Preventing OSHA Citations with Equipment Inspections - A Guide to OSHA's New Mandate

Inspections

Worn gear belongs off the floor, period. It's why OSHA mandates specific inspections and issues citations for failure to comply. Routine visual checks and detailed equipment inspections satisfy OSHA requirements and stop dangerous failures before they happen. When you build a proactive inspection process, you take control of workplace safety, eliminate hazards before they cause harm and stay clear of costly citations.

Be sure you understand which inspections are required in your facility or site and how often you need to perform them. Also note that some inspection requirements call for a “competent person” to perform the inspection. A competent person is different from a qualified person, who holds recognized certifications. A competent person isn't formally certified, but instead is defined as someone who “is capable of identifying existing and predictable hazards… and who has authorization to take prompt corrective measures to eliminate them.”

You know your facility, but staying on top of every inspection cycle takes time and resources. Partner with the Brady Safety Services team to request an on-site safety audit and build an inspection program.

Fundamentals of an effective equipment tagging system

An effective equipment inspection and tagging system includes visual safety protocols and thorough documentation. Keeping detailed records of every inspection can help you pinpoint gaps in your safety process, as well as demonstrate that you maintain an active tagging program. In the case of a violation, the OSHA Field Operations Manual states that the inspector can reduce fines if a “good faith effort” is shown. Having active procedures demonstrates this good faith effort.

Stoplight systems

To help with fast visual identification and give employees confidence in your inspection process, consider implementing a “stoplight system.” This very well-known and easy-to-identify system uses the traditional red, yellow and green colors of a traffic stoplight to indicate safety levels.

• Green tags mean the equipment has been inspected and is safe to use.
  
  Something to watch out for: Green tags can give a false sense of safety. Technically, if the date on the tag is not the current date, the equipment is uninspected. Scaffolding, for example, needs to be inspected before every work shift, as well as every time it is reconfigured or moved.
• Yellow tags indicate that the equipment may be safe to use, but there's a potential issue that needs further investigation. Some companies use yellow tags to show that a piece of equipment has been inspected, but a more thorough inspection, or mandatory replacement is coming up. Others use yellow tags to caution workers about equipment use that is more dangerous than they may expect.
• Red tags are a full stop. The equipment has been inspected and deemed unsafe, is undergoing maintenance or in the case of scaffolding, may be erected, but not fully inspected yet.

Encourage employees to validate safety by checking the date on the tag before every use.

Modernizing your inspection process

Consider incorporating unique IDs for each piece of equipment. While it may seem like overkill to assign IDs to large, stationary machines, ensuring that ladders, safety harnesses and other equipment have unique identifiers creates a stronger inspection and documentation link. Your records can show the exact ladder that was inspected by whom and on what date, in a centralized system. Using QR codes can help streamline this process. And when integrated with the right safety documentation system, compliance can become an automated task.

Scaffolding Inspection Process

The type of scaffolding will impact the safety procedures and inspection points. For example, in the case of suspended scaffolding, you should always inspect suspension ropes and platforms.

For system scaffolding, you’ll need to check that all of the modular components are connected correctly and locked. You also need to ensure that the scaffolding is stable, especially if the scaffolding is set on uneven or bare ground.

As with ladders, consider implementing a stoplight system with a “do not use” placard as the default. Create a process for shift changes that requires an outgoing competent person to remove the green tag and an incoming competent person to inspect and add a green tag before any work begins.

Read more about specific scaffolding requirements and best practices in Brady’s Guide to Scaffolding Safety.

Fall arrest systems and harnesses

Faulty fall arrest systems can have devastating consequences. Like scaffolding, harnesses and fall arrest systems have a two-tiered inspection cycle. There is a daily pre-use check by the primary user as well as a formal inspection by a competent person every six months to a year. These inspections should be recorded on a separate log card to show regulators.

If there is any damage to the fall arrest system, or if the safety information printed on the equipment isn’t clearly legible, destroy it immediately. Cut the straps or damage it beyond repair to prevent the gear from being pulled out of the trash and accidentally used.

Other major inspection targets

Here are a few other key areas to watch out for:

• Rigging slings. In addition to inspecting harnesses, be sure to pay special attention to rigging slings. These also need to be inspected daily, and any wear and tear or worn tags warrant immediate disposal.
• Eyewash stations. Eyewash stations require weekly visual inspections. Additionally, if the station is plumbed, it needs to be activated weekly to flush the lines. Stagnant water hosts bacteria and microorganisms that can lead to infection.
• Extension cords. Extension cords should be visually inspected before each use. Federal standards generally do not mandate written documentation or formal logs of these inspections, but if there is any damage to the cords they need to be removed from service.