Last year, the Occupational Safety and Health Administration (OSHA) in the State of Wisconsin conducted an extensive investigation into the food manufacturing industry. Over a six-year period from 2014 to 2020, they examined nearly 100 injuries and 3 fatalities that occurred in this sector. Almost, all of these incidents were a result of contact with moving machine parts, which is a clear violation of the Occupational Safety and Health Administration’s (OSHA) general requirements for all machines outlined in 29 CFR 1910.212.
During their review, OSHA discovered that the most common violations in the food manufacturing industry were related to the failure to properly control hazardous energy and the absence of adequate machine guarding. In fact, machine guarding ranks among the top 10 OSHA citations issued nationwide. Furthermore, workers in Wisconsin food production plants experience an injury rate approximately 24% higher than workers in other production facilities across the state.
In response to these alarming findings, the Wisconsin OSHA Area Offices took decisive action by establishing a Local Emphasis Program (LEP) specifically targeting food manufacturing companies. This LEP is directed at companies with a primary NAICS code beginning with 311, which corresponds to the Food Manufacturing industry.
Wisconsin is home to over 900 food manufacturers, employing approximately 19,000 workers on a seasonal and year-round basis. The primary objective of the LEP is to enhance compliance with required safety procedures within this industry. It aims to ensure that employers are effectively identifying and mitigating exposure to machine hazards during production activities, as well as various sanitation, service, and maintenance tasks.
One crucial component of the LEP is an outreach campaign designed to raise awareness about the program and focus on the hazards it aims to reduce or eliminate. This outreach may take the form of informational mailings, training sessions at local tradeshows, or meetings with industry groups and labor organizations.
Machine guarding plays a critical role in ensuring worker safety, regulatory compliance, and the production of high-quality and safe food products. The purpose of machine guarding is to protect workers from hazards associated with moving machinery, such as rotating parts, pinch points, and potential exposure to harmful substances. Therefore, scrutiny of machine guarding in the food manufacturing industry is essential to prevent accidents and injuries.
To effectively address machine guarding scrutiny in food manufacturing, there are several key considerations and aspects to keep in mind:
- Compliance with Regulations: Food manufacturing facilities must comply with OSHA safety regulations and standards. However, it is worth noting that compliance with other industry standards, such as those set by the FDA, may sometimes pose challenges in meeting OSHA standards. In such cases, seeking the assistance of experts and engaging in discussions with the relevant agencies can often lead to amicable solutions.
- Risk Assessment: Conducting thorough risk assessments is crucial. It is important to identify potential hazards associated with each machine and its operation. This includes considering factors such as the type of equipment, speed, size, and the nature of the materials being processed.
- Steps to Compliance: To ensure compliance with the LEP, companies should assess whether the requirements listed in regulation 29 CFR Subpart O- Machinery and Machine Guarding are being met. This can be achieved by:
- Understanding the OSHA and American National Standards Institute (ANSI) requirements for general machine guarding, as well as any equipment-specific requirements.
- Conducting Machine Guarding Assessments to identify gaps and implement necessary corrections. This applies to both new equipment, equipment that has undergone changes, and equipment that is currently in operation.
- Ensuring that safety programs and procedures are in place. The safety program should include:
- A comprehensive training program that includes all workers, including seasonal and temporary workers, delivered in a language they can fully understand. This training should address how machines work and how guards protect employees, ultimately reducing the risk of injury.
- A schedule for regular inspection and maintenance to ensure compliance with all relevant OSHA regulations.
- Best management work practices and procedures for work conducted in and around operating machinery.
Gallagher Bassett Technical Services has experts on staff who can assist in identifying gaps in machine guarding and help develop programs and assist in training your workers to help your company meet or exceed OSHA requirements. To take advantage of this service, reach out to Jay Jaros at 630-593-6073 or Jay_Jaros@GBTPA.com
Related Links