There are thousands of OSHA compliance items that should be implemented. However, focusing on a few areas will reduce the chance of receiving an OSHA citation by 75 percent.
By Lloyd B. Andrew III
If you are a hauling company manager and think it is too costly to comply with OSHA regulations, and plan on just paying the fines if caught, this article is for you. A review of all federal OSHA citations issued to waste hauling companies in 2016 was performed to help focus your OSHA compliance efforts.
It helps to know why OSHA performs inspections. Believe it or not, OSHA is shorthanded just like many businesses. They rarely perform random inspections. They focus their attention where the need is greatest—companies where workers have been killed, suffered a major injury or where someone has complained to OSHA about unsafe working conditions. OSHA also targets businesses considered high-risk, based on reported injury and illness data. Unfortunately, OSHA considers waste collection a high-risk business.
To avoid an OSHA inspection, keep your workers happy so they don’t file an OSHA complaint, and make certain your safety program prevents workers from being seriously injured or killed. However, OSHA may still show up just because your company is hauling waste. It is best to be prepared.
One of the first items an OSHA inspector will request is OSHA’s Work-Related Injury and Illness log. This link explains how to properly complete the required forms which are available free: www.osha.gov/recordkeeping/new-osha300form1-1-04.pdf. OSHA inspectors request this form to quickly identify where and how frequently workers are being injured, and how severely. Several companies in 2016 were cited for not reporting work-related fatalities to OSHA within eight hours.
Next, put up the OSHA poster. It is available free, in several languages, at www.osha.gov/Publications/poster.html. There is a potential $1,000 fine if not posted (some State OSHA programs have their own posters). OSHA relies on workers to report unsafe working conditions, so they want their phone number easily accessible. The following four key OSHA compliance programs on which hauling companies should focus made up 35 percent of the 2016 OSHA citations.
#1: Hazardous Energy Control Program, Commonly Called Lockout/Tagout
This requires much more than simply turning the ignition switch off on a truck. The core element is writing equipment specific hazardous energy control procedures. This requires seriously thinking about all the hazardous energy workers may encounter during their work tasks and how to control that hazardous energy before performing servicing or maintenance on equipment.
This OSHA standard applies to fixed and mobile equipment in the shop or on the road. One of the more common tasks is cleaning out behind the blade of a packer body (see Figure 1).
All hazardous energy must be controlled. For example, if entering a packer body to clean behind the blade, the equipment specific hazardous energy control steps would include the following: park on level ground to control gravity. Lower all hydraulic components—arms, tailgates, rails—and release any stored hydraulic pressure by moving controls back and forth. It is important to read the equipment manufacturer’s manual for your particular model truck on how to properly control the hazardous energy. Newer trucks may have “electric over hydraulic,” meaning the ignition switch must remain in the “on” position to release the hydraulic pressure. Set the parking brake. Turn off the ignition switch to control electrical energy and put the key in your pocket. If equipped, turn off the battery disconnect and lock it out. All these steps need to be written into your hazardous energy control program.
In the shop, there may be additional steps needed, such as chocking the wheels to prevent movement. Allowing the engine/equipment to cool off to control thermal energy. Shop mechanics may need special tools or equipment, to control the hazardous energy. Hauling company shops may need appropriately rated support stands, or hydraulic cylinder sleeves for front end loader arms, roll-off rails, and packer body tailgates to work on them in an elevated position (see Figure 2).
Once the equipment specific procedures are written, workers must be trained. Not only do shop maintenance personnel need training, but also drivers who add fluids into engines or enter packer bodies to clean. Workers need to be taught how to control the hazardous energy on the specific equipment they are performing servicing and maintenance upon.
Periodically, at least annually, workers must demonstrate their understanding of the hazardous energy control procedures. Hauling companies must perform and document job observations to ensure workers are following all the steps in their hazardous energy control procedures.
#2: OSHA’s New Hazard Communication Program
OSHA requires a written program which identifies the name of the Hazard Communication program administrator, how to obtain Safety Data Sheets, and outlines how the GHS (Globally Harmonized System of Classification and Labeling of Chemicals) chemical container labeling will be accomplished (see Figure 3).
The new OSHA labels require pictograms, signal words, hazard statements and precautionary statements. Chemical manufacturers label the chemical containers they supply; for example, spray cans of brake cleaner, quarts of motor oil and 55-gallon drums of hydraulic oil. However, containers, which these chemicals are transferred into, must also be labeled. Label pour cans and other containers in the shop, which are used to transport truck fluids from their original container and poured into a truck engine. If all the liquid is emptied out of the pour can, there is no need to label it. Also, label bulk fuel (i.e. diesel, gas, CNG) and oil storage tanks along with their piping systems. These OSHA labeling requirements do not apply to chemical containers on mobile equipment like truck diesel tanks or truck hydraulic oil tanks.
Safety Data Sheets, or SDSs, must be readily available to workers for all the chemicals they may come across on the job. Some people chase down SDSs for office or cleaning supplies and are missing important ones, like diesel fuel, motor oil and hydraulic oil because these are delivered in bulk quantities. In the shop, if mechanics weld on steel containers or trucks, a SDS for steel and welding wire/rods must be available which explains the hazards of welding fumes.
The chemical hazard information contained on the SDSs must be communicated to workers. Workers must be able to obtain a SDS without having to ask their supervisor. Workers need to be taught how to read SDSs, so they understand the hazards of the chemicals they encounter on the job. For example, truck drivers need to understand that diesel exhaust, and some motor oils, are potentially carcinogenic.
Training is a critical component to ensure workers also understand how to read the new GHS labels. Workers must be taught the new GHS chemical numbering system is opposite of the numbering system they may have used in the past. The old NFPA/HMIS 4-color diamond labeling system used a 1 to 4 rating system, where 4 indicated the most serious hazard category. Under the new GHS labeling system, a 1 indicates the most hazardous chemical hazard category. OSHA will conduct private interviews with workers, so it is important that workers can explain the hazards of the specific chemicals they come across.
#3: Confined Space Program
Waste hauling companies must have a confined space program which identifies all the permit required confined spaces workers may encounter. Some hauling company managers may think they do not need a confined space program because they do not enter them. Read the warning label next to the entrance into the side of a packer body truck (see Figures 4 and 5).
When a worker enters a packer body to clean behind the blade, or make repairs, they have entered a Permit Required Confined Space. OSHA considers the risk of being crushed to death inside the truck body a serious safety hazard and therefore defines it is a Permit Required Confined Space. Other confined spaces, which are typically not entered, but must be labeled: “Danger-Permit Required Confined Space – Do Not Enter,” are diesel fuel tanks, water tanks and other tanks, which a worker could physically enter.
A procedure in the written confined space program, which outlines the steps necessary to safely enter a packer body is required. This is accomplished through the implementation of the hazardous energy control program. Once the load is discharged from the packer body, and the hazardous energy control procedure has been implemented, it is typically safe for a worker to enter the packer body.
Worker training is again an essential component of the Permit Required Confined Space program. Hauling companies need to inform workers how to control the serious safety hazard inside packer bodies prior to entry. OSHA defines this as a reclassification of the space, which must be documented. Also, explain to workers not to enter spaces that have a Danger-Permit Required Confined Space label.
For a worker to enter a Permit Required Confined Space, like a diesel storage tank that has not been reclassified, requires specialized equipment and many hours of specialized training. Generally, waste hauling companies should hire qualified contractors to perform this work.
#4: Personal Protective Equipment Program
The fourth OSHA standard to concentrate on is the PPE program. A written hazard assessment, for each job type or task, must be completed and included in the PPE program. The hazard assessment must include a signed certification statement, which identifies the name of the person completing the hazard assessment and the date it was performed. OSHA requires this information in case a question arises, so they will know who to ask why certain PPE was, or was not, required.
OSHA requires PPE training. Workers must demonstrate their ability to properly put on, take off, wear, and maintain the PPE specified. For drivers and helpers working in traffic this includes wearing reflective vests and typically gloves, safety boots and maybe safety glasses, depending on the type of waste collection system they are operating.
Additional Areas of Focus
In 2016, OSHA used the general duty clause to cite hauling companies, with residential helpers, for not having a comprehensive heat stress program, which included worker training.
Citations were also issued for not inspecting fire extinguishers monthly and not providing training on how to use them.
Other hauling companies were cited for allowing workers to operate powered industrial trucks, typically forklifts, who had not been trained or demonstrated their driving skills within the last three years or were using improperly maintained equipment.
OSHA inspectors issued citations for several different items in truck shops and hauling facilities. Several citations were issued related to electrical systems, open or damaged electrical boxes and wiring, missing breakers, electrical receptacles not designed for use in wet locations like truck wash bays, electrical wiring run through doorways or holes in walls, and extension cords used instead of permanent wiring.
OSHA also cited hauling companies for: not providing eyewash stations when handling corrosive chemicals, like battery acid; in shops performing oxygen-fuel gas welding and cutting using damaged regulators, not securing and storing oxygen and fuel cylinders at least 20 feet apart with their protective valve caps in place; and not properly guarding equipment, including using bench grinders with the tool rest positioned >1/8” away from the abrasive wheel.
Since many OSHA standards require worker training, hauling companies are using online training programs to meet these OSHA requirements. It is important that the training provided be specific to the type of work the workers are performing. Using generic online training programs may not meet the OSHA equipment, and work task, specific training requirements. Hauling companies should use online training programs, which are tailored specifically to the waste hauling industry. OSHA inspectors will want to know when the training was provided, which workers attended, and what was covered. Quiz scores are an excellent way to measure a worker’s comprehension of the safety training, and can be provided to OSHA inspectors as training documentation.
Reduce Your Chance of Citations
There are thousands of other OSHA compliance items that should be implemented. However, focusing on the few areas of the OSHA regulations mentioned in this article will reduce the chance of receiving an OSHA citation by 75 percent, based on 2016 citations. It will show OSHA your company has implemented steps necessary to protect hauling company workers by complying with their requirements.
Lloyd B. Andrew III, CIH, CSP, serves on the Safety Advisory Board of Waste Industry Training (Houston, TX), a provider of LMS based on-line safety training programs tailored specifically to the waste industry. He can be reached at (713) 589-9929, via e-mail at Lloyd.Andrew@EnvirOSH.com or visit www.WasteIndustryTraining.com.