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Managing Safety on the Shop Floor

Kristen Butler, Senior Research Scientist

Georgia Tech Research Institute


Atlanta, Georgia

In May of 2011 OSHA announced a National Emphasis


Program (NEP) to identify and reduce or eliminate worker
exposures to harmful chemical and physical health hazards in
facilities in the Primary Metal Industries (OSHA.gov; CPL
03-00-013). This NEP, as well as others issued by OSHA,
was generated to address industries or areas of concern where
workers are exposed to specific hazards. This particular NEP
will be in effect for three years form the date of issuance,
ending in 2014. While this NEP targets the primary metals
industry, several prior national emphasis programs addressed
specific hazards related to die casting operations such as
those for the Hazard Communication standard and respiratory protection. In addition to the NEP there are also local
emphasis programs undertaken at the regional level which
may affect enforcement priorities. Specific employers may
also be targeted under the Site-Specific Targeted Program for
workplaces with the highest rates of injuries illnesses.
Die casting has been on OSHAs radar several years prior
to the formal issuance of this NEP and will continue to be
a focus of enforcement due to the relatively high injury and
illness rates for the industry. Trending upward since 2005,
the 2010 injury rate was 10.9 (SIC 331521) compared to
the overall industry rate of 3.5 (2010 & 2011)1. According
to the NADCAs own website, The frequency and injury
rates for the die casting industry are approximately twice
those of other private industries. OSHA has responded
and reported 18 inspections for 2012 (SIC 3315). (Note:
This figure does not include inspections conducted in states
with state run OSHA programs.)
Unlike many industries and manufacturing operations,
the die casting industry exposes employees to a wide variety of hazards. Whether it is a slip/trip hazard due to wet
conditions or a health hazard related to metal fumes, the
hazards must be controlled. In this article, we will look at
just a few of the potential exposures related to die casting
and the preferred methods for controlling such hazards.

Crush/Amputation Hazards
OSHA standards require employers take all necessary
steps to protect employees from coming in contact with
moving equipment, or parts. This can be done through
several different methods depending on operations and
may include, but not necessarily be limited to, guarding by
distance/location, fixed guards, or devices. Regardless of
the method, effective machine guarding will prevent haz-

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James B. Howry, Senior Research Associate

Georgia Tech Research Institute


Atlanta, Georgia

ards created by the point of operation, ingoing nip points,


rotating parts, flying chips and sparks.
Many amputation injuries are caused by not following
a set procedure designed to isolate equipment and render
it safe. When servicing and/or maintaining equipment,
employees must be protected from the unexpected energization or startup of equipment as well as be protected
from any potential energy sources. Referred to as Lockout Tagout (LOTO), or Hazardous Energy Control, an
established procedure is followed by authorized employees
prior to beginning work. In addition to a written lockout
tagout program, equipment specific procedures must be
developed and audited annually. These equipment specific
procedures shall clearly and specifically outline the scope,
purpose, authorization, rules, and techniques to be utilized
for the control of hazardous energy, and the means to
enforce compliance. [29 CFR 1910.147(c)(4)(ii)] The most
important step is verification of isolation where prior to
commencing work, the equipment is checked to ensure it is
properly isolated from all potential energy sources and that
any stored energy has been dissipated.
When it comes to interacting with a piece of equipment, employees must be trained commensurate with
the employers expectations as authorized; or affected
employees. The standard requires they are trained to
understand the hazards associated with the machines,
energy sources and appropriate control methods. When
multiple employees are engaged in servicing and/or maintenance operations, each employee must be afforded the
same level of protection. One person, one lock!

Fall Hazards
Most die casting operations do not involve working aloft, and
yet fall hazards continue to be cited by OSHA during inspections. Exposures range from issues with walking and working
surfaces creating slip/trip hazards, to employees working
on equipment being exposed to falls greater than four feet.
Walking and working surfaces must be kept in good working
condition and in good repair at all times. As difficult as this
may be we also need to work to eliminate wet areas through
appropriate drainage, grates, or other effective means. Spills
must be cleaned up quickly and steps should be taken to
repair any leaking (i.e. hydraulic oil) equipment.
OSHAs standards for general industry require employees
be protected from falls greater than four feet, or any case
www. diecasting.org/dce

where they may encounter dangerous equipment. While


maintaining or servicing equipment, employees should not
be allowed to climb on the equipment and instead should
be provided with a suitable working platform. This may
include catwalks with standard rails, fixed stairs or movable stair towers, or ladders. The only alternative is to ensure
when employees are exposed to falls, they are tied off using
a suitable fall arrest system tied to appropriate anchor points.
Since most exposures to fall hazards occur while performing
servicing and/or maintenance on equipment, it would be best
addressed in a pre-job meeting, or job hazard analysis (JHA).

to prevent injuries. The general duty clause describes the


employers obligation to furnish to each of his employees
employment and a place of employment which are free from
recognized hazards that are causing or are likely to cause
death or serious physical harm to his employees. This clause
from the OSH Act is utilized to cite serious hazards where no
specific OSHA standard exists to address the hazard, as is the
case with ergonomic stressors.

Health Issues
Material Handling
The handling, moving and storage of equipment, known
as material handling creates a number of exposures in the
workplace. Industrial lift trucks account for roughly 85
fatal accidents per year. In terms of serious injury, 34,900
are injured, with another 61,800 classified as non-serious
in the workplace each year. These numbers indicate over
11% of all forklifts in the United States will be involved in
some kind of accident each year. 2 Due to the wide variety
of lifts and operations it is difficult to address each specific
hazard. In order to address this, OSHA requires all forklift operators to be properly trained. This training must
include some type of classroom or lecture based training
(CBT is acceptable), practical training to hone an operators skills, and an evaluation. The evaluation must be done
on a lift similar to the one to be operated and in a similar
environment to which the operator will be exposed. The
evaluation must be completed every three years.

Ergonomics
According to the BLS, approximately 36% of nonfatal injuries
in the die casting industry are strains and sprains.3 The risk
factors for strains and sprains found in die casting facilities
include physical factors (heavy loads, pushing/pulling, highfrequency repetitive lifting, awkward postures, excessive work
duration); and environmental factors (heat, high humidity,
noise, poor lighting). Good ergonomics can eliminate or
reduce exposure to nearly all of the physical risk factors in the
workplace. A comprehensive ergonomics program includes
training to increase ergonomic awareness, identifying risk
factors in the workplace that are causing injury and discomfort, giving workers input into how they do their jobs, and
developing ways to control ergonomic hazards by modifying
equipment and the organization of work. OSHAs current
ergonomics inspection plan prioritizes inspection of high
injury workplaces in industries which have been identified as
having a significant number of injuries related to ergonomic
hazards. OSHAs plan to reduce ergonomic hazards calls for
enforcement under the general duty clause where ergonomic
hazards exist and employers are not making good-faith efforts
www. diecasting.org/dce

Less obvious but just as important as safety hazards, a


variety of occupational health hazards are associated with
die casting operations, including: worker exposures to
metals, acids, heat stress, and noise. Exposures to these
physical and chemical hazards can cause occupational
illness in employees. The processing of metal castings
through heating, grinding, cutting, sanding, etc., can cause
unhealthy levels of metal fumes and/or dust in the air and
on surfaces. Exposures to certain toxic metals, commonly
referred to as heavy metals, can cause nervous system
disorders, organ damage, and cancer. Acid exposures can
occur when dies are cleaned in a hot acid bath. Sulfuric
acid can cause severe damage to skin and eyes, erosion
of teeth, irritation of the nose and throat, and difficulty
breathing. Good industrial hygiene practices recommend
that engineering controls (enclosures, ventilation, substitution, etc.) be used to reduce environmental concentrations
to below the permissible exposure limits for metals and
acids. Both the process of heating metal and the acid bath
create a hot environment where heat stress may occur.
Long sleeves, long pants, and personal protective equipment all impair the bodys ability to regulate temperature,
making it imperative that new employees working in hot
areas be allowed time to acclimate, and that all employees
be provided access to drinking water and break time to
move away from heat sources. Exposure to high levels of
noise in die casting can cause impaired communication,
hypertension, heart disease, and hearing loss.
Properly assessing these exposures requires an industrial hygiene survey including air and noise monitoring.
If monitoring results reveal that employees are being
exposed above permissible or recommended exposure
limits, OSHA requires that engineering controls (substitution, enclosures, ventilation, etc.) be used to reduce
exposures whenever they are feasible to reduce overexposures. Permissible exposure limits (PELs) are the regulatory limits set by OSHA that employers are required to
meet. PELs have not been established for all air contaminants, and in some cases the exposure levels set by
the PELs are not sufficient to protect employees from
developing occupational disease. In those cases, guidance
limits set by agencies such as the American Conference
of Governmental Industrial Hygienists (ACGIH) should
be referred to and considered best practice. Whenever
engineering controls are insufficient or infeasible to reduce
exposures, other protective measures like job rotation and
personal protective equipment must be used.
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Combustible Dust

Training

In addition to being a health concern, metals in molten


form or as fine particles present varying degrees of
combustion risk. In powder form, most metals are combustible to a varying degree, depending on the physical
conditions. In addition to being subject to spontaneous heating, dust explosion, or ignition, some metals
also undergo dangerous reactions with water, acids, and
certain other chemicals. In order to prevent fires and
explosions, facilities should implement work practices and
procedures like appropriate housekeeping, fugitive dust
control, and safe handling of fine particles. Outside of
normal die casting processes, combustible metals should
not be exposed to sources of heat, open flames, or sparks.
Excess metal chips, fines, ribbons, or other leftover pieces
from processes should be immediately collected and
properly stored or discarded. Housekeeping is critical to
safety and the prevention of dust explosions in the die
casting industry. Dust accumulations must be prevented
through systematic cleaning, and inspections should be
conducted frequently to ensure there is no accumulation
of combustible metal chips, powder or dust. Other factors
to consider include control of ignition sources, emergency
plans and procedures, and appropriate extinguishing
agents. While OSHA does not have a standard specifically addressing combustible dust hazards, the agency has
identified relevant existing standards that can mitigate
combustible dust hazards, and is promoting enforcement of these standards through the Combustible Dust
National Emphasis Program (NEP). The most frequently
cited violations under the Combustible Dust NEP have
included Hazard Communication (1910.1200), Respiratory Protection (1910.134), Housekeeping (1910.22),
Electrical Safety (1910.305 and 303) and Lockout/
Tagout (1910.303).

Employers are required to provide training to all employees


so they can recognize, avoid, and potentially abate hazards in
the workplace. The specific nature of the hazards will depend
on manufacturing, die casting, and finishing processes and
will require a detailed hazard analysis to determine. This may
be done through the use of Job Hazard Analysis (JHA) or
Job Safety Analysis (JSA) or several other methods designed
to look at facilities, equipment, and processes. Once this has
been completed training can be designed to address immediate and anticipated hazards. Hazard Communications,
Machine Guarding, Lockout Tagout, and Personal Protective
Equipment training will no doubt be paramount. OSHA
requires the company to provide employees training prior
to exposing them to hazards and in many cases provide an
annual update or refresher training.

Controlling Hazards
Companies must Recognize, Evaluate, and Control hazards in the workplace. Due to the wide variety processes
and operation it is imperative manufacturers conduct a full
hazard assessment to identify (recognize) the hazards. This
assessment should include facilities, equipment, and manufacturing processes to identify all known and potential
hazards. Once identified, steps should be taken to control
the hazards using the hierarchy of controls.
Eliminate

Substitute

Engineering Controls

Administrative Control
Work Practices
PPE

It is often helpful to employ subject matter experts and/ or


an independent third party to provide the necessary assistance.

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Safety Management Systems


The most effective and sustainable way to create a safe
working environment and avoid unexpected occurrences
is through the implementation of a safety management
system. For far too long we have treated the elements of our
safety programs and injuries and illnesses in the workplace
as discrete events. It is as if machine guards are removed by
hapless employees lacking supervision and accidents occur
due to individual employee behaviors when that isnt really
the case. Often the law of unintended consequences is at
play. Managers errantly create a culture where safety is a
necessary evil and not a true business process.
Catastrophic accidents and injuries are most likely to occur
when there is a lack of, or a breakdown in, a companys safety
and health management systems. A strong culture of safety
starts with strong leadership. We are going to look at ways to
take proactive steps to mitigate hazards in the workplace by
having a strong safety and health management system.
OSHAs approach to safety management systems (SMS)
consists of four basic guidelines: Management Commitment &

Value Added by Safety


Management Systems (SMS)
Defines SAFETY as a business process
Horizontally integrates business units
Continual Improvement Process
Plan-Do-Check-Act
Compatible with ISO 9000/14000
(QA & EMS)
Suited for a variety of organizational structures
Proactive risk assessment
Provides for efficient allocation of resources

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Employee Involvement; Worksite Analysis; Hazard Prevention & Control; and Safety & Health Training. Each of these
guidelines has several embedded guidelines to help the user
along with the process. This model lays the foundation for what
OSHA sees as a successful safety and health program and the
backbone for the Voluntary Protection Program (VPP).4
Other safety management system models exist; including
OHSAS 18001 and ANSI/AIHA Z10, which each rely on
process development and documentation to define safety
as a business process and to ensure continual improvement.
Each has its own merits and can provide a model by which
a company can develop their own effective system of safety
and health management. The most effective approach would
be to take tenets from each on their own merits.
Safety Management Systems provide a systematic
approach to evaluating and controlling risk in the workplace.
In an era of limited resources the implementation of a strong
safety management system keeps safety at the forefront by
making it a part of our business processes. From ANSI Z10
to OHSAS 18001, companies with an SMS experience the
benefits as pertains to OSHA citations and exposure, and
the overall bottom line of the company.
Resources
G
 eorgia Tech Research Institute
www.oshainfo.gatech.edu
Georgia Techs OSHA Training Institute
www.pe.gatech.edu/gt-oti
OSHA
www.osha.gov
State Consultation Programs
www.osha.gov/dcsp/smallbusiness/consult.html
Industry Organizations such as NADCA
References
1 Bureau of Labor Statistics; News Release,
USDL-12-2121, Thursday, October 25, 2012
2
 Emery I Reddy, July 7, 2011, OSHA Focuses
on Forklift Hazards.
www.emeryreddy.com/2011/07/osha-focuses
-on-forklift-hazards
3 BLS, Percent Distribution of nonfatal injuries and
illnesses, 2011. Table R113.
www.bls.gov/iif/oshwc/osh/case/ostb3315.pdf
4 United States Department of Labor/Occupational
Safety and Health Administration.
www.osha.gov/SLTC/etools/safetyhealth/index.html
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About the Author

James Howry, MSM, CUSA, is a Senior Research Associate


at the Georgia Tech Research Institute providing research and
consulting services in the field of occupational safety and health
and management systems. He is also an instructor and course
director at Georgia Techs OSHA Training Institute. Jim can
be reached at jim.howry@gtri.gatech.edu.
Kristen Butler, CIH, is a senior research scientist at the
Georgia Tech Research Institute. She serves as an industrial
hygiene consultant for Georgias OSHA Consultation Program
and a course director and instructor for several courses at
Georgia Techs OSHA Training Institute. She can be reached at
kristen.butler@gtri.gatech.edu.
www. diecasting.org/dce

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