Guide to Plant Safety

By Steve Wolszczenski
Steve Wolszczenski is Chairman of NPCA’s Safety, Health & Environmental Committee.

Precast concrete manufacturers don’t have to look far and wide for help in developing their safety programs – a guide is available from the National Precast Concrete Association on CD-ROM. The “Guide to Plant Safety” is included in with NPCA membership packages, and is available to non-members as well.

NPCA’s Safety, Health and Environmental Committee published the guide in early 2003 to assist precasters in developing safety programs that comply with Occupational Safety and Health Administration (OSHA) standards. Additionally, the guide serves to establish programs that can actually reduce accidents. Fifteen programs are included in the guide, but be aware that many additional OSHA standards may apply to precast manufacturing. Figure 1 shows a listing of the programs included in the Guide to Plant Safety.

Each program in the “Guide to Plant Safety” must be tailored to the individual location. This requires each plant to designate responsible parties, specify locations and add specific company information to the written programs. From that point, the programs require training and implementation. The word “Guide” in the title emphasizes that the document is not in its intended final form. The Guide is intended to be used as a tool to help you establish programs for your company. You will learn a hard lesson if you give an OSHA inspector an unchanged, unimplemented version of the Guide to Plant Safety.

OSHA plans to conduct 37,720 workplace inspections during the fiscal year. Of these inspections, about 13,000 will be identified through its Site Specific Targeting program, which identifies the companies with the highest injury and illness rates. Companies that have received a letter indicating their incident rates are high are likely to be inspected under this program.

Some of the remaining inspections may also hit home with precasters. One of OSHA’s six national Special Emphasis Programs currently in place focuses on silica exposure. OSHA is inspecting industries that use materials containing silica in their processes to audit employee exposures.

There are also 135 Local Emphasis Programs (LEPs) that Regional and Area OSHA offices have developed to meet their local needs. These programs focus on initiatives specific to their areas of jurisdiction, and some of these LEPs may focus on the precast concrete industry. One such recently announced LEP initiative includes the Atlanta-East Area and includes companies in industries within the Standard Industrial Classification codes 3271, “Concrete Block and Brick Manufacturing,” and 3272, “Concrete Products Manufacturing, Except Block and Brick.” Note that precast manufacturing is included in the 3272 SIC code. During fiscal 2002, OSHA conducted 275 of their 37,493 total inspections within the 3272 SIC code.

By implementing the Guide to Plant Safety, you will take a large step toward preparing for such an OSHA audit. In 2001-2002, the five most commonly cited violations in the 3272 SIC code, listed in order of ranking, included hazard communication, lockout and tagout, powered industrial trucks, respiratory protection and overhead cranes. The Guide to Plant Safety includes written guidelines for all five of these programs. The “meat” of the programs is all there, and you will find an incredible benefit in having the sample plans prewritten for you to modify and adopt.

The responsibility for implementation of these programs should be assigned to an individual or group of individuals. Be sure to establish accountability and follow up to ensure the programs have been implemented.

Supervisors, foremen and employees all play a definitive role in the implementation of these programs and must also be held accountable for adherence to and administration of the programs. This may be accomplished by including safety on performance appraisals for everyone in the organization. Tie these appraisals to financial incentives and they will be very effective. Conduct and document periodic audits and inspections. This will reinforce the initial directive and remind everyone that these programs are important.

OSHA will test the implementation of written programs to ensure that they are in effect. This is where accountability is very important. This accountability must exist at the management level, supervisory level and employee level. If a manager has not fulfilled his or her responsibility, there must be consequences either in the form of discipline and/or on the performance appraisals. If it can be established that an OSHA violation is the result of misconduct, OSHA may withdraw the citation. Therefore, it is very important to document disciplinary action and document reinforcement of these policies.

None of this will happen, of course, without full commitment by executive management. If executive management doesn’t set a positive example, continually reinforce the commitment and hold employees accountable, the written programs in the Guide to Plant Safety will not do much to prevent accidents or promote OSHA compliance.

If used properly, the Guide to Plant Safety will assist you in developing a responsible safety program. The next phase of the Guide to Plant Safety is in the works, and the Safety, Health and Environmental Committee plans to incorporate additional documents to the Guide. These will serve as training tools for when companies are implementing the programs. These quick training guides will help the user comply with the OSHA training criteria for the 15 programs currently in the “Guide to Plant Safety.” This initiative is targeted for completion by the 2005 MCPX.

Don’t underestimate the impact that a properly implemented safety program can have on a business. Rising insurance costs, increased litigation and liability claims, OSHA enforcement and, most importantly, the well-being of employees and their families are tremendous reasons to take action and use this great tool!