Integrated Safety Management Systems
Inspecting a workplace after an accident may seem like a straightforward task. However, as an OSHA safety inspector, I will be looking for the risks or hazards that the SMS at the workplace has omitted. Hopefully, it will be a learning experience for everyone involved, and the workplace will be a safer place after the audit is complete.
Opening and Closing Conferences
Since the audit is an External Third Party audit, the auditor would be involved, the safety manager, and the employees involved such as the maintenance manager in the opening conference. The injured employee and the employees who witnessed the accident or had information about the accident or the forklift could be met with at another time. Other than those relevant employees, I would invite as many employees as wanted to be involved in the audit to join in though. McKinnon (2017) says, “As many employees as possible should be involved in the safety auditing process. This provides further training” (McKinnon, 2017, p. 91). I would also invite a mechanic from a neutral business so that there was a neutral expert on hand to look at the brakes on the forklift, but that would also be at another time before the audit. This way I would have the relevant reports and my own eye witness view of the setting of the accident.
For the closing conference, all those involved/interested would be invited. McKinnon (2017) says, “Once all the documentation has been reviewed and systems are verified, a feedback session is held with all concerned parties. Here, the auditors present feedback on the strengths and weaknesses of the system, and at the conclusion, announce the score for each section and the total for the entire safety system” (McKinnon, 2017, p. 95). The closing conference is where all parties find out the results of the audit, and that is important for everyone to know.
OSHA Standards
The OSHA standards that apply to the accident and should be considered in an OSHA compliance audit include 29 CFR 1910.78 for powered industrial trucks (PITs) also known as forklifts, which says, “All new powered industrial trucks acquired and used by an employer shall meet the design and construction requirements for powered industrial trucks established in the "American National Standard for Powered Industrial Trucks” (OSHA, 2003). The age of the forklift involved in the accident is unknown, but it should still comply with the OSHA standard.
Other OSHA standards related to the forklift come from the standard 1910.178q Maintenance of Industrial Trucks. Portions of that standard read: “1910.178(q)(1) Any power-operated industrial truck not in safe operating condition shall be removed from service. All repairs shall be made by authorized personnel” and 1910.178(q)(7) “Industrial trucks shall be examined before being placed in service, and shall not be placed in service if the examination shows any condition adversely affecting the safety of the vehicle. Such examination shall be made at least daily” (OSHA, 2019). While it is unclear if the employee injured in the accident inspected the forklift in compliance with the OSHA safety standard, but he did know that the brakes did not feel right.
Finally, another relative OSHA standard is one that applies to lighting, 1926.56 (a), which says, “General Construction areas, ramps, runways, corridors, offices, shops, and storage areas shall be lighted to not less than the minimum illumination intensities . . . while any work is in progress (OSHA, 2019). The illumination intensity in the area where the accident occurred is unclear.
Items to Look for to Determine Compliance
The first thing I would look for is the maintenance log on the forklift. Then I would ask to see if the inspection had been done on the day of the accident. I would want the mechanic to look at the brakes on the forklift and at other parts of it to determine if it was in safe working order. The next item that I would be sure to look at is the lighting in the area where the accident occurred. I would bring an illumination tester to see if the amount of lighting in the area (and in other areas of the facility) complied with OSHA’s standard. While touring the facility, I would also make notes about risks or hazards that I see.
Scoring System
While there are several ways to score items on an audit list. One way is just to say “go” or “no go,” but that is not detailed enough. A piece of equipment could have a problem but still be useable. I want that diminished level of acceptability noted and detailed further. That is why I would use the numbered scoring system that McKinnon (2017) describes. He says, “Some rank fulfillment of the requirements on a 1–10 scale, where (10) indicates complete compliance and (0), non¬compliance to the requirements of the standard. Others again use a 1–5 scale of measurement. A number must be allocated as managers understand numbers of measurement and what gets measured gets attention” (McKinnon, 2017, p. 87). I would use the 1-5 scale though because as the “go” “no go” system is not detailed enough, a 1-10 ranking is too detailed and may not be specific enough.
Feedback
The main feedback would be to impress upon employees that it is important that they report safety issues such as brakes and lighting immediately. They should also be documenting these issues. One of the employees that has used the forklift in question in the past noticed the problems with the brakes, and he should have reported this. If the maintenance manager was out sick, then the employee could have reported it to the next person up the management hierarchy. The same goes for the lighting. An employee says the area is not lit well, and others agree, then someone should have reported it. The issues with the difficulty in finding items in the area should have also been reported.
Another recommendation would be that management get involved with documenting the safety issues. Managers can inspect their areas for safety issues and report them too. If they do this, then their employees may follow suit because they are setting a good example for them. I would also recommend regular safety audits.
Some other specific recommendations include creating a daily inspection checklist for each forklift that employees who use the forklifts must go through, check off and sign their names to. This makes them more responsible for doing the daily safety inspections rather than telling someone after an accident that the brakes felt off on that particular forklift. One employee or manager could also be designated to check for issues such as lighting, supplies, and other related safety issues. If the supplies for a regular maintenance item such as bandages or eye wash is low, or if there are burned out light bulbs, or any other similar safety issue, this employee or manager would be responsible for documenting it and bringing it to the attention of the person responsible for replenishing those supplies. This assignment could be done on a rotating basis.
I would also recommend not asking an employee unfamiliar and untrained in a particular objective being sent to do a job that he or she is not qualified to do based on the lack of training. This is what happened with the injured employee in the accident in question. The confusion and the unfamiliarity of the area he was working in probably contributed to the accident.
Conclusion
Hopefully, despite what is discovered and who is held accountable for the accident, the employees of this facility will have learned that compliance with OSHA standards is important. Perhaps in the future they will document the issues they find, and report potential risks better. That way, the SMS at this particular workplace will be strong and no future accidents will occur.
References
McKinnon, R. C. (2017). Risk-based, Management-led, Audit-driven, Safety Management Systems. Boca Raton, FL: CRC Press/Taylor and Francis.
OSHA. (2003). OSHA compliance for powered industrial trucks (PITs). Retrieved from Occupational Safety and Health Administration: https://www.osha.gov/SLTC/powe...
OSHA. (2019). Illumination. Retrieved from Occupational Safety and Health Administration: https://www.osha.gov/laws-regs...
OSHA. (2019). Maintenance of industrial trucks. Retrieved from Occupational Safety and Health Administration: https://www.osha.gov/SLTC/powe...
