My name is Deontaye Chisholm and I run and own Safety Comes First Consultants. I have been contacted by a local welding company that has just been issued several serious safety citations for violating 29 CFR 1910.252 (a) (2) (iii) (B) and 29 CFR 1910.252(b) (2) (i) (A). My service has been retained and I have scheduled a meeting with management to discuss an immediate action plan to implement corrective actions at their facility.
I open up the meeting with a brief introduction of my company’s history and my background in the safety field. After the introduction I get down to business, I go into deliberation about the violations. I explain to the management team that the fines accumulated from the violations can be negotiated in hearing. I advised them that a considerable reduction could be negotiated if the company implemented corrective measures that could reduce or eliminate the hazards that there company was fined for.
I introduced the management team to a proven system management system called the PDCA The Plan-Do-Check-Act concept. (pg. 36) I break down the concept so that it easily understood what type of transformation that I am going to take their company through. The PDCA processes, as follows: Plan: Establish the objectives and processes necessary to deliver results in accordance with customer requirements and the organization’s policies. Do: Implement the Processes
Check: Monitor and measure processes and product against policies, objectives, and requirements for the product and report the results. Act: Take actions to continually improve process Performance.
Now that management is aware of the process plan it’s time to put it to action. It’s now time to discuss there violations and the reason why they were fined. 29 CFR 1910.252 (a) (2) (iii) (B) is the code regulation for Firewatchers. The managers begin to tell me that have not been using firewatchers when they conduct hot work in their facility. I explain to them that this is an OSHA requirement that requires appropriate trained and competent firewatchers. I explain that firewatchers shall be required whenever welding or cutting is performed in locations where other than a minor fire might develop. (1910.252 (a) (2) (iii) (B) I advised them there company had to implement a fire watch training program where documentation and certification of training will be maintained.
29 CFR 1910.252(b) (2) (i) (A is the code regulation is for wearing the proper PPE when conducting hot work. The order states Helmets and hand shields shall be used during all arc welding or arc cutting operations, excluding submerged arc welding. Helpers or attendants shall be provided with proper eye protection. I advised management that welders and helpers must be trained on how to properly wear and maintain proper ppe until the job is completed.
Action plan: Trained firewatchers will be trained and be accessible whenever hot work is to be conducted inside of the facility. A new hot work permitting system will be put in place that will require approval and signature from the general manager and safety officer. Once the safety officer receives the hot work permit, the officer will be required to assess the work area where the hot work will be done. A check list on the hot work permit will need to be verified by the safety officer before the permit is signed off on. This check list will require that a certified fire watch be present with credentials, and that fire extinguisher within 10 ft of were the work will be done is onsite. The area has to properly inspected to ensure the area is free of debris, wood shavings, textile fibers or any type of object that can present a fire hazard. A ppe checklist must be reviewed and approved onsite in order for the approval of the permit. The fire watch shall remain 30 minutes after the work is done to ensure that no smoldering fire may occur after completion of the hot work.
After implementation of these new policies and procedures management and the safety officer will observe and complete an assessment of how effective to new process is. The continual improvement of the process will be implemented and monitored to assure a safe and effective hot work safety program.
Fred A. Manuele (2008) Advanced Safety Management: Focusing on Z10 and
Serious Injury Prevention, an Overview of Ansi/AIHA Z10 2005 , 35,36 Mancomm (2011)29 CFR 1910 OSHA General Industry Regulations