Health and Safety Management Systems in the Manufacturing Industry
Authored by Charles Schnurpel, Senior Compliance Manager at August Mack

In today's manufacturing environment, it is vital to maintain awareness of the changing standards and regulations from OSHA. The implementation of a health and safety system that reviews and establishes applicability of all new and changing regulations and guidelines will not only make for a safer work environment, it will also save money and improve a company's production and bottom line. Savings and increased revenue can occur from increased production, reduced loss-time accidents, reduced insurance and workers' compensation premiums, and an overall positive workforce. In addition, a well-managed safety program reduces the risk of NOVs (Notices of Violation), which many facilities are familiar with receiving during OSHA inspections. As an example of savings, an automotive facility initiated a comprehensive safety program and estimated savings of more than $150,000 annually following implementation. Almost all facilities see tens of thousands to hundreds of thousands of dollar savings annually after implementation.

In establishing a comprehensive safety program, it is critical to determine applicable regulations. A company's total number of employees has a large effect on the level at which a company is regulated. The person in charge of health and safety issues for the facility will need to evaluate operations in regards to the applicable standards to ensure the company is achieving compliance. In many cases, it is a good idea to enlist an organization's corporate staff or outside services to ensure a complete review is performed. Some of the key issues facing industry are hazard communication planning, blood borne pathogens, indoor air quality issues, emergency action planning and fork lift operation. Due to the extent of OSHA plans and programs, developing plans and procedures for all OSHA programs simultaneously may be burdensome. If this implementation is too burdensome, employers in the manufacturing industry need to prioritize implementation of the guidelines that will have the biggest impact to safety and improved operation in the workplace.

Once the basic safety program is in place, manufacturers also need to maintain an understanding of changing regulations and the impact they will have on the safety program. As previously stated, indoor air quality is a primary safety concern for industry. It is important to know the concentration of contaminants in the air that employees are breathing. When determining what contaminants should be monitored, today's manufacturer needs to be particularly aware of new regulations that reduce the allowable exposure concentration regarding Hexavalent Chromium.

Changes in the Hexavalent Chromium Standard
Chromium is a naturally occurring metal with many uses and many risks. In its riskiest form, Chromium has been identified as a human carcinogen that significantly increases the risk of lung cancer. It has recently prompted the Occupational Safety and Health Administration (OSHA) to enact new requirements for reducing the concentration of Hexavalent Chromium that an employee is exposed to during the workday. The new OSHA standards are extremely pertinent to any business that uses or has the potential to convert any other form of Chromium to Chrome VI in any aspect of its operations.

OSHA originally adopted standards for Hexavalent Chromium in 1971, establishing an exposure concentration of 52 g/m3 as the Permissible Exposure Limit (PEL) for the compound. The regulation remained unchanged until a number of complaints, including two lawsuits, forced OSHA to re-evaluate its dated standard for Hexavalent Chromium exposure. On October 4, 2004, OSHA proposed that the PEL be lowered to 1 g/m3. This benchmark, although higher than the 0.25 g/m3 standard that the Oil, Chemical and Atomic Workers International Union (OCAW) lobbied for in 1993, was met with vehement resistance from the chrome industry. As a result, a standard of 5g/m3 was adopted. According to the risk assessments, an exposure rate of 52 g/m3 yields a death rate of roughly 1,000 people/year. The 5-g/m3 standard, which took effect in May of 2006, reduces the expected death rate to four people/year.

The tools to ensure compliance
As can be seen by the Chromium Standard example, it is critical that a facility continuously be aware of all regulatory changes associated with health and safety in the workplace. If someone is unsure of how to determine or ensure compliance, they can start by visiting the OSHA website or requesting information from local health & safety committees. One might also look into hiring an EH&S (Employee Health & Safety) consultant to aid in meeting the compliance guidelines.

EH&S consultants specialize in possessing an in-depth knowledge of applicable standards and then applying that expertise to those doing business in an affected industry or trade. At its heart, their job is to ensure OSHA compliance without placing an undue burden on the companies subject to regulation.

An EH&S consultant will develop and implement programs based on applicable regulations and OSHA logs detailing the occurrence of workplace accidents. For example, a process palletizing orders to be shipped might be shown to result in an overly high number of forklift-related injuries. The EH&S consultant would then evaluate the company's process to determine why the accidents are occurring and what types of injuries they are causing. Through investigation, the consultant finds the root cause, and then develops additional programs and guidelines to lower the rates of incidents.

The benefits of compliance
As previously indicated, there are many benefits associated with a well-implemented safety program beyond the obvious safe workplace. In the global marketplace, competition is at an all-time high, and all ancillary programs must evaluate costs and benefits. To summarize, the following describes some of the benefits of a good safety program.

The reduction of accidents and injuries obviously helps to minimize the time and money lost to personnel being off the job. Furthermore, when an employee must take time off to recover from an injury, someone else must step in to take that person's place temporarily. If that person possesses a lower level of expertise or experience, both productivity and quality can be adversely affected. In addition, occurrences of injured workers raise an employer's modification and workers compensation rates, increasing the cost of insurance.

When not in compliance, a company also runs the risk of high fines. OSHA inspects many facilities randomly every year. If a serious reportable accident occurs, OSHA will definitely inspect a facility. The result of those inspections will result in NOVs and associated fines. When a company is fined, OSHA will conduct a formal administrative hearing to inform the company of where they need to take corrective action. By bringing in a consultant, a company demonstrates its commitment to taking care of the issue, which can often result in a reduction of fines and penalties.

Finding time to achieve compliance
Today's manufacturers are very busy with trying to stay competitive and don't always have time to keep up with complex and changing OSHA regulations. An EH&S consultant can provide the additional effort and security needed for a facility to achieve compliance, a necessary thing that is often outside of a company's core competencies.

For more information contact:

August Mack Environmental

8007 Castleton Road

Indianapolis, IN 46250


Fax: 317-579-7410