HazCom Plan Rolling Along

I spent time yesterday and Today working on our written HazCom plan.

One of the most frustrating parts about dealing with OSHA concerns is that it is not a straightforward list of rules you need to comply with. They give you the framework and leave it up to you to determine what that means for your business.

There is a lot of guidance, though available online. I found tremendous help available on OSHA's website at http://osha.gov/SLTC/hazardcommunications/standards.html There's also a lot of information available here: http://osha.gov/SLTC/hazardcommunications/index.html

But to be completely frank (and that's what blogs are for) in the end, I searched online until I found a HazCom plan that was already written, and I downloaded it and adapted it for my business.

In a couple of days I'll post the HazCom plan up here so you can read through what I did.

It really took me about 2-3 hour to adapt the HazCom plan. I didn't think that was too bad.

The next thing I did was prepare a powerpoint presentation for employee training. I am working on a management module next for my managers so they understand the regulations and their repsonsibilities. Once that is done, I will put them through the training, and then work with them to put together a chemical inventory. From that, we will gather the MSDSs we need (I already have most of them I think). We'll put the HazCom Plan, Chemical Inventory, Trianing Programs and MSDSs in a binder. Then we'll train all of the employees with the employee training modules. If it wasn't documented, it never happened, so we'll document the training and keep that in the binder.

More later when those portions are done.

Plan of Attack!

So over the last week, I spent quite a lot of time on the OSHA website. Others might find it very useful as well. http://www.osha.gov/ Of particular interest are the sections onthe right hand toolbar titled Small Business and Quick Start.

I've decided that you will NEVER be completely in compliance with every little item, primarily because the inspectors all interpret things differently, and they can always find something if they really try. But that doesn't mean we can't have a safe work place, and be in compliance with as much as we know and understand.

My plan of attack is this: to identify the most commonly cited violations, and make sure I'm in compliance with those. This is a little out of date, but the NFIB (a GREAT resource for small business) listed the top 10 violations in 2006 as follows:

1. No written Hazard Communication Plan (automatic $1500 fine)
2. No Information and Training on Hazardous Chemicals
3. Electrical Conductors Not Protected Entering Boxes, Cabines or Fittings
4. Electrical Covers and Canopies Missing
5. Tongue Guards Missing or Not Adjusted on Wheel Grinders
6. Hard Hats Not Worn on Construction Sites
7. Fall Protection-Unprotected Sides on Surfaces 6 Feet or More in Height on Construction Sites.
8. No Portable Fire Extinguishers Provided.
9. Flexible Electrical Cords Used Unsafely
10. Not Maintaining an OSHA 200 Log.

Other ones that seem to come up all the time include:

• Scaffolding Issues (not having a full floor, employees not trained in use)
• Respiratory protection
• Lockout/Tagout
• Powered Industrial Trucks
• Ladders

So I'm tackling these things one at a time. First on the list was Hazard Communication (HazCom). HazCom is consistently among the very top most cited violations, and something that is very relevant to my business: we sell chemicals, basically.

So my next post will go into depth about HazCom and what I'm going to do about it!

Thanks for reading!

Introduction

Hi! My name is Bill, I work for a family-owned home heating business. We sell fuel oil, kerosene, propane, diesel fuel and coal to mostly residential customers in the northeast.

Safety and compliance have always been very important to our company. We have always strived to provide a safe work environment, and to continually provide training and resources to keep a culture of safety in our company.

But we've always had one gaping hole: OSHA, the Occupational Safety and Health Act. For whatever reason, in keeping in compliance with Department of Transportation, Department of Environmental Conservation, the Environmental Protection Agency, National Fire Protection Agency, more recently the Department of Homeland Security and a host of other governmental and non-governmental agencies, we never focused much attention on OSHA.

Now, after tremendous growth, we decided to build a new office building. I naively thought that OSHA pretty much applied to physical structures, and with that mindset, I thought this would be a great opportunity for us to get in compliance with OSHA requirements; if we could focus on OSHA compliance as we built the building, we'd avoid expensive retrofitting costs that prevented us from being in compliance before. Boy was I in for a lesson.

I've just (today) returned from a Fred Pryor training seminar on OSHA compliance. I learned that in fact, there's a lot more to it than just your physical surroundings. There are recordkeeping requirements which we have never really done, or at least done right. There are requirements for written Hazard Communication Plan. While we have kept Material Safety Data Sheets (MSDS) on hand, I didn't know that we were supposed to keep them for all of 30 years, nor that the chemicals we needed to keep MSDSes for many more chemical than I thought. And that's just the beginning.

I learned that, in 2006 there were 38,579 inspections, which generated $84,413,006.00 in revenue for OSHA. do the math: that works out to an average of $2,188.00 per inspection. That's not small change for a small company like ours. I heard horror stories of a safety officer of a large company who was fined $120,000 when an OSHA inspector found an overhead door propped up with a 2x4. A small company was cited for dust on top of the electrical outlet covers. Another company, about my size, had a surprise visit by OSHA and came out with $26,000 in fines. And none of these were related to the physical office building, like I originally thought.

So I decided that, as part owner, it is a critical aspect of my job to make sure we're in compliance with these regulations. As the OSHA guidelines continually point out: abatement and mitigation. I decided with very little effort I could abate and mitigate quite a lot of our glaring defects, and over time, continually picking at the low hanging fruit until the tree is empty, we could get in compliance.

This blog is dedicated to sharing what I learn through this process. I'll be posting daily, as long as there is anything relevant. I'll focus a lot of it in my specific industry. I'll outline the procedural steps we're taking, hopefully to provide a framework for others to get in compliance as well.

I won't be identifying my company or specific location for obvious reasons. I don't hope to invite OSHA in, only to get in compliance so that, if they ever come knocking, I'm ready.

So let's start learning!
Bill