Industrial & Specialty Printing - July/August 2012 - 13

Establish a meeting schedule with set agendas. All meeting notices should be publicly announced and minutes and outcomes prominently displayed. For the committee to be effective, its actions and outcomes need to be transparent and visible to all employees. It is also critical that the committee establish a formal communication system that both informs and solicits ideas from the rest of the employees. A note of caution regarding the person delegated to run the safety committee: It is important that whoever you choose to run the committee understand the safety regulations that apply to your facility. This may require that additional outside training be acquired. The knowledge base must be present to develop a program to maintain compliance. If this is not an option, then it is recommended that you bring in an outside expert to help you identify your compliance issues and develop, if necessary, a safety program. The first step for any safety committee is to conduct an assessment of your facility’s compliance status. It is up to you to make the decision how to accomplish this goal. You cannot begin to correct problems if you do not have a process in place to identify the hazards. your safet y program Completion of your in house safety and health audit provides you with the framework for moving forward with implementation of your safety program. Your audit results will identify the gaps that you have in the safety compliance arena. The next step is to fill those identified gaps with the proper steps and policies. Your audit should cover the core issues of training elements, written programs, and recordkeeping associated with each standard. For some standards, such as ladder or electrical safety, the requirements are very specific as to what needs to be accomplished in the workplace. The diversity and breadth of the regulations is yet another reason to ensure that the audit is conducted by a person who has both the familiarity and knowledge of the regulations involved. To gain a better understanding of the process, let’s take a look at several of the most misunderstood regulations, and outline how one can proceed. As mentioned earlier, the Hazard Communication Standard is still the most

often violated standard. There are several key components that all workplaces must follow. All employees must be trained regarding the hazards of the chemicals used in the workplace. And, you must have a program in place that trains all new hires regarding these hazards. Facilities must develop and maintain an in-plant labeling program for containers that are used in the workplace. Called secondary container labeling, the requirement is fairly straightforward. If an employee is provided with a container of ink for use, then the container does not need to be labeled as it is assumed that the employee was trained regarding the hazards associated with that chemical. However, if a second employee uses the same container, then it must be labeled. You can begin to see how training plays a critical role in compliance with this standard. Employees must also receive training on how to read and understand the Material Safety Data Sheets (MSDS). These sheets must be maintained in the area in which they are used. Again, training is key. Finally, the facility must maintain a list of hazardous chemicals found in the workplace as well as a written hazard communication program. And, it is recommended that a list of all training activities be established including dates and employees. Establishing this recordkeeping trail is critical as OSHA inspectors have been known to ask employees about training exercises. Records can help establish the validity of your efforts. To be in compliance with the Hazard Communication requirements, your facility will need the following key elements: training program for current and new hires; a training schedule that includes an annual refresher for all employees; training records; system for identifying new hazards that enter the workplace (as this would necessitate training regarding this new hazard); copies of all MSDS located in their relevant areas; a list of all hazardous chemicals; and a written hazard communication plan. Do you have all these key program elements in place? Do you need to make any adjustments? Once all information has been gathered, the safety committee can make recommendations regarding any necessary improvements. Let’s take a look at another area, specifically the use of powered industrial trucks,

also known as forklifts. This standard, amended in 1999, requires that all operators be trained in the use of the equipment. It is a violation of Federal law for anyone younger than 18 years of age to operate a forklift or for anyone older than 18 years of age who is not properly trained and certified to do so. Many manufacturers provide training programs that are specific to their equipment. It is recommended that you check with your manufacturer for available programs as the training needs to be specific to the type of truck that you use in your facility. Refresher training should be conducted every three years or if involved in an accident or near miss accident, if a new truck is being used, or if the driver is operating in an unsafe manner. For this program, there is no requirement to develop a written program nor to maintain records. However, it is recommended that you do maintain training logs that include name of employee, equipment as well as the date trained. To be in compliance with the powered industrial truck standard, your facility will need to implement a training program specific to each type of vehicle used in your facility. It is recommended that you maintain training logs to establish your compliance status. The question again is where you stack up vis-á-vis this important safety regulation. Are you maintaining records? Do you need to maintain records? Have all operators been trained by a knowledgeable expert? The safety committee plays a key role in recommending necessary changes as well as evaluating the status of the current program. ConClusion Implementing a safety and health program should not be seen as a luxury, but as a necessity for any manufacturing operation. Providing a safe work environment can result in lower worker’s compensations costs as well increased staff morale. Developing an effective safety and health program takes time and commitment but it is a worthy investment.

SGIA

marCia y. Kinter

marcia y. Kinter is vice president, government and business information, for the specialty graphic imaging association, fairfax, Va. July/august 2012 | 13

Industrial & Specialty Printing - July/August 2012

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