Use Good Practices Throughout Your Facility

Good housekeeping helps you comply with seven OSHA regulations.

Keeping a facility clean isn't solely a job for an off-hours maintenance staff. Incorporating good housekeeping practices that are used by all employees, each day, and throughout the facility not only will keep it looking nicer, but also can help improve overall safety compliance efforts.

During the past year, OSHA has been ramping up enforcement efforts and issuing bigger fines for non-compliance. A clean facility can help to minimize the potential for some violations.

On the Dock
One of the top five most commonly issued OSHA citations in general industry is for violations of the Hazard Communication standard, 29 CFR 1910.1200. Failure to have a written hazard communication program, failure to conduct necessary employee trainings, and failure to have the proper Material Safety Data Sheets for hazardous chemicals in the workplace are all common violations under this standard.

Although it may not seem like a good housekeeping tip at first because it doesn't exactly make any area of the facility sparkle, establishing a protocol for receiving crews to forward to the safety officer any MSDS that arrives with packing slips, attached to the outside of a box, or in any package of goods helps keep the books clean and helps everyone stay safer.

This simple action informs the safety officer about any new chemical that may be brought into the facility so that containers can be properly labeled, workers can be trained on any associated hazard or product changes, and plans can be established for proper storage and use of those chemicals while they are on site.

To aid in compliance with this standard, in addition to having all MSDSs forwarded, some safety officers opt to require an MSDS to be present with a new chemical or be on file before a delivery can be received. This helps to prevent "unknown" chemicals from ending up somewhere in the facility (and being discovered during an inspection) and potentially causing problems somewhere in storage or use. Computer programs can facilitate this, or spreadsheets can be used and kept updated so receiving crews have a reference to use when orders arrive at the dock.

Fluid Dispensing Areas
When fluids are transferred, there is a likelihood of leaks, drips, and spills that not only make dispensing areas look messy, but also create other hazards. Keeping containers on spill decks helps to contain leaks and drips, and it will keep floors and aisles near dispensing areas drier and safer.

Stocking absorbents or wipers in areas where fluids are dispensed encourages employees to clean up incidental leaks and spills. If employees need to go somewhere to obtain these items, cleanup is far less likely. Place a suitable waste collection container in the area to prevent the absorbents or wipers from accumulating and creating another mess.

If faucets are used to dispense flammable liquids from containers, OSHA requires them to be self-closing. [29 CFR 1910.106(e)(2)(iv)(d)] Using self-closing faucets for all fluids dispensed from horizontally stored containers can further safety efforts by minimizing leaks and drips from all containers, not just those that contain flammables.

Processing Areas
Overspray, leaky machinery, and dip tanks can all be contributors to wet, slippery floors and aisles in processing areas. OSHA requires floors in work areas to be, “maintained in a clean, and so far as possible, a dry condition.” [29 CFR 1910.22(a)(2)] Often, this can seem like an impossible, or at the very least, a never-ending task.

Using berms around machinery that leaks contains those fluids, and helps to keep walking areas and aisles outside of the contained area drier and safer. Flexible berms that can be driven over or walked on keep leaks contained while allowing cart or forklift access to the area. They are also easier than concrete berms to relocate should floor plans or processes change at the facility.

For areas with overspray, absorbent mat rolls help to minimize slippery floors and provide additional traction in aisle ways and working areas.

Waste Collection Areas
Whether waste collection is performed in one centralized location or at several satellite accumulation areas throughout the facility, just like fluid dispensing areas, waste collection areas provide an increased opportunity for leaks, drips and spills.

EPA requires hazardous waste generators to keep hazardous waste collection containers closed, unless waste is being added to or removed from the container. [40 CFR 264.173] While this regulation was created to help prevent spills from harming the environment; it is also a good housekeeping idea, and there are safety advantages to keeping containers closed. Fugitive emissions can be better kept in check, and closed containers are less likely to create slippery spills, should the container be tipped.

Choosing funnels with large openings, and funnels that screw directly into container openings will help employees channel waste liquids into collection containers more easily, helping to prevent spills. Funnels and lids with tight-sealing covers help keep the waste contents in the container.

For facilities that are required to have fire prevention plans, keeping waste collection areas clean helps comply with the requirement to have proper handling and storage procedures for any hazardous materials onsite. [29 CFR 1910.39(c)(1)]

Aisles and Storage Areas
Rare is the facility that can boast of having tons of excess storage space. When large orders arrive, lack of storage space too often translates to cluttered aisles, creating a number of potential hazards. In areas where mechanical handling equipment is used, OSHA requires that aisles, doorways and loading docks remain unobstructed with "sufficient safe clearance." [29 CFR 1910.176(a)]

Having production foremen coordinate large deliveries with receiving crews can help assure that there is a "space" -– other than aisle ways -- when those large orders arrive. Sometimes it is also helpful to review stock rotation procedures or conduct periodic "stock audits" to ensure that expired products or materials that are no longer used at the facility aren’t taking up valuable storage space that could be used to keep things out of aisle ways.

Outdoor storage buildings and enclosures can also provide flexible solutions for a variety of feedstock goods or finished products awaiting shipment if storage space truly isn’t available within the main facility.

Laboratories
Facilities with on-site laboratories have an obligation to keep those areas cleaned up as well. Laboratories are required to have a written Chemical Hygiene Plan that sets forth, “procedures, equipment, personal protective equipment and work practices that… are capable of protecting employees from the health hazards presented by hazardous chemicals used in that particular workplace.” [29 CFR 1910.1450(b)]

Establishing good housekeeping procedures and practices that include daily cleaning of work surfaces and proper waste management will aid in compliance with this standard.

Sanitation
Like the general duty clause, OSHA also has a citation that covers any areas that aren’t specifically addressed in regulations: “All places of employment shall be kept clean to the extent that the nature of the work allows.” [29 CFR 1910.141(a)(3)]

Doing all of the “little things” to keep a facility looking tidy really can help improve safety. Taking the time to keep things neater and cleaner will not only make an OSHA inspector happy, they’ll keep employees smiling, too.

This article originally appeared in the December 2010 issue of Occupational Health & Safety.

About the Author

Karen D. Hamel, CSP, WACH, is a regulatory compliance professional, trainer, and technical writer for New Pig. She has more than 24 years of experience helping EHS professionals find solutions to meet industry consensus standards as well as EPA, OSHA and DOT regulations. She is a Certified Safety Professional (CSP), OSHA-authorized General Industry Outreach Trainer, Walkway Auditor Certificate Holder (WACH), Community Emergency Response Team (CERT) Trainer, hazmat technician, serves on the Blair County, Pa. LEPC, and has completed a variety of environmental, safety, emergency response, DOT and NIMS courses, including Planning Section Chief. She conducts seminars, webinars, and trainings for a variety of national organizations. She can be reached at 1-800-HOT-HOGS® (468-4647) or by email, karenh@newpig.com.

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