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Avoiding OSHA Issues: Implement a Sound Safety Plan

By Frank Dunn

Nearly 4,900 workers were killed on the job in 2014, according to the Occupational Safety & Health Administration (OSHA). When operating institutional and commercial facilities, it is critical that safety for all staff – especially those working in a high-risk capacity – be a number one priority. In-house maintenance staff and engineering managers should take the proper steps to ensure that all necessary safety measures are in place, staff are properly trained on all equipment and all compliance requirements are being met. While this may seem like a daunting task, there are many things facility managers can implement in order to enhance workplace safety.

Quality safety plan
The level of safety in your facility is dependent on the systems operating in them and the employees that run them. Implementing a quality safety plan is a simple and cost effective way to ensure that you have policies and procedures in place to foster a safe working environment for all staff and visitors to your facility. A quality safety plan can involve many aspects, but typically includes the following key elements:

  • commitment from management to implement a plan
  • routine monitoring of the plan
  • compliance of the plan by employees

Readily available resources through OSHA, a recognized state governing body, or a safety professional can be utilized to help build a program. Compared to the costs associated with a work accident or low employee morale because of unsafe conditions, the cost of implementing a quality safety plan is minimal.

Facility maintenance
When a facility is committed to creating and maintaining a safe work environment, it shows. What does your facility say to people? Ask yourself:

  • Does the facility look clean and maintained? Housekeeping itself is a big part of safety.
  • In addition to safety logs and charts displayed in common areas, can a worker easily identify important safety items such as a Lock Out Tag Out station or an eyewash station?
  • Do all employees know where the MSDS sheets are stored?
  • Are tools inspected, maintained and stored properly?
  • Are hazards like confined spaces and places where fall protection may be needed clearly identified?
  • Is all equipment properly guarded?


This list is just the beginning of the questions facility owners and managers should ask when evaluating their own operational safety protocols. When it comes to safety, once you have identified something that is unsafe you have unknowingly identified a need for safety training and the topic on which the team needs to be trained.

Employee training
Training is critical to safety. You can have all of the appropriate safety processes in place, but if your team is not knowledgeable and comfortable with them, the processes are essentially useless.

If your facility has recently upgraded equipment, you need to ensure that your employees have been properly trained on how to safely use the new equipment. If your facility has had three widgets that have been running for the past 30 years and one needs to be replaced, the new one will introduce changes to the facility and how it runs.

It will inherently have newer controls and upgraded features from the 30-year-old model — and with new upgrades comes new operating procedures.

It is imperative that any equipment and operational changes be looked at from a safety perspective. Newer equipment has different operating parameters and with that comes different safety concerns.

Additionally, some facilities have employees that play a dual role during their shifts. For example, a hospital may assign the plant operator tasks inside of the hospital. If they have to enter the hospital or patient areas it is critical that they have received the proper training to do their jobs in this new environment without compromising their safety or the safety of the patients.

All engineers regardless of their age or years of experience should be given the same safety training. Older, more seasoned engineers can learn just as much as the young, new engineers. Having full facility trainings can increase overall safety compliance, ensure all employees are trained to the same standards and bolster employee morale.

Ultimately, you want to make sure that if your facility employs multiple shift operators of varying levels of expertise, they all have the same level of training. Ask yourself if you can interchange any staff members and have the same safety requirements met. Many facilities cannot. All it takes is one staff member without the proper training to have a lost time accident — or worse.

Visitor safety measures
Safety extends beyond employees. It’s important to make sure safety rules are in place and communicated to anyone visiting your facility. Contractors, vendors and various support staff that visit need to be educated about specific safety rules and hazards. Contractors alone accounted for 17 percent of all fatal work injuries in 2014, according to OSHA.

Make sure your facility is prepared for guests or visitors. Are there areas that should be off limits to non-essential facility personnel that have not been properly trained? Anyone entering your facility should not be allowed to freely wander about. Most facilities/plants have chemical areas or areas with hazards that should only be entered by properly trained personnel. The facility should have a safety plan in effect for everyone who may enter that facility. Anyone performing work in your facility should have to acknowledge your safety plan and adhere to it, and if it’s a construction company, you should require they submit their safety plan to the facility to prevent liability on your end. Facility employees should monitor any outside entity performing work in their facility for compliance to the safety plan.

On-site risks
There are a four key operational areas that facilities managers should pay special attention to when evaluating their building’s safety features:

Ladders. Ladders are very dangerous when not used properly. On a yearly basis, OSHA estimated that as many as 36 fatalities and 24,882 injuries occurred due to falls from stairways and ladders. Unfortunately, proper training for ladder safety is often overlooked or dismissed with the idea that ladder usage is common sense. Facilities managers should ensure that ladders are maintained in safe conditions and inspected for defects daily. Ladders should also be matched to the task at hand as well as the worker’s weight.

Hand tools. According to OSHA, more than 4,800 injuries occurred as a result of a handheld object or equipment. It’s important that no matter how simple the tool, employees are trained on proper use. Facilities managers should be sure that tools are used in a properly lit space; are disconnected when not in use; and are kept away from heat, oil and sharp edges.

High access points. Do you have tanks, boilers or platforms that staff members routinely walk on without adequate fall protection? Depending on what OSHA standard applies to your facility, fall protection may be required at as little as four feet. If your facility hoists chemicals or materials to an upper level with removable handrails, it is imperative that employees wear fall protection when transporting potentially catastrophic substances.

Confined spaces. Larger facilities typically have multiple tanks and spaces that are considered confined spaces. Facilities that have identified confined spaces should have these areas clearly marked so employees or contractors do not enter without the proper training. Managers should also consider when it is necessary for an employee to enter a confined space as well as the safety requirements for contractors entering these spaces. Are your employees subject to entering confined spaces? What are your requirements for contractors entering confined space in your facility?

Implementing the Plan
Once managers have identified unsafe operational elements, it is important to address these problems. Luckily, there are several tools that employers can use to ensure workplace safety:

The OSHA 10/30-hour course. This is an excellent platform to introduce employees to safety and hazards they may encounter. The course provides employees the ability to recognize hazards and the knowledge to properly and safely work around them. Employees can also earn OSHA accreditation.

Personal protective equipment (PPE). Managers should ensure that all employees wear basic safety equipment as required including hard hats, safety glasses, hearing protection and safety toe footwear. The amount of equipment worn will vary based on the worker’s task. For example, facility engineers are involved in everything from taking chemical water samples to fabrication, which will require considerably different PPE items. For each task, the appropriate PPE should be selected and used accordingly, which is another benefit of proper safety training.

Lock out tag out (LOTO). Establishing a proper LOTO system ensures that employees properly de-energize and prevent equipment from starting while the equipment is in use or is in repair, and also provides the tools to complete it safely. More often than not, LOTO systems are overlooked due to time constraints. However, electrical safety is paramount in workplaces where machines are running. Statistics show that upwards of 100 people die each year because of improperly locked out equipment.

In addition to the training mentioned above, facilities should also consider training related to electrical work, hazardous materials, chemical handling, forklifts, emergency action, and life safety/fire protection.

Standards published by OSHA explicitly require the employer to train or instruct employees in the safety and health aspects of their jobs. OSHA.gov is an excellent free resource to help navigate a safety plan and institute training. Alternatively, smaller companies can benefit from outsourcing general safety training from safety consulting firms. These firms can customize an online or classroom program without requiring a full-time safety position.
No amount of training can prevent all accidents, but it can prevent most. Company training standards need to be established proactively to consistently provide all employees with the proper information and training needed to perform their jobs. Doing so will not only decrease potential hazards, but will also increase productivity and efficiency.

Frank Dunn — frank.dunn@rmf.com — is a field services specialist at RMF Engineering. Dunn began his career in construction as a pipefitter. For the last 13 years, he has performed construction observations and testing on industrial and institutional projects for RMF. He is an OSHA authorized construction trainer and is responsible for developing RMF’s safety policies.