Michigan Occupational Safety and Health Act (MIOSHA) Vol. 6, No. 4 Fall 2002 Cont. on Page 18 In This Issue Director’s Column 2 Dow Ludington - MVPP 3 Deceptive Marketing 4 Minor Tool Changes 5 Ergonomics Case Study 6 The Bottom Line 7 Plastics Safety Challenges 8 CET Grants 9 MVPP Strategies for Change 10 Wheel Chocks Clarification 11 Steel Erection Implementation 11 CET Awards 12 Education & Training Calendar 13 Standards Update 14 Variances 16 BSR Award Winners 17 By Richard J. Mee, Chief Construction Safety Division Tanya Loewen Memorial Sign, erected by co-workers on I-94 near the site of the work zone accident that took her life. R OADWAY W ORK Z ONES A Most Dangerous Place to Work The atmosphere was almost eerie. I couldn’t hear the breeze blowing, although I could feel it on my face. I didn’t hear the engines of the large plane that I saw flying low overhead as it pre- pared to land at a nearby airport. My senses were distorted. The ominous noises of passing traffic, roaring engines, turning wheels, and tires slap- ping pavement joints were a stark contrast to the clear and otherwise peaceful late summer day. The constant din of passing cars and trucks made the ordinarily loud construction equipment seem quieter somehow. Every few moments, the sound of vehicle brakes caused heightened aware- ness and occasionally screeching tires caused me to react with a jerk and quickly turn around to see if a vehicle might be out of control, heading my way. I was in a freeway work zone. Insulated inside their protective vehicle, most people don’t have the opportunity to ex- perience working in close proximity to high- speed traffic. The noise is overwhelming. Of- ten, you have to yell in a loud voice to commu- nicate. The noise of the traffic doesn’t take breaks, stop for lunch, or leave at quitting time. The continuous stream of traffic can be unnerv- ing; and it can be fatal. It Happened Again On Friday, August 9th, it happened again. A car left the traveled lanes of the roadway on I- 94 in Macomb county and struck the traffic con- trol device that two workers were installing on the shoulder of the freeway. The impact killed Tanya Loewen instantly, and critically injured Bill Hattan. Tanya Loewen, a 26-year-old civil engi- neer, was a graduate of the University of Saskatchewan, Canada. While at the university she took a special interest in traffic safety. Her experience included employment with an engi- neering firm in Scotland. She was employed by International Road Dynamics (IRD) on a contract with the Michigan Department of Trans- portation to install trailer- mounted computerized safety systems on I-94. “She was doing what she believed in. She was installing equipment for workers’ safety on the highway,” said her boss, Terry Bergan, president and CEO of IRD. Her employer saw her as a dedicated and enthusi- astic civil engineer. Better traffic control de- vices are evolving with each passing year and recent im- provements have helped to en- hance worker and motorist
Transcript
Michigan Occupational Safety and Health Act (MIOSHA)Vol. 6, No. 4 Fall 2002
Cont. on Page 18
In This IssueDirector’s Column 2
Dow Ludington - MVPP 3
Deceptive Marketing 4
Minor Tool Changes 5
Ergonomics Case Study 6
The Bottom Line 7
Plastics Safety Challenges 8
CET Grants 9
MVPP Strategies for Change 10
Wheel Chocks Clarification 11
Steel Erection Implementation 11
CET Awards 12
Education & Training Calendar 13
Standards Update 14
Variances 16
BSR Award Winners 17
By Richard J. Mee, ChiefConstruction Safety Division
Tanya Loewen Memorial Sign, erected by co-workers on I-94 near thesite of the work zone accident that took her life.
ROADWAY WORK ZONESA Most Dangerous Place to Work
The atmosphere was almost eerie. I couldn’thear the breeze blowing, although I could feel iton my face. I didn’t hear the engines of the largeplane that I saw flying low overhead as it pre-pared to land at a nearby airport. My senses weredistorted. The ominous noises of passing traffic,roaring engines, turning wheels, and tires slap-ping pavement joints were a stark contrast tothe clear and otherwise peaceful late summerday.
The constant din of passing cars and trucksmade the ordinarily loud construction equipmentseem quieter somehow. Every few moments, thesound of vehicle brakes caused heightened aware-ness and occasionally screeching tires caused meto react with a jerk and quickly turn around to seeif a vehicle might be out of control, heading myway. I was in a freeway work zone.
Insulated inside their protective vehicle,
most people don’t have the opportunity to ex-perience working in close proximity to high-speed traffic. The noise is overwhelming. Of-ten, you have to yell in a loud voice to commu-nicate. The noise of the traffic doesn’t takebreaks, stop for lunch, or leave at quitting time.The continuous stream of traffic can be unnerv-ing; and it can be fatal.It Happened Again
On Friday, August 9th, it happened again.A car left the traveled lanes of the roadway on I-94 in Macomb county and struck the traffic con-trol device that two workers were installing onthe shoulder of the freeway. The impact killedTanya Loewen instantly, and critically injuredBill Hattan.
Tanya Loewen, a 26-year-old civil engi-neer, was a graduate of the University ofSaskatchewan, Canada. While at the universityshe took a special interest in traffic safety. Herexperience included employment with an engi-neering firm in Scotland. She was employed by
International Road Dynamics(IRD) on a contract with theMichigan Department of Trans-portation to install trailer-mounted computerized safetysystems on I-94.
“She was doing what shebelieved in. She was installingequipment for workers’ safetyon the highway,” said her boss,Terry Bergan, president andCEO of IRD. Her employer sawher as a dedicated and enthusi-astic civil engineer.
Better traffic control de-vices are evolving with eachpassing year and recent im-provements have helped to en-hance worker and motorist
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From the
Bureau
Director’s
DeskBy: Douglas R. Earle, DirectorBureau of Safety & Regulation
Thank You
for All the
Wonderful
Years!
Farewell MIOSHAAs some of you know, I will be retiring on October 31, 2002. I
have been privileged to serve as Director of the Bureau of Safety andRegulation (BSR) since 1979. I’ve had the opportunity of working inthe MIOSHA program with the most dedicated and capable staff thatanyone could possibly have.
Although I must admit there have been stressful times during mytenure, for the most part, every minute of every day has been reward-ing. To have the opportunity to work in an organization whose missionand noble purpose is that of protecting human lives, health and safetyhas been a blessing from God. I have also had the privilege of knowingthat I have made a positive difference in peoples lives.New Standards to Improve MIOSHA
Standards do make a difference. First they protect workers, whichis our primary mission. And secondly, they give the regulated commu-nity specific notice of their responsibilities. Leaving enforcement in someof these areas to the “general duty” requirements has failed. It simplydoesn’t work effectively in most cases, and it certainly provides employ-ers with little specificity concerning their responsibilities.
Specifically, I would like to see MIOSHA promulgate the follow-ing standards. In Construction Safety there is a need for standards toaddress: Sanitation, Communication Tower Erection, and Lockout/Tagout for construction. Moreover, the varying array of heights for fallprotection in construction is confusing and not effective. I believe thata seven foot requirement for using fall protection for all constructionworkers, regardless of trade or job activity, should be promulgated byMIOSHA and OSHA.
In General Industry Safety the following standards are needed:Vehicle Safety and Violence in the Workplace. With regard to Occupa-tional Health, standards are needed for: Biological Hazards and Expo-sure to Isocyanates, In all three areas, there is a need for an Ergonom-ics standard, and a Workplace Safety and Health Program standard.New Legislation to Improve MIOSHA
Over the years, MIOSHA has been instrumental in helping Michi-gan employers provide safe and healthy workplaces. There is, how-ever, always room for improvement. The legislation suggested belowwould help employers provide a safe and healthy workplace.
� Require those who produce products, and more importantly,those who design systems, to incorporate worker safety and health pro-tection as part of their product or system design. Retrofitting to im-prove worker safety and health is inefficient, often unsuccessful, and,in many cases, impractical. MIOSHA should not, however, have anypre-approval and/or licensing authority for such products or systems.
� Workers’ compensation laws need to be amended to provide foran “integrated disability management” approach to compensate injuredworkers for lost wages and medical costs. At Steelcase in Grand Rap-ids, any worker who is injured, regardless of where the injury occurred,is compensated for lost wages and any medical costs based upon the
injury or illness. Such an approach would eliminate the arguments re-garding where did the injury occur, what was the source of the injury,and who is responsible for the associated costs. These all present ob-stacles to OSHA in attempting to administer workplace safety and health.
� Legislation is needed to provide employer incentives for achiev-ing workplace safety and health beyond those already available, suchas: lowered costs, rebates, insurance, and increased productivity. Addi-tional incentives could take the form of tax incentives or other positiveincentives that employers could obtain for achieving improved occupa-tional safety and health.
� Owners and general managers must be made responsible underOSHA and MIOSHA for hazards that their actions create. This is par-ticularly obvious in construction where owners and general contractorsoften set unrealistic deadlines for the completion of work. This placesthe subcontractors in an extremely difficult position, indeed, an almostuntenable position. There needs to be a way under the OSHA Act, orperhaps through some other means of negative taxation, to hold theemployer, owner, general manager, general contractor responsible.
An area that needs close examination is the practice by departmentsof transportation, including the Michigan Department of Transportation,of providing early completion incentives to contractors for highway con-struction jobs. In my view, this practice has led to a number of injuriesand fatalities in the last several years in highway construction in Michi-gan. Either the practice needs to be refined so that it does not lead tounsafe practices in its application, or it needs to be eliminated.The Future of Workplace Safety and Health
MIOSHA has made a remarkable impact on worker health and safetyin this great state. Injury and illness rates have gone down along withworkplace fatalities. Indeed, MIOSHA has helped reduce program-re-lated fatalities nearly 50 percent, since we began tracking them with auniform system and definition in 1976.
Many old hazards have been reduced significantly or eliminatedall together. Regrettably, many new hazards have taken the place ofthose we have helped to conquer. Many more challenges lie ahead. Anumber of us still believe that zero injuries, as well as zero fatalities, isachievable and must remain our ultimate goal. With high quality andcommitted staff, MIOSHA and federal OSHA have a bright future intheir quest to help employers and employees reduce injuries, illnesses,and fatalities in the workplace.
I am pleased to announce that Douglas Kalinowski will becomethe BSR Director when I retire. He has been the BSR Deputy Directorof Compliance since 1996. Doug is a dedicated professional who, alongwith the rest of the MIOSHA staff, will work diligently to help employ-ers and employees provide a safe and healthy work environment.
I am moving on now to other challenges in life. I must, therefore,say farewell as Director of the MIOSHA program. Thank you for all thewonderful years! God Bless you All and God Speed.
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Congratulations Dow Ludington!
�
Dow Cal/Mag Ludington Plant becomes the first chemical manufacturer in the state to receive the MVPP Star
Employees, elected officials and guests celebrated the presentation of the MVPP Staraward to Dow Chemical Company’s Cal/Mag Ludington Plant.
CIS Deputy Director Kalmin Smith (far R.) presented the MVPP StarFlag to (from L.) Abe Williams, Allen Arneson, Lisa Rokosky, JeffContardi, Rick Treesh, and Greg Dykstra.
Dow Chemical Company’s Cal/MagLudington Plant has become the first chemicalmanufacturer in the state to receive the presti-gious Michigan Voluntary Protection Programs(MVPP) Star award for workplace safety andhealth excellence. CIS Deputy Director KalminSmith presented the Star flag at a special cer-emony today on behalf of the Michigan Depart-ment of Consumer & Industry Services (CIS).
“The Dow Chemical Company is an out-standing corporate leader in Michigan andwe’re honored to present the Dow LudingtonPlant with Michigan’s highest safety and healthaward,” said Smith. “Their exceptional lead-ership in safety, health and the environment isa strong corporate example for all Michiganbusinesses.”
MIOSHA established the MVPP programto recognize employers actively working towardachieving excellence in workplace safety andhealth. It was developed in 1996 to reward pri-vate and public sector work sites that developand implement outstanding safety and healthprograms that go beyond MIOSHA standards.
Employees raised the MVPP Star flag dur-ing the ceremony. Accepting the Star awardwere Jeff Contardi, EH&S Delivery Leader,as well as EH&S employees Lisa Rokosky,Allen Arneson, Greg Dykstra, and RickTreesh. State and local elected officials, cor-porate leaders, as well as CIS and MIOSHArepresentatives, were on hand to congratulatethe Ludington Plant employees and manage-ment on their outstanding achievement.
“We have a corporate policy that statesprotecting people and the environment will bepart of everything we do and make,” said MikeMiller, Manufacturing Leader, Dow Ludington
Plant. “We are extremely proudthat our employees are being rec-ognized for their outstanding ef-forts and leadership to continu-ously improve our safety andhealth performance.”
The site uses Dow GlobalWork Process, complying with cor-porate and MIOSHA safety re-quirements, including approxi-mately 60 corporate safety stan-dards. Based on interviews withemployees and observation,MIOSHA found that employeesare empowered to be “safety di-rectors,” and to integrate safetyand health into all aspects of their operations.Strong safety and health leadership was evidentin all phases of the management system–there wasa clear sense that employees recognize that safetyis a core company value that will not be compro-mised.
The MVPP Review Team consisted of: DougKimmel, CET Safety Consultant and TeamLeader; Mike Mosher, CET Health Consultant;David Luptowski, CET Safety Consultant; andSherry Walker, CET Health Consultant. TheMVPP Team conducted 66 interviews with man-agement, health and safety personnel, operators,maintenance personnel, medical staff, union rep-resentatives and a contractor.
“Your involvement in the MVPP program andthe trust and cooperation upon which it is baseddemonstrates that the implementation of an out-standing safety and health program is an admi-rable and achievable goal,” said MIOSHA Direc-tor Doug Earle.
The Ludington plant has 240 employees, withapproximately 140represented by theUnited Steel Work-ers of America, Lo-cal 12773–bothunion and manage-ment confirmed thatthey work togethertoward mutual goals.All employees take“ownership” of thesite’s safety andhealth managementsystem and all em-ployees are encour-aged to take a proac-tive personal interestin hazard prevention
and control. There is an electronic safety sug-gestion program, as well as a near-miss report-ing and tracking system.
Contractors are also required to have a com-prehensive safety program, with an injury/ill-ness rate below their industry average. Contrac-tor orientation and training is very thorough, andincludes an eight-hour safety awareness course,as well as the Dow Ludington safety orientationcourse. They also pre-plan each job, to assurethat hazards are identified and eliminated be-fore the job is started.
The Ludington Plant’s Incidence Rates andLost Work Day Rates are significantly below theMichigan average for their industry and Stan-dard Industrial Classification (SIC) code 2819,“Industrial Inorganic Chemicals, Not ElsewhereClassified.” The Total Case Incidence Rate forthe Ludington Plant was 2.3 in 1999, 3.0 in 2000,and 2.4 in 2001–compared to 4.2, 5.3, and 5.3,respectively, based on national Bureau of LaborStatistics (BLS) data. The Total Lost Work DayCases for the Ludington Plant was 1.2 in 1999,1.9 in 2000, and 0.8 in 2001–compared to 2.1,2.1, and 2.1, respectively, based on BLS data.
The Ludington plant produces Dow’s trade-mark products PELADOW*, DOWFLAKE* andLIQUIDOW* calcium chloride, magnesium hy-droxide, bromine and bromine derivatives. DowChemical Company is a leading science andtechnology company that provides innovativechemical, plastic and agricultural products andservices to many essential consumer markets.With annual sales of $28 billion, Dow servescustomers in more than 170 countries. Commit-ted to the principles of Sustainable Develop-ment, Dow and its approximately 50,000 em-ployees seek to balance economic, environmen-tal and social responsibilities. There are fiveDow sites in the national VPP program.
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CET Safety Consultant Suellen Cook meets with Virgette Sutton,Industrial Health and Safety Administrator, L&W Engineering,Plant 2, Belleville, to discuss their recent hazard survey.
Attention!MIOSHAMIOSHAMIOSHAMIOSHAMIOSHA does not condone the use of does not condone the use of does not condone the use of does not condone the use of does not condone the use ofextorextorextorextorextort ion or the impersonat ion oft ion or the impersonat ion oft ion or the impersonat ion oft ion or the impersonat ion oft ion or the impersonat ion ofMIOSHA personnel to prMIOSHA personnel to prMIOSHA personnel to prMIOSHA personnel to prMIOSHA personnel to promote anomote anomote anomote anomote anyyyyyprprprprproducts or seroducts or seroducts or seroducts or seroducts or services.vices.vices.vices.vices.
If yIf yIf yIf yIf your companour companour companour companour company has been a target of falsey has been a target of falsey has been a target of falsey has been a target of falsey has been a target of falseor deceptivor deceptivor deceptivor deceptivor deceptive marke marke marke marke marketing tactics,eting tactics,eting tactics,eting tactics,eting tactics, pleasepleasepleasepleasepleasecontact the Dircontact the Dircontact the Dircontact the Dircontact the Director’ector’ector’ector’ector’s Office immediatels Office immediatels Office immediatels Office immediatels Office immediatelyyyyyat 517.322.1814.at 517.322.1814.at 517.322.1814.at 517.322.1814.at 517.322.1814.
MIOSHA Warns Businesses to Be Wary ofDeceptive Worker Safety Marketing TacticsBy: Douglas Kalinowski, Deputy DirectorBureau of Safety & Regulation
MIOSHA is warning businesses to beware ofindividuals using deceptive tactics to market safetyand health services in Michigan. MIOSHA hasreceived several complaints of individuals contact-ing employers and posing as a MIOSHA represen-tative or affiliate. The phony representative thenattempts to pressure the company to sign a con-tract to perform safety and health services.
“Impersonation of a state employee is sim-ply intolerable,” said MIOSHA Director DougEarle. “The MIOSHA program provides exten-sive education and training services. However,these services are provided free to employers–our safety and health consultants do not use thethreat of a MIOSHA inspection to market theseservices.”
MIOSHA became aware of this situationwhen companies called to complain about thetactics. These companies stated the individualsnot only identify themselves as MIOSHA repre-sentatives, but in some instances carry a book-let with a MIOSHA logo and a photograph ofMIOSHA Director Doug Earle. The phonyMIOSHA representatives state that they can pro-vide a certificate, which will prevent the statefrom taking further action in the event it ini-tiates a MIOSHA inspection.One Company’s Experience
On Aug. 5, 2002, Suellen Cook, a Consul-tation Education & Training (CET) DivisionSafety Consultant assigned to Wayne County,made an unscheduled visit to Gouth SheetMetal and Heating in Wyandotte to introduceherself and the availability of CET services.
Gouth is a privately owned business with fiveemployees. During this visit, Tom and CindyGouth, Owner/Operators, explained they werenot surprised by a MIOSHA visit because the firmhad been called on by a private safety and healthconsulting company several months earlier, andthe representative had offered to inspect the 8,000square foot plant for approximately $3,500.
The consulting firm required full paymentfor the survey within several days. Addition-ally, this consulting representative aggressivelyinsinuated that if the offer for the plant inspec-tion was rejected, MIOSHA would be contactedby the consulting firm and Gouth Sheet Metaland Heating would be visited by a MIOSHA rep-resentative and heavily fined for any violations.
Ms. Cook explained that neither privatesafety and health consulting firms nor MIOSHAcan use extortion as a marketing tool for theirservices. The Gouth’s were familiar with theMIOSHA program and had attended a CET semi-nar given by CET Safety Consultant RichardZdeb in Clarkston. They decided to have SuellenCook conduct a hazard survey for them follow-ing their initial meeting.
Several CET Division consultants have re-ceived similar complaints from other companies.The General Industry Safety Division has alsoreceived recent complaints from employers whosaid they had been contacted by individuals whoinsist they must use their health and safety au-dits to come into compliance with MIOSHA.MIOSHA Inspection Policy
In order to effectively check for conditionsthat could endanger the well being of employ-ees, MIOSHA may inspect, with few exceptions,any work operation in the state of Michigan. In
addition to responding to com-plaints, accidents and referrals,MIOSHA also conducts inspectionsat establishments that have the mostsafety problems.
MIOSHA uses a data-basedhistory to target inspections at com-panies with high injury and illnessrates, while avoiding inspectingcompanies that are providing a safeand healthy work environment.MIOSHA targets worksites wherean inspection may provide the nec-essary incentive for positive change.
During a MIOSHA inspection,a safety or health officer arrives un-announced and begins with an open-ing conference by explaining theinspection purpose and format.Upon completion of the officer’s ex-
planation and review of records, a walk-throughof the facility usually takes place. Conditionsthat could endanger the health or safety of em-ployees are pointed out, and worker exposureinformation is taken if necessary. After the clos-ing conference to discuss the findings, theofficer’s report is reviewed, which helps ensureuniformity and consistency of the application ofMIOSHA procedures and processes.
All MIOSHA employees carry a photo ID,issued by the Bureau of Safety and Regulation.If a business is contacted by a MIOSHA repre-sentative, we are advising employers to carefullycheck IDs to be sure they are dealing with a le-gitimate MIOSHA representative.Attorney General’s Response
Information provided to MIOSHA by em-ployers like the Gouth’s have been invaluable tohelp MIOSHA deal with these deceptive prac-tices. After the first group of complaints, MIOSHAmanagement referred the complaints, with spe-cific details, to the Attorney General’s office.
On March 5, 2002, Assistant Attorney Gen-eral Richard Gartner sent a letter to the com-pany regarding the false and deceptive practicesof their employees, or independent contractors.Mr. Gartner stated that the false representationsmust cease immediately.
After receiving several new complaints, Mr.Gartner again notified the company on Aug. 28,2002. His letter stated that MIOSHA continuesto receive complaints of false representations anddeceptive tactics. In conclusion Mr. Gartnerstated, “Legal action will be taken by this officeif these actions continue.”CET Services
The MIOSHA Consultation Education &Training (CET) Division provides voluntaryeducation, training and consultation services atno cost to employers. The CET Division alsotargets its outreach services to those companieswith the greatest need. Employers can call theCET Division to request MIOSHA safety andhealth services at 517.322.1809. �
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55555
Minor Tool Changes & Adjustments
I s L o c k o u t R e q u i r e d ?By: Martha Yoder, ChiefGeneral Industry Division These questions can help determineThese questions can help determineThese questions can help determineThese questions can help determineThese questions can help determine
if a task is a minor tool changeif a task is a minor tool changeif a task is a minor tool changeif a task is a minor tool changeif a task is a minor tool change.....
� How long does the task take?� Is the task relatively minor in nature?� Does the task involve no, or only minor,disassembly?� Does the task occur frequently duringthe day, shift, or week?� Does the task exist even when things areoperating normally?� Does the task occur on a regular,predictable basis?� Is the task normally performed by theoperator?� Is the task conducted using parts andtools readily available to the operator?� Does the operator require specifictraining for the task?� Does the task minimally interrupt theproduction process?� What happens if the task is notperformed?
These These These These These questions can help determine whatquestions can help determine whatquestions can help determine whatquestions can help determine whatquestions can help determine whatprprprprprotectivotectivotectivotectivotective measure measure measure measure measures should be takes should be takes should be takes should be takes should be taken.en.en.en.en.
� Are there established procedures for thistask?� Are the operator and other employeestrained on this task?� Are there other established energycontrol procedures for more involved taskson this machine?� Is the operator trained to know thedifference?� What control state is the machine putinto?� Is any control input required? (Cycle stop/emergency stop)� What energy state does this leave themachine in?� How does the operator verify this/� How can the operator monitor theenergy controls?� What guards must be opened/removed?� Are the guards interlocked?� If interlocked, how are the interlocksintegrated into the control system?� Are any other emergency controlmeasures instituted?� Is partial activation possible of necessaryduring the task?� What steps must be followed to returnthe machine to operation?
If the work activity is simply a minor ad-justment or tool change, is full compliance withthe provisions of MIOSHA Part 85., Control ofHazardous Energy Sources, required? The an-swer is that it depends!
Part 85., commonly referred to as the Lock-out-Tagout standard, contains an exception forminor tool adjustments and changes. The excep-tion states that the minor tool adjustment orchange or minor serving activity must take placeduring normal productions operation and mustbe routine, repetitive, and integral to the use ofthe equipment for production. If the work activ-ity meets both conditions, then an employer mayuse alternative measures in lieu of full compli-ance with the lockout-tagout standard.
Three-Part TestTo determine whether the exception ap-
plies, employers must apply a three-part test.1. Is the task a minor tool change or adjust-
ment or minor servicing activity?2. Is the task:Routine: The activity must be a regular
course of procedure and in accordance with es-tablished practices.
Repetitive: The activity must be repeatedas part of the production process or cycle.
Integral: The activity must be inherent tothe production process.
3. Is the task performed using effective,alternative, protective measures?
The exception is intended to sustain themachine within the acceptable performancerange and output quality. It is part and product
oriented rather than repair oriented.If the answers to all three of the questions
above are “yes,” then the exception applies andthe employer may use alternative measures inlieu of full compliance with the lockout-tagoutstandard.Assessing the Risk
The first step in determining acceptable al-ternative measures is to conduct a risk assess-ment of the process. There are a variety of riskassessment models that can be used to help withthis process.
Review Tasks: In general, risk assessmentbegins with a review of all tasks and activitiesto determine those that may be considered mi-nor tool changes, adjustment, and minor servingactivities.
Identify Hazards: Hazards, such as me-chanical, electrical, thermal, pneumatic, hy-
draulic, radiation, residual orstored energy, motion, fuels,and human factors, associatedwith each task shall be consid-ered. There may also be asso-ciated hazards for a particulartask not related to hazardousenergy release which may alsoneed to be reviewed.
Assess Potential Conse-quences: The severity of in-jures to all persons that couldbe harmed by the hazardsmust be considered. The mostsevere injury that can reason-ably be expected to resultfrom the exposure must beused to determine the protec-
tive requirements.Assess Potential Exposure to the Hazards:
Consider the potential exposure of all persons tothe hazards identified. This assessment shallconsider the nature, duration, and frequency ofexposure to the hazards.
Assess Probability of Occurrence: To thor-oughly assess the probability, there are a numberof areas that must be reviewed. Consider the safe-guards, safety devices, and safety systems eitherin use or that will be used. Check the past reli-ability and potential for failure, operational ormaintenance demands of the task, and the likeli-hood of defeating the safeguards. In addition, re-view the accident history relating to the task, ac-tivity, machine, equipment, and process. The train-ing, proficiency, and competence of all persons
Cont. on Page 18
The Lockout-Tagout standard allows an exception for minor tool changesand adjustments with the use of alternative protective measusres.
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�
AN ERGONOMICS CASE STUDYTG FLU ID SY S TEMS OF BR IGHTON USES EXERC I S E S TO DRAMAT I C A L L Y REDUCE THE I R ERGONOM I C IN JUR I E S
By: Karen Odell, Safety ConsultantConsultation Education & Training Division
Employees at TG Fluid Systems participate instretching exercises before their shift.
TG Fluid System employees believe their stretchingexercises really help.
Ergonomics has become a common wordin the workplace today. It is frequently definedas the “fit between worker and work.” Ergo-nomic-related injuries and illnesses remain aserious problem in Michigan. More than half ofthe total workers’ compensation cases each yearare related to ergonomics. In 2000, there were66,827 Form 100 work-comp cases, and 33,999were ergonomic-related.Reducing Ergonomic Risks
MIOSHA is committed to helping employ-ers reduce the risk factors associated with mus-culoskeletal disorders (MSDs). There is exten-sive evidence today that an ergonomics programcan dramatically reduce injuries, cut workers’compensation costs, increase productivity, anddecrease employee turnover.
An ergonomics program offers significanthealth improvements to workers and significantsavings to employers. It is part of a comprehen-sive safety and health program. The basic ele-ments of a safety and health program include:
� Management commitment,� Employee involvement,� Worksite analysis,� Hazard prevention and control, and� Safety and health training.MSDs occur when there’s a mismatch be-
tween the requirements of a job and the physicalcapacity of the human body. Many injuries resultfrom repetitive motion activities that produce wearand tear on the body. Effective ergonomic inter-ventions include integrated solutions that addressequipment designs and work procedures. Thesolutions can be simple and inexpensive.
Identifying Ergonomic InjuriesTG Fluid Systems in Brighton has had great
success with their safety and health program,particularly in identifying and preventing ergo-nomic injuries. TG Fluid Systems started in 1996as Eagle-Picher, with a name change in 2000.TG Fluid Systems is a manufacturer of plasticfuel and vapor line assemblies for the automo-tive industry. Today they have 65 full-time em-ployees working three shifts.
In 1998, after reviewing their MIOSHA In-jury/Illness Log, TG Fluid Systems found that 20of the 30 recordable injury/illnesses were repeti-tive motion injuries. They decided to take actionto reduce those injuries. “When we discover aproblem, we attack it,” said Ron Buck, Tooling/Maintenance Manager & Safety Coordinator.
As they reviewed their records, the areaidentified with the most problems was the form-ing process for plastic lines. During this pro-cess, employees put plastic tubing into a form,send them through an oven to be heated, andthen remove them once they’ve cooled. Theemployees use various hand movements andapply pressure to push and bend the tubing intothe form.
This is the area where TG Fluid Systemsconcentrated their efforts. Like many companies,job rotation was the first step they took to ad-dress MSDs in the plastic lines. However, theywanted to do more, so they invited the Universityof Michigan Center for Occupational Rehabilita-tion and Health to conduct a trend analysis.
The U of M team evaluated injuries that re-sulted in clinic care for employees, to see if anytrends could be identified. The study reinforcedthe company assessment that the injuries were oc-curring in the forming process line. The research-ers recommended that strengthening and stretch-ing exercises be done at the beginning of each shift.Initiating Ergonomic Improvements
When they began the exercise program, allproduction employees did five minutes ofstrengthening and stretching exercises at the startof their shift. Shortly after, they eliminated thestrengthening exercises and concentrated on thestretching exercises. The exercises are done bypulling an elastic band apart, both in front of andbehind the body, stretching the arms and wrists.The employees said the exercises really do help.
TG Fluid Systems also examined engineer-ing controls. They evaluated the work stationsthat employees use and made some changes withtools and table height. For new jobs, they de-signed work stations to try and eliminate someof the repetitive motions with automation.
These successful ergonomic changes are a
direct result of TG Fluid Systems’ comprehen-sive safety and health program. As part of thatprogram, Ron Buck holds safety meetings oncea month for all production employees, coveringdifferent safety topics throughout the year. Theyalso have an active safety committee, which con-sists of two employees from each shift and man-agement personnel.
In 1998 they started an employee involve-ment program. Employees are able to give their
input, recommendations and suggestions for allareas of safety and health. Many suggestions havebeen implemented and have enhanced job per-formance.Evaluating the Results
The Human Resources Department handlesthe recording of all injuries and illnesses.Marlene Hardesty, Human Resources Manager,provided the injury and illness records for thisarticle. From 1998 to 2001, TG Fluid Systemsdoubled their number of employees, and at thesame time decreased the number of cumulativetrauma injuries. In 1998 they had 768 restricteddays–in 2001 that number was reduced to 22.
Even with this significant decrease, TGFluid Systems is continuing to work on improv-ing their work processes.
The Consultation Education & Training(CET) Division provides a range of services toassist employers and employees who wish toreduce or eliminate ergonomic injuries in theirworkplaces. All of these are voluntary services,and may be obtained without charge by contact-ing the CET Division at 517.322.1809.
MIOSHA CET Grants also provide train-ing and assistance on ergonomic issues. For in-formation, see the article on Page 9.
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Workplace Safety and HealthMakes Good Business Sense
This column features successful Michigan companies that have established a comprehensiveThis column features successful Michigan companies that have established a comprehensiveThis column features successful Michigan companies that have established a comprehensiveThis column features successful Michigan companies that have established a comprehensiveThis column features successful Michigan companies that have established a comprehensivesafety and health program which positively impacts their bottom line. An accident-free worksafety and health program which positively impacts their bottom line. An accident-free worksafety and health program which positively impacts their bottom line. An accident-free worksafety and health program which positively impacts their bottom line. An accident-free worksafety and health program which positively impacts their bottom line. An accident-free workenvironment is not achieved by good luck—but by good planning! Creating a safe and healthyenvironment is not achieved by good luck—but by good planning! Creating a safe and healthyenvironment is not achieved by good luck—but by good planning! Creating a safe and healthyenvironment is not achieved by good luck—but by good planning! Creating a safe and healthyenvironment is not achieved by good luck—but by good planning! Creating a safe and healthyworkplace takes as much attention as any aspect of running a business. Some positive benefitsworkplace takes as much attention as any aspect of running a business. Some positive benefitsworkplace takes as much attention as any aspect of running a business. Some positive benefitsworkplace takes as much attention as any aspect of running a business. Some positive benefitsworkplace takes as much attention as any aspect of running a business. Some positive benefitsinclude: less injuries and illnesses, lower workers’ compensation costs, increased production,include: less injuries and illnesses, lower workers’ compensation costs, increased production,include: less injuries and illnesses, lower workers’ compensation costs, increased production,include: less injuries and illnesses, lower workers’ compensation costs, increased production,include: less injuries and illnesses, lower workers’ compensation costs, increased production,increased employee morale, and lower absenteeism.increased employee morale, and lower absenteeism.increased employee morale, and lower absenteeism.increased employee morale, and lower absenteeism.increased employee morale, and lower absenteeism.
The Bottom L ine
Keykert USA, Inc. - Webberville Plant
These Keykert employees are working on the NGL11 Lower Line, whichmakes power locking systems for the Ford Escape, Mazda Tribute, LincolnLS, Jaguar, and Transit vehicles.
Keykert USA, Inc., is a subsidiary of the Kiekert Group, head-quartered in Germany, and began operations in the U.S. just over10 years ago. The Webberville facility produces automobile lock-ing systems for cars of the world, and is Keykert USA’s only manu-facturing plant in the U.S
Keykert USA produces complete locking systems for devicesthat open, close, lock and unlock cars. Their primary automotivecustomers include Ford, Mazda, Saturn, Jaguar, and General Mo-tors. Keykert has two facilities in the U.S. The Wixom site is dedi-cated to research and development, and prototype engineering andtesting.
The Webberville facility has seen extensive growth since the plantwas built in 1997. Production began in late 1998, and their workforcemore than doubled in 1999 and 2000. Currently, Keykert is the city ofWebberville’s largest employer–with over 300 employees. Keykert USAis certified to the QS-9000, ISO14001 Standards, and a member of theMichigan Business Pollution Partnership (MBP3).Health and SafHealth and SafHealth and SafHealth and SafHealth and Safety Pety Pety Pety Pety Policyolicyolicyolicyolicy
It is the policy of Keykert USA, Inc. to protect the health andsafety of its employees, protect the health and safety of the public,and protect the natural resources that may be impacted by thecompany’s activities. Keykert USA is dedicated to protecting thehealth and welfare of all employees in the workplace.
They follow recognized safety and health practices to identifysafety and/or health hazards, and then initiate action that will elimi-nate or control the unsafe condition. Keykert employees are re-quired to obey all health and safety policies and procedures, and toconduct their jobs in a safe and healthful manner. Employees areresponsible for actively participating in the continuous safety im-provement process. Keykert USA places safety as its primary ob-jective in the operation of its business and continues to strive foraccident-free performance.SafSafSafSafSafety ety ety ety ety AchieAchieAchieAchieAchievvvvvementsementsementsementsements
On, Oct. 25, 2001, the Webberville plant received the BronzeAward from the Consultation Education & Training (CET) Divi-sion for an outstanding safety and health record. CET Safety Con-sultant Debra Gundry has conducted supervisory training and spe-cific standards training, such as lockout/tagout, for the company.
“Keykert USA is an outstanding economic success story inMichigan,” said CIS Deputy Director Dr. Kalmin Smith duringthe award presentation. “Since 1999, the Webberville plant doubled
the size of its workforce, while at the same time its lost-time inju-ries were cut in half.”
CIS Deputy Director Smith presented the award to KenYungkans, Plant Manager. Yungkans credits the efforts of EHSCoordinator Kathy Gurnee, the plant’s Safety Committee andthe entire production team for the accomplishment.
Since receiving the Bronze Award in 2000, Keykert has con-tinued to see significant improvements. In 2001 recordable inju-ries were reduced, restricted duty workdays decreased and theirlost workday case rate decreased nearly 25 percent. The total num-ber of days lost due to occupational injuries decreased from 101 in2000 to just 36 in 2001–a decrease of nearly two-thirds!
Kathy Gurnee attributes their success to the extensive safetytraining and awareness for all employees. “The ergonomic work-stations, job rotations, an aggressive case management of workrelated injuries, and job coaching restricted employees has con-tributed to our success,” states Gurnee. Implementing a Safety Com-mittee also has employees actively involved.
“The safety of our people really is our number one concernhere. We’re living proof that improved quality and improved effi-ciency, don’t have to come at the expense of our employees’ well-being,” said Yungkans.
88888
Plastics Industry Safety ChallengesBy: Elmer Miller, Onsite SupervisorBob Carrier B.S., Safety & Health ConsultantConsultation Education & Training Division
Proper ladders and perimeter barriers are required for access to plasticsinjection molding machines.
The plastics industry is one of the largestmanufacturing industries in the United States,employing 1.5 million people and creating morethan $330 billion dollars in annual shipments.The Michigan plastics industry employed nearly112,000 workers in the year 2000, placing thestate third in the nation. Michigan ranked fifthwith $22.7 billion in shipments.
Plastics play an indispensable role in a widevariety of markets, including packaging, con-struction, transportation, automotive compo-nents, consumer products, electronic compo-nents, adhesives and more.Plastics Industry Hazards
While the plastics industry is increasinglybased on advanced technology, employers stillshare similar risks of workplace injuries, illnessesand fatalities with other high-hazard industries.
Likely hazards can include exposures to:� Unguarded or inadequately guarded ma-
chinery;� Unexpected energization of equipment
and release of stored energy (lock out/tag out);� Failure to guard rotating equipment that
could cause amputations;� Hazards associated with improper elec-
trical wiring;� Falls from lack of guardrails along open-
sided floors;� Fall hazards as a result of inadequate
access and work platforms on top of machines.� Confined spaces and chemical hazards;� Thermal burns; and� Slip and trip hazards due to poor house-
keeping and improper floor maintenance.These safety and health hazards pose dan-
gers of electrocution, falls, crushing injuries,being caught in moving machine parts, and as-phyxiation. Since 1998 in Michigan, there havebeen numerous tragic injuries and fatalities inthe plastics industry.Tragic Plastics Accidents in Michigan
� Loose wiring on a grinder caused an em-ployee to be electrocuted.
� A reciprocating part and frame of a mold-ing machine pinned a worker’s head, causing afracture.
� A safety gate was improperly adjustedcausing an employee’s hand to be amputated.
� While pulling a part out of a mold, aworker’s finger was amputated.
� While trying to dislodge a part, the ma-chine cycled and pinned the employee.
� While retrieving a plastic product, anemployee’s hair was caught in rotating machinery.
� While adjusting a mold, the set-up person’shead was crushed by an automated robot.
Complying with MIOSHA rules can helpeliminate unsafe conditions and prevent the typesof injuries described above. Between 10/1/00 and9/30/01, the MIOSHA program cited 745 haz-ards in the plastics industry, with initial penal-ties of $369,650.Plastics Top 10 Serious Safety Violations
1. Part 39., Design Safety Standards forElectrical Systems - Guard exposed live parts ofelectrical equipment operating at 50 volts or moreagainst accidental contact.
2. Part 1., General Provisions - Guard pinchpoints or otherwise protect employees exposedto contact.
3. Part 2., Floor & Wall Openings, Stair-ways & Skylights - Guard open-sided floor orplatform that is four feet or more above adjacentlevel with a standard barrier.
4. Part 85., Control of Hazardous EnergySources (Lockout-Tagout) -Develop, document and uselockout procedures.
5. Part 33., PersonalProtective Equipment - Pro-vide face and eye protection.
6. Part 7., Guards forPower Transmission - Guardbelts and pulleys seven feetor less above the floor.
7. Part 1., General Pro-visions - Provide point ofoperation guard or device.
8. Part 85., Control ofHazardous Energy Sources(Lockout-Tagout) - Providetraining to employees autho-rized to perform lockout.
9. Part 2., Floor &
Wall Openings, Stairways & Skylights - Provideappropriate means to gain access to another el-evation in excess of 16 inches.
10. Act 154, Section 11(a) - These are vio-lations of the “General Duty Clause” requiringemployers to furnish a workplace free of recog-nized hazards, primarily issued for allowingemployees to climb machines and stand on topwith no barrier guard or fall protection.
Employers are encouraged to develop asafety and health program to identify and elimi-nate the specific hazards in their workplace. Thebasic elements include:
� Management commitment,� Employee involvement,� Worksite analysis,� Hazard prevention and control, and� Safety and health training.Recognizing and identifying safety hazards
is the first step in developing an effective pro-gram. Employee involvement is critical becausethey are familiar with the operations and risksinvolved. Hazard assessment provides the basisfor developing procedures for each operation.The information below describes some of thecommon hazards in the plastics industry. Em-ployers are encouraged to obtain copies ofMIOSHA standards that apply their workplace.Amputation and Crushing Hazards
Safeguards must be provided to protectworkers from point of operation hazards andpinch points caused by moving parts and equip-ment. Of special concern in the plastics indus-try is protection from possible amputation inju-ries. Equipment that must be evaluated for haz-ards include: automatic closing doors, fans tocool personnel, feed rolls, rotating equipmentsuch as screw augers, motor couplings andshafts, platen pinch points, ejector plates, con-veyors, and portable scrap grinders.Lockout-Tagout
Equipment and machinery must be lockedout when employees are performing servicingor maintenance work in which the unexpectedenergization or start up of the machines or equip-ment, or a release of stored energy, could causeinjury to employees. This includes changing diesand cleaning of equipment.
The provisions of the lockout-tagout stan-dard apply when any of the following situationsexist:
� An employee must either remove or by-pass machine guards or other safety devices,resulting in exposure to hazards at the point ofoperation;
� An employee is required to place any partof his/her body in contact with the point of op-eration of the machine or piece of equipment; or
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E T G R A N TC SFY 2003 CET Grant Projects
$1 Mi l l ion for Worker Protect ionBy: Jerry ZimmermanCET Grant Administrator
Dr. Nicole Poirier, a Michigan Chiropractic Council member,conducts a WorkSafe seminar for staff at Pine Ridge SeniorVillage in Sterling Heights.
On Sept. 18, the Michigan Departmentof Consumer & Industry Services (CIS)awarded 18 Consultation Education andTraining (CET) Grants totaling $1 million topromote workplace safety and health.
“Employers today recognize that one ofthe most effective ways to increase profits isto provide a safe work environment,” said CISDirector Noelle Clark. “These grants willprovide employers with down-to-earth strat-egies to protect their workers from injuriesand illnesses.”
The MIOSHA Consultation Educationand Training (CET) Division provides directstaff assistance to employers in a variety offormats. The CET Grant program providesadditional options for safety and health edu-cation and training to employers and employ-ees.
“One vital area of concern for employ-ers today is preventing ergonomic injuries,”said BSR Director Doug Earle. “A signifi-cant number of these grants will provide ef-fective ergonomics evaluation and training.”
The 18 statewide projects include a widerange of training activities and proficiencylevels. Many of the grants offer interactivecomputer-based training modules and mayinclude: text, video, interactive questions, andretention testing.
Most of the grants focus on the perfor-mance goals identified in the MIOSHA stra-tegic plan, including: ergonomics training andback safety, construction safety, road build-ers safety, hearing conservation, hazard rec-ognition and prevention, and training forhealthcare and nursing home workers.
Other grants include: workplace vio-lence, Rapid Intervention Team training forfirefighters, logging safety, safety and healthtraining for new workers, and safe work prac-tices for agricultural workers.
Seventeen of the projects focus on train-ing programs, while one research grant quan-tifies and evaluates protections concerningthe noise level exposures of employees in thewood products industries.
CET grants are awarded on a competi-tive basis to management/employer groups,labor/employee organizations, and not-for-profit organizations, such as universities,hospitals and service agencies.
Alpena Community College will pro-vide targeted safety training in three key areas:manufacturing, construction, and health care/long-term care. Additionally it will obtain andshare detailed survey data from four key employ-ers that received CET training. This will dem-onstrate the impact of safety training.
Associated General Contractors willprovide an interactive computer-based trainingprogram for construction. The program is designedto provide easy access to 14 standardized mod-ules which include: Asbestos Awareness, ConfinedSpace, Electrical Safety, Fall Protection, HazardCommunication, Lockout/Tagout, PPE, Trench-ing and Shoring, Scaffold Safety, Cadmium Safety,Silica Safety and Lead Safety.
Bay de Noc CommunityCollege will provide statewidetraining and services for the woodharvesting (logging) and the woodusing industry with emphasis onsawmills and secondary wood manu-facturing. The training program willoffer on-site presentations on:awareness of hazards, personal pro-tective equipment, chain saw safety,safe work habits, and sound ergo-nomic practices.
Center for Workplace Vio-lence Prevention will providetraining to small business ownersand employees, human resourcemanagers, field personnel in the fol-lowing areas: personal safety strat-egies; early warning signs of angerand aggression and early prevention;de-escalation and personal safety strategies;managing high-risk situations; and crisis man-agement.
Eastern Michigan University will pro-vide training for workers whose health and safetyis threatened by the possibility of serious backinjury due to using improper techniques whilemoving, transporting or repositioning patients.The training will provide workers with the nec-essary knowledge, hands-on-training and equip-ment to perform these necessary functions.
Great Lakes Training Center will pro-vide computer-based health and safety trainingfor construction . Topics will include: basic safetyorientation, hazard communication, back safety,ergonomics, scaffolding, electrical safety, etc.The modules contain text, video, interactive
questions, and retention testing.Michigan Aggregates Association will
develop a Hearing Conservation and Noise Sam-pling training program. The program will consisttraining and technical assistance. The seminarswill include: overview of noise rule and compli-ance issues, hands-on training in using dosim-eters and sound level meters, the importance ofaudiometric testing and the requirements.
Michigan AFL-CIO will provide both ge-neric and customized workplace safety andhealth training to new employees and incumbentworkers affected by new technology and newwork processes, equipment or operation. Train-ing topics will include back injuries, lifting tech-niques, workplace hazards and recognition, right-to-know and hazardous substances.
Michigan Chiropractic Council facili-tators will provide back safety and ergonomicstraining to workers in nursing home, manufac-turing and construction industries. Prior to con-ducting the training, the facilitators will conductan on-site evaluation of the workplace. TheWorkSafe program is designed to increase em-ployee awareness of ergonomics injuries.
Michigan Farm Bureau will providetraining targeted to agricultural employers, man-agers, service providers and owners. The projectwill develop and provide realistic hazard iden-tification guidance and minimization practicesutilizing computer and DVD formats. Host fa-cilities will be provided with a pre-seminar on-site survey to determine current safe work prac-
Cont. on Page 19
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The VPPPA 18th Annual Conference in Orlando, Sept. 9-12, offered a uniqueforum for more than 1,800 employee, management and government leaders towork and learn together to achieve workplace safety and health protection.
MVPP STRATEGIES FOR CHANGEBy: Richard Zdeb, Safety ConsultantConsultation Education & Training Division
In today’s work environment, the key wordis “change.” One obvious indication is the preva-lence of ISO concepts. ISO certification atteststhat a company has met or exceeded a series ofstandards, developed and published by the In-ternational Organization for Standardization(ISO), that define, establish and maintain aneffective quality system for manufacturing andservice industries.
It is a demonstration that the operation hasattained a high level of excellence regarding themethods and systems of the business. And yet,at that same high-achieving company, when acall from the receptionist indicates “someonefrom MIOSHA is here,” it is cause for anxietyand concern.
There are more than 850 employers acrossthe nation who do not have that concern. Theyare participants in the Voluntary Protection Pro-grams (VPP). These employers have outstandingsafety and health management systems and arepartners with OSHA. In Michigan, there are eightemployer sites recognized as the “best of the best”in their safety and health accomplishments.
A common trait of a VPP company is theiremphasis on employee involvement. VPP com-panies have successfully communicated their ex-pectations to their employees. Many companieshave empowered employees to develop, imple-ment and maintain required programs. Participa-tion in these work groups, allows for true owner-ship. Without relinquishing responsibility, man-agement monitors the work group activity.Recognizing a Need for Change
At the 18th Annual VPPPA Conference thisSeptember in Orlando, one national companyshared their VPP experiences. Their past inci-dence rates were well above the industry aver-
age, and OSHA compliance was marginal.Knowledge regarding basic OSHA standards waspoorly understood. The safety process was disor-ganized, and an attitude of “it’s not my job” wasprevalent. Management was disconnected andinjuries were considered a cost of doing business.
Traditional approaches at the companyweren’t working--management recognized theirworkplace culture had to change. Top executivesdecided that a proactive safety and health man-agement system would be included as part ofthe productivity, quality and operations process.A system of safety auditing and resources wouldbe put into place. Safety would be included inthe performance system and evaluation.
From that point it became a company goalto establish safety as a value to the organiza-tion, reinforcing fundamental OSHA standards,and establishing a vision. The values that wereestablished included:
� Accidents are unacceptable.� Everyone must work safely.� Management will lead by example.� Safety is a shared responsibility.� Safety is about people.� Safety is the right thing to do.
Meeting Safety ExpectationsAfter establishing these values, safety and
health was incorporated into the business plan.Action plans were developed and implemented.Safety expectations were established and com-municated to all employees. Concern for injuredemployees was clear, with support for return-to-work activities. And follow-up…follow-up…follow-up was done on systemic breakdowns.
Safety accountability was established. Un-safe conditions and acts were addressed swiftlyand consistently. Near-miss and accident investi-gations were conducted immediately and the re-sults communicated to employees and manage-ment. With regard to unsafe acts, immediate
coaching and counselingwas encouraged and given.
This grassroots ap-proach to health andsafety resulted in some-thing more than zero tol-erance for accidents. Itfostered involvement, par-ticipation and ownership.The VPP process providedthem with the structure toachieve safety and healthexcellence.
OSHA enforcementno longer was a concern.Work groups were formedto insure that the companywas in compliance. OSHA
standards became guidelines--not to avoid mon-etary penalties, but to go beyond the minimumregulatory standards and establish the best pos-sible safety practices.
The company today has several locationsacross the nation that have achieved VPP status.Achieving VPP Benefits
Benefits from participating in the VPP pro-gram are many. Nationally, VPP sites generallyexperience from 60 to 80 percent fewer lostworkday injuries than would be expected of an“average” site of the same size in their indus-tries. Other benefits include:
� Improved employee motivation to worksafely, leading to better quality and productivity.
� Reduced workers’ compensation premi-ums resulting from lower injuries, which canproduce a competitive company advantage.
� Opportunity to showcase best safety andhealth practices in your industry.
� Opportunity to mentor and network withother operations in your industry.
� Recognition in the community as a leaderin health and safety.
The VPP program has been in existencefor nearly 20 years. MIOSHA has been a par-ticipant for seven years. It is a program of part-nership and mentoring without the potential ofa MIOSHA enforcement inspection. However,an accident investigation, a fatality or an em-ployee complaint would still bring aboutMIOSHA enforcement participation.Attaining MVPP Star Status
In Michigan, the MVPP program consistsof Star and Rising Star achievement awards. Itis administered through the MIOSHA Consul-tation Education and Training (CET) Division.The Star Award defines the ultimate in healthand safety success. In order to attain this Starlevel, employers must:
� Attain incidence rates below the state av-erage for a period of three years, as determinedfrom their MIOSHA Injury and Illness Log.
� Demonstrate that they have a safety andhealth management system in place for a mini-mum of one year.
� Submit a formal application with docu-mentation supporting the key elements of theirsafety and health management system.
� Agree to a MIOSHA onsite review toverify the information submitted, and to identifythe strengths and weaknesses of their system.
For information about the MVPP program,including the MVPP application process, the listof current MVPP sites and commonly askedquestions, check the MIOSHA website at:www.michigan.gov/cis. (Select “WorkplaceSafety and Health.”) You can also call the CETDivision at 517.322.1809.
F a l l 2002
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The MIOSHA rule rThe MIOSHA rule rThe MIOSHA rule rThe MIOSHA rule rThe MIOSHA rule regaregaregaregaregarding use of wheel chocksding use of wheel chocksding use of wheel chocksding use of wheel chocksding use of wheel chockshas not changed,has not changed,has not changed,has not changed,has not changed, and Michigan’ and Michigan’ and Michigan’ and Michigan’ and Michigan’s position rs position rs position rs position rs position remains:emains:emains:emains:emains:The use of wheel chocks prThe use of wheel chocks prThe use of wheel chocks prThe use of wheel chocks prThe use of wheel chocks prooooovides a grvides a grvides a grvides a grvides a greater leeater leeater leeater leeater levvvvvelelelelelof wof wof wof wof workorkorkorkorker prer prer prer prer protection than air brakotection than air brakotection than air brakotection than air brakotection than air brakes es es es es alonealonealonealonealone.....
MIOSHA General Industry Safety Standard Part 21., PoweredIndustrial Trucks, Rule 2176(1) requires that an employer ensurethat a highway truck and trailer shall not be boarded by a poweredindustrial truck before the highway truck and trailer has its brakesset, and not less than two wheels clocked or restrained by othermechanical means, installed in a manner that will hold the trailerfrom movement.
The MIOSHA rules requires more than setting the brakes alone.“Other mechanical means” are interpreted by the program to meanone of the available devices which latch onto the InterstateCommerce Commission required bar, or hydraulically move a wedge-shaped block in front of the wheels. Alternatively, some employershave chosen to chain the vehicle to the dock. There may be othersimilar devices which would be acceptable. Any acceptable devicemust be used in conjunction with setting of the brakes to complywith the MIOSHA rule.
As a state-run program for occupational safety and health, MIOSHAis subject to its own state enabling legislation, Act 154 of 1974, asamended. The Michigan program is authorized under the provisionsof Section 18 of the federal OSH Act of 1970, which provides thatstates may seek approval to operate its own program provide it is“at least as effective as” the federal OSHA program in promotingsafe and healthful working conditions. While state plan programs likeMIOSHA must be at least as effective, it does not require the stateprogram requirements be mirror images of the federal program.
Recently there has been some confusion regarding wheel chockingbecause of federal jurisdictional issues. The reason the federalOccupational Safety and Health Administration’s wheel chockingregulation isn’t applicable in Michigan is based on Section 4(b)(1) ofthe federal OSHA legislation (P.L. 91-59); which states, in part, that:fffffederal OSHA rederal OSHA rederal OSHA rederal OSHA rederal OSHA requirequirequirequirequirements shall not aements shall not aements shall not aements shall not aements shall not applpplpplpplpply to wy to wy to wy to wy to working conditionsorking conditionsorking conditionsorking conditionsorking conditionsof emploof emploof emploof emploof employyyyyees with rees with rees with rees with rees with respect to which other fespect to which other fespect to which other fespect to which other fespect to which other federal agenciesederal agenciesederal agenciesederal agenciesederal agenciesexexexexexererererercise statutorcise statutorcise statutorcise statutorcise statutory authority to pry authority to pry authority to pry authority to pry authority to prescribe or enfescribe or enfescribe or enfescribe or enfescribe or enforororororce standarce standarce standarce standarce standardsdsdsdsdsor ror ror ror ror regulations affegulations affegulations affegulations affegulations affecting occupational safecting occupational safecting occupational safecting occupational safecting occupational safety or ety or ety or ety or ety or health.health.health.health.health.
The Michigan occupational safety and health enabling legislationcontains no similar provision. Previous decisions on MIOSHA caseshave upheld the program’s authority to apply MIOSHA requirementsin these cases. Nor do other federal laws preempt or otherwiseimpact the state from inspecting and applying MIOSHA requirements;and that comity should not be regarded as applicable in this case.
Therefore, while Michigan may look to federal directives on the issueof wheel clocking for guidance and /or information on how rulesmay be interpreted or applied, the program is not bound to adoptthe federal OSHA approach.
Steel Erection StandardPart 26
Effective September 18, 2002M I O S H A w i l l d e l ay a p p l y i n g t h enew prov is ions cover ing des ign andfabr i ca t ion o f components .
The new MIOSHA steel erection standard became ef-fective for covered Michigan employers and employees onSeptember 18, 2002. This standard has adopted languagefrom the recently effective federal Subpart R and providesmany enhanced protections for Michigan workers.
Several of the new provisions of the revised standardaffect the design of structural components which are typi-cally fabricated two to three months prior to being erected.
Re-fabricating components that are already in the de-sign/fabrication process would be very costly, cause seriousconstruction delays, and affect the building trades workersinvolved. To facilitate the transition to the revised standard,enforcement of the component fabrication requirements willbe delayed to accommodate a phase-in by the industry inMichigan.
Therefore, MIOSHA will delay applying the new provi-sions listed below covering design and fabrication of com-ponents affected by the revised steel erection standard untilJanuary 1, 2003.
In addition, if a building permit was issued prior to Sep-tember 18, 2002, or if steel erection commenced prior to Sep-tember 18, 2002, the component requirements of the stan-dard will not apply to the project. Employers who intend torely on these dates must provide at the job site documenta-tion to support any assertion that the provisions would notapply.
This delay will allow sufficient time to implement de-sign changes into the structural members of all size projects.Employers are urged, however, to implement the design andfabrication requirements at the earliest date possible.
ParParParParPart 26 Rules t 26 Rules t 26 Rules t 26 Rules t 26 Rules AffAffAffAffAffected bected bected bected bected by they they they they theImplementation DelaImplementation DelaImplementation DelaImplementation DelaImplementation Delayyyyy
R408.42616(1) Installation of shear connectorsR408.42626(1)(2) Columns anchored by 4 anchor boltsR408.42628(4)(5) Column splices and perimeter cablesR408.42629(1) Double connectionsR408.42634(1)(a) Open web joists stabilizer plate
(3) Joists 60 feet or less in length capableof supporting one employee
(8)(a) Field bolting joistsR408.42643 (2)(5) Anchorage and girt and eave strut to
frame connections
Al l s t andards can be ob ta ined on l ine a twww.michigan.gov/cis. (Select “Safety and Health” fromthe left navigation bar.)
Clarification onUse of Wheel Chocks
For information, contact the GeneralIndustry Safety Division at 517.322.1831.
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Craig Spoelhof, Plant Manager; Mike Everett, CETSupervisor; Elaine Hoover, Safety Engineer; and PaulGeldaker, Production Manager.
Johnson Controls Meadowbrook Plant - HollandJohnson Controls’ Meadowbrook plant received the CET Silver Award for an out-
standing safety and health record on July 3rd. The CET Silver Award recognizes one yearwithout a lost time accident.
CET Supervisor Mike Everett and CET Consultant Dave Nelson presented theaward to Craig Spoelhof, Plant Manager; Elaine Hoover, Safety Engineer; and PaulGeldaker, Production Manager.
The Meadowbrook facility in Holland employs 400 workers and manufactures over-head consoles for cars, trucks, SUVs, vans, etc. The overhead consoles consist of manyoptions, including: onstar, compass with trip odometer, and homelink options. Theyhave the technology to build and offer a DVD player with screen and headphone attach-ments, for a quiet ride with the kids.
Johnson Controls, Inc. is a global leader in automotive systems and facility manage-ment and control. In the automotive market, it is a major supplier of seating and interiorsystems, and batteries. For non-residential facilities, Johnson Controls provides buildingcontrol systems and services, energy management and integrated facility management.Johnson Controls, headquartered in Milwaukee, had sales for 2001 of $18 billion.
Ignac Jakovac, Rand Haas ISS GM; Jerry Medler, CET Consultant;Ayalew Kanno, CET Dep. Chief; Doug Earle, BSR Director; RobHeck, PACE Safety Rep.; Don Kuk, EHS Mgr., Rohm and Haas;Jerome Thebault, PACE Safety Rep.; Barry Crawford, Mnfg. Mgr.,Rohm and Haas; Bob Stewart, Manistee Plant Mgr.
Rohm and Haas Company - Manistee PlantOn July 11th, Rohm and Haas Company’s Inorganic and Specialty Solutions (ISS)
Division in Manistee received the Ergonomic Innovation Award, which is issued toemployers for innovative ideas that have been implemented to reduce worker strain.
BSR Director Doug Earle and CET Consultant Jerry Medler presented the awardto Plant Manager Bob Stewart, Environmental Health & Safety Manager Donald Kuk,and the Safety and Health Committee members involved in their ergonomic project.
The ISS Division makes specialized magnesia products for the pharmaceutical,food, plastics and rubber markets. Under the leadership of EHS Manager Donald Kuk,the company conducted a full-scale study of lifting and palletizing 50-pound bags, be-cause of the high potential for back injury. The goals of the project were to find im-provements toreduce the potential for injury. Rohm and Haas Company will use thestudy in other company facilities with similar work environment, to help reduce ergo-nomic injuries.
Rohm and Haas Company is one of the world’s largest specialty chemical compa-nies, with annual sales of $5.7 billion, and more than 100 research and manufacturingfacilities in 25 countries.
Bernard Sznaider, CET Consultant; Roger Paige, Safety Mgr.,Focus: HOPE; Dr. Kalmin Smith, CIS Dep. Director; Linda Hanks,Manager, ITC; and Eleanor Josaitis, Ex. Director, Focus: HOPE.
Focus: HOPE Information Technologies CenterOn July 17, Focus: HOPE Information Technologies Center (ITC) received the
CET Silver Award, which recognizes one year without a lost-time accident. ITC’s 28employees attended the presentation of the award by CIS Deputy Director Kalmin Smithand CET Consultant Bernard Sznaider.
“We applaud your outstanding efforts to maintain an accident-free environment, byteaching your students the benefits of workplace safety,” said Smith.
Focus: HOPE started the ITC in 1999, which trains students for entry-level posi-tions in the Information Technology industry. Their curriculum was developed by indus-try leaders, such as Microsoft, Cisco and Novell. They are partners in the Cisco Net-work Academy Program, Comp TIA, BICSI and Novell Education Academic Partners.
Safety for their customers, colleagues and themselves is an important part of an ITprofessional’s performance. The ITC program has found that diligence in maintaining asafe environment is the best method to teach their students about safety.
Focus: HOPE, a nationally recognized civil rights organization , was co-founded in1968 by Father William Cunningham (1930-1997) and Ex. Dir. Eleanor Josaitis.
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Education & Training CalendarDate Course MIOSHA Trainer
Location Contact Phone
Co-sponsors of CET seminars may charge a nominal fee to cover the costs of equipment rental, room rental, and lunch/refreshment charges. Forthe latest seminar information check our website, which is updated the first of every month: www.cis.state.mi.us/bsr/divisions/cet/cet_cal.htm.
November19 Ergonomics: A Practical Approach Suellen Cook
Ann Arbor Ray Grabel 734.677.525919 & 20 2-Day Mechanical Power Press Richard Zdeb
Ms. Cynthia HollandCapt. Michael McCabeMs. Margaret Vissman
ManagManagManagManagManagementementementementementMr. Robert DeBruyn*
Mr. Michael LucasMr. Richard Olson
Mr. Douglas WilliamsPublic MemberPublic MemberPublic MemberPublic MemberPublic Member
Dr. Darryl Lesoski**
*Chair **Vice Chair*Chair **Vice Chair*Chair **Vice Chair*Chair **Vice Chair*Chair **Vice Chair To contact any of the Commissioners or the Standards Division Office, please call 517.322.1845.
Standards Update
New Hearing Loss Recording Rules
Beginning January 1, 2003, the criteria stated in MIOSHA Part 11., Recordingand Reporting of Occupational Injuries and Illnesses, will change regarding whenemployers are required to record work-related hearing loss cases if an employee’s hearingtest shows a marked decrease in overall hearing.
Currently, Part 11. requires employee hearing loss to be recorded if a standardthreshold shift (STS) is detected after performing an employee’s annual hearing test(audiogram). An STS is defined in the occupational health standard Part 380., NoiseExposure, as a change in the hearing threshold relative to the baseline audiogram of anaverage of 10 decibels(dB) or more at the following tones, 2000, 3000, and 4000 Hertz(Hz), in either ear. Decibels is a measure of how loud a sound is. Hertz is a measure-ment of the frequency or pitch of a sound such as a low musical note or a high musicalnote.
This definition of an STS will not change. But starting January 1, 2003, Part 11.will include an additional recording criteria. The STS will be recordable if the hearingloss is at least 25 dB above audiometric zero, averaged over the three tone frequenciesof 2000, 3000, and 4000 Hz. No change will occur in how to record work-relatedhearing loss on the MIOSHA Log 300 . As currently required, work-related hearingloss should be recorded in section (M), column 5 “All other illnesses.”
No change will occur regarding worker protection. MIOSHA’s occupational noisestandard, Part 380., requires employers in general industry to conduct periodic audio-metric testing of employees when employees’ noise exposures are equal to, or exceed,an 8-hour time-weighted average of 85dBA. Under these provisions, if such testingreveals that an employee has sustained a hearing loss equal to an STS, the employermust take protective measures, including requiring the use of hearing protectors, toprevent further hearing loss.
Also, employers can make adjustments for hearing loss caused by aging, seek theadvice of a physician or licensed health care professional to determine if the loss iswork-related, and perform additional hearing tests to verify the persistence of the hear-ing loss.
Hearing loss can result in a serious disability and put employees at risk of beinginjured on the job. MIOSHA’s Five Year Strategic Plan reflects this concern by includ-ing a performance goal to reduce the number of employees harmed due to work-relatedhearing loss.
For questions on the recording of hearing loss, contact the MIOSHA InformationDivision at 517.322.1851.
EffEffEffEffEffectivectivectivectivective September 18,e September 18,e September 18,e September 18,e September 18, 2002 2002 2002 2002 2002
A NeA NeA NeA NeA New Standarw Standarw Standarw Standarw Standard fd fd fd fd for the Construction Industror the Construction Industror the Construction Industror the Construction Industror the Construction Industryyyyy
Please note: MIOSHA will delay applying the new provisions covering design andfabrication of components. Please see article on Page 11 for details.
All standards can be obtained on line at www.michigan.gov/cis. (Select “Safetyand Health” from the left navigation bar.)
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Occupational Safety StandardsGeneral Industry
Part 08. Portable Fire Extinguishers ..................................................................... Approved by Commission for reviewPart 18. Overhead and Gantry Cranes ................................................................. Final, effective 4/10/02Part 19. Crawler, Locomotives, Truck Cranes ..................................................... At Advisory CommitteePart 20. Underhung and Monorail Cranes............................................................ Approved by Commission for reviewPart 58. Vehicle Mounted Elevating & Rotating Platforms ................................ Approved by Commission for review
ConstructionPart 01. General Rules (Consolidating with health rules) ................................... Final, effective 8/9/02Part 07. Welding & Cutting .................................................................................... Approved by Commission for reviewPart 08. Handling & Storage of Materials ............................................................ Approved by Commission for reviewPart 12. Scaffolds ..................................................................................................... Approved by Commission for reviewPart 14. Tunnels, Shafts, Cofferdams & Caissons ................................................ Draft to Advisory Committee for reviewPart 16. Power Transmission .................................................................................. Approved by Commission for reviewPart 18. Fire Protection & Prevention ................................................................... Final, effective 9/18/02Part 25. Concrete Construction .............................................................................. Approved by Commission for reviewPart 26. Steel and Precast Erection ....................................................................... Final, effective 9/18/02Part 30. Telecommunications .................................................................................. Approved by Commission for reviewAd Hoc Communication Tower Erection .............................................................. Approved by Commission for review
Occupational Health StandardsGeneral Industry
Carcinogens R 2301-2302 ........................................................................................... Final, effective 9/27/02Grinding, Polishing & Buffing ................................................................................... RFR approvedNon-ionizing Radiation R 2420 .................................................................................. Final, effective 8/1/02Powered Industrial Trucks R 3225 (OH Rules only) .............................................. Rescinded due to duplicationRespirators in Dangerous Atmoshperes (OH Rules only) ....................................... Rescinded due to replacementSanding Machines R 3230 (OH Rule only) ............................................................... Rescinded due to duplicationVentilation for Certain Hazardous Locations R 3110 ............................................. Rescinded due to duplication
ConstructionAir Contaminates R 6201 (Gases, Vapors, etc.) ....................................................... Final, effective 1/23/02General Workplace Requirements R 6601 ............................................................... Rescinded due to duplicationSanitation for Construction R 6615 ........................................................................... Consolidated with CS Part 1Illumination for Construction R 6605 ....................................................................... Consolidated with CS Part 1
Administrative RulesPart 11. Recording and Reporting of Occupational Injuries and Illnesses.......... Formal rules submitted
Status of Michigan Standards Promulgation(As of October 4, 2002)
The MIOSHA Standards Division assists in the promulgation of Michigan occupationalsafety and health standards. To receive a copy of the MIOSHA Standards Index (updatedSeptember 2002) or for single copies and sets of safety and health standards, please contactthe Standards Division at 517.322.1845.
RFR Request for RulemakingORR Office of Regulatory ReformLSB Legislative Services BureauJCAR Joint Committee on Administrative Rules
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V a r i a n c e sFollowing are requests for variances and vari-ances granted from occupational safety stan-dards in accordance with rules of the Depart-ment of Consumer & Industry Services, Part12, Variances (R408.22201 to 408.22251).
Variances Requested Construction
Published October 30, 2002
Variances Granted Construction
Variances Revoked General Industry
Part and rule number from which variance is requestedPart 8 - Material Handling: Rule R408.40833. Rule833 (1)Summary of employer’s request for varianceTo allow employer5 to tandem lift structural steel mem-bers under controlled conditions and with stipulations.Name and address of employerAmerican Erectors, Inc.Location for which variance is requestedSouthgate Recreation Center, SouthgateClarkston Medical Building, ClarkstonHutchings Elementary School, HowellName and address of employerAssemblers, Inc.Location for which variance is requestedSouth State Commons Building, Ann ArborName and address of employerDouglas Steel Erection CompanyLocation for which variance is requestedHolocaust Memorial Center, Farmington HillsDelta Township, LansingMichigan State University, East LansingSt. Joseph Mercy of Macomb-W. Campus, Clinton Twsp.Name and address of employerGeneral Steel Erectors Inc.Location for which variance is requestedSt. Joe Hospital, PontiacName and address of employerMcGuire Steel Erection Inc.Location for which variance is requestedPerforming Arts High School, DetroitOakwood Annapolis Hospital Surgery Expansion, WayneName and address of employerWhitmore SteelLocation for which variance is requestedFord Motor Company Rouge Plant, Dearborn
Part and rule number from which variance is requestedPart 10 - Lifting and Digging Equipment: RuleR408.41015a (2) (d)(g) (3) (4)Summary of employer’s request for varianceTo allow the use of a work platform mounted on the boomof a Krupp Crane & Tadano Crane for unscheduled emer-gency power outage restoration work, provided all of therequirements listed are met.Name and address of employerLansing Board of Water and LightLocation for which variance is requestedAs reported in Item #1 in Terms of Interim OrderName and address of employerHi-Ball Co Inc.Location for which variance is requestedAs reported in Item #1 in Terms of Interim Order
Part and rule number from which variance is requestedPart 13 - Mobile Equipment: Ref. #1926.1000 (a) (1&2)(b)Summary of employer’s request for variance
To allow the employer to work under overhead conveyorobstructions in an assembly plant to dig shallow founda-tion pad excavations without the use of rollover equip-ment providing certain stipulations are adhered to.Name and address of employerKent Concrete ConstructionLocation for which variance is requestedWestern Michigan University, KalamazooName and address of employerMead Brothers Exc Inc.Location for which variance is requestedWestern Michigan University, Kalamazoo
Part and rule number from which variance is requestedPart 32 - Aerial Lift Platforms: Rule R408.43209, Rule3209 (8) (c)Summary of employer’s request for varianceTo allow employer to firmly secure a scaffold plank tothe top of the intermediate rail of the guardrail system ofan aerial lift for limited use as a work platform.Name and address of employerMotor City Electric Co.Location for which variance is requestedGeneral Motors Renaissance Center, Detroit
Part and rule number from which variance is requestedPart 8 - Material Handling: Rule R408.40833, Rule833(1)Summary of employer’s request for varianceTo allow employer to tandem lift structural steel mem-bers under controlled conditions and with stipulations.Name and address of employerAmerican Erectors, Inc.Location for which variance is requestedAnchor Bay High School, FairhavenMartin Street Condos, BirminghamName and address of employerAzco Inc.Location for which variance is requestedGrand Rapids Convention Center, Grand RapidsName and address of employerDouglas Steel Erection CompanyLocation for which variance is requestedGeneral Motors Corp. Metal Fabrication Div., FlintName and address of employerMcGuire Steel Erection Inc.Location for which variance is requestedCrittenton Hospital Medical Center, RochesterNew Public Works Complex, Battle CreekDowntown Center, Ann ArborChildren’s Center of Wayne County, DetroitName and address of employerSova Steel Inc.Location for which variance is requestedShelby Creek Commercial Development, Shelby Twp.Name and address of employerTri-Steel Inc.Location for which variance is requestedSaginaw Valley State University, SaginawName and address of employerWhaley Steel Corp.Location for which variance is requestedKettering High School, Waterford
Mott High School, WaterfordName and address of employerWhitmore SteelLocation for which variance is requestedCherry Capital Airport, Traverse CityHowell Parking Deck, Howell
Part and rule number from which variance is requestedPart 10 - Lifting & Digging Equipment: RuleR408.41018, Rule 1018a(21)Summary of employer’s request for varianceTo allow the employer to utilize rotation resistant cableto raise and lower work platform provided stipulationsare adhered to.Name and address of employerChicago Bridge & Iron CompanyLocation for which variance is requestedVarious sites in Michigan to be reported as stated in Item# 1 in Terms of Temporary Variance
Part and rule number from which variance is requestedPart 12 - Scaffolds and Scaffold Platforms: RuleR408.41121, Rule 1221(1)(c)Summary of employer’s request for varianceTo allow employer to use stilts at a maximum height of24 inches under controlled conditions and according tocertain stipulations.Name and address of employerRitsema AssociatesLocation for which variance is requestedFIA Project, Allegan
Part and rule number from which variance is requestedPart 32 - Aerial Lift Platforms: Rule R408.43209, Rule3209 (8)Summary of employer’s request for varianceTo allow employer to firmly secure a scaffold plank tothe top of the intermediate rail of the guardrail system ofan aerial lift for limited use as a work platform, providedcertain stipulations are adhered to.Name and address of employerElectrol Corp.Location for which variance is requestedGeneral Motors Corp. Warren Tech Center, WarrenName and address of employerWilliam E. Harnish Acoustical, Inc.Location for which variance is requestedGeneral Motors Tech Center, WarrenName and address of employerPontiac Ceiling & Partition Co., LLCLocation for which variance is requestedAnchor Bay High School, New Baltimore
Part and rule number from which variance was grantedPart 3, Fixed Ladders Rule 335(3)Summary of varianceAllows the use of 3 fixed ladders in the storage silos witha minimum clearance of 6" between the center line of therungs on the back side to the nearest permanent object.Name and address of employerLietzke Farms, Inc., DeWittLocation for which variance was grantedSameReason for revocationUnable to locate employer
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Part and rule number from which variance was grantedPart 1, General Rules Rule 33(3)Summary of varianceAllows for an alternative to required concurrent machinecontrols for operation of all guillotine rubber cutters.Name and address of employerGoodyear Tire & Rubber Co., JacksonLocation for which variance was grantedSameReason for revocationFacility is closed.
Part and rule number from which variance was grantedPart 2, Floor & Wall Openings, Stairways & SkylightsRule 215(2)Summary of varianceAlternate means of guarding pit or vat areas.Name and address of employerBay View Orchards, OmenaLocation for which variance was grantedBetween Omena and Northport on M-22Reason for revocationUnable to locate employer
Part and rule number from which variance was grantedPart 23, Power Presses Rule 2365Summary of varianceAlternate methods the Department will accept in lieu ofguide pin enclosures on power presses at this location.Name and address of employerC & F Stamping Company, Inc., KentwoodLocation for which variance was grantedSameReason for revocationUnable to locate employer
Part and rule number from which variance was grantedPart 24, Mechanical Power Presses Rule 2431(1)Summary of varianceVariance applies to presses in Department #2 and allowsfor alternate methods in lieu of a single stroke mecha-nism required for presses using full revolution clutches.Name and address of employerChesley Industries Inc., FarmingtonLocation for which variance was grantedSameReason for revocationUnable to locate employer
Part and rule number from which variance was grantedPart 11, Polishing, Buffing and Abrading Rule 1115(1)Summary of varianceAllows for alternate means of guarding the polishing andbuffing jacks.Name and address of employerComet Corporation, DetroitLocation for which variance was grantedSameReason for revocationUnable to locate employer
Part and rule number from which variance was grantedPart 6, Fire Exits Rule 695(3)Summary of varianceAllows the installation of a fixed ladder in lieu of exte-rior stairs or basket ladder type fire escape from the roofof the working house to ground level.Name and address of employerCroswell Milling Company, CroswellLocation for which variance was grantedSameReason for revocationUnable to locate employer
The Bureau of Safety & Regulation is pleased to announceYear 2002 special employee recognition awards. Several ofthe awards are named after former exemplary employees.
HerberHerberHerberHerberHerbert Ct Ct Ct Ct C..... Austin DirAustin DirAustin DirAustin DirAustin Director’ector’ector’ector’ector’s Discrs Discrs Discrs Discrs Discretionaretionaretionaretionaretionary y y y y AAAAAwarwarwarwarwardddddRecipient:Recipient:Recipient:Recipient:Recipient: MarMarMarMarMartha tha tha tha tha YYYYYoderoderoderoderoder,,,,, Chief, Chief, Chief, Chief, Chief, General Industr General Industr General Industr General Industr General Industry Safy Safy Safy Safy Safety Divisionety Divisionety Divisionety Divisionety DivisionAs Chief, Martha has worked to protect and enhance the division’s reputation as one ofthe pre-eminent compliance organizations in the nation. With 18 years of service, sheprovides consistent direction to her employees and assumes a leadership role in the bureau.
Galeeta Galusha-Antes Galeeta Galusha-Antes Galeeta Galusha-Antes Galeeta Galusha-Antes Galeeta Galusha-Antes “Excellence in Ser“Excellence in Ser“Excellence in Ser“Excellence in Ser“Excellence in Service!” vice!” vice!” vice!” vice!” AAAAAwarwarwarwarwardddddRecipient:Recipient:Recipient:Recipient:Recipient: Bea Nielsen,Bea Nielsen,Bea Nielsen,Bea Nielsen,Bea Nielsen, Secr Secr Secr Secr Secretaretaretaretaretaryyyyy,,,,, General Industr General Industr General Industr General Industr General Industry Safy Safy Safy Safy Safety Divisionety Divisionety Divisionety Divisionety DivisionBea is retiring with 23 years of service to the bureau. She developed a spreadsheet thattracks the location and stage of all active and closed inspection files, which eliminated twoother tracking systems. She has consistently performed above her class.
Allan Allan Allan Allan Allan WWWWW..... Har Har Har Har Harvie Meritorious Servie Meritorious Servie Meritorious Servie Meritorious Servie Meritorious Service vice vice vice vice AAAAAwarwarwarwarwardddddRecipient:Recipient:Recipient:Recipient:Recipient: AAAAAyaleyaleyaleyaleyalew Kannow Kannow Kannow Kannow Kanno,,,,, Deputy Chief, Deputy Chief, Deputy Chief, Deputy Chief, Deputy Chief, CET Division CET Division CET Division CET Division CET DivisionAyalew has dedicated more than 20 years of service to the bureau. He is an excellentleader who expects the best from those he works with. He is considered by all those whoknow him as a man of dignity and integrity.
William H.William H.William H.William H.William H. Sebring Meritorious Ser Sebring Meritorious Ser Sebring Meritorious Ser Sebring Meritorious Ser Sebring Meritorious Service vice vice vice vice AAAAAwarwarwarwarwardddddRecipient:Recipient:Recipient:Recipient:Recipient: TTTTTononononony y y y y Allam,Allam,Allam,Allam,Allam, Super Super Super Super Supervisorvisorvisorvisorvisor,,,,, Construction Saf Construction Saf Construction Saf Construction Saf Construction Safety Divisionety Divisionety Divisionety Divisionety DivisionTony is an excellent supervisor and has accepted many division projects and assistedother division on construction outreach. Tony has 18 years of service with the bureau, andwas instrumental in the development of MIOSHA’s first experimental variance.
Bernie Bloomfield Meritorious SerBernie Bloomfield Meritorious SerBernie Bloomfield Meritorious SerBernie Bloomfield Meritorious SerBernie Bloomfield Meritorious Service vice vice vice vice AAAAAwarwarwarwarwardddddRecipient:Recipient:Recipient:Recipient:Recipient: Elaine ClaElaine ClaElaine ClaElaine ClaElaine Clapppppppppp,,,,, Industrial Hygienist, Industrial Hygienist, Industrial Hygienist, Industrial Hygienist, Industrial Hygienist, Occupational Health Division Occupational Health Division Occupational Health Division Occupational Health Division Occupational Health DivisionElaine has eight years with OHD and is the division’s industrial hygienist metals specialist.Elaine won this award by a vote of her peers for her integrity and quality field work andfor exemplifying all of the best qualities of an industrial hygienist.
performing the tasks must be considered. Fi-nally, consider the overall conditions of the workenvironment.
Evaluate Risk: Use the information gath-ered from the above identification and assess-ment activities to evaluate each identified haz-ard and task. From the review, determine thelevel of risk.Alternative Measures
Once the level of risk has been determined,it is possible to explore whether there are ad-equate alternative measures available. Alterna-tive measures include all of the following, andemployers are expected to select the highestlevel of feasible control(s).
� Eliminate the hazards through design.� Use full lockout.� Use engineered safeguards and tech-
niques such as: area scanners, guards, light cur-tains, pressure mats, presence sensing devices,or stop devices under exclusive control of theoperator.
� Use warning and alerting devices to in-clude audible, visual devices, or barricades.
� Use administrative controls such as:work procedures, practices, and training.
� Use personal protective equipment asappropriate to the hazard.
In many cases, application of any singlecontrol measure is not adequate to provide aneffective level of protection for employees. Inthese cases, it is necessary to use a combina-tion of measures.Appropriate Implementation
The General Industry Safety Division isseeing an increase in the number of employerswho have taken the time to thoroughly evaluatethe risk of a minor tool adjustment or change orminor serving activity, and are implementingappropriate alternative protective measures.
Some of the examples safety officers haveseen involve combinations of procedures requir-ing a number of steps to restart a machine, re-dundant interlocks, reduction of machine powerto a level where it will not cycle, and takingsteps to prevent motion through blocking.
Each circumstance where alternative mea-sures are used are evaluated by safety officersto determine whether the work activity meetsthe parameters of the exception in the standard;whether the alternative measures provide ad-equate protection; whether employees are prop-erly trained in the alternative measures, whenthe measure may be use, and when full lockoutis required; and whether the employer is pro-viding adequate monitoring to ensure compli-ance by staff performing the work.
Remember that the ultimate goal, whetherusing lockout or alternative measures, is to takethe steps necessary to ensure that employeesare safe during the work activity.
safety in the work zones. Engineers like Tanyacontributed greatly to the science of traffic regu-lation. Most work zones are very well designed,properly equipped, and well set up.
Contractors, utilities, government agencies,and others working in the road right-of-way stillmust remain diligent to ensure the work zones arecorrectly set up and maintained. Part of the prob-lem is that some work zones are not establishedand adequately maintained according to specifi-cations. That part of the problem, however, can becontrollable.An Uncontrollable Element?
Traffic control devices, however, are not theonly factor in work zone safety. It is important thatdrivers are alert, heed the warning signs, followthe channelization devices, and proceed throughthe area affected by the construction with all duecaution. Indeed, the Michigan Road Builder’sAssociation (MRBA) perceives drivers as the onlyuncontrollable element in work zone safety.
In an effort to affect that uncontrollable ele-ment, Governor Engler signed a bill last yearknown as “Andy’s Law” that imposes severe pen-alties including prison time for persons foundguilty of killing or injuring a road worker. MichaelEckert, Director of Safety Services for MRBAcommented, “Andy’s Law was designed to directdriver’s attention to the problem with the hopethat the law would never have to be used. Themost important issue is to get the drivers to payattention and obey the posted signs.”We All Owe It
Every spring, as the roadwork season ap-proaches, the message goes out to raise aware-ness among the motoring public about the dan-gers to workers and motorists alike in roadwaywork zones. Many years are like this year and aworker is killed by the very traffic flow that theyare risking their life to improve. Just last year, onOct. 1, 2001, while directing traffic Eva Simbler
Cont. from Page 1Roadway Work Zones was struck and killed by a car in Kent county.
Ironically, Andy’s Law became effective thatvery day.
Next year and every spring as the season’sroad work projects begin, road workers willlabor to make our roads better and safer in theeerie din of the constant traffic noise. Theywill be unnerved by the rush of traffic just afew feet from their work area. They may stillnot be able to hear the breeze blowing or resteasily while performing their dangerous work,but each person deserves to end their work shiftin the same healthy condition they were inwhen they began. Every employer who hasworkers in a roadway work zone and all of uswho drive owe this to Tanya. We owe it to Eva.We owe it to Bill.
International Road Dynamics, the companythat employed Tanya Loewen, announced ascholarship fund in her memory.Contributions to the fund can be addressed tothe Tanya Loewen Memorial Scholarship, c/oInternational Road Dynamics, 702 43rd St.East, Saskatoon, Saskatchewan, Canada,S7K3T9. More information is available atwww.irdinc.com.
Tanya Maria Loewen
Video Loan ServiceThe Consultation Education and Training (CET) Division provides safety and health trainingvideos through a vendor loan service. There are no user fees for the videos borrowed; however,the borrower is responsible pay the return postage through an express package service. A fullrange of safety and health videos are available. Among the many topics covered are: AccidentCauses & Prevention; Accident Investigation; Bloodborne Pathogens; Confined Space;Construction; Ergonomics; Fire Safety; Hazard Communication; Respiratory Safety; and Welding.
Employers are encouraged to take advantage of this free service to help promote safety andhealth in the workplace. Make your request for safety and health videos to:
tices and possible hazards.Michigan Health and Hospital Associa-
tion will continue to implement an ergonomicsprevention program tailored to nursing and per-sonal care facilities. The project which will fo-cus on back injury, and will also address shoul-der strain, carpal tunnel syndrome, pinchednerves, etc. On-site ergonomic evaluations willbe provided along with the staff training.
Michigan Road Builders Association willprovide interactive style presentations, work-shops and courses for contractors, management,supervisory and line workers. The training willinclude Heavy/Highway Contractor Update,“Safety Day” Presentations, Excavation; Trench-ing; and Shoring and Technical Assistance.
Michigan State University/Labor Pro-gram Service will provide train-the-trainercourses in Rapid Intervention Team (RIT) train-ing. These trained personnel then go back to theirfire departments and train their employees. Thetraining will be directed to firefighters, offic-ers, and fire chiefs because all fire service per-sonnel have RIT responsibilities.
North Central Michigan College will pro-vide safety and health training to employers andemployees in seven remote counties served byNorth Central Michigan College. They will de-sign, develop and deliver targeted safety train-ing for nursing and personal care facilities, build-ing construction and plastic industries.
PASSES will work with Michigan Con-struction Teachers Association and other con-struction trade schools, to provide training forconstruction technical students in the classroom.They will also develop a web-based training pro-gram using the PASSES Edge curriculum andoffer it to tech schools.
Safety Council for West Michigan willprovide training programs to nursing homes andlong-term care facilities on: lifting safety, liftingequipment, bloodborne pathogens, dealing withaggressive behavior, and personal protectiveequipment. They will offer technical assistancein developing a written safety and health program.
Wayne State University will establish andimplement a twelve-month safety training pro-gram using the CD ROM based Safe2 Worktraining package. The courses are interactive,self-paced curricula that allow the worker towork and be tested using a simulation of theenvironment they are studying.Research Profect
Bay de Noc Community College will mea-sure and quantify the average noise level expo-sure of employees in the wood products industry.The data will be used to: establish more accurateindustry standards for hearing protection; assistin the creation of more comprehensive hearingconservation programs; and increase workerawareness of noise level hazards.
CET GrantsCont. from Page 9
� An employee is required to place any partof his/her body into a danger zone associated witha machine operating cycle.Personal Protective Equipment (PPE)
Employers must assess hazards in the work-place to determine what PPE is needed. ProperPPE is necessary to protect workers face and/orhands from the heat of the molds. Purging ac-tivities pose the potential of severe burns to op-erators and set-up personnel. Burns also occurto personnel when they come into contact withthe heated portions of the barrels.
To protect against thermal hazards, heat re-sistant PPE is required when guards are not pro-vided on the heated surfaces of the machine. Handtrimming operations can present the risk of cuts,and cut resistant gloves should be provided.Fall Prevention
Employees who fill resin bins located onthe tops of machines or have other needs to ac-cess the top must be provided with an appropri-ate means of access. Employees must not be al-lowed to climb up the side of the machine. Ap-propriate work surfaces must also be provided.Standard barriers are required around work plat-forms or fall protection must be provided.Electrical Hazards
All electrical cords should be maintained freeof defects and should not be allowed to create elec-trical hazards or trip hazards. The cords of grind-ers that are moved manually between stations maybecome damaged due to minor abrasions.
Electrical connections to heated portions ofa ram or screw cylinder must be covered with anonconducting guard or a grounded metal bar-rier to prevent contact with live terminals. Per-sonal fans should be grounded properly and cordsshould not be frayed or spliced.Mold Transfer and Handling
It is critical that moving slings and eyeboltsare in good condition. No bent eyebolts shouldbe used. Eyebolts should be fully engaged inmolds to the shoulder of the bolt. No spacers areallowed between shoulder of bolt and the mold.Welding on eyebolts will destroy the integrity ofthe forged eyebolt. It is important that slings,eyebolts, and material handling devices be in-spected for defects frequently.Housekeeping
Poor housekeeping can lead to debilitatingback injuries as a result of slips or falls. Theover loading and filling of hoppers and grinderbins with granular material contributes to un-safe conditions.
No oil, fluid, water or plastic pellets orgranules should be allowed to collect on thefloor, work platforms, or any other work sur-faces. All work platforms and steps should beof open design or slip resistant surface. No air,hydraulic or water lines should be allowed to
create a slip or trip hazard.Preventive Maintenance
Continuous preventive maintenance is acritical element in the prevention of unsafe con-ditions. Hydraulic and coolant hoses have asafety factor rating of four, which will meet andexceed high temperature and pressure ratings.Scheduled routine repair of these hoses will helpeliminate the potential for accidents.Ergonomics
Employers are encouraged to conduct anassessment to identify jobs or work conditionsthat may cause undue strain, localized fatigue,discomfort or pain. Job tasks that involve ac-tivities such as repetitive and forceful exertions;frequent heavy or overhead lifts; awkward workpositions or use of vibrating equipment shouldbe evaluated for possible ergonomic problems.
It is recommended engineering controls beused when possible to reduce or eliminate thesetypes of hazards. Ergonomically designed handtools, work stations, material lifting devices canhelp eliminate hazards. Designing work areas thatdo not require employees to work in awkwardpositions, use repetitive movements or forcefulexertions can reduce the risk of cummulativetrauma and musculoskeletal disorders.Partnership with MIOSHA
On May 25, 2000, MIOSHA signed a land-mark partnership with The Society of the Plas-tics Industry, Inc. (SPI). The purpose of the for-mal partnership is to focus on the importance ofproviding a safe workplace for all workers inthe plastics processing industry in Michigan. SPIis the 1,700 member trade association represent-ing the plastics industry in the U.S.
The formal partnering charter establishesa relationship in which the parties will: promoteworker safety; conduct stakeholder meetings todiscuss pertinent and/or urgent issues; cooper-ate in the development and improvement of plas-tics processing training programs; and foster aclimate in which workplace safety is promotedas a good business practice.
As a result of this partnership, the plasticsindustry has been added as an “Initiative” tothe MIOSHA Strategic Plan. As part of the ini-tiative, the Consultation Education and Train-ing (CET) Division is providing outreach infor-mation and guidance specific to the plastics in-dustry to help them protect employees.
Part 62., Plastic Molding, Rule 6211 re-quires that an employer shall provide trainingto all employees regarding the operating proce-dures, hazards and safeguards of any assignedjob. Safety and health training is an integralcomponent of skill training for plastic mold op-erators. It is important that safety training beviewed as a function of the job and not as anextra responsibility.
For information on MIOSHA education andtraining services, please contact the CET Divi-sion at: 517.322.1809. �
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Consumer & Industry ServicesBureau of Safety & RegulationDirector: Douglas R. Earle
MIOSHA News is a quarterlypublication of the Bureau ofSafety & Regulation, which isresponsible for the enforcementof the Michigan OccupationalSafety and Health Act (MIOSHA).
The purpose is to educateMichigan employers andemployees about workplacesafety and health. This documentis in the public domain and weencourage reprinting.
Printed under authority of theMichigan Occupational Safety andHealth Act, PA 154 of 1974, asamended. Paid for with the state“Safety Education and TrainingFund” and federal OSHA funds.
Editor: Judith Keely Simons
Consumer & Industry ServicesDirector: Noelle A. Clark
Consumer & Industry ServicesBureau of Safety & RegulationP.O. Box 306437150 Harris DriveLansing, Michigan 48909-8143
(20,000 copies printed at a cost of $9,510 or $0.48 per copy.)
Website: www.michigan.gov(Select “Workplace Safety & Health” from the left navigation bar.)
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