Unit I Assignment

Instructions: This assignment involves reading a case and then helping an organization by identifying the
training needs to meet OSHA requirements. This assignment provides you with an opportunity to
demonstrate the following course learning outcome:

1. Explain safety and health training requirements specified by standard setting organizations.

Read the case below, complete the table below, use the OSHA publication as a guide, save all of your
work to this document, and submit it in Blackboard for grading.

Background on Carter’s Material Handling Equipment Manufacturing Company

Carter’s Materials Handling Equipment Company is a small business that employs between 38 and 55
employees throughout any given year. This firm manufactures materials handling equipment that includes
small cantilever racks, hand trucks, and various dollies commonly used in the manufacturing sector. The
facility was built in 1958 and is roughly 80,000 square feet. The firm receives raw materials in the form
of round metal tubing, sheet metal, square tubing, and cold and hot rolled metal rods.

Raw materials are removed from flatbed trailers using a large, LP-gas-powered forklift with the assistance
of smaller, LP-gas-powered forklifts. These materials are stored in racks in the receiving/shipping
department. From there, raw materials are moved via forklift and various heavy duty carts to the
fabrication department. This department cuts, punches, bends, copes, and shears the various materials into
parts used to make the final product.

The metal fabrication department includes two 70-ton, part revolution mechanical power punch presses,
three 250-ton, part revolution press brakes, a 300-ton hydraulic press, two pipe benders, a twelve-foot
shear, a 10-foot shear, a mill for milling a bevel on hand truck toe plates, several off-hand grinders, and
two large drill presses. The fabrication department can get quite noisy for days at a time (>85 dB),
especially when making cantilever racks. The department includes maintenance workers to keep the
machines running.

After being cut, punched, bent, and formed, fabricated parts go to the welding department or the Work in
Process (WIP) crib. WIP includes a mezzanine and an area populated with pallet racks for storage.
In the welding department, there are 12 MIG welding machines that are used by welders to assemble the
parts into the pre-finished items manufactured by the firm. The welders also use an assortment of hand-
held grinders and an oxyacetylene torch. Once welded, items either go in their pre-finished condition into
inventory, or are further processed by the painting department. Pre-finished items that are inventoried are
taken to one of two mezzanines or placed in storage racks. In the painting department, items are wiped
down with various solvents and hung on an overhead hook conveyor. Items go into the paint booth where
they are painted using various enamels. Xylenes and Toluene are common solvents used in this operation.
The paints also contain these solvents.

After painting, axles and wheels are applied, and the completed products are boxed up in the
shipping/receiving department or, depending on their size, loaded directly on trucks with no packaging.
Larger items, such as racks, are loaded onto flatbeds using an unmanned overhead crane controlled by a
pendant control. Smaller items are typically loaded onto standard semi-trailers using battery-powered
forklifts or pallet jacks.

Page 1 of 4
Carter’s OSHA Form 300 log of injuries and illnesses for the past year reveals that eight employees
experienced minor injuries (cuts) from handling metal parts, one employee lost 15 workdays after getting
debris in his eye while grinding, six employees lost two days each due to back strains, and four welders
were treated for minor burns.

The human resources manager provided you with this additional information about the departments and
their employees:
 Shipping/Receiving Department: 60% male, 40% female. Age range 18-62. 80% have completed
high school; some attend junior college. Temporary employees are added when production is
high, usually in summer
 Metal Fabrication Department: 80% male, 20% female. Age range 30-45. All have completed
high school and some have junior college technical training.
 Welding Department: 50% male, 50% female. Age range 25-50. All have completed high school
and all have completed junior college technical training.
 Painting Department: 30% male, 60% female. Most have completed high school. Some are
attending college, pursuing bachelor’s degrees.

While all employees understand and speak English, several employees in the Shipping/Receiving
Department use Spanish as their primary language. All employees work 7 AM – 4PM with a one-hour
lunch break, Monday through Friday. On Saturday, overtime is worked at peak production times, usually
in the summer. The shop is not unionized, and employee relations are good. The annual employee
turnover is 5%. The average employee has worked for Carter for 6.5 years. Some employees have worked
for Carter for more than 15 years.

Instructions for completing the table below: You have been hired by Carter to develop an effective safety
training program for his employees. Carter is concerned about being in compliance with regulations and
standards, so your first task is to identify 10 training requirements from the OSHA standards that apply to
Carter’s operations. Carter’s operation will be required to meet more than 10 OSHA standards; however,
your job is to identify what you feel are the 10 most important. List the 10 requirements in the order in
which they should be developed and specify which department(s) should receive the training. Then,
provide a brief justification (rationale) for each training requirement identified—why is it one of the most
important?

Use the following publication as your guide: Training Requirements in OSHA Standards (OSHA
Publication No. 2254-07R 2015).

Training Need OSHA Standard Justification

1. Welders and supporting staff
should be trained frequently
and comprehensively in the
operation of portable fire
extinguishers, standpipe and
hose systems, fire detection
systems and fixed extinguishing
systems.
2. The metal fabrication
29 CFR 1910 Subpart L
1910.155 Fire protection
1910.156 Fire brigades
1910.157 Portable fire
extinguishers
1910.158 Standpipe and hose
systems
1910.160 Fixed extinguishing
systems
1910.164 Fire detection systems
1910.165 Employee alarm
systems
Subpart O - Machinery and
Page 2 of 4
The welders use an assortment
of hand-held grinders and an
oxyacetylene torch, which pose
potential fire hazards that
should be effectively managed
through adequate fire
protection, fire brigades,
portable fire extinguishers and
fire detection systems.
In the past year, four welders
were treated for minor burns.
The metal fabrication
department should be trained to
safely operate and assess risks
for mechanical power presses
and forging machines.
3. All employees should be
trained and familiarized on key
emergency action and fire
prevention plans, as this has the
potential to impact large areas
of the facility.
4. Welders, cutters and support
staff in the welding department
should be trained in rules and
instructions for safe operation
and maintenance of oxygen or
fuel-gas supply equipment, and
instructed and qualified
adequately to operate such
equipment.
5. Industrial truck operators and
overhead crane operators
should be instructed, certified
and trained in the safe operation
of truck loading and overhead
crane operation.
6. Painters exposed to airborne
concentrations of xylenes and
toluenes should be issued with
appropriate personal protective
equipment, and made aware of
the health effects, presence,
quantity, location and
Machine Guarding
1910.217 Mechanical power
presses
1910.218 Forging machines
29 CFR 1910 Subpart E
1910.38 Emergency action plans
1910.39 Fire prevention plans
29 CFR 1910 Subpart Q
1910.252 General Requirements
1910.253 Oxygen-fuel gas
welding and cutting
29 CFR 1910 Subpart N
1910.178 Powered industrial
trucks
1910.179 Overhead and gantry
cranes
29 CFR 1910 Subpart Z - Toxic
and Hazardous Substances
Page 3 of 4
department includes two 70-
ton, part revolution mechanical
power punch presses, three 250-
ton, part revolution press
brakes, a 300-ton hydraulic
press, two pipe benders, a
twelve-foot shear, a 10-foot
shear, a mill for milling a bevel
on hand truck toe plates, several
off-hand grinders, and two large
drill presses.
In the past year, eight
employees experienced minor
injuries (cuts) from handling
metal parts.
The welders also use an
assortment of hand-held
grinders and an oxyacetylene
torch.
In the past year, four welders
were treated for minor burns.
In the welding department,
there are 12 MIG welding
machines that are used by
welders to assemble the parts
into the pre-finished items
manufactured by the firm.
In the past year, four welders
were treated for minor burns.
After painting, axles and wheels
are applied, and the completed
products are boxed up in the
shipping/receiving department
or, depending on their size,
loaded directly on trucks with
no packaging. Larger items,
such as racks, are loaded onto
flatbeds using an unmanned
overhead crane controlled by a
pendant control.
Items go into the paint booth
where they are painted using
various enamels. Xylenes and
Toluene are common solvents
used in this operation. The
paints also contain these
solvents.
engineering controls used to
mitigate the health impacts of
said exposure.
7. All facility employees should
be provided with hearing
protectors, and should
participate in hearing
conservation and awareness
programs on the impacts of
noise on hearing, and the
purpose and correct use of
hearing protectors.
8. Operators of LP-gas-powered
forklifts should be trained in the
safe operation of powered
platforms for storage and
transport of materials.
9. Operators of battery powered
forklifts or pallet jacks should
be trained on safe and insulated
operation of electrical
equipment.
10. A first aid team should be
trained onsite, and a nearby
infirmary, clinic or hospital
should be designated for the
rapid evacuation and treatment
of personnel injured at the
workplace.
29 CFR 1910 Subpart G
1910.95 Occupational Noise
Exposure
29 CFR 1910 Subpart F
1910.66 Powered platforms for
building maintenance
Subpart S - Electrical Safety-
Related Work Practices
1910.332 Training
29 CFR 1910 Subpart K
1910.151 Medical services and
first aid
Page 4 of 4
The fabrication department can
get quite noisy for days at a
time (>85 dB), especially when
making cantilever racks.
Raw materials are removed
from flatbed trailers using a
large, LP-gas-powered forklift
with the assistance of smaller,
LP-gas-powered forklifts.
These materials are stored in
racks in the receiving/shipping
department. From there, raw
materials are moved via forklift
and various heavy duty carts to
the fabrication department.
Smaller items are typically
loaded onto standard semi-
trailers using battery-powered
forklifts or pallet jacks.
Carter’s OSHA Form 300 log
of injuries and illnesses for the
past year reveals that eight
employees experienced minor
injuries (cuts) from handling
metal parts, one employee lost
15 workdays after getting
debris in his eye while grinding,
six employees lost two days
each due to back strains, and
four welders were treated for
minor burns.