Joseph Paranac, Jr. | LeClair Ryan
Companies are continuing to search for cost-effective ways to speed up the movement of goods from factory to the ultimate consumer, and state-of-the art warehouses and distribution facilities are taking on an increasingly important role in the process.
But even as businesses step up their investments in the category – nationally, warehousing and storage centers added about 53,000 jobs during the one-year period ending April 2016, according to the most recent data from the Bureau of Labor Statistics – federal safety regulators are increasing their scrutiny of the industry, stepping up enforcement and penalties for perceived violations.
It’s important to pay attention to all aspects of safety, but warehousing and distribution center operators should know that OSHA has been paying extra attention to certain key areas. One of them is forklift truck safety, where regulators want to see evidence that the trucks are being inspected daily, that forklift operator training meets OSHA standards, and that operators are recertified every three years.
Best practices in this area include placing blocks under the wheels of a forklift when it’s backed up against a dock, to ensure that the forklift doesn’t drift away. Additionally, while electric forklifts are often used because they produce zero emissions, virtually eliminate the hazard of carbon monoxide poisoning and run more quietly than internal combustion vehicles, they do present other serious potential hazards that must be addressed.
Most electric forklifts are powered by large lead-acid batteries that must be routinely charged, and the concern here is that the battery charging area must be adequately ventilated to avoid the build-up of hydrogen gas during charging. An ample and readily available water supply should be maintained for flushing and neutralizing spilled electrolyte, along with enough eyewash to provide a 15-minute flow. For large installations, a plumbed drench shower and an eyewash station should be maintained.
Facilities that use forklifts powered by liquid propane gas (LPG) should feature prominently displayed signage warning that a flammable power source is in use. Further, the LPG forklifts should be safely stored when they’re not being used and, at all times, workers should have easy access to portable, clearly labeled fire extinguishers.
As part of an overall fire safety program – another OSHA favorite – fire extinguishers should be inspected monthly, and workers should be trained in using them. Fire exits must be clearly marked, and adequately spaced aisles must provide easy access to the exits.
OSHA also requires warehouses and distribution centers to have written emergency evacuation plans in the event of fire, hazardous weather, or other conditions. Workers should know where exits are, and how to safely leave the building. As part of the evacuation program, workers should periodically practice leaving the premises and be familiar with warning signals, like fire alarms, or other signals like two loud blasts of a horn.
Hazard communications, or HazCom, is another issue that’s received more attention from OSHA. As of June 1, a phase-in of previously issued Hazard Communication Standards – which require employers to take measures to prevent illness or injury that could occur when working with hazardous materials – now mandate enhanced labeling for hazardous materials, and training in handling them. Additionally, new standards have been implemented regarding material safety data sheets that must be made available to workers, informing them of the properties and hazards of certain substances.
Employers can assume that there will be a big jump in OSHA HazCom inspections, so they should prepare by reviewing the new standards to ensure they conform.
Storage issues are another ongoing OSHA concern. While this not a new focus for regulators, the jump in inventory demand spurred by e-commerce and other factors are spurring warehouse distribution centers to pack ever-more inventory into their facilities. OSHA inspectors want to be sure that inventory is stored safely, and that operators are not simply piling one pallet on top of another. Instead, racks should be installed to ensure stability of the stored goods.
Fall protection is a related concern. When workers need to reach top-shelf goods, for example, a simple forklift is not appropriate. Instead, a lift truck with a cage or harness can safely transport pickers to top-level inventory tiers.
Warehouse and distribution facilities are also likely to see a step-up in the volume of OSHA site visits, thanks to an increase in the agency’s Rapid Response Investigation (RRI) requests. Following an accident, OSHA may contact the reporting employer to learn more about the root cause and how to prevent similar incidents from occurring.
We have seen a sizable increase in the issuance of RRI requests, and if OSHA believes a reporting company is trying to whitewash an incident – perhaps by simply blaming the victim instead of thoroughly investigating the incident and documenting the findings – the agency may mount its own incident inspection. This could uncover even more violations that could land a business in even hotter water.
To minimize the chance of this, companies may consider working with outside advisors who offer OSHA and RRI seminars that focus on best reporting and other practices.
Warehouse and distribution center owners and operators should keep up with these and other regulatory developments, since they can potentially impact a wide range of activities. OSHA has been pursuing an activist position that has meant more costs for businesses, but the costs of non-compliance could be even more.