As featured in:
	On the 40h Anniversary of OSHA by Robert Dunne Safety First, But Confusion Over Regs Confounds Rotomolders, Inspectors My grandfather often took me to tour manufacturing plants in my pre-teen years. I'll never forget seeing dozens of stern, brawny steelworkers fleeing for cover, hiding from splattering molten metal as it spilled and poured out from a gigantic, open ladle. I still think about the steel workers and others I saw applying fiberglass resins to auto parts without any gloves or ventilation. It seems outrageous today but these were standard procedures in the late 1960's and these procedures were similar at the more than 25 other Midwest manufacturing companies my grandfather managed from offices in downtown Cleveland, then a thriving boomtown. I traveled from one inner-city neighborhood to another, seeing firsthand how cars, trucks, boats and other products and parts were produced with metals, plastics, wood and other materials. In nearly every case, though, these companies operated from dark, shabby facilities in tight, cluttered layouts that would terrify today's lean manufacturing experts. Uneven flooring demanded we watch every step while outdated elevators squeaked, creaked and jerked up and down the building, transporting product in various states of completion. Ceilings kept a grimy, chemical record of everything that was produced since the smokestacks were often unable to usher all the particulate waste out of the buildings as airflow was never recognized as an issue worth studying. Clearly, manufacturers had established an infrastructure over several generations built on chasing the dollar with seemingly little regard for worker health and safety. Though barely a teenager, I somehow understood that no amount of extra vacation time, higher hourly wages or pension benefits could substitute for a worker's safe return home each day - or as I realize now, for a worker's longevity. It is with these memories etched in my mind that I join many in recognizing the 40th anniversary of the passage of the Occupational Safety and Health Act that established the Occupational Health and Safety Administration (OSHA). Sure, the agency earns criticism today for its bureaucratic structure, politically inspired regulations and uneven enforcement but look around your plant and it's easy to see the Act's achievements are surely notable. We're careful about smooth flooring with clear entries and exits. We put gates and bars around our machinery with strikingly alarming yellow, black and red signage in multiple languages. Dust is painstakingly collected and controlled while strict lockout/tagout procedures are followed before any machine maintenance is performed. Assembly operations have been adjusted for ergonomics just like the chair you're sitting in at the office. Safety has become an integral element in how machines, products and processes are designed and in how our operations are organized. Though OSHA officials may take credit for a boundless number of injuries prevented or their severity minimized, and rightfully so, the Act's greatest contribution - in my mind - is its elevation of worker safety to a position of importance. The Act was passed to eliminate the profits only-centered approach of prior generations and it required that, managers needed to recognize that workers were entitled to a reasonable level of safety in the workplace. Today, most employers recognize the correlation between improvements in safety and productivity. Yet despite the great advances we've seen in OSHA's first 40 years, the original Act has been dwarfed in size and scope by thousands upon thousands of pages of additional regulations, rules, standards and guidelines. The agency has to publish summaries of publications originally published to clarify its publications. Often, these regulations are devised based on conditions at the country's largest manufacturing plants and they just aren't easily applied to small businesses such as many of our companies involved in rotomolding. Consider how material is stored in silos. Some OSHA inspectors consider silos as confined spaces under OSHA's 29 CFR 1910.146 regulating permit-required confined space entry. They fit the criteria as permanently bolted structures. Yet many other OSHA inspectors understand the near impossibility of human entry without disassembling the silo - no labeling, colorful signage or protective equipment is needed. It seems to me it would be nearly impossible for inspectors trained to reveal potential slips and falls in a healthcare setting to properly assess the situation in a rotomolding facility as it relates to confined space. Imagine, how could standards developed by attorneys in Washington D.C. be effectively applied to equipment an inspector has never seen, especially when operated in a manner that differs in how it is used from one industry to another? If we cannot confidently take corrective action based on the direction of our own local OSHA inspectors then how can we protect our workers and our companies from excess risk and liability? Further, OSHA Chief Administrator Dr. David Michaels touted in a letter to his staff in celebration of the 40th anniversary of the Act that the agency has increased the severity of penalties and fines and shifted the agency's focus from helping companies comply with its regulations to one of enforcement. You can see that the cost of confusion and uncertainty has just increased. Michaels also went so far as to recognize some of the agency's shortcomings. "When these programs don't work well, when they are just paper programs, they detract from our efforts because they provide a false indication of activity and commitment." Unfortunately, most of that activity involves small businesses scrambling to auditing, documenting and reporting far more activity than is necessary to support safe plant operations. It is clear that rather than passively awaiting federal agencies to misapply their regulations to our companies, we need to drive the proper clarification and application of existing regulations, even going so far as drafting appropriate regulations ourselves. The workers and managers operating the machinery in any given industry are most able to assess best practices for both safe operation and for proper inspection methodologies. In fact, I contend that such initiatives need to be driven by each industry as a primary focus of its trade associations. We rotational molders, specifically, need to establish guidelines and standards for machinery and equipment including inspection procedures for verifying the safety of the equipment while in actual operation. Given that many rotomolders still operate machines that have achieved their own 40th anniversaries, and have modified and customized them over the years with little regard to current standards, there simply cannot be enough inspectors to review every machine in service nor can these inspectors fully understand how to apply current regulations to the aging machines. It is up to us to help OSHA help both our workers and our businesses. My grandfather might think this an odd position. His organization typically purchased manufacturers that were undercapitalized or struggling to manage the succession from one generation to another due to a complex snare of tax, capital and/or personnel issues. I suspect he'd be surprised that a group of well-intentioned safety regulations could cause enough confusion and frustration that profitable rotomolders could quickly become one of the struggling companies he would target for acquisition despite their honest efforts at compliance. Nevertheless, why take the chance with your company??? Send comments to Bob Dunne at rdunne1@usa.net or see www.Rotomolding.com/bobdunne.shtml. Meese Orbitron Dunne Co. is the first rotomolder in North America to invest in the Leonardo system. Its parent company, Tingue, Brown & Co., Saddle Brook, New Jersey, has a history of bold moves since 1902 that include pioneering the use of plastics for rotomolding laundry handling products.