osha red flags for safety

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OSHA Red Flags for Safety. For Construction at YOUR Pharmaceutical Facility Tom Moon, MS Safety Manager, Torcon, Inc. The Pharma Industry is Very REGIMENTED. FDA Regulations 21 CFR 210 and 211 Federal and State Environmental Regs OSHA Safety Standards 29 CFR 1910 - PowerPoint PPT Presentation

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  • OSHA Red Flags for SafetyFor Construction at YOUR Pharmaceutical Facility

    Tom Moon, MS Safety Manager, Torcon, Inc.

  • The Pharma Industry is Very REGIMENTEDFDA Regulations 21 CFR 210 and 211

    Federal and State Environmental Regs

    OSHA Safety Standards 29 CFR 1910

    Your companys internal protocols and SOPs Usually MASSIVE

  • In this maze of detailed procedures,Its easy to miss the FOREST for the TREES

  • Compartmentalized Thinking

    Keep SAFETY IN MIND!

  • Goals for This PresentationMake you cognizant of Red Flags

    For SAFETY in your facility

  • Ignoring these Red Flags can cost your company . . .Cause injuries to people you work with

    Cost people their lives or careers

    Cause shutdowns, wasted or adulterated product

    OSHA Violations and fines

    Bad Publicity for your organization

  • About 700 Pharma Facilities have been Inspected by OSHA Since 2000Inspections occur for three reasons:

    Random inspections

    Programmed inspections For critical or at-risk industries

  • OSHA Inspections can be generated from your operations by . . .

    Serious employee injuries or fatalities

    Complaint of a serious hazard from an employee or member of the public

    Referral from DEP, Local Government agency, or interest group

  • Pharma has a lot of hazardsFor FY 2008, of the top 20 most cited types of OSHA Violations . . .

    18 of the top 20 violations can occur in a pharmaceutical research lab or manufacturing plant

    Laboratories Manufacturing Lines Maintenance Facilities Vehicles

  • Construction is hazardous, tooOf the top ten most cited violations by OSHA in FY 2008:

    Five of the top ten occur in

    Both CONSTRUCTION and

    PHARMACEUTICAL OPERATIONS

  • The OSHA Red Flags come in two types

    Specific Construction Activities

    Failure to do Due Diligence in Safety Procedures during Construction

  • Fall Protection

  • The Last Lunch Time

  • Motor Vehicle Accidents#1 Cause of Fatalities in ALL Industries

    # 3 Cause in Construction

  • Preventing Vehicle AccidentsPharma Company in 5 years cut vehicle accident costs in half with:Extensive training of newer drivers (most crashes during first 5 years driving)

    Graduated warnings/disciplinary actions for minor infractions

    Periodic retraining of drivers, esp. following any minor incident

  • Crane Lifts

  • Crane Lifts

  • Tie-Ins to Existing SystemsLockout/Tagout ProgramCoordination of ShutdownsPre-job meetings to clarify procedures

    Direct communication from construction foremen to owners facilities/operations personnel

    Incident of The Unopened Email

  • Safety Training of Contractors

  • Exposure of Plant Employees to Construction HazardsNotify your employees of construction in their areas

    Barricade and place clear signage around hazardous construction activities

    Discipline employees that ignore barricades

  • Process Safety Management: Integrate Construction Activities into Your Existing PSM ProgramOSHA Concern: Are contractors doing the work qualified to work on systems?

    Include the general contactor in your design review and subsequent Haz/Ops reviews

    Keep your construction contractors in the loop of your PSM activities and info

  • Spill Reporting and CleanupWritten procedures for timely reporting and remediation of hazardous material releases for contractors

    Your companys reputation as a good corporate citizen with government agencies and the public - if you lose it, you cant get it back

    The common theme of many of these critical issues is . . .

  • Communication between Facility Owners and ContractorsIs the key to safety coordination of dangerous construction activitiesKeeps your workers safeHelps prevent injuries and major incidents that come across as RED FLAGS to OSHA

  • Thank You! I hope weve helped to expand your mind today!

    *Ideally, barricades prevent access to the skylights. If covers are provided, they must support twice the intended load.The photo on the right is from a fatality investigation, where an employee sat on the skylight to eat his lunch, and fell through.