Keeping your maintenance shop safe is probably a high priority for you—and if it's not it should be. Nothing can shatter the productivity and morale of a shop like a workplace accident, and a safety audit conducted by the U.S. Occupational Safety & Health Administration (OSHA) can upset your operations for days or weeks.
The State of West Virginia's Department of Transportation (WVDOT) has taken a proactive approach to workplace safety, by addressing the crucial issue of tire safety. That's why the WVDOT recently brought in a professional tire safety instructor from the Tire Industry Association (TIA).
Most fleet maintenance managers are aware of OSHA Standard 29 CFR 1910.177, that states, in part, "The employer shall provide a program to train all employees who service rim wheels in the hazards involved in servicing those rim wheels and the safety procedures to be followed". But not every shop complies, according to TIA director of tire service Jeff Faubion.
"The tire industry for years has been driven by speed," Faubion explains. "Management thinks, 'An eight mount, off and on the vehicle should be in and out of the shop in an hour.' And we have to slow our people down to do things safe and right."
Faubion spent two days in June in Buckhannon, WV, training 28 technicians, supervisors and trainers from WVDOT service centers around the state to slow down and do things right.
"It's just like the difference between preventive maintenance and demand maintenance on their vehicles," he explains. "They're doing preventive maintenance on their employees, to prevent them from having to do mandatory maintenance dictated by OSHA after an accident. Then they get double-dinged: not only do they have to do the training, they get fined by OSHA. And the civil suit follows that. So, it's a matter of being reactive or proactive."
REAL WORLD EXPERIENCE
Over the course of two days, Faubion covers every aspect of 1910.177, so that each technician can be tested and certified in tire safety. He travels all over the country, at the behest of TIA, and he never seems to run out of technicians to train.
"I'm not surprised that this many people still need training because of the turnover," he says. "The turnover is so high, I don't think we'll ever run out of people to train."
It's a good thing, then, that Faubion enjoys spreading the word about tire safety. He's changed tires for both tire dealers and fleets, and he has no problem listing some typical tire safety mistakes he sees in fleet maintenance shops:
- "The most common is not wearing safety glasses. Kids don't like wearing safety glasses, so they put them on their hat, put them on the back of their neck, put them in their pocket, put them on the bench, whatever. Damage to eyes is one of the most common injuries."
- "Back injuries are huge, mainly because of the way people pick up tires. Most of the people in our industry, they're young kids, and they're strong, but they reach down and start lifting these 150 lb. tires and they wind up injuring their backs. Teaching proper lifting practices is a big point that I push: lift with your legs and not your back."
- "Keeping the wheels on properly. Teaching these guys to torque lug nuts is super important, but not that many people do it. And that includes the retorquing—this is important because, if lug nuts have been overtorqued before, like a lot of them have in the U.S., they've stretched the lug nuts and the studs so far that if you torque them to where they're supposed to be, then they will loosen up. If they use the retorquing, they will find that and fix the problem by replacing the studs and lug nuts or looking at them and examining them and finding out why. If you just crank them down with an impact wrench, you're doing damage to a lot of things. You're overworking your compressor, you're damaging your employee's hearing—just working in a tire shop without hearing protection is dangerous enough."
- "Tire repairs—you can still go into shops and see them plugging tires, which amazes me, because of the liabilities. On every package of plugs that you buy, it states that it is a temporary repair, and people put them on tires and think that they last forever."
Faubion's training approach seems to work, because the WVDOT technicians remained involved in the class from beginning to end, asking and answering questions, digging into the worksheets and exams, and taking advantage of all the materials Faubion had with him.
"I think it's real good, especially after you become a supervisor, because you don't want one of your people to get hurt," says Bob Pritts, equipment supervisor for WVDOT District 5. "When I started as a mechanic, my father told me that the way to change these 3-piece rims is, you turn it upside-down and you sit on top of it. That's how I was told. The trainer said, right at the beginning, the reason they're doing this is because the people who have been doing this for 30 or 40 years keep telling the newer people the wrong ways."
"A lot of this is interesting to me, because I've never been too involved with tires or safety," says Roger Channell, highway equipment specialist for WVDOT District 8. "But I'm a trainer, so I'm taking this back to my 18 techs."
"First thing I'm going to tell my guys is, 'If you're not trained, you're not going to change a tire,'" says Pritts. "And I know we just hired two and they didn't have enough seats to get them in this class, and I know one of them has already changed tires on a vehicle—I will call back before I leave here today and tell them, 'These two guys don't change any more tires until they've had this class.'
"It's great that the state cares enough about us that they want to keep us safe," Pritts concludes.
Of course, tire work is only one small part of the safety picture. Accidents can happen anywhere in the fleet maintenance shop, and an accident will bring an OSHA safety inspector to your door pronto. Is the average fleet ready for an OSHA safety audit?
To find out, we talked with two OSHA compliance experts at J.J. Keller, a leading safety training company based in Oshkosh, WI.
According to Mark Stromme, safety & workplace editor, there are four reasons why OSHA will conduct a workplace safety audit.
"If there's an accident or fatality, you can count on OSHA making a visit, especially if it makes the news," he explains. "You are required to report an accident within a certain time period, but essentially, if it makes the news they're going to be there.
"Another reason OSHA would come and inspect your facility is if someone complains; they feel they're threatened or in danger in your workplace, they call OSHA and OSHA will come out. They do that relatively fast—within a day or two. Because if they don't and somebody gets hurt, they wouldn't be doing their job.
"Another reason they would come would be if your company falls into one of the 'high hazard' industry areas," Stromme explains. "I don't think fleet maintenance shops do, so you'd probably be fine there.
"Lastly, OSHA will come for follow-up inspections if they've been there before and they want to check up on things," he concludes.
In Stromme's experience, the most common reason for OSHA to conduct a safety audit of a fleet maintenance shop is a worker complaint.
If an OSHA inspector comes to investigate a worker complaint, he or she will tell you the reason for the safety audit, but not the identity of the complaining worker.
"As soon as they get to your facility, your safety professional should be prepared to meet with them, and should have gone over this scenario in his or her head already," Stromme explains. "You sit down with them in an office, and they will normally want to look at your record keeping requirements, your OSHA 300 log, and your training requirements. That could take 15 minutes, it could take an hour; it depends on how big your facility is, and what you do, exactly. The more hazards you have, the more training requirements you're going to have. And they may only be focusing on one area; they may not want to see everything.
"Then they're going to want to go out into your facility, and they can talk to employees privately. And they're going to look for two things initially: if certain signage is up, warning of hazards, and if certain machines are guarded properly, equipment is being operated properly.
"Then they're going to talk to employees," he says. "They're going to pull one aside, and they'll talk to this person privately. They're going to ask this person what kind of safety orientation they got. What about job training? Let's say you had a mechanic changing tires—there's an OSHA regulation that requires them to operate this equipment a certain way—so if that person's doing that work, obviously they need to be trained to operate the equipment, so they'll ask about that."
Stromme explains that the OSHA inspector will ask that employee how often safety meetings are held, and whether they understand the hazards associated with their job. The inspector will ask if the employee understands what to do in an emergency, who to call, what number to call, and what to report.
"And then they're going to ask the employee if he or she feels his or her job tasks are safe," he says. "Or, do they feel apprehensive when they come to work every day?
"Somewhere in orientation training, you would want to communicate to your employees that if they see you walking around with someone and that person wants to talk to an employee, it's okay. You would tell them, 'Heaven forbid we have an OSHA inspection, but it could happen. And if an inspector wants to talk to you, he or she is going to identify himself or herself, show you an ID badge and ask you questions, and you should cooperate, answer truthfully, and tell him or her what they need to know.'
Stromme emphasizes the importance of having a safety officer on staff, who understands the hazards in the workplace and understands what needs to be done to protect employees.
"Now, does that mean a full-time safety person who, that's all they do? Maybe not," he says. "Maybe if you only have 15 employees, could you have one of them do that job full-time? Probably not. But it could be anyone who is knowledgeable and willing to take the responsibility in training, and is also knowledgeable about the hazards. It's very important, because if an inspector comes on-site, he needs to have a point person to talk to."
Just as important, according to Stromme, is your record keeping. "If you have 11 or more employees, that's the threshold where you end up having a certain number of additional obligations: you've got to fill out the OSHA 300A and 301 record keeping logs, and you have to post those for a certain period of time," he explains. "Less than 11, you don't have to do quite as much, but if you have even one employee, in a facility that is doing maintenance, there are probably going to be a lot of chemicals. A hazard communication program is a requirement.
"You're going to have equipment that you may have to lock out or tag out," he continues. "You have to have a written program for that. And you have to comply with all the other standards that protect your employees against hazards.
"Flammable liquids are another area," Stromme adds. "You have to have an emergency action plan if you have more than 11 employees. What if there's a fire emergency? There's just a myriad number of regulations that you may have to comply with. The person that's tasked with that responsibility has to understand that there's a hazard, and what he or she needs to do to be in compliance with OSHA regulations. It can be a very daunting task.
"Safety has to start at the top," he concludes. "Be it the company owner, or the person put in charge of a facility, it has to start at the top. If it doesn't start there, you'll never get buy-in from any of the managers. If management doesn't express an interest in safety—or, worse, they cut corners and needlessly put workers at risk—it's never going to get off the ground, and you're going to have accidents, and you're going to have OSHA knocking at your door."
DOES OSHA MATTER?
According to Tom Bray, editor of transportation management for J.J. Keller, many fleets don't think OSHA matters.
"Fleets are deathly afraid of the DOT or Federal Motor Carriers Safety Administration, or anybody with that in its name…. even the highway patrol!" he says. "'OSHA? We don't have to worry about them.' So it takes a back seat."
The difference, says Bray, is that OSHA can't take a truck off the road.
"DOT or FMCSA can remove a revenue-generating component from the company," he explains. "The odds that one of our trucks is going to be inspected is fairly high. The odds that we're going have to go through a DOT audit are very high. The odds that we'll ever even talk to somebody at OSHA? That's low on our scale of problems we'll have to deal with."
Despite this, Bray feels that most fleets are already prepared for an OSHA audit, to one degree or another. "They'll have the basics—the hazcom requirements, some of the personal safety requirements—met," he says.
"The biggest issue is personal safety," he continues. "Personal injury is the quickest way to have OSHA come knocking at your door saying, 'We're here to help you out, because you obviously have a little trouble.'"
CASE IN POINT
Having worked in fleet safety before moving to J.J. Keller, Bray can cite personal examples of the worst and the best in maintenance shop safety practices.
In the "worst" category, he describes one fleet that had wash rack solvent areas, "And the technicians that worked there regularly, cleaning parts, cleaning trucks, had no glasses, no goggles, no gloves, no training. 'Here's your job: you take this stuff, you spray that off.' Well, that's taking an inch of grease off of a truck frame, with no shields, no eye protection, no gloves, no nothing. But the fleet considered that okay because all the technicians were doing was 'washing the truck.'"
In the "best" category, Bray describes one maintenance manager he knows who does safety training the right way, starting every new hire in the maintenance shop off with two full days of safety training.
"The technicians go through a full safety training session, and the company just 'eats' that; they realize that when they hire somebody they're going to have two days of non-productive time. And they emphasize to the new hire that we are more than willing to do this to make sure that you are going to be safe in your job. And in return we expect you, day-by-day as you're working here, to realize that if we're willing to give up two days, we expect you to be willing to give up five minutes, to be safe."
SETTING A GOOD EXAMPLE
Fortunately, the West Virginia Department of Transportation seems to get it right.
"Safety is #1 here," says WVDOT highway equipment supervisor A. Todd Campbell. "We have safety people at all 10 state districts. They do a monthly safety meeting, and they identify safety issues. They report that to Charleston, and then if it has to do with equipment we look into it."
Based on those findings, Campbell explains, safety training will be implemented if necessary. And, as in the case of the OSHA tire safety class, trainers will be certified to go back to their own districts to educate their technicians.
"We do have trainers in all 10 districts, and they get certified as instructors every year. Then they go back and school the technicians at their local districts," Campbell says. "They'll set up instructional meetings for their guys and get them up to speed on the OSHA regulations, so they're aware of the safety concerns."
Larry Johnson, a WVDOT technician going through OSHA tire safety training for a second time, is most definitely aware. "I've seen a couple boys get hurt, and it ain't pretty," he says. "It makes you think. That's like a stick of dynamite, and you're lighting the fuse. You've got to slow down and keep your mind on what you're doing."
J.J. Keller's Bray would approve. "They just get that culture started right from the beginning," Bray says. "And with safety issues, it's a matter of culture. Get the behavior shaped using cultural input.
"Watch your people, and make sure your culture is correct, and the behaviors are correct," he says. "If you have a good culture, and you have good behavior amongst your shop employees, OSHA compliance will fall right in line.
"The reverse is also true," Bray cautions. "If you have a poor safety culture and poor behaviors going on, and they're allowed to proliferate, OSHA compliance will become an issue. And worse yet, you're likely to have an injury among your employees."
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