall Protection standards 1926.500 to 1926.503 Subpart M cover fall protection fully, including when and where fall protection is required and for what construction activities. It also specifies system component requirements. General
Industry standard 1910.23 Subpart D covers fall protection requirements as they relate to walking and working surfaces. OSHA Fall Protection standards 1926.500 to
1926.503 Subpart M specify that any unprotected side or edge which is 6 feet or more above a lower level should be protected from falling by some type of guardrail
This report is for training/educational purposes only. This report is for training/educational purposes only. 6 or fall arrest system. OSHA walking/working surfaces standard 1910.23 Subpart D specifies that every open-sided floor or platform 4 feet or more above a adjacent floor or ground level shall be guarded by a standard railing on all open sides except for where there is entrance to a ramp, stairway or fixed ladder. Subpart M basically provides the standards for fall protection systems and employee training whereas subpart D of the General Industry standard addresses the basic elements of fall protection in the General Industry setting. Based on these two standards, the site’s
Safety Engineer and I determined more fall protection was needed on the production floor. The primary employees who are exposed to fall protection hazards are maintenance workers. Many times it is the responsibility of maintenance employee’s to maintain or work on broken machinery, which may be at elevated heights. In order to reach these elevated heights, employees may use a fixed ladder, which is secured to the machine, or use an aerial lift when a fixed ladder is not present. A fall protection hazard that may arise is the lack of a swinging gate or preferably a self closing swinging gate on the fixed ladder or a lack of an adequate guardrail on the machinery to prevent workers from falling off of the adjacent sides when working on the machines. Since 1984, fatalities from falls from elevations have gradually increased from the fourth leading cause of workplace deaths to the second leading cause in 2007. Based on data from the National Institute of Occupational Safety and
Health (NIOSH) National Traumatic Occupational Fatalities (NTOF) Surveillance system, falls from elevations were the fourth leading cause of workplace death from
1980 through 1994 (U.S. Department of Health and Human Services, 2000, Pg. 11).
The 8,102 deaths due to falls from elevations accounted for 10% of all occupational fatalities during this same period which averaged approximately 540 deaths a year
(U.S. Department of Health and Human Services, 2000, Pg. 11). The National
Institute of Occupational Safety and Health (NIOSH), stated in 1992 that “once the third leading cause of work-related death across all industries, falls have surpassed
This report is for training/educational purposes only. This report is for training/educational purposes only. 7 workplace homicide to become the second leading cause after motor vehicle crashes”
(NIOSH Falls From Elevation, n.d). The Census of Fatal Occupational Injuries (CFOI) data show that in 2007 there were 835 fatalities from falls from elevation, which is a
2 percent increase from the 827 deaths in the prior year. Furthermore, an even more troubling finding shows that’s since 1992 when the Bureau of Labor Statistics (BLS) started to track falls from elevated heights there has been a 39 percent increase in fatal deaths with an increase from 600 in 1992 to 835 in 2007. Based on data from
CFOI in 2007, the construction industry had the most fatal injuries from falls with
1,178 followed by transportation and warehousing which finished second with 836.
Manufacturing finished 6th respectively with 392 fatalities from falls from elevation.
On August 9, 1994 OSHA passed a final rule on a construction fall protection standard and it was finalized on February 6, 1995. On OSHA’s website, I performed an overall data search for accident investigation records dating from January 1, 1972 through January 1, 2007 that involved fall protection accidents. I was able to search for this data using the keyword “fall” in the description header on the accident investigation page. This site listed a number of 13,859 total fall accidents investigated between 1972 and 2007. From this number 6,515 accidents were fatal.
This data indicates that over a 35-year period, 47% of workers died performing jobs while working at elevated heights. Prior to the fall protection standard being passed
(1972 – 1994), there were 5,191 accidents investigated and 2,802 fatalities reported which translates to 53% of worker fatalities occurred while performing work at elevated heights. Since OSHA passed a final rule on the fall protection standard in the construction industry on August 9, 1994, there have been a total of 8,668 fall protection accidents investigated and of those accidents 3,713 represented fatal occurrences. This suggests that since OSHA passed a final rule on fall protection in the construction industry 42% percent of worker fatalities have occurred while working at elevated heights. Since OSHA’s fall protection standard was made final
This report is for training/educational purposes only. This report is for training/educational purposes only. 8 there has been an increase to 59% in the total number of accidents investigated, but only 42% of those investigations accounted for worker fatalities. In my opinion this suggests that the standard has been effective because even though there was an increased rate of 59% in investigated accident, the percentage of fatalities actually dropped by 11%. OSHA intent when this standard was passed was to provide more protection from fall hazards using more performance-based criteria where possible rather than using more specification oriented language. Performance based standards have historically been more flexible because in essence they tell you what the goal is and it is the employers job to achieve it using whatever means they wish.
Specification standards basically tell you step by step how to do things. These standards can be viewed on OSHA’s website. Searching OSHA’s website for 1926.500 and 1910.23, respectively allows a side-by-side comparison of each standard as it pertains to fall protection and walking and working surfaces.
This now brings me to my internship project at Briggs & Stratton. The project consisted of identifying fall protection hazards and recommending solutions to either engineer out, use administrative controls to lower the risk, or as a last resort assign, the appropriate PPE for employees to wear. The Briggs & Stratton Corporation, which is headquartered in Milwaukee, Wisconsin, is the world’s largest manufacturer of air- cooled gasoline engines.
Since the opening of the facility in 1995, a number of initiatives have been created in order to increase employee’s awareness about safety. These include the
Auburn Facility Safety Program. As a part of this program, a safety committee was created. The current committee consists of a mix of salary and hourly employees from the production floor and management. In order to create employee awareness of this committee, the names, pictures, and job titles of safety committee members are posted in conspicuous places throughout the facility. Among these listings is a list of options an employee can choose from if they were to have a safety concern.
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Ideally, when an employee has a safety concern their first option should be is to address the issue during crew meetings. When this is not successful, they should contact the Safety Engineer, and lastly the plant manager. At the Auburn Facility the safety committee usually meets twice a month to discuss any previously identified concerns, and address any question that may arise. When the safety committee was originally created, its primary intent was to act as a safety liaison between management and the floor employees. The outcome management sought to create was a more effective line of communication. If any potential safety questions can be answered without having to reach the Safety Engineer it could potentially take an enormous amount of pressure off of the Safety Engineer who can then attend to other matters. Furthermore, it would create greater employee moral for line workers as it could be considered a good form of transformational leadership, which would give line workers more freedom and empower them to make more decisions.
Wikipedia defines transformational leadership as…
“A leadership style that is defined as leadership that creates valuable
and positive change in the followers. A transformational leader focuses
on “transforming” others to help each other, to look out for each other,
to be encouraging and harmonious, and to look out for the
organization as a whole. In this leadership, the leader enhances the
motivation, moral and performance of his follower group.” (Wikipedia,
n.d.)
Employees may feel more comfortable discussing safety issues with their peers instead of communicating their concerns to a manager (coach) who is concerned with production output for that given day.
The plant has two employees whose primary concern is employee wellness.
These individuals are a registered Occupational Health Nurse and a Safety Engineer.
The Nurse is usually on-site for 8 hours per day. The Nurse is considered part of
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Human Resources and some of her duties include worker’s compensation and medical management. The Safety Engineer’s roles consist of employee education and safety program management; worksite analysis; and hazard prevention and control.
The on-site Safety Engineer is also a Certified Safety Professional (CSP). Upon my arrival at the facility, the Safety Engineer informed me about potential OSHA fall protection violations throughout the facility. The Safety Engineer had expressed his concern about some machines, which may or may not have had adequate fall protection. He had informed me that he would like for me to evaluate each potential fall protection hazard in the facility, and create a form with recommendations on how to address each hazard.
Methodology
Once the Safety Engineer informed me of the task at hand the first thing we did was to conduct a facility tour. During the course of this process, I was able to get a detailed view of how each motor was manufactured. Additionally, the Safety
Engineer was able to point out different machines and areas, which possibly did not have adequate fall protection. The Safety Engineer introduced me to key employees who could possibly answer questions that I may have had when I was on the floor.
This made it possible for me to ask employees who would work at elevated heights what type of work was performed and whether or not they consistently used proper fall protection. Once I had the opportunity to tour the production floor a couple of times, I spent the next day reading over the existing Briggs & Stratton fall protection policy and OSHA’s 1926.500 – 1926.503 Subpart M (Fall Protection Standard) and the 1910.23 Subpart D (Walking and Working Surfaces Standard) to review relevant
OSHA’s regulations. I was then ready to tour the production floor unattended and record extensive digital images of each potential fall protection hazard. These pictures are located on the JHA forms in Appendix A.
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After I went through the process of taking as many pictures as I could of each potential fall protection hazard on the floor, I then went through the process of compiling recommendations and summarizing this report. The Safety Engineer informed me that he would like the information put in a Microsoft Excel based form created just for this project and that it should be similar to a standard JHA form.
When creating this form, I indicated each process by name and preceded to list the potential hazard’s as well as lists the applicable OSHA Standards. I also numbered each potential hazard as this would become helpful later on for references purposes.
Fortunately, I was able to find detailed pictures of each job so the reader would be able to have a better idea of the potential hazard that existed. Finally, I put the recommendation of what I felt should be the control measure for that hazard based on OSHA applicable standards. A more detailed view of these forms can be seen in
Appendix A. After I completed the JHA forms, I gave them to the Safety Engineer for review and approval.
Results
Briggs & Stratton Corporation has a formal fall protection program which was established in April 2002. Since the inception of the program there have been no revisions to it. The program is based on OSHA’s 1926.500 – 1926.503 Fall Protection standard. As it currently stands, there has been no revision to OSHA’s Federal
Standard since January 26, 1995. One of the first things I wanted to look at was how
Briggs & Stratton fall protection policy compared to OSHA’s Fall protection regulations. After careful review, I saw that there were no major differences with regard to fall protection as much of Briggs & Stratton fall protection policy was copied verbatim from OSHA standards, but I did notice their policy was lack when it came to addressing the 1910.23 Subpart D walking/working standards. The primary concern I had was when it came to addressing swinging gates at all access opening to fixed ladders. 29 CFR 1910.23(a)(2) states that “every ladderway floor opening or
This report is for training/educational purposes only. This report is for training/educational purposes only. 12 platform shall be guarded by a standard railing with standard toeboard on all exposed sides (except at entrance to opening), with the passage through the railing either provided with a swinging gate or so offset that a person cannot walk directly into the opening”. Out of 34 total potential fall hazards which I have listed, 20 (59%) dealt with having inadequate fall protection at access openings. I definitely feel the corporate safety policy can be improved in this regard to include guarding against this type of hazard. This will improve compliance with applicable OSHA Fall Protection standards.
My primary responsibilities while working at the Auburn facility were to identify fall protection hazards and investigate and recommend solutions to the identified fall hazards. I identified 34 fall protection hazards in the plant. The employees who are at the most risk for these fall hazards are maintenance workers since they are usually the employees who work on these machines. Many of these workers have been employed with the Briggs & Stratton organization for many years, particularly at the Auburn facility since it opened in 1995. A major concern is that workers have done some jobs so many times that they may become accustomed to working at elevated heights without adequate fall protection, which could lead to a potential injury or death. The documents, which are located in the appendix, give a detailed view of each fall hazard in the facility listed with recommendations. There was some debate as to whether there should be some type of fall protection device on the top of a fixed ladder such as a swinging gate. In order to get a better understanding of this, I referenced the 29 CFR 1910.23 Subpart D walking/working surface standards. After careful review, we determined that a swinging gate should be installed at each elevated fixed ladder way. This way personnel working at an elevated height would not be able to fall through the ladder way opening as easily.
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In the table below I have listed each violation including the location, potential hazard, and recommended solution to fix the violation. A detailed view of this can be found in Appendix A. I have underline the best recommended solution in my opinion.
ID NO. Location Potential Hazard Procedure or Recommended Action 1 Dept. 312, Model 20 Inadequate Install a self-closing Assy. Lowrator Zone protection at swinging gate, or redesign 7. access opening. the work area such that the access opening will offset so that a person cannot walk directly into the opening. 2 Dept. 312, Model 20 Inadequate Install a self-closing Assy. Paint Oven. protection at swinging gate, or redesign access opening. the work area such that the access opening will offset so that a person cannot walk directly into the opening. 3 Dept. 312, Model 20 Inadequate *An adequate guardrail Assy. Top of Paint guardrail system should be installed Kitchen. protection. on the machine to meet OSHA's requirements. *A controlled access zones/controlled access zone program can be implemented. *Install a portable Anchorage Connector System. *Install a Horizontal Lifeline System *Require employees to wear appropriate PPE. *Install a Safety Net System
4(a) Dept. 312, Model 20 Inadequate Install a self-closing Assy. Pallet Washer. protection at swinging gate, or redesign access opening. the work area such that the access opening will offset so that a person cannot walk directly into the opening. 4(b) Dept. 312, Model 20 Inadequate *An adequate guardrail Assy. Pallet Washer. guardrail system should be installed protection. on the machine to meet OSHA's requirements. *A controlled access zones This report is for training/educational purposes only. This report is for training/educational purposes only. 14
system can be implemented. *Install a portable Anchorage Connector System. *Install a Horizontal Lifeline System *Require employees to wear appropriate PPE. *Install a Safety Net System 5 Dept. 311, Model 20 Inadequate *An adequate guardrail Parts Washer. guardrail system should be installed protection. on the machine to meet OSHA's requirements. *A controlled access zones system can be implemented. *Install a portable Anchorage Connector System. *Install a Horizontal Lifeline System *Require employees to wear appropriate PPE. *Install a Safety Net System 6 Dept. 286, Blower Inadequate *An adequate guardrail Housing Paint guardrail system should be installed Kitchen and Paint protection. on the machine to meet Booth. OSHA's requirements. *A controlled access zones system can be implemented. *Install a portable Anchorage Connector System. *Install a Horizontal Lifeline System *Require employees to wear appropriate PPE. *Install a Safety Net System 7 Dept. 312, Model 20 Inadequate Install a self-closing Assy. Lorator Zone 1. protection at swinging gate, or redesign access opening. the work area such that the access opening will offset so that a person cannot walk directly into the opening. 8 Dept. 303, Model 9 Inadequate Install a self-closing Assy. Lowrator Zone protection at swinging gate, or redesign 1. access opening. the work area such that the This report is for training/educational purposes only. This report is for training/educational purposes only. 15
access opening will offset so that a person cannot walk directly into the opening. 9 Dept. 287, V-Twin Inadequate Install a self-closing Assy. Engine Test. protection at swinging gate, or redesign access opening. the work area such that the access opening will offset so that a person cannot walk directly into the opening. 10 Dept. 287, V-Twin Inadequate Install a self-closing Assy. Lowrator Zone protection at swinging gate, or redesign 7. access opening. the work area such that the access opening will offset so that a person cannot walk directly into the opening. 11 Cooling Tower Inadequate *An adequate guardrail guardrail system should be installed protection. on the machine to meet OSHA's requirements. *A controlled access zones system can be implemented. *Install a portable Anchorage Connector System. *Install a Horizontal Lifeline System *Require employees to wear appropriate PPE. *Install a Safety Net System 12 Mechanical Room Inadequate Install a self-closing above Generator. protection at swinging gate, or redesign access opening. the work area such that the access opening will offset so that a person cannot walk directly into the opening. 13 Above Dyno Lab Inadequate Install a self-closing protection at swinging gate, or redesign access opening. the work area such that the access opening will offset so that a person cannot walk directly into the opening. 14 Dept. 287, V-Twin, Inadequate *An adequate guardrail Parts Washer. guardrail system should be installed protection. on the machine to meet OSHA's requirements.
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*A controlled access zones system can be implemented. *Install a portable Anchorage Connector System. *Install a Horizontal Lifeline System *Require employees to wear appropriate PPE. *Install a Safety Net System 15 Dept. 287, V-Twin Inadequate Install a self-closing Assy. Pallet Washer. protection at swinging gate, or redesign access opening. the work area such that the access opening will offset so that a person cannot walk directly into the opening. 16 Dept. 287, V-Twin Inadequate *An adequate guardrail Assy. Pallet Washer. guardrail system should be installed protection. on the machine to meet OSHA's requirements. *A controlled access zones system can be implemented. *Install a portable Anchorage Connector System. *Install a Horizontal Lifeline System *Require employees to wear appropriate PPE. *Install a Safety Net System 17 V-Twin Machining, Inadequate Either Install a self-closing Coolant Tank(s). (2 protection at gate or for a more cost Gates) access opening. effective method install a spring on this gate so it will self-close. 18 Lights on Roof’s Inadequate *An adequate guardrail Edge. guardrail system should be installed protection. on the machine to meet OSHA's requirements. *A controlled access zones system can be implemented. *Install a portable Anchorage Connector System. *Install a Horizontal Lifeline System *Require employees to This report is for training/educational purposes only. This report is for training/educational purposes only. 17
wear appropriate PPE. *Install a Safety Net System *Install a Horizontal Lifeline System
19 Dept. 312, Model 20 Inadequate *An adequate guardrail Paint Oven guardrail system should be installed protection. on the machine to meet OSHA's requirements. *A controlled access zones system can be implemented. *Install a portable Anchorage Connector System. *Install a Horizontal Lifeline System *Require employees to wear appropriate PPE. *Install a Safety Net System 20 Dept. 312, Model 20 Inadequate *An adequate guardrail Paint Oven guardrail system should be installed protection. on the machine to meet OSHA's requirements. *A controlled access zones system can be implemented. *Install a portable Anchorage Connector System. *Install a Horizontal Lifeline System *Require employees to wear appropriate PPE. *Install a Safety Net System 21 Dept. 312, Model 20 Inadequate *An adequate guardrail Paint Oven guardrail system should be installed protection. on the machine to meet OSHA's requirements. *A controlled access zones system can be implemented. *Install a portable Anchorage Connector System. *Install a Horizontal Lifeline System *Require employees to wear appropriate PPE. *Install a Safety Net System
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22 Dept. 312, Model 20 Inadequate *An adequate guardrail Paint Oven guardrail system should be installed protection. on the machine to meet OSHA's requirements. *A controlled access zones system can be implemented. *Install a portable Anchorage Connector System. *Install a Horizontal Lifeline System *Require employees to wear appropriate PPE. *Install a Safety Net System 23 Quality Lab Inadequate *An adequate guardrail guardrail system should be installed protection. on the machine to meet OSHA's requirements. *A controlled access zones system can be implemented. *Install a portable Anchorage Connector System. *Install a Horizontal Lifeline System *Require employees to wear appropriate PPE. *Install a Safety Net System 24 Model 20 Assy., Run Inadequate Either Install a self-closing Tunnel. protection at gate or for a more cost access opening. effective method install a spring on this gate so it will self-close. 25 Lowrator @ Model 9 Inadequate Install a self-closing Packout protection at swinging gate, or redesign access opening. the work area such that the access opening will offset so that a person cannot walk directly into the opening. 26 Model 9 Test Stand Inadequate Install a self-closing protection at swinging gate, or redesign access opening. the work area such that the access opening will offset so that a person cannot walk directly into the opening. 27 Access to ceiling Inadequate Install a self-closing walk-way. Access protection at swinging gate, or redesign This report is for training/educational purposes only. This report is for training/educational purposes only. 19
near nurse's station access opening. the work area such that the access opening will offset so that a person cannot walk directly into the opening. 28 V-Twin Parts Washer Inadequate Install a self-closing protection at swinging gate, or redesign access opening. the work area such that the access opening will offset so that a person cannot walk directly into the opening. 29 Model 20 parts Inadequate Install a self-closing washer #1 protection at swinging gate, or redesign access opening. the work area such that the access opening will offset so that a person cannot walk directly into the opening. 30 Model 20 coolant Inadequate Either Install a self-closing tank/pit #1 protection at gate or for a more cost access opening. effective method install a spring on this gate so it will self-close. 31 Model 20 parts Inadequate Install a self-closing washer # 2 protection at swinging gate, or redesign access opening. the work area such that the access opening will offset so that a person cannot walk directly into the opening. 32 ABCOR Inadequate Install a self-closing protection at swinging gate, or redesign access opening. the work area such that the access opening will offset so that a person cannot walk directly into the opening. 33 Model-20 coolant Inadequate Either Install a self-closing tank/pit # 2 protection at gate or for a more cost access opening. effective method install a spring on this gate so it will self-close. 34 Dept. 287 Assy., V- Inadequate Install a self-closing Twin Lowrator protection at swinging gate, or redesign (beginning of line) access opening. the work area such that the access opening will offset so that a person cannot walk directly into the opening. Note: More details of these hazards can be located in Appendix A
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Cost Justification
During tough economic times the amount of available money an organization has available to spend will almost always decrease and every expense is usually evaluated to see if it can possibly be reduced or justified by cost savings or cost avoidance. In my opinion, the most successful organizations today are those which value the safety and well being of their employees. A commitment to safety has to start at the senior management level of an organization. Unfortunately, in many organizations safety will always be one of the first departments to be affected by cost saving measures, and Briggs & Stratton is no exception. The site Safety
Engineer wanted to come into compliance with all applicable OSHA Standards as they relate to fall protection but he wanted to do it in the most cost effective way possible. He knew that coming into compliance was necessary because the cost of an
OSHA citation and the resulting penalties, and the potential for lower employee moral which could affect production rates far outweighed the cost of coming into compliance with applicable standards. When it comes to defining citations OSHA states that “Citations inform the employer and employees of the regulation and standard alleged to have been violated and of the proposed length of time set to correct alleged hazards” (OSHA Inspections, 2002). The employer will receive citations and notices of proposed penalties by certified mail. The employer must post a copy of each citation at or near the place a violation occurred for 3 days or until the violation is abated, whichever is longer” (OSHA Inspections, 2002). A penalty usually is attached to each citation that OSHA issues. These penalties consist of…
Other-Than-Serious Violation A violation that has a direct relationship to job safety and health, but probably would not cause death or serious physical harm. OSHA may assess a penalty from $0 to $1,000 for each violation. Serious Violation A violation where there is a substantial probability that death or serious physical
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harm could result. OSHA assesses the penalty for a serious violation from $1,500 to $7,000 depending on the gravity of the violation. Willful Violation A violation that the employer intentionally and knowingly commits. The employer is aware that a hazardous condition exists, knows that the condition violates a standard or other obligation of the Act, and makes no reasonable effort to eliminate it. OSHA may propose penalties of up to $70,000 for each willful violation. The minimum willful penalty is $5,000. An employer who is convicted in a criminal proceeding of a willful violation of a standard that resulted in an employee(s) death may be fined up to $250,000 (or $500,000 if the employer is a corporation) or imprisoned up to 6 months, or both. Repeated Violation A violation of any standard, regulation, rules, or orders where, upon re- inspection, a substantially similar violation is found and the original citation has become a final order. Violations can bring a fine or up to $70,000 for each such violation within the previous 3 years. To calculate repeated violations, OSHA adjusts the initial penalty for the size and then multiples by a factor of 2, 5, or 10 depending on the size of the business. Failure-to-Abate Failure to correct a prior violation may bring a civil penalty of up to $7,000 for each day that the violations continue beyond the prescribed abatement date. Source: (OSHA Inspection, 2002, Pg. 16-18)
The site Safety Engineer informed me that he felt that if OSHA were to conduct an inspection of his facility today, that more than likely several of the hazards I documented could result in a citation, which would probably be considered serious. Based on of the above criteria each citation could carry a penalty of $1,500 to $7,000 and this does not include the indirect and direct cost associated such as lost production time; loss of profit because of lost work time and idle machines; and overhead cost that continues during lost work. You could possibly be looking at a penalty ranging from $36,000 to $168,000 depending on the amount of each This report is for training/educational purposes only. This report is for training/educational purposes only. 22 penalty. Just from these values alone it is easy to see why it would make more sense from a financial perspective to fix the problem rather than having OSHA compel you to fix them.
Some of the possible OSHA violations at Auburn’s Briggs & Stratton facility may be elevated work platforms which need a guardrail or some other type of fall arrest device. OSHA standard 29 CFR 1926.501(b)(1) states that “Each employee on a walking/working surface (horizontal and vertical surface) with an unprotected side or edge which is 6 feet (1.8m) or more above a lower level shall be protected from falling by the use of guardrail systems, safety net systems or personal fall arrest systems”. Additionally, the standard specifies that employers have the duty to
“determine if the walking/working surfaces on which its employees are to work has the strength and structural integrity to support employees safely”. In my opinion, a trained professional needs to inspect all surfaces to ensure they are able to support a fall protection device such as an guardrail. To address access openings at all ladder ways, OSHA Standard CFR 1910.23 Subpart D states that “Every ladder way floor opening or platform shall be guarded by a standard railing with standard toe board on all exposed sides (except at entrance to opening), with the passage through the railing either provided with a swinging gate or so offset that a person cannot walk directly into the opening”. In addition to this OSHA mandates that the swinging gate be equivalent to a guardrail. Finally, the OSHA General Duty Clause 5(a)(1) states that each employer “shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees”. If steps are not taken to rectify the listed fall hazards not only might the facility be in violation of Federal standards, which could result in possible OSHA citations should an inspection occur, in addition to potential litigation by an employee who was hurt from an existing recognized fall hazard.
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NIOSH estimates that from 1992 to 2002 the total cost of falls for employers cost an estimated $352 Million (NIOSH Fatal Fact Sheet, n.d.). The cost of all accidents in the U.S. is approximately $600 billion annually, excluding some indirect costs and the value resulting from pain and suffering (Brauer, 2006). An organization can quickly incur a “mountain” of unnecessary costs by not focusing on operating a safe workplace. Losses from an accident can take many forms. Besides the threat of injury, illness, disease, and death, an organization has to deal with the potential of damage or loss to property, equipment, materials, the environment, and the cost of repair or replacement and this does not even begin to count the fines and penalties that comes from an OSHA citation. Just from these costs alone you can see how quickly some of these expenses can add up for an organization. Brauer (2006) classifies these expenses in two forms: Direct and Indirect Costs. Direct costs usually consist of expenses incurred because of an accident or the direct affect of the accident. Some of these expenses are but not limited to; medical expenses, workers compensation, and the cost to repair or replace damaged items. Indirect cost is the remaining expenses that result from the aftermath of an accident. Examples of some indirect cost are listed below.
Lost time of injured employee.
Time lost by other employees to assist injured coworker, to see what is going on, and to discuss events.
Time lost by a supervisor to assist injured worker, investigate incident, prepare reports, and make adjustments in work and staffing.
Time spent by company first aid, medical, and safety staff on case.
Damage to tools, equipment, materials, or property.
Losses due to late or unfilled orders, loss of bonuses, or payment of penalties.
Payment made to injured employee under benefits programs.
Losses resulting from less than full productivity of injured workers on return to work. This report is for training/educational purposes only. This report is for training/educational purposes only. 24
Loss of profit because of lost work time and idle machines.
Losses due to reductions in productivity of coworkers because of concern or reduced morale.
Overhead cost that continues during lost work.
Adapted from: H.W. Heinrich, Industrial Accident Prevention, 4th ed., McGraw-Hill, New York, 1959
With this information in mind, it is easy to see how the cost(s) associated with potential injuries which arise partially from non-compliance with OSHA standards can rise very quickly and affect organizations in a negative way far after the original injury occurred. The OSH Act forced many companies to implement safe working conditions in their workplaces. Once you consider all of the cost that is associated with an injured employee who has fallen from an elevated height you must then be prepared to deal with a OSHA citation massive penalties which could be levied against your organization. While reviewing OSHA’s webpage, I saw a link called industry profile, which lists all citation, inspections, and current penalties by Federal
OSHA during the time period of October 2007 to September 2008. The search I conducted was based on OSHA’s 1926.500 to 1926.503 Standard’s as well as the
General Industry 1910.23 Walking/Working standard. This site did not include the states which administer their own state OSHA plans. The table below shows the total number of citations, inspections, and the total dollar amount acquired from penalties in the manufacturing sector.
Standard Respective Number Number of Penalty Industry Ranking Cited Inspections Amount Classification # (Compared with other Industries) 1910.23 1 913 697 $1,177,226 Division D/Manufacturing 1926.500 - - - - - 1926.501 3 12 10 $18,555 Division D/Manufacturing
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1926.502 2 5 1 $3,250 Division D/Manufacturing 1926.503 3 5 5 $8,665 Division D/Manufacturing
Countermeasures
I felt there was a number of ways the facility could address their fall protection hazards and improve compliance with Federal OSHA standards. For the hazards which required the use of a fall arrest system such as a guardrail, safety net, controlled access zones, or anchorage system, I felt the best option would be a guardrail followed by a safety net system. The guardrail systems would be most effective because you would be effectively engineering the hazard out and engineering the hazard out should always be the first choice when resources allow.
One alternative I felt would be effective would be some types of anchorage or controlled access zones system that could be put into place. I felt one type of anchorage system I felt would work well would be the Man Safe Freestanding
Constant Force Post which could be placed at different points of the work platform.
When personnel start to work at elevated heights they would simply connect the lanyard from off of their full body harness to the anchorage point system. To ensure that they are always protected one hundred percent of the time they would wear two lanyards and one would be hooked/connected to the anchorage point at all times.
Another anchorage system that might be effective would be the use of a vertical lifeline system. Personnel would appear to be like “Tarzan swinging on vines” by connecting to the next anchored point before disconnecting their current anchorage point as they move along the work surface. This would be created by having lifelines hang from the ceiling of the facility. They would hang over each potential elevated work platform to ensure that potential tie points would be available for them while working. This method could be made more effective if the hanging lifeline was connected to rollers on the above steel beams. By doing this it would give employees
This report is for training/educational purposes only. This report is for training/educational purposes only. 26 more freedom to move where they needed to move while performing jobs. Finally, as a last resort I felt a controlled access zones would be an inexpensive option. On many of the machines a controlled access zones could be a viable option but the site
Safety Engineer would need to make sure the program is implemented effectively.
For the hazards which include(s) the use of swinging gates at ladder way access openings the solution is not as flexible. Based on 29 CFR 1910.23 Subpart D Walking and Working standard a swinging gate must be present on all fixed ladderways on a access openings. The swinging gate strength must be equivalent to that of a guardrail. I have included a list of manufacturers who produce swinging gates that meets OSHA requirements in Appendix D. There were a few instances where there was already a swinging gate present at the access opening but were deemed inadequate by the Safety Engineers since they were not self closing. The concern that the Safety Engineer had was that someone was going to open the gate but not close it and this could create a new hazard. These locations were (17) V-Twin
Maching Coolant Tank(s), (30) Model 20 Coolant Tank/Pit #1, and (33) Model – 20
Coolant Tank/Pit #2. I feel the best solution would be to install a new self-closing gates at these areas or have maintenance put some type of spring on the existing gates which would cause them to self close.
Discussion and Conclusion
As it was previously stated, many times workers can become complacent and not work as carefully as they should when working at heights because they have done the job so many times. I personally like to use the reference that the safety and well being of employees is very much like driving. People drive so much that they forget how dangerous the act really is. In my opinion, most people feel that nothing can happen to them when they drive which may lead them to drive recklessly. The same can be said for many of the employees here at the Briggs &
Stratton Auburn facility that works at elevated heights. In my opinion, most
This report is for training/educational purposes only. This report is for training/educational purposes only. 27 employees feel they will be safe when working at elevated heights if they are careful or if they just wear a body harness without using a lanyard. Another problem with body harnesses is that many times a worker will tie off their lanyard on an unapproved anchor point. The dangers that can arise from this are when they tie off to a structure that is unable to support their weight. OSHA regulations mandate that a tie off structure be capable of withstanding five thousand pounds of force.
Furthermore another potential problem is workers not tying off their lanyard at all which basically offers no fall protection at all. If they were to slip and fall they would have no type of fall protection. About a year ago, the Safety Engineer gave all maintenance workers their own body harness with lanyards attached. One problem, which has arisen from this, is workers not regularly inspecting their harnesses. Many times workers will just put the harness on when it is time to do some type of work at elevated heights. This is a potential problem because the harness could have some damage to them and could malfunction when used. Another potential fall hazard the
Safety Engineer informed me of is when employees are working in aerial lifts. Many times during work in aerial lifts employees will not wear any addition fall protection
PPE. On OSHA’s webpage regulations state that some form of PPE must be worn while working in aerial lifts such as a body harness with an attached lanyard. If a body harness is worn the lanyard must be tied off on the guardrail of the lift or from some type of retractable device, which will not retract more than six feet.
Based on the data in the cost justification section hopefully the site Safety
Engineer can make a more convincing argument to management to spend the necessary money to purchase the equipment needed to come into compliance with all applicable Federal standards. Another benefit of the new JHA forms is that they are very user friendly. You do not have to have a college degree or be familiar with all of OSHA’s standards in order to know what the potential problem is, the applicable OSHA standard, and what needs to be done to fix the problem. Also, by
This report is for training/educational purposes only. This report is for training/educational purposes only. 28 being able to work on this project I have had the opportunity to become very familiar with the OSHA fall protection standard as well as OSHA’s walking and working surfaces standard. I was able to gain an understanding of how to do safety audits and what hazards to look for as it pertains to fall protection. From talking to the
Safety Engineer I was able to find out the strengths and weaknesses of the safety program at Briggs & Stratton Auburn facility. For example, the current fall protection program needs to be updated. The strength of the site’s safety program is the Safety
Engineer. I say this because of the development and implementation he brought to the old program. It is also very helpful that the Safety Engineer is easy to talk to and has good communication skills. This is especially helpful for employees because it can make them feel more comfortable expressing their concerns to him. It is also helpful that the Safety Engineer can solicit help from his peers within the company.
Briggs & Stratton has numerous facilities throughout the U.S. and many of the processes for each plant are very similar, which is a tremendous advantage for him to have. When I asked the Safety Engineer about what element needed the greatest improvement he immediately said the updating of training programs and compliance with OSHA standards. With training programs being improved it could potentially lead to lower injury rates since it would potentially raise employees awareness of the potential hazards, which exist on the production floor. Furthermore employees are consistently forgetting how to follow the required safety rules such as always wearing their safety glasses when on the plant floor, forklift drivers wearing their seat belts, or maintenance employees using the correct fall protection PPE when working at elevated heights just to name a few. The second round of improvements deals with improving compliance with Federal OSHA standards and regulations.
Some examples of areas needing improvement include forklift training. OSHA requires that forklift training be done yearly and as it currently stands now the Briggs
& Stratton Auburn facility does not conduct annual training. Fall protection is another
This report is for training/educational purposes only. This report is for training/educational purposes only. 29 area where this facility could use significant improvement. As shown with the JHA forms located in Appendix A there are numerous concerns regarding compliance with
OSHA standards such as inadequate guardrail systems and lack of fall protection in certain areas. Hopefully, this project will help Briggs & Stratton improve compliance with applicable Federal OSHA Standards. The JHA form was used on every space in the plant that appeared to need additional fall protection in order to comply with all federal fall protection standards. The JHA form does a good job of explaining applicable OSHA standards. One of my primary missions when I was designing the form was to make sure it was user friendly and easy to understand. Outside of the site Safety Engineer and I, most employees are not too familiar with OSHA standards. The Safety Engineer suggested that I make a form, which could clearly show the hazards, the applicable standard, and the recommended solution to the problem. By doing this the Safety Engineer felt management would be more receptive to approving the funds, which would be needed to purchase certain equipment that would be used to come into compliance with Federal OSHA standards.
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Appendix A
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Appendix B
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Appendix C
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Appendix D
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This report is for training/educational purposes only.