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      PostPress

      PostPress

      Print Decorating, Binding and Finishing

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        Safety & Compliance

        OSHA Regulatory Update For 2017

        September 8, 2017

        by Gary Jones, assistant VP EHS Affairs; Kaitlin Rundle, EHS associate; and Matthew Crownover, EHS associate, Printing Industries of America

        Typically, when there is a change in the presidency, the outgoing administration rushes to issue new and revised regulations to complete their agenda. This is what occurred under the Obama administration. One of the more active agencies was the Occupational Safety and Health Administration (OSHA) as it issued several significant regulations impacting printing and finishing operations. This article will provide an overall summary of the rules.

        Mandatory injury reporting

        OSHA revised its mandatory injury reporting rule with the revised reporting requirements greatly expanding the scope of injuries that must be reported to OSHA. What remained unchanged was the requirement to report a fatality within eight hours.

        Employers now are required to report within 24 hours of any work-related incident that results in:

        • in-patient hospitalization of one or more employees
        • an amputation
        • the loss of an eye

        Since reporting of any in-patient hospitalization or amputation is required, it is important to understand how OSHA is defining them. While the definitions address the circumstances where OSHA wants to receive injury reports, they also raise many questions. OSHA has not issued any guidance to answer the questions.

        Since the printing industry is classified as a high-hazard industry for amputations, any report of an amputation or a hospitalization due to an equipment-related injury will generally result in an inspection. Inspections generate large fines due to violations of either the machine guarding standard, the lockout/tagout standard or both.

        OSHA is publicizing the injury information on its web page. Therefore, every company that reports a severe injury will be identified along with the circumstances associated with the injury.

        Electronic injury and illness recordkeeping/non-discrimination provisions

        The May 2016 recordkeeping rule requiring employers to annually submit injury and illness data became instantly controversial and has come under legal challenge. The rule, Improve Tracking of Workplace Injuries and Illnesses, has two components. The first requires companies to submit records of workplace injuries and illnesses electronically to OSHA. The second prohibits employers from discouraging workplace injury and illness reporting and retaliation against employees who do report them.

        The electronic injury and illness reporting was scheduled to begin July 1, 2017, but has been delayed by OSHA. The requirements apply to any company that has more than 20 full-time employees. Companies that have more than 250 employees are required to submit more detailed information. OSHA has not provided any details as to when the new reporting deadline will be finalized.

        As part of the rule, OSHA mandated that by Dec. 1, 2016, all employers develop an injury reporting procedure and that it be communicated to all employees. The procedure must have reasonable requirements that do not discourage reporting. For example, OSHA has required companies to modify their procedure to not require reporting by the end of a work shift to accommodate an employee who may experience problems once they get home from work.

        The rule also implemented bans on blanket post-accident drug and alcohol testing, safety incentive programs based on lack of injuries and indiscriminate discipline for violating safety rules. Companies that wish to conduct post-accident drug and alcohol testing need to show it is required by law (such as DOT requirements), or an employer is enrolled in a workers’ compensation rate reduction program. Otherwise, the employer must show good cause that it was a necessary step in the investigation to determine the cause of the injury. Safety incentive programs such as those that provide rewards for not having an injury or going a certain amount of days without a lost work day claim are now illegal. Companies that terminate injured employees for violating safety rules need to ensure they have a very well-documented program that can withstand OSHA scrutiny.

        Increased OSHA penalties

        For the first time in 25 years, OSHA dramatically increased its fines for violations of workplace health and safety requirements. At one time, the penalties for many first-time violations was $7,000, and those for willful or repeat violations was $70,000. Since OSHA was granted permission to increase their penalties, the agency will continue to do so each year based on the Consumer Price Index.

        The current penalties are shown in the table shown at right.

        Walking and working surfaces

        The walking and working surfaces rule is a group of individual regulations designed to address hazards associated with every surface where an employee will work. Previously, the regulations were outdated and unclear. To clarify the rules, OSHA released its revision in January 2017 that phases in training and other requirements with various deadlines.

        Walking-working surfaces include ladders, floors, elevated surfaces, openings, stairways and scaffolds. Many requirements address design, construction and installation specifications for the prevention of worker injury from falls. Other aspects cover procedures and guidelines for safe use of equipment, such as scaffolds and fixed and portable ladders. The revisions in the rule are significant and here is a summary of some of the requirements:

        • Periodic inspections for all walking and working surfaces are now required for slip, trip and fall hazards, with any deficiencies corrected. The frequency has not been defined by OSHA; therefore, it must be determined by the employer. Documentation is not required but is highly recommended.
        • Portable ladders must be inspected before each use. Defective ladders must be tagged out of service. Employees must be trained on how to inspect a ladder, as well as how to properly ascend and descend them.
        • Existing fixed ladders, 24 feet or higher, must have a personal fall arrest system or a ladder safety system by Nov. 19, 2036. For new fixed ladders, the deadline is November 2018. Wells and cages will no longer be acceptable. Platform openings must have an offset passage or a self-closing gate that swings away from the hole and has a top and midrail.
        • Employees who work on a flat roof are required to be provided fall protection if they are within six feet of the roof’s edge. There are additional requirements if the work is greater than six feet but less than 15 feet from the roof’s edge.
        • Fall protection is required when a work surface is elevated more than four feet. Fall protection systems and employee training is required.

        Conclusion

        In all, a whirlwind of changes has occurred with OSHA’s regulations. It is still unclear if these rules will remain in their current form, or if revisions will be proposed. Since these rules are in effect, the best course of action is to comply with them.

        The View from 30 Feet: Cultivating Caution in the Workplace

        March 10, 2017

        by Jeff Peterson, editor-in-chief, PostPress

        Business gurus often talk about the view from 30,000 feet – the big picture that provides a look at overall operations. Perhaps, however, the focus should be on the view from 30 feet – a close-up of specific processes and procedures that make an impact now.

        Finishing and binding environments afford many opportunities for potential accidents. As a result, it is important for companies to establish a comprehensive safety program – perhaps even more so than in other types of plants based on the variety of equipment used in finishing and binding departments.

        In most manufacturing plants, three or four different types of equipment might be used to produce a specific product. However, a finishing and/or binding facility could have as many as 20 to 30 different machines. This creates the need for more specific safety rules.

        All plants should be concerned with several areas, including knowing the laws for each specific region and/or state. Safety regulations are not always consistent from state-to-state. All factories also should have an Emergency Preparedness and Response program in place – no larger safety issues exist than those potentially caused by fire, tornadoes, hurricanes, flood or a chemical spill. Furthermore, all companies should have response personnel trained in first aid, CPR and the use of an automated external defibrillator (AED). It may not be mandatory for all personnel, but at least one person, or more, should be trained to administer first aid on site for all shifts.

        Establishing a consistent program

        A quality safety program can be set up in many ways. The key is to make sure a consistent, comprehensive program is available for new and existing employees to follow. For example, at Trojan Litho, headquartered in Renton, Washington, safety is engraved within company culture. Trojan provides mandatory safety training once a month and covers, in detail, one specific topic. New Trojan employees participate in a safety orientation their first day on the job. Two weeks later, those employees and managers are expected to review that safety training and address specific job safety functions in a more in-depth way.

        “As a safety department, we spend a great deal of time on the shop floor every day talking with the employees,” said Sandy Burns, Trojan Litho’s environment health and safety manager. “We believe constant engagement is the greatest help in making sure safety procedures are being followed correctly.”

        Trojan Litho also has implemented “total productive maintenance” (TPM) and performs an annual audit on all of its equipment, which helps the company address and stay on top of any safety issues with its machinery.

        At MCD Incorporated, a print finisher in Madison, Wisconsin, training sessions are scheduled every two months and focus on a key area identified by OSHA. A video is played, along with questions and answers, followed by a quiz for all the employees. Employees must sign in for the training. For those who cannot participate, a make-up session is scheduled.

        In addition, MCD has created a safety team from employees who work in different areas of the plant. “Every month, we do safety inspections and have a member of the safety team, along with a non-member, go through the shop and look for safety violations,” explained Glenn Gauger, MCD production manager. “This helps make safety more than just the safety team’s responsibility.” The safety team at MCD also will hold a cookout periodically as a reward when the plant is doing well across the board in all areas of safety.

        Independent Printing Co., Inc., De Pere, Wisconsin, also believes that providing proper safety guidelines for employees is of utmost importance. The company offers safety and material data sheet training during initial orientation before an employee is ever allowed on the production floor. Lift truck certification also is required by any employee who will be operating powered hand trucks. “We even go so far as to require stretching exercises by all employees before their shift begins to help prevent injury or strains,” stated Jim Smarzinski, finishing supervisor.

        Dressing the part

        Wearing the proper clothing and safety glasses also is an important aspect of safety on the production floor. It is imperative that companies have specific written rules on what is considered proper attire and when safety glasses are needed.

        “Because we have so many different types of production areas on the MCD shop floor, we don’t have specific rules across the board,” explained Gauger. “However, there are rules in place with personal protective equipment (PPE) for all employees, which include no open-toed shoes and restrictions on baggy clothes to prevent anything being caught on a machine.”

        Independent Printing has similar rules on clothing, including long pants only (no shorts) in the production area and a ban on open-toed shoes. “We have rules for specific functions, such as requiring cut gloves when changing knives or having welding gloves on when handling hot stamping dies and cases,” added Smarzinski. “In addition, safety glasses are required for certain functions, such as operating a die grinder.”

        “We have areas and tasks that require specific PPE,” stated Burns. “This includes hearing protection for some areas, tasks that require safety glasses, gloves, etc.” Trojan Litho similarly has a strict policy on excessivly baggy clothes and requires long-sleeved shirts (uniform shirts are provided). In addition, no jewelry is to be worn, long hair must be tied back and, as with most plant rules, closed-toed shoes must be worn at all times on the production floor.

        Rewarding safety

        To keep safety in the forefront of all the employee’s minds, Trojan Litho has established a monthly bingo game where numbers are drawn daily and prizes are awarded to the winners. The tie-in with safety is that if there is a recordable incident, the game is canceled and will not start up again until the beginning of the following month.

        “This has been a fun way to keep safety in the minds of our employees at all times,” concluded Burns. “Everyone knows how important safety is in our plant – from management down to part-time workers. We are very proud of our programs and safety record.”

        The Foil & Specialty Effects Association recently updated its Safety Self-Inspection Checklist that was specifically developed for the finishing and binding industries. The checklist covers several areas, including facility, protecting employees and equipment. It is an excellent way to help start or update your current safety program. If you are interested in receiving this detailed checklist, contact Brenda Schell for a PDF.

        OSHA is Increasing Penalties

        September 6, 2016

        by Gary A. Jones, assistant vice president, EHS Affairs; Kaitlin Mackey, EHS associate; and Matthew Crownover, EHS associate, Printing Industries of America

        On July 1, 2016, the US Department of Labor (DOL) released its interim final rule, increasing the civil penalties for violations of its standards. The increase was required due to the passage of the two-year bipartisan budget President Obama signed on Nov. 2, 2015.

        This is the first time in 25 years that OSHA has increased its penalties. Since 1990, OSHA has been one of only three federal agencies that were specifically exempt from a law that required federal agencies to raise their fines to keep pace with inflation. The bill allows OSHA to have a one-time adjustment this year to catch up from the last time the agency’s civil penalties were modified. In addition, the law allows the penalties to be increased each year.

        OSHA’s new penalties

        Table 1

        The required initial penalty “catch-up adjustment” was tied to the percentage difference between the October 2015 Consumer Price Index (CPI) and the October 1990 CPI. The inflation adjustment factor for this period worked out to be 78.16 percent.

        The new penalties became effective on Aug. 1, 2016, and the maximum penalties for workplace safety violations issued by OSHA are shown in Table 1.

        Due to the new law, the rounding down to the nearest $1,000 has been eliminated. The new law eliminated the rounding rules so penalties are now rounded to the nearest dollar.

        New penalties and existing inspections

        The interim final rule mentions how OSHA is going to apply the new penalty structure to inspections that began before August 1, 2016. The rule states that the adjustment will apply to any penalty assessed after August 1, 2016, “including those whose associated violation predated such increase.” The adjusted penalties apply to any citations issued after Aug. 1, 2016, whose associated violations occurred after Nov. 2, 2016.

        This means that any inspection that has not been closed on or before July 30, 2016, may be subject to the higher penalty amounts. OSHA could wait to issue a citation until after August 1, 2016, so they can use the new higher penalties. It was not clear if OSHA would intentionally delay issuing a citation. It remains to be seen how OSHA is going to address the penalties for these inspections.

        States with OSHA-approved programs

        According to the rule, states that operate their own Occupational Safety and Health Plans must also increase their penalties. This is because state-approved programs must have requirements that are at least as effective as those issued by federal OSHA. The penalties are an important part of enforcement for state plans, and they need to be consistent with the new ones.

        There are 22 states that have their own programs, and they now will have to revise their penalties to be consistent with this new rule. The rule did not provide a deadline for when states had to revise their penalties. In some instances, the states will simply incorporate new rules by reference so the increase will have the same effective date as federal OSHA. In other instances, states have to go through their own rulemaking process, and it can take between six to 12 months for this to occur. This means that until such time that the state plan increases its penalties, a printing operation cited by its state will not pay the increased penalty.

        Annual increases

        The budget law requires OSHA to now implement annual cost-of-living increases. The increases are tied to the increase in the CPI. Adjustments must be made by January 15 each subsequent year. In order to keep up with federal OSHA, states with their own plans need to do the same.

        Summary and conclusion

        After 25 years of no increase in penalties, OSHA now has reversed course and dramatically increased them. Since the rule is an interim one, there is a remote possibility that some aspects might change.

        However, it is highly unlikely that OSHA will not increase their penalties to the maximum extent allowed by the law. Another factor, which will be evident once OSHA starts using the new penalty structure, is that the maximum penalty for each alleged violation will be applied. Under the current penalty policy that was put in place in 2010, OSHA typically issues citations with penalties at or near the maximum and itemizes each violation with its own penalty so that the total amount is much higher than how the penalties were calculated prior to 2010. They also changed their negotiation approach. They now are only willing to reduce the proposed penalties by one-third as compared to one-half, which was in the policy that was in place prior to 2010. OSHA has not issued any information that provides insight into how they may revise the current penalty policy in light of the increased penalties. This means they may continue to use the same approach that was instituted in 2010 so the total proposed penalties will be even greater than what they are if a citation were issued today.

        The penalty increase means now more than ever that those in the printing industry need to assess their compliance status. In order to avoid injuries, violations, and now penalties that are 78 percent greater than before, it’s crucial to understand exactly what OSHA regulates and what inspectors looks for when they arrive to conduct an inspection. An excellent resource is the OSHA Primer publication. The OSHA Primer serves as a simple resource that provides an overview of federal OSHA regulations applicable to the printing industry. You can download the OSHA Primer from the Printing Industries of America online store at http://prnt.in/OSHAPrimer.

        If you have any questions or need further information, please contact any member of the Printing Industries of America EHS team at ehs@printing.org or 800.910.4283.

        Article reprinted with permission from Printing Industries of America.

        Q&A: Proper Safety and the Right Coverage Can Go a Long Way with Property and Casualty Insurance

        September 6, 2016

        by Eric Stiles, lead account executive, Sentry Insurance

        Question: For the most part, my employees make good decisions when it comes to their own safety. However, we continue to see some choices by employees that not only violate our policies, but also result in an injury. Is there a way I can keep our employees from making these decisions?

        It starts with management. To create a safe work environment, expectations regarding safety need to be developed and communicated. Most importantly, the safety guidelines must be followed by all employees, including and most importantly, managers. Here’s what to do:

        • Create a Safety & Risk Management policy statement and share it with every employee.
        • Annually, require every employee to read, agree with, sign and return an acknowledgement stating they will follow the guidelines in the Safety & Risk Management policy statement.
        • Set a safety improvement goal each year, and update employees on the injury and loss trends on a quarterly basis.
        • Integrate safety performance objectives into all employees’ annual performance evaluations and update employees on a quarterly basis of their results.
        • Ensure your management team is held to the same guidelines as all other employees.

        Ultimately, working safely and preventing accidents need to become part of the organization’s culture. Setting expectations and monitoring results is a great first step.

        Question: What do I absolutely need to do to prevent vehicle accidents from hurting our business?

        Driver selection is an essential part of avoiding accidents. By definition, safer drivers will get into fewer accidents. From the company’s perspective, there are two additional factors: the accidents safer drivers get into likely will be less severe and more likely to be someone else’s fault. Both of these factors will tend to mitigate the cost to your company.

        Conversely, unsafe drivers represent an increased, ongoing exposure to more and greater losses. Having a formal, written hiring policy that specifically targets problem drivers for exclusion in your hiring process may help protect you from loss due to accidents.

        Choosing better drivers sounds simple: hire better drivers and don’t hire problem drivers. Making it happen requires having a plan in place. Follow these strategies to help protect your business from the potential risk of negligent entrustment:

        • Make it a practice to review each driver’s motor vehicle record as a condition of employment.
        • Use preset criteria to determine what is acceptable. Use concrete numbers and set numeric limits for how many accidents and/or violations it takes to disqualify a hire.
        • Train new drivers on safe driving practices for the specific type of vehicle they will operate.
        • Have a written safety policy and distribute a copy of that safety policy to new drivers.
        • Require new hires to sign a safe driving practices commitment statement.
        • Have potential employees complete a ride along or driving test with a current employee to observe their driving skills.
        • Require new drivers to attend periodic safety meetings.

        Driver selection is the first step to reducing your exposure to negligent entrustment. Reaffirm your commitment to safety with regular reviews, training and support.

        Question: Does my standard property insurance policy cover my equipment when it breaks down from an internal source?

        Most likely not. A property policy covers external causes of loss – things like fire, lightning and wind. A mechanical failure, electrical surge or other internal source wouldn’t be covered. For that, you’d need to consider equipment breakdown coverage – sometimes called boiler machinery coverage.

        Equipment breakdown coverage protects you from several exposures that can bring your business to a halt – including failures of electrical, mechanical or production equipment. Here are some examples of equipment covered under the plan:

        • Printing presses
        • Offset
        • Rotogravure
        • Flexographic
        • Letterpress
        • Finishing and binding equipment
        • Programmable logic devices
        • Electric motors
        • Enclosed gear sets
        • Line shafts
        • Electrical equipment
        • Switch panels
        • Circuit breakers
        • Motor control centers
        • Pad or pole-mounted transformers
        • Boilers

        Even the most well-maintained equipment can experience a mechanical or electrical catastrophe. Equipment breakdown coverage provides you with the protection you need to help cover the cost of repairing and replacing your damaged equipment. Check with your insurance carrier to learn more about specific coverage for your business.

        As an endorsed P&C and 401(k) carrier for FSEA, Sentry Insurance offers coverage options and services to meet business needs. Eric Stiles is Sentry’s lead account executive responsible for maintaining the FSEA/Sentry relationship.

        Property and casualty coverages and safety services are underwritten and provided by a member of the Sentry Insurance Group, Stevens Point, Wisconsin. For a complete listing of companies, visit sentry.com. Policies, coverages, benefits and discounts are not available in all states. See policy for complete coverage details.

        This document is made available by Sentry Insurance a Mutual Company and its subsidiaries and affiliates (collectively “SIAMCO”) with the understanding that SIAMCO is not engaged in the practice of law, nor is it rendering legal advice. The information contained in this document is of a general nature and is not intended to address the circumstances of any particular individual or entity. Legal obligations may vary by state and locality. No one should act on the information contained in this document without legal advice from competent and licensed local professionals. 40-165514001311 7/29/16

        Reducing the Risk of Combustible Dust

        December 14, 2015

        Provided by Grainger
        The presence of combustible dust, both in open and unseen areas, can present a grave hazard to employees, employers and facilities as explosions can be catastrophic in nature.

        Combustible dust, as defined by the Occupational Safety and Health Administration (OSHA), is “a solid material composed of distinct particles or pieces, regardless of size, shape or chemical composition, which can present a fire or deflagration hazard when suspended in air or some other oxidizing medium over a range of concentrations.” The presence of this dust, both in open and unseen areas, can present a grave hazard to employees, employers and facilities as explosions can be catastrophic in nature. An OSHA Fact Sheet, titled “Hazard Alert: Combustible Dust Explosions,” explains how dust explosions can occur.

        Five factors (oxygen, heat, fuel, dispersion and confinement) are known as the Dust Explosion Pentagon.

        “In addition to the familiar fire triangle of oxygen, heat and fuel (the dust), dispersion of dust particles in sufficient quantity and concentration can cause rapid combustion, known as deflagration. If the event is confined by an enclosure such as a building, room, vessel or process equipment, the resulting pressure rise may cause an explosion. These five factors (oxygen, heat, fuel, dispersion and confinement) are known as the Dust Explosion Pentagon (Figure 1). If one element of the pentagon is missing, an explosion cannot occur.”

        Combustible dust explosions typically occur in two waves. The first wave, also known as the primary explosion, starts with just the “right” concentration of airborne accumulated dust. This dust is held captive within a limited or enclosed space, such as inside the chamber of processing equipment. This captive dust then is subjected to a heat source, which causes the dust to ignite. The ignited dust can burn very rapidly and release gases, causing the pressure to rise within the enclosure, and can result in an explosion.

        Secondary explosions often are more destructive than primary ones because of the sheer volume and concentration of additional dust available to fuel them.

        Unfortunately, the first explosion usually is only the beginning. The primary explosion disturbs and shakes up dormant dust, which has collected over time on a variety of surfaces within the area. Some examples of these surfaces can be on top of or underneath machinery, ledges, rafters, duct work, inside suspended ceilings, on top of support beams, etc. The second wave, or secondary explosion, occurs as this additional dust becomes suspended in the air and also ignites. Secondary explosions often are more destructive than primary ones because of the sheer volume and concentration of additional dust available to fuel them (Figure 2).

        Many employers and employees are unaware of the potential threat of dust explosions or fail to recognize it as a serious hazard in their facility. In the Chemical Safety Board (CSB) video, “Combustible Dust: An Insidious Hazard,” Stephen Selk, a CSB investigator, says, “The big problem with combustible dust is that we underestimate its hazards. We become complacent and we fail to take the necessary precautions.” There also may be inadequate information available to help employers recognize a combustible dust hazard on their Safety Data Sheets (SDS). After reviewing the SDS of 140 substances known to create combustible dust, the CSB found they contained insufficient information to assist the end user in determining the hazard: 41 percent of the documents did not warn of the potential hazard at all, while the remaining 56 percent did not clearly or specifically describe the hazard in a way which was easy to identify (CSB, 2006).

        There is a long list of industries vulnerable to the hazard of dust explosions, including, but not limited to, the following: agriculture, chemicals, food (such as sugar, candy, spice, starch, flour, feed), grain, fertilizer, tobacco, plastics, wood, forest, paper, pulp, rubber, furniture, textiles, pesticides, pharmaceuticals, tire and rubber manufacturers, dyes, coal, metal processing (such as aluminum, chromium, iron, magnesium, zinc), recycling operations and coal.

        OSHA suggests completing an in-depth dust hazard assessment analyzing the following areas:

        • Materials that may be combustible
        • Processes that utilize any combustible dust
        • Open and especially hidden areas where dust may collect
        • Opportunities that may cause dust to become airborne
        • Any source of ignition

        The key to the hazard assessment is correctly identifying whether or not the dust is indeed combustible. The National Fire Protection Agency (NFPA) Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing and Handling of Combustible Particulate Solids (NFPA #654) and NFPA #454, Standard for Combustible Metals, Metal Powders and Metal Dusts, both define combustible dust as “any finely divided solid material that is 420 microns or smaller in diameter and presents a fire or explosion hazard when dispersed and ignited in air.” Other variables to consider, in addition to particle size, are how the dust will be dispersed, what kind of ventilation is available, air currents, sources of ignition and the presence of physical barriers to either provide dust confinement or which provide separation of work processes one from another.

        In addition to the hazard assessment, controlling and eliminating combustible dust also is critical. Per OSHA, the following are ways to mitigate combustible dust:

        • Create a program to inspect for and test for the presence of dust; implement housekeeping and control measures.
        • Use only appropriate dust collection systems and filters.
        • Recognize and eliminate fugitive dust, which may escape from process equipment or ventilation systems.
        • Reduce the amount of horizontal surfaces which may collect dust and require cleaning.
        • Regularly inspect for dust residue in hidden and open areas.
        • Provide access to hidden spaces to facilitate inspection.
        • Identify specific housekeeping practices close to ignition sources so dust clouds are not created.
        • Use only explosion-proof vacuum cleaners.
        • Do not place relief valves in close proximity to dust deposits.

        OSHA also provides several suggestions for controlling ignition sources, including the following:

        • Only utilize approved electrical and wiring equipment and methods.
        • Bond and ground equipment to the ground and control static electricity.
        • Control open flames, sparks, smoking and friction.
        • Segregate materials to prevent combustible material from work processes.
        • Put distance between heated surfaces/systems and dust exposure.
        • Follow proper operating instructions when using cartridge-activated tools.
        • Implement a preventative equipment maintenance program.

        The 2006 CSB investigative study concluded engineering controls and adequate safety practices exist in general industry to control combustible dust, but no comprehensive federal standard was in place to require adherence to these practices. The CSB advocated for OSHA to form a new combined standard based on the existing five NFPA standards (NFPA Standards 654, 664, 61, 484 and 655). In 2013, CSB voted to put this issue on its “Most Wanted Safety Improvements” program. The CSB has recommended the following codes be included in the proposed combined standard:

        • Hazard assessment
        • Engineering controls
        • Housekeeping
        • Building design
        • Explosion protection
        • Operating procedures
        • Worker training

        Grainger has the products, services and resources to help keep employees safe and healthy while operating safer facilities. It also provides a network of safety resources that help companies stay in compliance and protect employees from hazardous situations. Count on Grainger for lockout-tagout, fall protection equipment, confined space products, safety signs, personal protective equipment (PPE), emergency response and so much more. For more information, visit www.grainger.com.

        This publication is not a substitute for review of the applicable government regulations and standards, and it should not be construed as legal advice or opinion. Readers with specific compliance questions should refer to the cited regulation or consult with an attorney.

        Sources for information

        www.csb.gov
        Combustible Dust: An Insidious Hazard

        www.osha.gov
        OSHA Fact Sheet, Hazard Alert: Combustible Dust Explosions
        Hazard Communication Guidance for Combustible Dusts
        Combustible Dust
        Combustible Dust in Industry: Preventing and Mitigating the Effects of Fire and Explosions

        www.nfpa.org
        NFPA 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids
        NFPA 664, Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities
        NFPA 61, Standard for the Prevention of Fires and Explosions in Agricultural and Food Processing Facilities
        NFPA 484, Standard for Combustible Metals
        NFPA 655, Standard for Prevention of Sulfur Fires and Explosions (Rev. 5/2014)

        Full Implementation of Hazard Communication Standard Expected in 2016

        October 13, 2015

        PostPress

        Three years ago, the Occupational Safety and Health Administration (OSHA) aligned its Hazard Communication Standard (HCS) with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

        Once fully implemented in 2016, OSHA expects the changes will impact over five million facilities and over 40 million workers.

        HazCom 2012 provides a common approach to classifying chemicals and communicating hazard information on labels and safety data sheets (SDS). The definitions of hazard were changed to provide specific criteria for classification of health and physical hazards and for the classification of mixtures.

        Chemical manufacturers and importers now are required to provide a harmonized label that has six standardized elements for classified hazards, including product identifier, manufacturer contact information, hazard pictograms, signal word (DANGER or WARNING), hazard statements and precautionary statements.

        SDSs, previously known as Material Safety Data Sheets, remain the backbone of HCS. Employers must ensure they are readily accessible to employees. The major change here is a required, standardized 16-section format, which includes identification; hazard(s) identification; composition/ingredient information; first-aid measures; firefighting measures; accidental release measures; handling and storage; exposure control/personal protection; physical and chemical properties; stability and reactivity; toxicological information; ecological information; disposal considerations; transport information; regulatory information; and other information.

        To be compliant, an SDS needs all 16 sections; however, OSHA will not enforce sections 12-15, which fall outside its jurisdiction.

        For more information on complying with the standards, visit www.osha.gov/dsg/hazcom.

         

        Fall Protection and Hazard Communication Top OSHA’s List of Common Citations

        June 17, 2015

        by Jen Clark, PostPress

        According to a recent Occupational Safety and Health Administration (OSHA) report, “Adding Inequality to Injury: The Costs of Failing to Protect Workers on the Job,” the Bureau of Labor Statistics (BLS) found “approximately 4,500 workers are killed on the job each year … and that employers record nearly three million serious occupational injuries and illnesses annually.” These records are mandated by a nearly 40-year-old legal obligation to provide safe workplaces.

        The Occupational Safety and Health Act of 1970 required employers to provide workplaces “free from recognized hazards that are causing or likely to cause death or serious physical harm.” OSHA inspectors cite thousands of companies for unsafe working conditions every year, usually resulting in costly fines. OSHA annually provides a list of the Top 10 violations for the fiscal year during the National Safety Council Congress and Expo, which took place in San Diego, California, last September. For the fourth year in a row, OSHA’s Fall Protection Standard (1926.501) was the agency’s most frequently cited violation (6,143 violations), followed by hazard communication (5,161 violations) and scaffolding (4,029 violations).

        For owners and managers, knowing about these violations can help them assess their companies’ risk potential, which could help avoid business disruption, citations and/or fines.

        1. Fall Protection

        OSHA requires that fall protection be provided at elevations of 4′ in general industry workplaces, 5′ in shipyards, 6′ in the construction industry and 8′ in longshoring operations. In addition, fall protection should be provided when working over dangerous equipment and machinery, regardless of the fall distance. Appropriate fall protection gear can include railings, personal fall arrest systems or warning lines.

        2. Hazard Communication

        In 2012, OSHA revised its Hazard Communication Standard, aligning it with the United Nations’ global chemical labeling system. It will be fully implemented in 2016, with the goals of reducing confusion about chemical hazards in the workplace, facilitating safety training and improving understanding of hazards. Employers should identify and evaluate all chemical hazards in the workplace and then make that information readily available to all employees through safety data sheets. Keeping an up-to-date list is just as important as having one. Training also is a key component of the HazCom standard (see sidebar for more information).

        3. Scaffolding

        Established guidelines help protect employees who are working on or near elevated, temporary work platforms at heights of 10′ or more. OSHA noted that a big problem is people using scaffolding as ladders and ladders as scaffolding, assuming one could work for the other. Other problems include holes in platforms, not having an adequate point of access, lack of fall protection and not having a competent person assigned to select and direct employees, asses the weather, train employees, inspect scaffolding and determine if scaffolding is structurally sound.

        4. Respiratory Protection

        Air quality or breathing hazards – such as dust, fumes, gases, mist, sprays and vapors – may require the use of respiratory protection either with a respirator or dusk mask. Respirators protect the user in one of two basic ways – by removing contaminants from the air or supplying clean air from another source. Employers must have a written program to show how they are implementing various parts of the standard.

        5. Powered Industrial Trucks

        Powered industrial trucks, commonly called forklifts or lift trucks, are used in many industries, primarily to move materials. Employers must ensure that each powered industrial truck operator is trained and competent to operate a powered industrial truck safely. No one under the age of 18 is allowed to operate a forklift. Training must be provided for each type of equipment the company operates.

        6. Lockout/Tagout

        According to OSHA, nearly 200 workplace deaths occur each year because hazardous energy hasn’t been controlled during routine maintenance or machine servicing. Proper lockout procedures help prevent the accidental startup of machinery. There are nine steps to a general lockout/tagout procedure.

        1. Prepare for shutdown
        2. Notify others
        3. Shut down the equipment
        4. Isolate the equipment
        5. Lockout/tagout the equipment
        6. Release stored energy
        7. Verify isolation
        8. Perform service
        9. Release from lockout/tagout

        7. Ladders

        Similar to the fall protection standard, ladders only should be used for what they are designed for and must extend 3′ above the upper landing surface. OSHA prohibits ladder use as a walking platform or lifting device. Ladders also must be in good shape.

        8. Electrical: Wiring

        Dangers such as electric shock, arc flash, electrocution, fires and explosions are possible. To help avoid potential violations, inspect wiring and insulation, plus take steps to ensure proper grounding of electrical equipment.

        9. Machine Guarding

        Guard the machinery to help protect operators and others from hazards, such as rotating parts, flying chips, sparks and other dangers. OSHA uses the 1910.212 standard to cite employers for lack of guarding on several types of equipment.

        10. Electrical: Systems Design

        Stay in compliance and avoid workplace injuries by following factory instructions when designing, installing and using electrical equipment. Using equipment in the workplace that only has been labeled or listed for home use is an OSHA violation.


        Full Implementation of Hazard Communication Standards Expected in 2016

        Three years ago, the Occupational Safety and Health Administration (OSHA) aligned its Hazard Communication Standard (HCS) with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Once fully implemented in 2016, OSHA expects the changes will impact over five million facilities and over 40 million workers.

        HazCom 2012 provides a common approach to classifying chemicals and communicating hazard information on labels and safety data sheets (SDS). The definitions of hazard were changed to provide specific criteria for classification of health and physical hazards and for the classification of mixtures. Chemical manufacturers and importers now are required to provide a harmonized label that has six standardized elements for classified hazards, including product identifier, manufacturer contact information, hazard pictograms, signal word (DANGER or WARNING), hazard statements and precautionary statements.

        SDSs, previously known as Material Safety Data Sheets, remain the backbone of HCS. Employers must ensure they are readily accessible to employees. The major change here is a required, standardized 16-section format, which include identification; hazard(s) identification; composition/ingredient information; first-aid measures; firefighting measures; accidental release measures; handling and storage; exposure control/personal protection; physical and chemical properties; stability and reactivity; toxicological information; ecological information; disposal considerations; transport information; regulatory information; and other information. To be compliant, an SDS needs all 16 sections; however, OSHA will not enforce sections 12-15, which fall outside of its jurisdiction.

        For more information on complying with the standards, visit www.osha.gov/dsg/hazcom.

        OSHA Releases New Resources on Hazardous Chemicals

        December 13, 2013

        The US Department of Labor’s Occupational Safety and Health Administration has launched two new web resources to assist companies with keeping workers safe.

        The first is a toolkit to identify safer chemicals that can be used in place of more hazardous ones. The toolkit walks employers and workers step-by-step through information, methods, tools and guidance to either eliminate hazardous chemicals or make informed substitution decisions in the workplace by finding a safer chemical, material, product or process.

        Another new web resource, the Annotated Permissible Exposure Limits, will enable employers to voluntarily adopt newer, more protective workplace exposure limits. OSHA’s PELs set mandatory limits on the amount or concentration of a substance in the air to protect workers against the health effects of certain hazardous chemicals; and OSHA will continue to enforce those mandatory PELs.

        Since OSHA’s adoption of the majority of its PELs more than 40 years ago, new scientific data, industrial experience and developments in technology clearly indicate that in many instances these mandatory limits are not sufficiently protective of workers’ health.

        For more information, visit www.osha.gov.

         

        Building a Defense for Your OSHA Compliance

        May 20, 2013

        by Rick Hartwig, Printing Industries of America

        The Occupational Safety and Health Administration (OSHA) never can announce an enforcement inspection ahead of time, but it does provide a host of indicators that can be used to predict the chances of an inspection. OSHA collects a vast amount of data on specific industry sectors that are used in part to develop materials such as compliance directives, emphasis programs and injury and illness trends, among others. Combined, this collection of information paints a picture for a particular industry or sector as to OSHA’s focus, and therefore, probability of being selected for an inspection. For companies within the printing and printing-related sectors of manufacturing, the probability for enforcement inspections is high. Ultimately, (OSHA) has the legal authority to develop and issue standards and enforce those standards through on-site inspections.

        What Triggers an OSHA Inspection?

        OSHA inspections occur for a number of reasons such as a programmed inspection policy, employee complaints, other agency referral, the Site Specific Targeting (SST) program or through self-reporting requirements.

        Programmed inspections are the result of OSHA’s emphasis programs, which are designed to address specific hazards or industries with particular risks and are the main trigger for inspections these days. These could be either local emphasis programs (LEP) or national emphasis programs (NEP). While there are several programs concerning General Industry, the two main NEPs impacting the postpress industry include the Amputation NEP (addressing injury potential associated with running certain equipment) and the Combustible Dust NEP (addressing fire and explosion hazards associated with paper dust generated within the bindery operations). Employee complaints remain the second largest reason for enforcement inspections to occur. The Site Specific Targeting (SST) program is a database of injury and illness data collected by OSHA through a survey of companies, and it identifies companies that have higher than average injury or illness rates. Both states following the Federal OSHA plan and those with OSHA-approved state plans are required to implement a targeting system. Agency referrals occur via first responders, police, fire rescue or others that report to a company incident because of an accident or emergency. Self-reporting of accidents or fatalities are self-explanatory.

        Understanding Inspections

        Those involved in the printing industry need to recognize and treat compliance of OSHA standards as a true legal issue that has the potential for legal action. Days or weeks prior to an inspection, OSHA begins to make its legal case by collecting information about the company and continues this effort throughout the inspection process. This can include records of previous violations, corporate structure of the company, operations performed at the company, equipment used and applicable industry standards. OSHA will be working to prepare a case that would hold up in court if necessary. Will your compliance program?

        Once at the facility, OSHA will hold an opening conference and then begin the physical inspection, which will include a records review of injuries and illnesses forms, a facility tour, photographs, written notes and confidential employee interviews. A closing conference is held at the end of the inspection process, which can be anywhere from a few hours to a few weeks depending on the circumstances or scope of the inspection. Finally, the Area Director for OSHA will determine whether any citations should be issued and assess the appropriate penalties.

        If citations are issued and a notice of penalty is issued, there are opportunities for discussion to clarify or contest either a citation or penalty; however, a company’s best chance of success is with a fully compliant safety program already established.

        What are some of the core materials to have developed for compliance?

        • Written programs
        • Company policies and guidelines
        • SOPs
        • Sampling/test results
        • Audits and assessments
        • Medical records
        • Injury and illness recordkeeping
        • Accident investigation reports
        • Training records
        • Discipline records

        In order to be sure a company is in compliance, the company must have a strong knowledge and understanding of the applicable OSHA regulations. There are over 130 general industry rules that could apply to postpress operations. Some of the regulations have very specific elements that often are overlooked and cause increased and unnecessary citations to be issued. Further, to effectively defend the company’s compliance program, an understanding of all supporting evidence is needed. This can include letters of interpretation, OSHA directives, case law precedence, compliance strategies, ANSI standards, ISO standards, NFPA standards and much more. An OSHA inspection can be well-managed if the facility understands the scope of the inspection, has a compliance program in place and understands which regulations do and do not apply. Effectively communicating the compliance program to all employees and having documentation to support the safety program that was implemented can go a long way toward ensuring compliance and making it through the OSHA inspection process.

        The Best Offense is a Good Defense

        A review of 100 companies cited by OSHA showed that 58 percent had not developed a required compliance program. Of those with a compliance program, 71 percent were found to be generic, missing several key elements and/or seriously inadequate. Eighty-two percent of those with generic programs were unaware of any of the standard requirements. The citations and penalties associated with these companies easily could have been avoided.

        A commitment must be made to ensure OSHA compliance. The first step toward that commitment is assessment. Inventory your facility and operation; find out what is actually occurring and measure this against the regulations. Initial development of a compliance program cannot begin without support from all levels of employees, so seeking staff input is vital. Additionally, compliance requirements must be woven into everyday business operations and should be handled just like any other personnel matter in order to be effectively maintained and monitored.

        Compliance does not have to be “THE” priority, but it must be “a” priority. A leader must be appointed to walk the company through the requirements, and that leader should be given thorough training and support.

        As previously mentioned, all employees should be involved in compliance efforts. Explain the need for compliance and ask for input from the front-line employees. Find ways to combine OSHA requirements with everyday procedures, and make those procedures consistent throughout the facility. Then maintain oversight, whether through safety committees, production meetings or scheduled walk throughs of the facility. Violations should be addressed with consistent and fair disciplinary measures that demonstrate – both to the employees and potential OSHA inspectors – that compliance is active and a priority.

        Remember, inspections cannot be prevented, but preparation can greatly improve the outcome.

        Rick Hartwig is manager, Environmental, Health and Safety Affairs at Printing Industries of America. With over 27 years’ experience within the printing industry, he has been directly involved with operations management, regulatory compliance and sustainability. In his capacity, Hartwig works closely with all regulatory agencies on addressing related EHS issues at the federal, state and local levels. Hartwig provides assistance to print members, including regulatory and standard interpretations, industry representation, enforcement and penalty engagement, sustainability consultation, facility and operation assessments and compliance program reviews. For more information, visit www.printing.org.

        CPSIA and Its Implications for Binderies

        February 1, 2010

        by: Staff

        Recently, a conversation on the BIA listserv revolved around the Consumer Product Safety Improvement Act (CPSIA), lead and phthalate testing, and its applicability to binders. The responses indicated that not all binderies are clear as to the testing requirements and the manner in which the requirements will affect their business. Lead and phthalate testing and certification requirements were due to become mandatory on Feb. 10, 2010; however, after a petition was submitted by Printing Industries of America, the Consumer Product Safety Commission (CPSC) granted an additional one-year stay to Feb. 10, 2011. Even though the one-year stay was granted for testing and certification, the core requirements of not selling a product that exceeds the lead and/or phthalate limits remain in effect. In addition, the stay does not impact any painted product such as coil for a coil-bound book.

        At this time, it would be wise for binderies to prepare to meet the testing and certification requirements of the act.

        What is CPSIA?

        In August 2008, the U.S. Congress established safety standards for children’s products under the Consumer Product Safety Improvement Act. The act establishes several key requirements regarding the safety of children’s products, including limits for lead and phthalates, a requirement that manufacturers and importers test and certify that their products meet the limits using accredited third party labs, and imposes tracking labels for products.

        The current lead limit for non-painted products is 300 parts per million (ppm). The limit for paint is 90 ppm. The phthalate limits are 0.1 percent di-(2-ethylhexyl) phthalate (DEHP), dibutyl phthalate (DBP), or benzyl buty phthalate (BBP) and an interim prohibition on children’s toys that can be placed in a child’s mouth or child care articles containing more than 0.1 percent diisononyl phthalate (DINP), diisodecyl phthalate (DIDP), or di-n-octyl phthalate (DnOP).

        As of August 14, 2009, tracking labels or “permanent markings” on children’s products are now required to facilitate recalls. The label or permanent mark must contain core information or at least provide enough information (such as company name and address) that would allow a consumer to “ascertain” the core information. The core information is the identification of the manufacturer, date of manufacturing, location of manufacturing, and cohort information such as batch or lot number.

        As can be imagined, the publishing industry reacted strongly to the CPSIA and questions are still arising as to its implications for printers and binderies. The full text of the CPSIA can be found at http://www.cpsc.gov/cpsia.pdf.

        Are Any Products Exempt from Testing?

        As noted, the testing requirements were granted an additional one-year stay and are now taking effect in February 2011. Binders need to be aware of their responsibility in regard to compliance for the individual components that are used to make a children’s printed product (e.g., paper, inks, binding components).

        On Aug. 26, 2009, the CPSC acted on a petition by the Printing Industries of America, granting a permanent exemption from testing and certification for the following items:

        • Paper
        • Any product printed with four-color process inks (CMYK)
        • Any product coated with varnish, water-based, or UV-cured coatings
        • Threads used for book binding
        • Animal-based glues
        • Adhesives that are not accessible
        • Binding materials that are not accessible

        The items that have not received an exemption are as follows:

        • Spot or PMS inks
        • Saddlestitching wire
        • Non-animal-based glues that are accessible
        • Metal coils, both coated and uncoated, for coil bound materials
        • Plastic coils for coil bound materials
        • Foils used in foil stamping
        • Laminates

        Since many of the materials that have not received an exemption are critical components of books and other printed matter, any product that contains a non-exempt component will have to be tested and a certificate issued for the product. Work continues with the CPSC to gain an exemption for the products that are not currently exempt.

        How Does CPSIA Affect Children’s Books?

        In the Frequently Asked Questions section of the CPSC website, the following question was posed:

        Does the new requirement for total lead on children’s products apply to children’s books, cassettes and CD’s, printed game boards, posters, and other printed goods used for children’s education?

        In general, yes. CPSIA defines children’s products as those products intended primarily for use by children 12 and under. Accordingly, these products would be subject to the lead limit for paint and surface coatings at 16 CFR part 1303 (and the 90 ppm lead paint limit effective Aug. 14, 2009) as well as the new lead limits for children’s products containing lead (600 ppm lead limit effective Feb. 10, 2009, and 300 ppm lead limit effective Aug. 14, 2009). If the children’s products use printing inks or materials which actually become a part of the substrate, such as the pigment in a plastic article, or those materials which are actually bonded to the substrate, such as by electroplating or ceramic glazing, they would be excluded from the lead paint limit. However, these products are still considered to be lead-containing products irrespective of whether such products are excluded from the lead paint limit and are subject to the lead limits for children’s products containing lead. For lead-containing children’s products, CPSIA specifically provides that paint, coatings, or electroplating may not be considered a barrier that would render lead in the substrate inaccessible to a child.

        What are Coil Manufacturers Doing to Meet CPSIA Requirements?

        Anna Massey, sales and marketing manager for Gateway Bookbinding Systems, Ltd., explained the process the company went through to confirm that its PLASTIKOIL binding is lead- and phthalate-free: “When the legislation was originally initiated, we immediately went to work with our base resin and colorant suppliers. We already knew that our PVC base compound was lead-free and phthalate-free, because it is actually a food-grade compound. However we still had our compound supplier confirm through accredited lab testing that the material was well within the To assist its binder partners, Gateway keeps all lab testing and accreditation on file and available upon request. All of its PLASTIKOIL coil and filament customers are provided Certificates of Conformity, offering assurance that Gateway’s products meet the CPSIA standards.”

        Matt Roth, vice president for Spiral Binding Co./James Burn, explained that the certification process was relatively simple, albeit expensive. The company knew compliance would be critical to its customers since it was a wire-bound book that started the original lead scare in the United States. “Not only do we support the nation’s cause to make sure our children’s books are bound safely, we viewed this as an opportunity to distinguish ourselves and our bindery partners from those using low-priced imported wire that might not be CPSIA-compliant and lead- and phthalate-free,” he said. “With certification on file, our bindery partners can feel confident using our products in their operation and can prove to their customers that the binding elements they use in their books are safe.”

        For links to additional CPSIA information, including The Printing Industries of America’s CPSIA Resource page, visit www.thebindingedge.com.

        Additional Resources:
        Due to the complexities and ever-changing interpretations of CPSIA, printers and binders should monitor the CPSC website for amendments to the Act at http://www.cpsc.gov/ABOUT/cpsia/cpsia.HTML#whatsnew.

        The Printing Industries of America also has created a CPSIA Resource Page, which can be found at http://www.printing.org/page/4344.

        To access the CPSIA Frequently Asked Questions section, visit http://www.cpsc.gov/about/cpsia/faq/101faq.html.

        Additionally, the CPSC website contains a statement from the General Counsel Advisory regarding books and the CPSIA: http://www.cpsc.gov/library/foia/advisory/323.pdf

        Thank you to Gary Jones, director of Environmental, Health & Safety Affairs, Printing Industries of America, for his valuable input.

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