OSHA’s New Scrutiny on Plastics Companies
by Robert Levandoski
Fuss & O’Neill Manufacturing Solutions
Over the past year, OSHA has reinvigorated its regulations, focusing on key industries classified by the North American Industrial Classification System (NAICS). As an industry listed in one of those target groups, plastics manufacturers and related businesses are under increased scrutiny.
In fact, today thousands of companies that have never been subjected to OSHA rules in the past now must scramble to make sure their safety management programs meet the agency’s requirements and, if not, bring them up to the appropriate standards.
As a result of this change in focus, many plastics businesses have a newfound sense of urgency when it comes to safety management. Why is this such an important issue today? Currently, each OSHA Serious Citation carries a fine of up to $7,000, and simple accidents can lead to a site inspection – possibly resulting in hundreds of thousands of dollars in fines.
In 2016, the cost for each citation is expected to increase to $12,740. The fines are just one problem that can be caused by inadequate safety management and resulting accidents. The negative publicity that often accompanies a serious accident can be devastating and demoralizing to any company.
Why is the plastics injury under particularly close scrutiny? Plastics companies face higher-than-typical risks of machinery injury exposure – particularly with plastic injection molding equipment, which is a major source of accidents resulting in amputation. OSHA has been paying particular attention to reducing the risk of amputation, which – along with lacerations and burns – is among the most common serious injuries at plastics companies with inadequate safety management programs.
As damaging as OSHA fines and bad publicity can be, there’s another financial reason that it’s important to ensure that the work environment is safe: Productivity is undermined by an unsafe work environment. Accidents lead to equipment stoppages and equipment damage. Frequent accidents also can lead to staff morale issues that can undermine productivity. Of course, unsafe workplaces also experience much higher workers’ compensation costs than businesses with effective safety management programs.
Most businesses want to do the right thing and protect their employees. Good intent, however, doesn’t always equal success when it comes to safety management. It’s not just the companies that cut corners that run afoul of OSHA. In most cases, the businesses that get in trouble are ones whose managers thought they were covered by good safety management programs – only to find their confidence was misplaced.
Now is the time for plastics businesses to reevaluate their safety management programs. In this ever-evolving regulatory environment, every plastics manufacturing company should expect to be the subject of an OSHA inspection, and each manufacturer needs to be sure it is in compliance.
The first step is to conduct a pre-inspection assessment of the safety program. Usually, this is accomplished by hiring a consultant to conduct the same type of inspection as OSHA. This pre-inspection survey should identify the same conditions that would be discovered by OSHA, but without the penalty. The process most often will provide ample time to plan, develop and implement mitigation strategies to solve problems before they are discovered by OSHA.
A key to an assessment is to conduct a thorough evaluation of all equipment to determine whether it is operating properly, whether maintenance plans are effective and verify whether safety measures originally installed by the manufacturer remain in place and functional. One of the most dangerous hazards in any manufacturing operation is machinery that’s not operating or maintained properly – that is, not working in the fashion its operators expect or for which it was originally designed. Loose or misaligned machine components, missing or damaged guards, custom modifications or frequent breakdowns can cause serious harm to operators and bystanders.
One of the most commonly discovered areas of noncompliance can be found around the operation of injection molding machinery. Horizontal injection molding equipment poses serious amputation hazards, and a survey can determine whether sufficient guarding is in place, if suitable safety training is being provided, if appropriate lockout/tagout procedures are functioning and whether additional safety measures are needed to protect workers. When unsafe conditions or other problems are identified, plans can be implemented to address them.
When it comes to mitigation, there are no “out-of-the-box” answers. Every mitigation program – indeed, every safety management program – must address the unique operations and workforce of an individual company. There are, however, common threads.
Safety training, for instance, is a particularly important element of most companies’ safety management programs. Training should provide managers and workers with a comprehensive overview of common injuries found in injection molding, thermoforming and extrusion operations; the causes of injuries; and ways to best avoid them. Many companies use a “train the trainer” approach through which in-house trainers learn the information and skills they need to provide ongoing education to management and staff.
Safety and maintenance surveys and plans shouldn’t only happen in anticipation of a visit from OSHA. They should be standard protocol for any manufacturing business, and they must constantly be reevaluated and updated. This isn’t just a safety issue. Proper maintenance has a huge impact on a company’s bottom line. Effective maintenance also keeps equipment running properly, production schedules on target and product quality high.
Maintenance actually can save companies thousands or even millions of dollars every year by avoiding costly unanticipated downtime, equipment repairs, replacement losses caused by production shut-downs or slow-downs, and unnecessary worker compensation claims due to injury.
In fact, it costs companies five to 10 times more to act reactively to resolve breakdowns than to implement proactive maintenance programs. Clearly, maintenance is a vital element of any production plan, and corporate executives must consolidate maintenance and safety into their long- and short-term business plans.
Not all of the manufacturing companies that seek assurances about their safety management programs are doing so because they fear OSHA penalties. Many companies go through the process because they want confirmation that their programs are effective and exceed the minimum criteria established by OSHA. These companies place a high value on workplace safety, have comprehensive programs in place and want to be sure those programs are as strong as they can be.
There are advantages to being proactive. Regardless of whether the company is large or small, when an employee is injured on the job, that injury reduces the production capacity and effectiveness of the equipment involved. Accidents also leave production floors short-staffed, which can have a far-reaching impact – not just on the equipment involved in the accident, but with processes down the line. Of course, if a piece of equipment isn’t running because an accident occurred or because there’s the possibility of an accident, the company is losing money due to lost productivity of that equipment.
Ultimately, it doesn’t matter whether a company’s safety management programs are evaluated out of concerns over potential OSHA penalties or in an effort to be proactive. The bottom line is that when companies are certain that their safety programs are effective and meet their unique safety needs, the workplace is safer and more productive, high quality product is produced and the company is more profitable.