OSHA Compliance

Many businesses do not have the budget or resources for a full-time safety and health manager; however, they still need to comply with safety and health regulations from the Occupational Health and Safety Administration (OSHA) or the State agencies. This reality can leave owners and managers feeling overwhelmed, and with a mindset that safety compliance is competing against their bottom line. Consequently, this leaves employees facing risk and possible injury. CTI can help mind this gap while meeting the specific needs and requirements of the client. We can provide safety and health consulting services that are cost-effective and OSHA compliant.

Has OSHA visited your facility? Click here to learn the do’s and don’ts if OSHA knocks on your door.

Click below to explore a number of the safety and health consulting service that CTI can tailor to your personal industry and business dynamic.

Confined Space Entry Procedures
Industrial Hygiene/Indoor Air Quality
Job Hazard Analysis (JHA)
Lab Safety
Machine Guarding Risk Assessment And Evaluation
Machine Specific Lockout/Tagout Procedures
Noise Exposure Monitoring
OSHA Compliance Audits & Mock OSHA Inspections
OSHA Required Safety Training
Robot Risk Assessment & Safety
Safety Policies, Procedures, and Programs

Confined Space Entry Procedures

While working in confined spaces, your employees will encounter many hazards not found within standard worksites: lack of ventilation, high concentrations of hazardous vapors, engulfment, oxygen deficiency, etc. Therefore, OSHA requires special identification, testing, and training for these environments, as well as space-specific entry procedures for each confined space at your facility. In accordance with regulations, CTI will visit your facility and identify all confined spaces, non-permit and permit-required spaces. Upon identification of the confined spaces, CTI will provide written procedures outlining requirements and processes for safe entry, as well as advise on proper employee notification and signage of confined space. CTI can provide the necessary training to ensure all personnel are aware of and understand the proper protocol for safe entry.

Industrial Hygiene/Indoor Air Quality

Exposure to health hazards at work can result in any number of work-related illnesses. For this reason, OSHA continues to get more stringent and regularly issues rulings in order to protect workers from exposure to air contaminants in the workplace. An assessment of a facility and a review of the Industrial Hygiene Program are good resources in determining a facility’s compliance with government regulations, as well as ensuring alignment with industry best management practices, and aiding in the investigation to identify the reason behind an employee complaint. CTI has a professional and knowledgeable team experienced in diverse working environments throughout many industrial sectors. We can provide practical and proven solutions through assessments & analytic services using regulatory interpretation. Check out our Industrial Hygiene Brochure for more information.

CTI provides comprehensive indoor environment investigations to evaluate employee health hazards and occupant complaints associated with indoor building environments. We conduct area or personal air monitoring in accordance with the applicable National Institute for Occupational Safety and Health (NIOSH) or Occupational Safety and Health Administration (OSHA) sampling protocols. CTI’s sampling capabilities include testing for:

    • Various chemicals
    • Metals
    • Acids/bases
    • Volatile organic compounds (VOCs)
    • Inorganic compounds
    • Particulates
    • Gases
    • Mold

We use accredited laboratories to perform the analysis of sample media. The laboratory results are included in the final Occupational Air Exposure Monitoring reports, along with a breakdown of the sample location and personnel, and recommendations for corrective actions to reduce the exposure to employees.

Job Hazard Analysis (JHA)

A Job Hazard Analysis (JHA) is a safety management tool that can be used to define and control hazards associated with a certain process, job, or procedure. It focuses on the relationship between the worker, the task, the tools, and the work environment. A JHA examines and documents all of the tasks and jobs performed throughout your facility to identify all potential hazards and the current state of controls in place for each task. Our safety consultants will evaluate the tasks, equipment, and processes conducted at your facility to determine the potential risks, the potential consequences of these risks, as well as the likelihood of these risks occurring. These findings will be compiled into an easy-to-read report that will allow you to effectively take the steps necessary to eliminate or reduce the hazards to acceptable risk levels.

Lab Safety

Laboratory personnel routinely handle hazardous chemicals. To ensure these employees are safe, it is important to comply with OSHA’s hazard communication standard 1910.1200 and with their laboratory safety standard 1910.1450. OSHA’s hazard communication standard requires all containers of hazardous chemicals to be properly labeled, and that associated Safety Data Sheets (SDS’s) are maintained, and that the facility has a Written Hazard Communication Program. All labels and SDS’s must align with the Globally Harmonized System for the Classification and Labeling of Hazardous Chemicals (GHS).

In addition, OSHA requires that all facilities with laboratories must have a Chemical Hygiene Plan (CHP) to protect laboratory workers from harm due to improper handling of hazardous chemicals. Your CHP should include standard operating procedures that are relevant to safety and health considerations for each activity involving the use of hazardous chemicals. The plan should identify control measures used to reduce exposure to hazardous materials, such as engineering controls, use of PPE, and administrative controls. The plan should include permissible exposure limits (PEL’s) for OSHA-regulated substances and should identify where SDS’s are made available to laboratory employees.

Along with maintaining a CHP, you should ensure that your laboratory employees are trained in methods and observations to detect the presence or release of a hazardous chemical. Training should also identify the physical and health hazards associated with chemicals used in the laboratories, and measures that workers can use to protect themselves from these hazards.

Lastly, OSHA often refers to consensus standards when conducting inspections. For laboratory safety, OSHA will often cite NFPA 45 – Standard on Fire Protection for Laboratories Using Chemicals. NFPA 45 includes information regarding fire protection requirements for laboratories, laboratory design, vent hood use, and safe quantities of flammable materials allowed to be stored and used in the laboratories. CTI can help ensure that your laboratories are in compliance with OSHA laboratory and chemical safety requirements by conducting NFPA 45 compliance reviews and by reviewing or preparing Written Hazard Communication Programs or Chemical Hygiene Plans.

Machine Guarding Risk Assessment and Evaluation

Conversion Technology Inc. employs a knowledgeable staff of mechanical engineers, machine designers, and industry specialists with backgrounds in overall machine specification along with a working knowledge of OSHA regulations and machine guarding requirements. With these skills and backgrounds, CTI is able to come to your facility and conduct a walkthrough risk analysis of the equipment and process lines at the facility. From the walkthrough, we will determine and identify gaps in machine guarding that could be unsafe to employees or non-compliant with OSHA regulations. CTI will analyze the potential risks posed to employees from each piece of machinery and process and determine if they satisfy the OSHA requirements for guarding. Should any gaps be noticed during the risk assessment, CTI will detail what the gaps are, the potential level of risk posed to employees, and remediation techniques that can be installed and easily implemented throughout the facility.

CTI is able to work with facility maintenance personnel or 3rd party machine contractors to design safe and compliant machine guarding that is suitable for the equipment and culture present at your facility. See below for some before & after photos of recent machine guard design projects.

Click here to read CTI’s published article on Machine Guarding

Click here to view Adam Haroz’s conference presentation on Who is Responsible for Machine Guarding

Machine Specific Lockout/Tagout Procedures

OSHA’s lockout standard 1910.147(c)(4)(i) requires that lockout procedures be developed, documented and utilized for the control of potentially hazardous energy. Lockout procedures are vital to helping your employees stay safe and compliant. The key to effective procedures is concise content that clearly tells your workforce just what they need to do. Whether you have existing procedures in place or you are starting from scratch, CTI’s high level engineers have the knowledge and experience to help you properly develop and implement specifically designed lockout/tagout procedures for the equipment at your facility. A CTI engineer, along with your experienced personnel, will perform a hazard analysis of your current equipment to create machine specific lockout/tagout procedures. These procedures will be designed to be user friendly in order to ensure the equipment to be serviced or maintained can be easily locked out by authorized employees.

Noise Exposure Monitoring

OSHA requires that facilities with noise exposure over 90 dBA on a time-weighted average (TWA) implement engineering controls to reduce the noise level exposed to employees. Solely relying on the use of hearing protection devices to protect employees from excessive noise levels is not considered best management practices by OSHA. CTI can assist in identifying noise levels and evaluating noise control options. We utilize various sound level meters and dosimeters to measure the noise level in a workplace in order to evaluate a facility’s compliance with OSHA’s action level of 85 dBA and permissible exposure limit of 90 dBA.

OSHA Compliance Audits & Mock OSHA Inspections

OSHA requires all employers in the United States to provide their employees with a workplace free of hazards. In an effort to ensure a safe working environment for your employees, as well as maintain compliance with applicable OSHA regulations, Conversion Technology provides on-site OSHA compliance audits and Mock OSHA inspections. OSHA Compliance Audits are designed to evaluate compliance with applicable safety and health regulations and assist you in achieving a high level of regulatory compliance. Our role is to come in and identify potential hazards and unsafe work practices in the workplace, determine any regulatory non-compliance, and develop a corrective action plan along with recommendations on how to abate the identified deficiencies. These inspections and audits include a thorough review of your operations and a walkthrough of the facility to identify any potential hazards. A records review could also accompany the walkthrough, in order to ensure that training records and safety policies and programs meet OHSA requirements. A detailed report listing the findings and recommended abatement measures will be provided with each OSHA compliance audit and mock OSHA inspection.

CTI can aid a facility by coming in with fresh eyes, and an extensive background in safety regulations & requirements and a deep understanding of manufacturing processes, to shine a light on any deficiencies. We can help prioritize where resources should be allocated for abatement. All of CTI’s findings and inspection reports are kept confidential and are for internal use by CTI and your facility ONLY.

OSHA Required Safety Training

There are over 100 OSHA standards that explicitly require workplace safety training. Worksite-specific training is important for compliance with OSHA and to help maintain a safe working environment. An effective occupational safety and health training program can result in fewer injuries and illnesses, better morale and lower workers’ compensation insurance premiums, among other benefits. A custom tailored OSHA safety training program can be created based on your company’s needs. One of CTI’s qualified OSHA safety trainers can travel to your site to conduct the training.

Some examples of safety training topics include, but are not limited to:

• Confined Space
• Distracted Driver
• Drug Free Workplace
• Emergency Response
• Fall Protection
• Forklift and other Vehicle Safety (Includes Employee Evaluation)
• Fire Protection
• Hazard Communication
• Identifying Hazards in the Workplace
• Lab Safety
• Lockout/Tagout
• Machine Guarding
• ISO 45001 Awareness
• Train-the-Trainer on any of the abovementioned topics
• And many more (including company-specific policies)

Robot Risk Assessment

Assessing risk has always played a vital role in the development and implementation of machinery, industrial robots, and CNC machines. With the rapidly evolving robot and CNC machinery applications comes a growing need, as well as an increase in regulatory requirements, to identify and understand the risks involved in working with these machines. Due to the passage and enforcement of regulations governing robots and CNC machines by RIA, OSHA, ANSI, ISO, etc., regardless of the safety equipment installed on robotic systems, a risk assessment for robots and CNC machines is mandatory.

CTI has extensive experience working with industrial robots (including Collaborative Robots, Welding Robots, AGVs, etc.) and CNC machines, and is an industry leader in risk assessment techniques. CTI is an Associate Member of the ANSI/RIA R15.06 Rulemaking Committee as well as a part of the OSHA-RIA-NIOSH Alliance Committee. CTI will evaluate the current robotic safety procedures, operations, and potential hazards in place and prepare a detailed report identifying robotic safety deficiencies and specific recommendations for your facility to be in compliance with ANSI consensus standards and OSHA regulations. We are able to conduct a quantitative risk assessment that allows for an objective and pragmatic appraisal of the hazards associated with your robots and CNC machines.

Click here to watch Adam Haroz’s conference presentation on Robot Risk Assessments

Click here to view CTI’s company profile on the Robotics Industries Association (RIA) Website

See also our Machine Guarding Risk Assessment services.

Click here for our Robot Resources page

Safety Policies, Procedures, and Programs

Written safety & health plans are an important part of a company’s safety & health mission. Not only does OSHA require companies to have written programs, but federal and state OSHA laws are complex. CTI can help create new safety programs from scratch that are specific to the needs of your facility, or just update a current safety manual to address new requirements. Our experienced safety engineers will collaborate with you to develop the exact health and safety program that your facility needs. Components of our program are based on OSHA standards, best practices, and the personal experiences of our field personnel. Our staff has adopted and perfected a systematic approach to producing OSHA compliant written safety programs. CTI’s safety and health policies and programs can are commonly used on and can be prepared for submission to ISNetworld and Avetta.

CTI is also able to assist with the management of, as well as sit in on, Safety Committee Meetings.