Five OSHA Regulation Changes That Could Impact Your Facility This Year

Hardhats in a row at a job site.
OSHA’s $5 million budget increase could suggest an increase in regulatory actions, inspections, and citations, as the organization has regulatory changes in store for the year ahead.

The Occupational Safety and Health Administration’s (OSHA) fiscal year 2019 budget, according to Industrial Safety and Hygiene News, increased by $5 million over 2018 to reach a $557.8 million total. This increase could suggest an increase in regulatory actions, inspections, and citations, as the organization has regulatory changes in store for the year ahead. While these safety regulation updates and additions are spread across several industries, here are five that workers and facilities should be prepared for.

IEEE 1584-2018

Published just before December of last year, this Institute of Electrical and Electronics Engineers guide for performing arc flash hazard calculations was significantly updated from IEEE 1584-2002.

Related to the method for calculating the arc flash hazard distance and the incident energy to which employees could be exposed during work on or near electrical equipment, designers and facility operators in facilities where live work is performed on electrical equipment need to become especially familiar with this change. With arc flash hazard calculations being implemented in most plants because of OSHA regulations, this new model accurately accounts for a wide variety of setup parameters.

Employers should be sure to confirm that an arc flash risk assessment has been done within the last five years. Calculations are most often listed on arc flash and equipment labels and are used as part of an arc flash risk assessment. Updates to labels to reflect new calculation requirements may be necessary depending on the results of the arc flash assessment.

Increased Fines

To adjust for inflation, and as required by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, OSHA has increased the maximum civil penalties on employers cited for safety violations. The annual penalty increases are required by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (ACT) and apply to Federal OSHA states. Information on the change can be found here.

Random Inspection

Late last year OSHA announced it would implement its Site Specific Targeting 2016 inspection plan, which applies to non-construction workplaces with more than 20 employees. Employers who failed to provide 2016 Form 300A data to OSHA will be selected at random and added to an inspection list combined with employers who reported high rates of days away, restricted, or transfer in 2016. OSHA will include a random sample of employers with low rates to the list. The collected data will be used to create inspection lists.

Drone Inspection

Midway through 2018 OSHA began gradually implementing a new policy of inspecting workplace inspections utilizing drones. The organization issued a memo authorizing compliance officers to inspect areas that are inaccessible or pose a safety risk, with 2019 being the first full year of this practice being implemented. Compliance officers must obtain consent from an employer and notice must be provided to employees before the drone is launched.

Tracking of Workplace Injuries and Illnesses

For workplaces with 250 or more employees, OSHA now only requires an electronic submission of OSHA Form 300A. Facilities should continue to record workplace injuries and illnesses and follow reporting requirements, but OSHA amended its record-keeping regulation to remove the requirement to electronically submit information from OSHA Form 300 (log of work-related injuries and illnesses) and OSHA Form 301 (injury and illness incident report). However, the requirement to keep and maintain OSHA Forms 300, 300A, and 301 for five years is not changed.

Keeping up with regulations and requirements is key to avoiding shut downs and lost business costs. By implementing policies, holding staff accountable, and staying abreast of safety regulations you can positively contribute to your business’ bottom line. For more tips on how to optimize safety practices in your facility, read our white paper Six Keys to Managing Workplace Electrical Safety.

Troubleshooting Safely: Using PtD Methods to Provide Safe Access to Energized Equipment

Control of Hazardous Energy – Lockout/Tagout has once again appeared on the Occupational Safety and Health Administration’s (OSHA) Top 10 Most Cited Violations in 2018. Although this category covers a wide range of violations, it confirms that personnel continue to pursue access into electrical enclosures without being fully aware of the danger involved. Before performing electrical work, OSHA and the NFPA 70E Standard for Electrical Safety in the Workplace both direct workers to de-energize circuit parts to which an employee may be exposed, but why would a worker attempt to access an electrical enclosure without first ensuring that the enclosure is de-energized?

In an increasingly connected and intelligent plant floor, the need to maintain, monitor, or troubleshoot Programmable Logic Controllers (PLCs), motors or Variable Frequency Drives (VFDs) in an electrical enclosure is exponentially increasing. As more and more of this technology is designed in to equipment today, the personnel required to service this technology expands beyond the standard qualified electrician role and into roles inhabited by machine operators, IT personnel, and others. But whether it’s a qualified or unqualified electrical worker, opening an energized electrical enclosure poses the same serious safety risks.

Even though there is inherent risk in opening an energized electrical enclosure, performing service work without power in the equipment is prohibitive to diagnosing or monitoring the equipment. This poses the question: how does a worker safely operate in a potential electrically unsafe work environment and still perform the duties they are assigned? This conundrum has challenged equipment designers to standardize on a solution that allows for personnel who are not electrically qualified to access networks or systems within an electrical enclosure without risk of exposure to hazardous electrical conditions.


APPLYING PtD AND THE HIERARCHY OF CONTROLS TO THE ISSUE

In order to combat this challenge, more and more designers have employed a methodology called Prevention through Design (PtD) when developing products. According to The National Institute for Occupational Safety and Health (NIOSH): “Prevention through Design encompasses all of the efforts to anticipate and design out hazards to workers in facilities, work methods and operations, processes, equipment, tools, products, new technologies, and the organization of work. The focus of PtD is on workers who execute the designs or have to work with the products of the design . The initiative has been developed to support designing out hazards, the most reliable and effective type of prevention.”

Hiearchy of Controls infographic
Hierarchy of Controls infographic by NIOSH. The most effective control methods are located at the top with the least effective at the bottom.

It is interesting to note that NIOSH states that “designing out hazards” is the most reliable and effective type of prevention. This is a core concept that is also shared in the hierarchy of controls system. As represented in the graphic, Elimination (physically remove the hazard) appears at the top of the pyramid and corresponds with being the most effective method of hazard prevention. Substitution (replace the hazard), Engineering Controls (isolate people from the hazard), Administrative Controls (change the way people work), and PPE (protect the worker with Personal Protective Equipment) follow Elimination in a descending order from most effective to least effective, respectively.

Returning to our challenge to standardize on a solution that allows for personnel to access networks within an electrical enclosure without risk of exposure to hazardous electrical conditions, we can apply the Prevention through Design methodology by employing the hierarchy of controls. Since Elimination is the most effective method to design out hazards, the solution to our challenge would be to completely remove any energy within the electrical enclosure. Unfortunately, in this case, removing all energy from the enclosure is prohibitive to diagnosing or monitoring the equipment within, so Elimination is not a practical or reasonable solution to our challenge.

Working down the hierarchy of controls pyramid, our next option is Substitution, the second most effective hazard control. Substitution involves replacing something that produces a hazard with something that does not produce a hazard. For our challenge, Substitution would seem to suggest that we either replace the energized enclosure with a de-energized enclosure, develop a PLC or VFD that somehow doesn’t require energy to operate, or create a separate panel for the PLC without any hazardous voltage. Again, it is impractical to entertain any of these substitutions as viable solutions to our challenge.

This leads us to the next option: Engineering Controls, the third most effective means of controlling hazards. Engineering Controls do not eliminate hazards, bur rather isolates people from those hazards. Isolation involves creating a physical barrier between personnel and hazards and this option seems to have potential. If there were a way to access the PLCs and VFDs in our electrical enclosure without having to open the door to the enclosure and expose the worker to significant risk, we could achieve the most effective hazard control that is practical to our challenge.

A FRESH APPROACH TO A MODERN NEED

Panduit Data Access Port

Isolating personnel from the risk of opening an energized electrical enclosure to access the intelligence inside has led to the development of the Panduit Data Access Port (DAP). The Panduit DAP is mounted on the outside of an electrical enclosure and provides programming ports as well as electrical outlet access without the need to open the enclosure. This allows personnel safe access to PLCs, VFDs, and other internal components without the risk of exposure to electrical hazards. With the Panduit DAP, a practical and successful solution with the most effective hazard control possible for the application has been attained.

While connected and intelligent plant floors continue to develop at the speed of light, there are additional aspects of new technology that often go overlooked. As OSHA’s Top 10 Most Cited Violations has indicated, electrical safety can be an afterthought, but planning for safety should be an important first step when developing new processes or products. The Panduit Data Access Port is designed from the beginning to provide the most effective safety control while still allowing personnel to complete their tasks. Even as intelligent plant floors develop faster than we realize, creating a culture of safety should always move equally as fast.

For more information on Prevention through Design methodology, read our whitepaper.

For more information on Panduit Data Access Ports, visit www.panduit.com

Implementation of a Lockout/Tagout Program

To successfully implement a lockout/tagout program at your facility, each of the 5 elements below are needed:

1. Program: Lockout/Tagout Program Documentation
To create the Lockout/Tagout program documentation, several areas need to be addressed. These topics include, but are not limited to, the following:

  • Purpose and Scope
  • Rules
  • Lockout Procedures and Techniques
  • Removal of Lockout Devices
  • Training
  • Tagout Procedures

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Safety in the Workplace

Recently we had the opportunity to guest write on Thorne and Derrick’s blog.  Below is what we published on the topic of Safety in the Workplace!

You may ask yourself why you need a safety services program in your organization?

It’s expensive, I need additional staff, and we haven’t had an incident yet…YET is the key word! It’s time to start being proactive instead of reactive! In addition to the numerous industry-wide standards for hazardous energy, electrical safety and environmental standards, the safety of your workplace and personnel should be a top of mind concern.

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Safety Is Key When It Comes To Construction

April 23rd is this year’s Construction Safety Day.  The first step in making the construction industry safer is to understand the biggest threats. Balancing worker safety, productivity and equipment optimization starts with establishing a strong safety infrastructure. Panduit’s Safety Solutions not only offer safety products, but encompasses safety services and safety training as well.

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Move Over Santa Claus, Here Comes GHS!

Guest post by Fred Dorman,
Global Solutions Mgr, Business & Channel Development

Some readers may already know the Globally Harmonized System of Classification and Labeling of Chemicals or GHS is an internationally agreed-upon system created by the United Nations. It has been designed to replace various classification and labeling standards used in different countries with a consistent labeling system on a global level. Occupational Safety and Health Administration (OSHA) has updated its Hazard Communication Standard to align with this Globally Harmonized System.

So what does this mean for Employers? Much of OSHA’s Hazardous Communication Standard has been changed in this transition and that means manufacturers and employers will have to update their hazard communication program accordingly. The new requirements include:

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