The 10th most frequently cited OSHA standard for 2008 was...

[Sidney Vianna]

ISRS® Solutions and the OSHA Top 10 Countdown

"If only I had a crystal ball that could see non-compliance with OSHA rules and provide some guidance on managing conformance systems!"
- Anonymous DNV author

Well, it's paper (or electronic), not crystal, and you have to read it to get information from it, but the International Safety Rating System® (ISRS®) has been a safety director's best friend since the late 1970's. Now in its seventh rewrite, the IxRS family provides a plethora of help across safety, quality and environmental management systems.
For the next ten issues of DNV's eMail Blast, we will be counting down the infamous "OSHA Top 10 Citation List for 2008" and linking ISRS requirements that, if managed properly, could help mitigate the conditions or practices that lead to such infractions.

The 10th most frequently cited OSHA standard for 2008 was:
#10 - Electrical systems design, general requirements, general industry (29 CFR 1910.303)

Common violations included

• Failure to adequately guard electrical equipment
• Failure to keep work spaces clear of electrical hazards
• Failure to identify disconnecting means and circuits
• Etc.

ISRS® sub-element activities that could control these risks and therefore reduce the likelihood these types of citations are:
ISRS 3.1 Planned General Inspections - Using a systematic approach to check compliance with electrical standards.
ISRS 7.5 Sources of Energy Controls - Using surveys and targeting objectives to ensure that disconnecting means and circuits have been identified with effective labeling, color-coding, etc.
ISRS 14.2 Hazard Identification and Risk Assessment - Using a systematic approach to ensure that all hazards relating to electrical exposures are identified and evaluated.
ISRS 14.2.2 Follow-Up System - Developing action plans and ensuring implementation of controls and routine hazard reviews to ensure that all identified electrical exposures are properly addressed.

These notes are provided from DNV's International Safety Rating System®. Your hands on, hands down, practical safety solution.®
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[Sidney Vianna]

The 9th most frequently cited OSHA standard for 2008 was:

#9 - Machine GuardingGeneral Requirements for All Machines (29 CFR 1910.212) Common violations included:

• Failure to provide one or more methods of machine guarding
• Failure to guard the point of operation of machines whose point of operation exposes an employee to injury
• Failure to anchor fixed machinery
• Failure to guard blades
• Failure to affix guards to machines

Examples of ISRS® sub-element activities that could help control these risk to people and property while also reduce exposure to regulatory citations include:

ISRS 3.1 Planned General Inspections - Integrating positive recognition verbally or in writing, when above standard practices are observed to reinforce positive performance.

ISRS 3.1 Planned General Inspections and 3.7 Pre-Use Inspections - Using an internal inspection program instead of waiting for regulatory inspectors to identify deficiencies in machine guarding and ensure employees verify guarding is in place prior to performing task.

ISRS 8.2 Specialized Work Permit System - Verifying your system ensures equipment tagout when guarding must be removed for maintenance and have a process to ensure guarding is in place prior to resuming operations. ISRS 14.1 Engineering and Change Management - Using a system to keep the organization current with relevant regulations, codes and standards to ensure compliance, ISRS 14.2 Hazard Identification and Risk Assessment - Using a systematic approach to ensure that machine guarding hazards have been identified by qualified individuals on a scheduled basis, ISRS effectively defines and integrates proven management practices to assist in building an effective management system to control risk to people, property, the environment and reduce regulatory violations.