It's no secret that many transportation professionals might consider an OSHA visit about as likely as a visit from Santa Claus. After all, your greatest concern in terms of regulations and compliance is the Department of Transportation, not OSHA.
If you are one of those people, you are certainly not alone; but $156,000 says that I can change your mind by the end of this blog.
I hear this statement all the time: "OSHA is for factories, and DOT is for semis." While true to a certain extent, I usually follow up by asking if the company does its own maintenance on its rigs. If the answer is yes, OSHA should be on your radar.
Case in point: a trucking company based in Louisiana recently had an OSHA inspection that it was not prepared for. OSHA found more than 25 serious violations and one willful violation. Fines for willful or repeat violations can be as high as $70,000, and fines for serious violations can be as much as $7,000. The total value of these OSHA citations? You guessed it, $156,000.
$156,000. I think it is fair to say that most transportation companies don't want to be throwing that kind of money out the door over violations that can (and should) be cleared up long before a compliance officer shows up.
The shortcomings that were discovered at the Louisiana facility give us an opportunity to learn from others' mistakes. How often do you discuss fall protection with your maintenance teams? Not often? What about never? It's time to start.
Where is the need for fall protection in a mechanic's shop? In general industry, any time an employee is working from a height where the next lowest level is lower than 48 inches below the current working surface, some means of fall protection is required. Now consider two of the most common exposures I've seen inside trucking companies:
Both of these scenarios produce a fall potential of greater than 4 feet. Subsequently, both are hazards and citable OSHA violations where some type of fall protection must be implemented. A guardrail system might be the best option for the mechanic's pit, while a horizontal lifeline might work as fall protection for the roof repair work.
Have you ever considered the value of your pedestal grinders to be $10,000? This is the approximate post-inspection value of the abrasion wheel at the violation-plagued Louisiana trucking company.
Abrasion wheels have guards that must be constantly adjusted to meet standard. The tool rest must be within 1/8-inch to the wheel and the tongue guard must remain within 1/4-inch. Keep in mind that every time the wheel is used it gets smaller, so continuous adjustments must be made. This company failed to do so with both guards, resulting in a $5,000 citation for each. And there you have your $10,000 pedestal grinders.
Fire safety is a real concern from a practical standpoint and in terms of avoiding OSHA fines. Transportation companies must prepare emergency action plans for each facility, including designating unlocked emergency exits that are properly illuminated and clear of all obstructions. Remember that something as simple as a framed welding curtain blocking the emergency exit can and will be considered an obstruction hazard.
Improper use of extension cords or other temporary wiring can pose a fire hazard and will be considered citable OSHA violations. It's not uncommon to have a plethora of extension cords or flexible wiring in our shops, but extension cords are designed to be a temporary solution and should never be used as permanent wiring.
In addition, extension cords or other flexible wiring should never be run through any type of doorway or wall opening that could close on the cord and diminish the integrity of its insulation. (Have your vending machines plugged in via flexible wiring that originates out of the only available outlet in the bathroom? I'm talking to you.)
The last one out gets the lights, right? But how are those lights turned off? If the answer is, "the breaker switch in an electrical panel is used as an on/off switch," we have a problem. OSHA describes this hazard as, "listed or labeled electrical equipment not being used or installed in accordance with instructions included in the listing or labeling." I am sure this comes as a bit of a shock (no pun intended) but the circuit panel's cover serves as the first line of defense from an arc flash, and there should be some means of turning the lights on and off without exposing the circuits.
Get things right before OSHA shows up, not after your are cited for a violation. We've prepared a guide to help you prepare for an OSHA inspection, as well as OSHA-focused toolbox talks you can use with your team.