workshop j - safety · audits of ehs management systems, and training, both at client facilities...
TRANSCRIPT
Workshop J
Is Safety One of Your Many Hats? Safety 101-
Keys to Success
Tuesday, March 27, 2018 11:15 a.m. to 12:30 p.m.
Biographical Information
Mack Overton, Vice President, EHS Compliance Services, KERAMIDA Inc. 401 North College Avenue, Indianapolis, IN 46202
Cell: 317-914-5757 Fax: 317-685-6610 [email protected]
Mack Overton serves as Vice President in charge of KERAMIDA’s Environmental Compliance and Health & Safety Services serving heavy industrial facilities, manufacturing facilities, utilities, and businesses. KERAMIDA’s Compliance Services provide clients technical support and strategy advise on addressing air emissions, storm water, community right-to-know, solid and hazardous waste, wastewater issues, industrial hygiene, safety and overall EHS compliance, internationally. KERAMIDA’s EHS services include permitting, in-plant services, reporting, corrective action, development of procedures, EHS Management Systems, audits of EHS compliance, audits of EHS Management Systems, and training, both at client facilities and by e-courses. Mack manages all phases of EHS compliance, including permitting and reporting, management plan development, compliance audits, corrective actions, waste management, and sampling and analysis across all media at facilities throughout the USA and abroad. He has completed in excess of 100 air permits for clients from various industries, including atmospheric dispersion modeling, as well as developed hundreds of plans for the management of hazardous waste, chemical products, and oil products, and pollution prevention assessments and risk assessments. Mack’s experience includes health and safety compliance audits, industrial hygiene sampling and analysis, indoor air quality assessments, and occupational health and safety training. He has been involved in negotiations of more than 50 Notices of Violation (NOV)/Agreed Orders (AO) and has served as an expert witness in both deposition and trial. Mack’s project work includes utilities, foundries, metalworking facilities, automotive products manufacturers, plastic molding and machining, pharmaceutical companies, food production, hospitals, schools, agricultural facilities, asphalt plants, wood treatment facilities, wood furniture manufacturers, secondary aluminum facilities, petroleum products manufacturers, distributors, transporters, and paper product manufacturers. These industries have been involved in a wide variety of manufacturing operations, including casting, surface coating, plating, forming and stamping, molding, shot-blasting, deburring and finishing. Mack has a B.A. in Chemistry from Wabash College and has completed graduate coursework in Environmental Planning at Indiana University. He has been a Certified Hazardous Materials Manager (CHMM) and a Certified Indoor Air Quality Professional (CIAQP). In addition, Mack has been a member of the Air and Waste Management Association, the American Indoor Air Quality Council, the Indiana Chamber of Commerce Environmental Committee. He has over 25 years of experience in the EHS field.
SAFETY 101KEYS TO SUCCESS
March 27, 2018
Mack [email protected]
www.keramida.com
Manufacturers’ Education Council
Case Study
Aluminum Finisher Approximately 120 employees 3 shift operations Approximately 250,000 foot square facility
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Industrial Operations include: Anodizing Grinding Welding Plating Surface Coating
Last OSHA Inspection occurred 20 years ago
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What does this mean? TROUBLE!
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What could make it worse? OSHA is at the door. Now what?
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Designated Person to meet regulators? – No
Facility staff aware of potential concerns on plant floor? – No
Records readily available? – No
Facility ready for visitors or inspectors? - No
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Existing Conditions – Paint Tunnel
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Existing Conditions – Paint Tunnel
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Existing Conditions – Emergency Exits
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Existing Conditions - Safety Data Sheets Up to date? Complete? Training and Communication? How is the Data Used?
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Existing Conditions – Machine Guarding
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Existing Conditions - Electrical
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Existing Conditions - Welding
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Existing Conditions – Combustible Dust
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Existing Conditions – Walking / Working Surfaces
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Inspection Prep
Be Prepared! Crisis Management
Who Represents your Company? Defined Tour Route? Basic Documents Available for Inspector?
How to Avoid Crisis Identify your Highest Risks! Do your Work Early!
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Crisis Management
Who is the Designated Representative? Familiar with the Regulations Knowledgeable of Plant Practices Communicates Concisely Not easily Rattled Excellent Listener
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Crisis Management
Designated Representative – Compliance Officer Develop a Relationship with the Compliance Officer This cannot be emphasized enough! The Compliance Officer Needs to Know that You Are on the
Same Team
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Crisis Management
Designated Representative – Company Management Management Must Understand the Severity of the Situation Management Buy-In to Safety Programming is Critical to
Successfully Surviving an OSHA Inspection
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Crisis Management
Define your Tour Route Know where you are going Pathways clearly marked Avoid trouble areas Less is More!
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Crisis Management
Basic Documents Available for Inspector OSHA 300 Logs Emergency Action Plan Evacuation Route Map Safety Data Sheets Training Manual Training Logs
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Transition from Crisis Management
Who Will Own Safety? Identify a Champion Give him or her Authority Establish Clear Expectations
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Transition from Crisis Management
Management Commitment Support your Champion Establish a Discipline Policy Follow the Policy
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Risk Identification
Chemical Exposure – SDS Review Chemicals subject to expanded health programs? BenzeneMethylene Chloride Hexavalent ChromiumMDI
Solvents Heavy metals Particulate
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Risk Identification
Chemical Exposure - Industrial Hygiene Sampling Identify All Significant Work Tasks Including:Work Task Frequency DurationWorkplace Conditions
Assess Exposure Potential Process Controls Chemical Volatility
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Risk Identification
Physical Hazards Impact Dust Penetration Compression Electrical Thermal Light / Non-Ionizing Radiation
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Risk Identification
Job Hazard Assessments All Job Functions and Work Classifications Determine Personal Protective Equipment Requirements Train all Staff Enforce these Requirements!
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Do Your Work Early
Review your Training Programs Make them Site Specific Be Sure they Reflect Current Conditions Keep Training Records Up-to-Date Evaluate Adherence to Training by Staff
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Do Your Work Early
Review your Training Programs Hazard Communication Blood Borne Pathogens Electrical Safety and Arc Flash Lockout / Tagout Hearing Conservation Confined Space Powered Industrial Vehicles Walking / Working Surfaces Fall Protection
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Do Your Work Early30
Conduct an Audit of your Facility Annual Comprehensive Quarterly Area Specific Cross train managers to Audit Fix What you Find! Focus on Continual Improvement Celebrate Success
Case Study
Hexavalent Chrome Operations Chrome Plating – PreTreat Hexavalent Chromium Containing Base Coat
Hexavalent Chrome Expanded Health Program IH Sampling Requirements Employee Training Medical Examinations Changing Stations
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Paint Tunnel Contents Removed Surfaces Cleaned Booths Rebuilt Ventilation Improved
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Safety Data Sheets / Hazard Communication All SDS Updated SDS Digitized to Enhance Access Hazard Communication Training Conducted On-boarding of New Employees Incorporates Haz Comm
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Machine Guarding
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Electrical Improvements Panels Repaired Cords Replaced Flex Cords Replaced with Conduit Wiring Upgraded to Class 1 in Paint Tunnel
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Welding New Ventilation Unit Installed
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Walking / Working Surfaces Working Surfaces Repaired Limited Access to Areas Behind Tanks
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Summary
Employee Safety Must a Priority for Any Business Investment of Time and Man Hours is Required Commitment and Support from Management Much Better to Do on your Own Time Schedule, Rather
than OSHA’s
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Questions39
