PMA March 2010 : Page 9 Money is tight, but I know I need to invest in on where I can get the biggest bang for my buck? If we look at this purely from a numbers standpoint, it might give us a better idea of where to invest limited resources. From January 2007 through January 2010, federal and state Occupational Safety and Health Administration (OSHA) offices conducted 33 inspections of photofinishing-related operations (North American Industry Classification System codes 54192 – portrait studios, and 812921 and 812922 – photofinishers and one- hour photofinishers). Of those inspections, 18 were planned, 12 were the result of complaints, and 3 fell into other categories. Seventy-six percent of the inspections were at portrait studios, with the rest being in photofinishing lab operations. Of the photofinishing labs, 75 percent of the inspections were because of complaints. A total of 38 violations were issued. The table lists the violations and the description of the standard that was violated. A total of $6,075 in fines was issued – if we exclude a single $5,000 fine issued to one lab as the result of an injury. Those violations marked with asterisks resulted in the highest fines being issued. OSHA Regulation Description of Violation 1910.0023 1910.0151c 1910.0305 1910.0023 D01 1910.0023 A08 1910.0022 1910.0132 D02 1910.0134 F04 1910.0157 Floor and Wall Openings – General Medical Services – First Aid Wiring and Components Stairway Railings Floor Opening – Guarding Walking and Working Surfaces PPE – General PPE – Respiratory Protection Fire Extinguishers – Portable 1910.1200E01 (*) Hazard Communication – Right to Know 1910.1200G01 Hazard Communication – Container Labeling 1910.1200H01 & 03 (*) Hazard Communication – Training 1910.303 1910.133 1910.151 c (*) Electrical General Requirements Eye and Face Protection Eye Wash Stations 1910.37 Exits (egress) some safety efforts. Do you have any suggestions Current penalties ranged from zero to $1,000. The more common penalty amount was in the $250 to $300 range. Current penalties are the negotiated or final settlement amount. A good rule of thumb is the final penalty amount is reduced by 50 percent from initial amounts. Keep in mind, even though the dollar amount of the fines may not be staggering, once a facility has been issued a citation, the likelihood of additional inspections greatly increases. Also, these fines do not take into consideration the internal costs incurred to bring the facility into compliance in the agreed-upon time frame as part of the settlement. Let’s go back to your question concerning where to invest limited resources available to commit to this effort. If we look at this strictly from a fine avoidance standpoint, investing in a Hazard Communications program is by far the wisest. A hazard communication program is a really good starting point, as there are sample programs that can be easily customized, depending on the size and complexity of your operation. Also, hazard communications programs are one of the most commonly cited violations. Even though they can be a fairly simple process to set up, a good hazard communication program is more than just a written document. Employers and managers need to train employees about the materials they are working with and how to safely work with them. The lack of employee training is a popular citation among safety program inspectors. Another area receiving additional attention in the past couple years is general housekeeping. Keeping a clean work area can avoid citations in several areas, such as egress (exits), fire extinguishers, and walking and working surfaces. A large percentage of OSHA citations can be avoided by conducting simple housekeeping activity items, such as not stacking boxes so they block exit routes, and fire extinguishers. Keeping a clean work area can also go a long way toward indicating the company has a good attitude about the work environment of the employees. If you don’t know where to start in this process, OSHA does have a good selection of etools on its website at www.osha.gov/dts/osta/oshasoft/index.html; or call the PMA Regulatory Activities office, and we would be happy to walk you through the process. ■ By Steve Noble In ComplianceSteve NobleMoney is tight, but I know I need to invest in some safety efforts. Do you have any suggestions on where I can get the biggest bang for my buck? Publication List |
