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A Personal Experience With a Plant Safety Inspection

By Tom Weber

May 17, 2024

After receiving several member inquiries about plant safety inspections, the use of a third party to do so objectively, and preparation for an Occupational Safety and Health Administration (OSHA) inspection, I thought I would share below what I orchestrated while leading a privately held folding carton and blister card company in Northeast Ohio.

We expected an unannounced OSHA inspection due to a workplace injury that resulted in a partial finger amputation from a drug-impaired employee, who was treated and then summarily terminated under our company drug testing for cause policy.

The inspection was performed based on the Safety Plus program, a free Council of Smaller Enterprises service to small Ohio-based businesses. This report details inspection findings and a list of recommendations. It also provides examples of safety and health hazards for future employee trainings and demonstrates what you could possibly expect, in the form of violations, after an on-site OSHA inspection.

The identified conditions in this report are those that might be addressed during an OSHA inspection and may be considered safety hazards. This safety inspection was performed as a service and is inten ded to be used as a tool to improve your company’s health and safety.

OSHA inspections are initiated by one of the following and are prioritized in the order presented:

  • Imminent danger
  • Catastrophes and fatal accidents
  • Employee complaints
  • Programmed high-hazard inspections
  • Follow-up inspections

Of these inspection priorities, our industry would be most susceptible to employee complaints. Sometimes, disgruntled employees contact OSHA after a discordant separation.

Top 10 Carton Plant Inspection Areas

1. Emergency Action Plan

  • There is an emergency action plan in place.

2. Material Handling and Storage

  • Production paper rolls were mostly stored properly in a horizontal position.
  • Some production paper rolls were stored in a vertical position with no roll chocks to prevent the rolls from moving and potentially causing a crushing injury.
  • The facility flammables storage room was appropriately maintained and included sill construction, an Ansul system, bonded containers, and a fire door.
  • The ink room and flammables storage room were equipped with a combustible gas (LEL monitor) and a Magnehelic pressure gauge.
  • The maintenance room was cluttered and difficult to get around. In addition, a large number of flammables were stored on shelves, not in a flammables cabinet.

3. Fire Prevention and Protection

  • Fire extinguishers are inspected and tagged annually.
  • Fire extinguishers are also inspected monthly.

4. Hazard Communication

  • A hazard communication program is implemented and includes Globally Harmonized System of Classification and Labeling of Chemicals (GHS) requirements and the proper labeling of secondary containers.
  • Material data safety sheets (also referred to as safety data sheets) were available for review.

5. Machine Guarding

  • Multiple machine-guarding deficiencies were observed.
  • Potential pinch points were observed.
  • The guards are insufficient; worker can reach under and/or around the device.
  • Foot pedal must be independent of the two-handed operation.
  • Multiple pinch points on the folder were observed.
  • The guards are compromised.
  • Gates provide some protection, but much of the folder has open pinch points.

6. Forklifts

  • Operators have been trained, certified, and evaluated per OSHA standards.
  • Manuals are not present on all of the forklifts.
  • Pre-use inspections are not being performed.
  • Paper roll clamp attachment is not reflected on the forklift data plate.
  • Propane fuel tanks are not properly secured to the vehicles.
  • This inspector observed a truck pull into the loading dock. The leveler was placed, and the employee began loading with a motorized pallet jack without the trailer wheels being chocked. The employee stated they had training within the past three months.
  • Open hatches present thermal hazard. If the hatch must remain open, install a screen or cage.

7. Electrical

  • Electrical panel not labeled with appropriate arc-flash personal protection equipment (PPE) per National Fire Protection Association (NFPA) 70E requirements.
  • Damaged extension cord should be taken out of service.
  • Uncovered electric junction box has energized conductors outside the box.

8. Confined Space

  • A confined space assessment has not been done and any confined spaces labeled as such.

9. First Aid

  • Eyewash stations must be properly maintained and inspected on a weekly basis.
  • Temporary eyewash solution was expired and must be replaced to prevent added injury.

10. Miscellaneous

  • Abrasive wheel grinder is not properly guarded or maintained.
  • It appears voluntary use of ear protection is allowed. However, this inspector concluded noise monitoring should be performed based on a noncalibrated sample.

Inspection-Specific Recommendations

Material Handling and Storage

  • Provide shocks for vertically stored or moved paper rolls.
  • Continue the policies relative to the flammables storage room.
  • Develop a housekeeping plan for the maintenance area and provide a flammables cabinet for storage.

Hazard Communication

  • Develop and implement a written hazard communication program, which includes GHS updates.
  • Enforce the proper labeling of secondary containers.

Machine Guarding

  • Perform a complete machine-guarding assessment and properly guard all machines.

Forklifts

  • Acquire forklift manuals and keep them on the forklifts.
  • Ensure daily inspections are being performed, and the inspections are documented and retained for record-keeping purposes.
  • Contact the forklift manufacturer and get approval and updated data plate for the paper roll clamp attachment.
  • Retrain or refresh forklift operators on the OSHA requirements for powered industrial truck operators, especially related to the refueling of propane-powered vehicles and the loading of semitrailers and rail cars.

Electrical

  • Mark electrical panels with appropriate arc-flash PPE per NFPA 70E.
  • Remove the damaged extension cord from service.
  • Cover or eliminate the open electric junction box.

Confined Space

  • Perform a confined space assessment and label any spaces identified as such.

First Aid

  • Develop and implement a weekly eyewash station inspection and maintenance program.
  • Replace the expired eyewash solution.

Miscellaneous

  • Adjust the guards for the abrasive wheel grinder to the correct distances—one-eighth of an inch from the wheel for the tool rest and one-quarter inch for the tongue guard.
  • Perform noise monitoring to ensure the facility falls under the OSHA 85dB trigger point for hearing protection program.

To Summarize

This inspection focused primarily on hazards identified on the day of the inspection and is not intended to be a comprehensive review of your overall annual health and safety program.

A total of eight (plus the number of machines on-site with improper guarding) potentially serious violations had been found. A serious violation is one in which there is substantial probability that death or serious physical harm could result and the employer knew, or should have known, of the hazard. A penalty of up to $7,000 for each violation is proposed.

Other than serious violations are those that have a direct relationship to job safety and health but probably would not cause death or serious physical harm. A proposed penalty of up to $7,000 for each violation is discretionary. A typical other than serious violation penalty would be $1,000 or less.

This report was completed to assist my company in understanding the types of citations we could have received from an OSHA inspection, which indeed did take place two months later as luck would have it. (Note: This report in no way reflects the opinions or positions of OSHA.)

I hope sharing this inspection report stimulates some of our readership to evaluate your plant safety programs and processes to make certain significant and long-lasting improvements are continually being made, just as you all do to your quality processes for all employees and clients involved.

Hats off to a safe and productive second half of 2024!


Tom Weber is president of WeberSource LLC and is AICC’s folding carton and rigid box technical advisor. Contact Tom directly at asktom@AICCbox.org.

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