Few things are more alarming to a safety manager than receiving news of an unexpected OSHA audit. With little time to prepare for an unannounced visit, you are left to face OSHA inspectors without the chance to make sure all the proper fall protection measures are in place and up to code.
The key to staying one step ahead is to schedule your own internal OSHA fall protection audit before OSHA does. If you’re unsure about how to conduct your own internal inspection, the steps below will help you organize an internal audit.
Step One: Request a no-cost onsite consultation with OSHA
The path to a proactive approach to safety begins with an understanding of your key deficiencies. The best way to identify your safety shortcomings is to schedule a no-cost onsite consultation with an experienced OSHA inspector. This process can help reduce injuries by pinpointing locations where you can install handrails and indoor safety gates, point out what machines should be guarded, and highlight any other hazards. Here is what you can expect during an onsite consultation:
- An initial meeting during which you can discuss your goals and challenges
- A thorough walkthrough of your facility
- An in-person review of the consultant’s initial findings prior to their departure
- A comprehensive report that covers findings in greater detail
Step Two: Inspect employee work stations and aisles
Cluttered warehouse aisles, debris on the floor, and unmarked landings or holes in your floor all contribute to employee trips and falls. Here are some specific measures you can take to protect workers from falling:
- Install indoor safety gates around mezzanines and elevated work platforms
- Never allow loose boxes to collect in the aisles
- Mark level edges with yellow warning line tape
- Install safety swing gates around loading docks and other regulated work areas
- Designate a member of your team to be responsible for cleaning spillage and combustible dust on floors
- Use safety rails on walkways
- If using a man lift or scissor lift, ensure workers use safety lanyards and harnesses
Step Three: Check your stairways and ramps
Unless your entire facility is on the same level, you need to check your stairwells and ramps on a regular basis. Slippery steps, loose handrails, and poor illumination are key factors that contribute to employee slips and falls. Some key ways to prevent falls on stairs and ramps include the following:
- Ensure all stairwells and ramps are well lit and have the appropriate emergency lighting
- Make sure steps feature a slip-resistant surface
- Ensure handrails are placed on stairwells with at least four risers
- Make sure steps are all the same with respect to their shape and size
- Check to confirm that stair tops and bottoms are well protected with self-closing safety swing gates or doors
Step Four: Examine floor holes and skylights
Uncovered skylights and floor openings present a permanent threat to the safety of your employees and visitors. Fortunately, you can reduce the threat of injury by installing strategically placed guardrails and safety swing gates around all floor openings. Covers, screens, and toeboards around the perimeter of openings can also be useful in preventing falls.
When installing skylight screens, make sure they can support at least 200 pounds. Any manhole coverings or trench covers on your property should be able to support the weight of heavy equipment and vehicles. OSHA requires that these coverings be designed to support a truck rear axle load of at least 20,000 pounds.
Step Five: Inspect your ladders and scaffolding
“Among workers, approximately 20 percent of fall injuries involve ladders, and among construction workers, an estimated 81 percent of fall injuries treated in hospital emergency rooms involve a ladder.” – Sandy Smith, EHS Today
Ladders and scaffolding play a key role in daily operations for many manufacturers and warehouse facilities. Failure to ensure ladders and scaffolding are clean, sturdy, and intact can result in OSHA violations and leave employees at greater risk for injury. Here are some specific things you can do to make sure your ladders and scaffolding are OSHA-ready:
- Make sure ladders feature slip-resistant grips
- Check all ladders to make sure each rung is intact and free of cracks
- Don’t forget to check portable step ladders you may have in storage
- Make sure scaffolding can support up to four times its maximum load
- Keep ladders and scaffolding clean and free of debris and grease
In addition to these measures, remember that fall protection should not cease once an employee has completed their ascent on a ladder. It’s up to you to ensure that employees are equipped with safety lanyards, harnesses, or the proper equipment to help safeguard against falls.
Step Six: Ramp up your employee safety training
A lack of training is never a valid excuse for an OSHA violation. It’s important to conduct an annual review of your safety training policies and procedures, giving special attention to the steps you take to boost fall protection. Ideally, safety training should be emphasized during onboarding and employee orientation, and on a regular basis throughout the year. Some specific points to mention are as follows:
- Train employees on the proper use of safety lanyards, harnesses, vests, and other gear designed to prevent falls
- Ensure employees have a clear understanding of policies and procedures to protect against falls
- Instruct employees about the correct way to use OSHA compliant indoor safety gates and guard rails
- Make sure employees know how to properly clean equipment, floors, ladders, and scaffolding
- Place safety signs around your facility to remind workers of potential hazards
One of the most effective ways to make sure employees get the most out of training is to make the training interesting. You can do this by involving them in the training process and using real world examples that will be relevant to their role in your operations. Finally, consider rewarding employees who achieve all training goals with proficiency.
What is the single best way to boost your fall protection?
Having the proper policies, procedures, and equipment in place to protect your employees from falling is critical to a successful OSHA inspection. By following the steps above, you can help ensure you are prepared when OSHA eventually knocks on your door.
In addition to completing these steps, the single best way to protect your employees from falls is to choose a trusted safety equipment provider to deliver high quality equipment to your facility. For decades, safety managers and facility owners have turned to Fabenco for safety gates, safety lanyards, and other protective devices. We invite you to contact us to discover how we can help ensure you are ready when OSHA arrives at your facility.
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