OSHA is still fulfilling its mission promoting worker and workplace safety. Safety, Amputations, and Planned Inspections led the OSHA inspection categories for NAICS 332721 so far this year.
At PMPA we take a look twice a week at the OSHA inspections posted online for our industry. In the event that one of our members is on that list, we call immediately to offer our assistance. If it is a non-member, we look to learn what vulnerabilities are being encountered in the industry shops not belonging to PMPA.
Here’s what we found out.
So far this year, OSHA has posted notices of 53  inspections for our NAICS code- 332721 online. 53!

Chart of OSHA inspections frequency for 2018 NAICS 332721 Precision Machining Shops

The single largest category were for “Safety” – 15 of 53, 28% of all inspections posted.
Go figure.
The second most frequent category was “Amputations“-12 of 53, 23%.
This really is aggravating. There is no excuse for anyone to be losing body parts. We need to contact our people immediately to review the basics about pinchpoints, rotating equipment, and the pointlessness of trying to stop a lathe with our fingers or thumb. 
I won’t display the photos but if you want to see what a drill can do to a human hand click this link:  Graphic Image
Programmed (planned ) Inspections were third  with 7 of 53 or 13%. Routine enforcement is still a “real thing” at OSHA.
Complaints  came in at fourth  with 4 out of 53 inspections being initiated as a result of a complaint- 8% of inspections due to complaints..
Health tied with Complaints at 4 inspections out of 53- 8% of inspections due to occupational health concerns
Rounding out the ten causes were Noise, Reinspections, Accidents, Referrals, and Inspections.
Reasons cited for OSHA Inspections for NAICS 332721 (frequency) Calendar year 2018 YTD

OSHA is still fulfilling its mission promoting worker and workplace safety. The above reasons show how your peers are being examined. Are you ready for an OSHA inspection?
Photocredit: Mystalk
Data and Chart Preparation credit Veronica Hopson, PMPA
Original Data sourced from USDOL OSHA.

The Precision Machined Products Association (PMPA) filed official comments opposing an Administration proposal to place additional burdens on employers while loosening injury reporting requirements on employees.

Clarity, not confusion, should be the work product coming out of here.
Clarity, not confusion, should be the work product coming out of here.

On August 14, 2014, the U.S. Occupational Safety and Health Administration (OSHA) issued a Supplemental Notice to a pending rule to make injury and illness reports public which becomes final in March 2015. The notice reframes Employee injury reporting as a “right” rather than a “duty.”
Reporting of injuries and illnesses is not a right. It is an obligation of the employee to report; and a responsibility of the employer to record, investigate, and take appropriate remedial actions to retrain as necessary and to remove any hazards so identified.
Employee Duty
Employee Duty

“We are very concerned that the as-yet unpublished regulatory text will actually become an obstacle to our ability to manage safety and hazard identification in manufacturing facilities,” said Rob Kiener, PMPA Interim Executive Director. “By changing the understanding of an employee’s “obligation to report injuries and illnesses” to a “right to report,” OSHA allows workers the discretion to not report while maintaining the burden on employers,” continued Mr. Kiener.
For these reasons, and the reasons given in our submitted letter, earlier comments, and testimony, the PMPA urged OSHA to withdraw both the proposed regulation and Supplemental Notice.
In the absence of actual regulatory text for us to review, OSHA creates only uncertainty regarding employers’ duties and obligations.
Furthermore, by ignoring OSHA’s own rule that employee compliance is a “duty,” OSHA potentially creates a means for employees to fail to report injuries and illnesses, with the proliferation of unrecognized hazards in workplaces across the country as a probable result.
Tracking Number: 1jy-8ex2-66lj
General Duty Clause Link

In my experience these are the three prime causes for accidents  and injuries in our manufacturing plants.

Who authorized this?
Who authorized this?

  • Failure to wear personal protective equipment.
  • Unauthorized use of tools, machinery or vehicles.
  • Failure to lockout/tagout when performing non routine work on equipment.

While it is personal responsibility to wear personal protective equipment, use only tools and equipment for which one has been trained and authorized, and to avoid hazards by not performing work on operating equipment, it is nevertheless management’s responsibility to assure that workers comply.
What have you done this week to make certain that your employees know that they are accountable for their personal safety?
Forklift Demotivational Poster from Motifake

The deadline for employers to train employees on the new GHS system is December 2013.

December 1, 2013
December 1, 2013

It is our pleasure to provide you with the essential links to the materials you need for providing the training your employees will need.
Final Rule : https://www.osha.gov/dsg/hazcom/GHSfinal-rule.pdf
OSHA Guide to GHS: https://www.osha.gov/dsg/hazcom/ghs.html
Training Requirements: https://www.osha.gov/Publications/OSHA3642.pdf
Labels and Pictograms: https://www.osha.gov/Publications/OSHA3636.pdf
Safety Data Sheets: https://www.osha.gov/Publications/OSHA3514.pdf
And just a note, the GHS pictograms do NOT replace those  diamond shaped DOT labels we’re also used to seeing.
disodium flammy
By the way we posted on this originally in March of 2012.

“Rigging equipment for material handling shall be inspected prior to use on each shift and as necessary during its use to ensure that it is safe. Defective rigging equipment shall be removed from service.”- OSHA 1926.251(a)(1)
Fabric and cable slings are widely employed in our shops to lift and move bundles of bar stock in particular, as well as scrap totes, pallets, and other equipment when needed.
They often carry weights as much as 5 tons. over valuable equipment, and in the vicinity of employees.
A failed sling could cause thousands, or hundreds of thousands of dollars in damage as well as potential injuries.
Do you know where your slings and straps are?
Do you know their condition?
Do you have a process to assure compliance?
Dan Ignaziak at Sepco-Erie  and his super cool  team do.
Here are some photos of the Best Practice Sling inspection control system in use at Sepco Erie.

A place for every sling, and every sling in its place...
A place for every sling, and every sling in its place…

Documentation, Baby! Documentation!
Documentation, Baby! Documentation!

It doesn’t take a lot to get  your shop into compliance for 1926.251.
Dan and his team wrangled all the slings into a defined place, numbered them, and inspect them, recording the inspections on the Inventory sheet shown on the clipboard.
This could be run on a spreadsheet on a computer as well.
The key is to be

  1.  aware of the requirement,
  2.  set up a simple system to track slings
  3.  then execute with training to inspect before use and to inspect monthly .

Dan’s Training Tip:  ” It’s also critical to train your people that slings are not to  be used without affixed, legible identification markings, required by paragraph (a)(2)(i) of the OSHA regulation.”
There you have it- Best practice compliance on slings, lifting devices, and rigging equipment from Sepco-Erie.
Their shop epitomizes the fun but professional spirit that makes precision machining super cool today.
In what  area is your shop the exemplar for Best Practices?

Hmmmm?1910.33 SubpartE Exit Routes

In June, OSHA issued an enforcement memorandum instructing their CSHO’s to “be mindful of whether the employer has provided and maintained adequate means of egress from work areas, eg., adequate number of exit routes are provided, exit routes are free and unobstructed, and exit doors are not locked.”
Here are some training materials from Ohio Bureau of Workmen’s Comp for training in this area.
Your employees and trainers are sure to enjoy these!
OSHA  Standard

Slips, trips and falls- here are some facts to help you with training for your team.

We are currently working on our analysis of the 2013 Spring Regulatory Agenda which includes an item “Walking Working Surfaces and Personal Fall Protection Systems (Slips Trips and Fall Protection)” shown as Final Rule  due for November 2013.

PMPA members will receive a report on each of the agenda items applicable to our industry.

Hope you find  this background information helpful in your training.
The Cost of Slip-and-Fall Accidents Infographic
Via: BOLT Insurance

Infographic produced by Infographicworld

You could ask this woodworker why they put guards on his machines.

Why exactly did you take off the guards?
A better question would be “Why,  exactly did you take off the guards?”

The hazards are real.

Respect the horsepower and sharp edges of our steel tools.

No one should get hurt  to make something. Not at work. Not in our shops at home.

Machine guards are there for our protection.

We are  the reason for the guards.


Good luck with the skin graft…

Getting back and forth to work may involve greater hazards than those we face on the job now that Orange Barrel Season has arrived.

Safety Awareness is just as important on the drive in to work and on the way home these days.
Safety Awareness is just as important on the drive in to work and on the way home these days.

While many of us take comfort in the fact that we can drive on autopilot- as long as we have had the first cup of coffee before inserting the ignition keys– the fact is that we need to be on the alert for changes that just might put us at greater risk than anything that we might face on the job.

Excavations, construction workers, construction equipment, and high horsepower vehicles are all hazards that might ‘ambush us’ now that Orange Barrel Season is upon us and in full swing.

I have a half mile of orange barrels after turning out of my neighborhood onto the state road- not even a quarter mile from my driveway.

“Safety First”  in Orange Barrel Season means being on the lookout for driving hazards  “Before getting to work!”

Four of every five victims in a work zone crash are motorists, not highway workers, which is why it is particularly important for drivers to remain alert while driving through work zones. The Federal Highway Administration (FHWA) has taken steps in the past several years to improve work zone design, strengthen enforcement near work zones, and heighten awareness among drivers for bringing the number of work zone fatalities to record lows.

Orange Barrel season is the opposite of Hunting Season.

No points for this!
No points for this!

“It’s a bad outcome if you “bag one!”

FHWA Statistic

Orange Barrel Season

Damaged Orange Barrel

When I started in manufacturing, “The Gals” were in the office- not the shop.

122  women who make a difference in Manufacturing today
122 women who make a difference in Manufacturing today

The inaugural group of 122 STEP honorees recognized by the Manufacturing Institute on February 5th in Washington D.C.  showed me that the times have changed and that there are many, many ways  that women can and do meaningfully contribute to manufacturing at their companies as

  • Plant and Production Managers,
  • Operations,
  • Engineers,
  • Technologists,
  • Process Control,
  • Regulatory Affairs,
  • Certified Welders,
  • CNC Machine Operators,
  • Weld Process Specialists,
  • Quality Control,
  • Health,
  • Environment,
  • Process Safety,
  • Chief Financial Officer,
  • Designers and Design Engineers,
  • Compliance Officers,
  • Chief Scientists,
  • Safety,
  • Quality,
  • Black Belts,
  • Training and Apprenticeship Instructors,
  • Manufacturing Lead,
  • Product Development,
  • Sales and Marketing,
  • Information Technology,
  • Lead Analyst,
  • Business Development,
  • Continuous Improvement,
  • Planning and Shipping,
  • Designer,s and Design Engineers
  • Information Security,
  • Assembly,
  • Legal and Corporate Affairs,
  • Systems Development,
  • President,
  • CEO
  • Owners

I am certain that I missed a few…

PMPA is proud to recognize our member and Vice President Darlene Miller, CEO of Permac Industries in Burnsville MN as one of this inaugural group of honorees.

Darlene Miller Nak“Darlene’s leadership  reaches far beyond PERMAC. As a member of the President’s Council on Jobs and Competitiveness she recognized the need for trained high skill workers and led the creation of Right Skills Now training program and helped support the 10,000 Engineers nationwide engineering student retention program. She was named small business person of the year in 2008 by the U.S. Chamber, and serves as an officer and board member at PMPA as well as a number of other nonprofits.”

Congratulations to Darlene and all the women recognized for their vital role in manufacturing today. And thanks to the Manufacturing Institute for helping raise the awareness of the vital need for the talents that these and all women bring to our shops.

Yes, I would like to see my daughter get into manufacturing. Wouldn’t you?