OSHA Compliance Audits
A compliance audit will identify which OSHA regulations apply
in your facility and what actions are required to ensure compliance.
The benefits of compliance, apart from avoidance of potential fines
and penalties, include a safer working environment, reduced injuries,
and savings on workers' compensation costs. Lamb Consultants
will review your worksite, procedures, equipment and records to
ensure you have written programs, standard operating procedures,
training records, personal protective equipment, in plant signage,
labeling, employee notification, medical surveillance, and other
record keeping required by applicable OSHA standards. The agreed
scope of an audit may include any or all of the following:
- Process Safety Management (PSM)
- Ammonia System Integrity Services
- Hazard Communications (HAZCOM)
- Control of Hazardous Energy
- Emergency Action/Response
- Hearing Conservation
- Respiratory Protection
- Employee Exposure Monitoring (air, noise)
- Personal Protective Equipment
- Engineering Controls
- Administrative Controls
- Industrial Truck Safety
- Training and Record Keeping
Following the detailed audit, you will
receive a confidential report indentifying deficiencies along with
specific recommendations to achieve compliance.
Process Safety Management (PSM)
OSHA’s Process Safety Management
Standard (1910.119) is a complex, goal-oriented standard designed to
prevent disasters from the accidental release of chemicals. The Lamb
Group specializes in Anhydrous Ammonia. Lamb Consultants, working
closely with your key personnel, will develop a compliance program which
identifies hazardous processes and details safety information related
to process chemicals, technology and equipment. We will conduct Process
Hazard Analyses (PHA’s) to analyze the potential causes and
consequences of fires, explosions, chemical releases and major spills,
focusing on equipment, instrumentation, utilities, human factors and
external factors which may impact the process.
Based on data collected, we will
develop Standard Operating Procedures (SOPs) to be performed. We will
further detail the training requirements, including safe work practices
and procedures for emergency response. We will provide written
procedures to maintain the mechanical Integrity of process equipment and
P&ID’s. Procedures for work authorization will be developed, along
with procedures to manage changes in process chemicals, technology or
equipment. The compliance program will detail the requirements for
investigating and acting on incidents which result, or could have
resulted, in the catastrophic release of anhydrous ammonia.
AMMONIA SYSTEM INTEGRITY SERVICES
In addition to normal programs for
Process Safety Management (PSM) for Ammonia Refrigeration, the Lamb
Group offers two additional services related to maintaining the
integrity of your ammonia refrigeration system.
- Five Year Independent Mechanical Inspection of the system and all components by competent refrigeration trained personnel.
- Ultrasonic Non-Destructive Testing Services utilizing trained and certified NDT technicians and the latest most reliable testing equipment
Our technicians are not only NDT
qualified but are also trained in ammonia refrigeration, giving us the
advantage of understanding your system and its applications, thus
enabling us to assist your personnel in the decision making process of
where to test and the number of tests needed. Our equipment utilizes
dual transducer probes to gain access to the bottom of surface pits and
to measure true minimum remaining wall thickness on piping, and pressure
vessels. All test sites are numbered, tagged, photographed, and
annotated on the system P&IDs.
The final testing results are provided
in a confidential easily understandable report format detailing the
results of the testing and recommendations for corrective actions. The
report may also use the data from the testing to project the remaining
service life of the piping and vessels.
Hazard Communications (HAZCOM)
OSHA's HAZCOM Standard (1910.1200)
requires all workers who may be exposed to hazardous chemicals and
compounds understand the risks of exposure, and the precautions
necessary to prevent exposure. In preparing your compliance manual, Lamb
Consultants will catalog all covered substances on your premises. They
will assemble all necessary MSDS's and will define the criteria and
methods for proper labeling and other forms of warning. They may assist
management in determining which employees may be exposed to specific
hazards and define the content and methods to be used to properly inform
employees of the hazards to which they may be exposed.
Control of Hazardous Energy
Workers required to service or
maintain machinery or equipment powered by hazardous energy sources, as
well as those in the area of such servicing, must be protected
(1910.147). Lamb's compliance program will specify each machine or
piece of equipment covered by the standard and will include your
operating procedures and responsibilities for the placement, removal and
transfer of Lockout/Tagout devices. This will include the steps for
shutting down machinery or equipment and for isolating energy sources,
including the requirements for testing the effectiveness of the energy
control measures and re-energizing. The plan will detail which employees
are affected and the training requirements and methodology.
Emergency Action/Response
Employees must know how to act or
respond in case of a workplace emergency (1910.38). Lamb Consultants
will detail pre-emergency planning and prevention and emergency
recognition. Methods and procedures for emergency alert will be
specified, as well as procedures for evacuation and handling emergency
response. Methods and frequency of training are also covered.
Hearing Conservation
Occupational hearing loss hurts both
the affected worker and the employer alike. Noise-induced hearing loss
is a gradual, deteriorative process which must be detected early in
order to avoid permanent injury and compensation costs. Our expertise in
hearing conservation is both extensive and comprehensive, involving the
three critical aspects: detection, prevention, and assessment.
We begin by preparing a formal,
written hearing conservation program. This plan is the first critical
step in the compliance process, scheduling the actions required. These
may include identifying noise sources and those employees who may be
exposed to excessive noise; the administrative and engineering controls
required to reduce the risk of exposure, as well as any personal
protective equipment that may be required; the method and frequency of
noise surveys and employee exposure monitoring; the methods and
frequency of audiometric testing and analysis; and the requirements for
employee education and for record keeping.
Lamb Consultants will conduct thorough
noise surveys, including octave band analysis with damage risk curves,
and can provide engineering solutions to reduce noise levels, as
outlined in later sections. Consultants will also conduct personnel
Dosimetry to determine employee exposure, identifying those individuals
and/or functions where exposure equals or exceeds the permissible 8-hour
time-weighted average. Such monitoring must be done whenever there is a
change in your processes, equipment, or production. Tests will also
determine the effectiveness of personal hearing protectors. All
employees must be informed of their time weighted (TWA) averages, in
writing by the employer.
Our mobile audiometric service can
provide on-site audiometric testing with minimal work disruption.
Annual audiograms are professionally analyzed and compared to the
baseline to provide early detection of problems.
Our comprehensive service incorporates
employee education on the effects of noise on hearing, the proper use
of hearing protectors, and the value of and procedures for audiometric
testing.
Noise Surveys & Dosimetry
Critical concerns for hearing
conservation are the level of noise in the workplace; the sources of
high noise levels; which employees are exposed to high noise levels and
for how long, etc. Equipped with state-of-the-art instruments, we
determine the time-weighted average (TWA) noise exposure of individual
workers. Using octave band analyzers, we can assist in determining the
appropriate type of hearing protection. Our management reports include
TWA graphs for each job function, attenuation data for hearing
protectors, and a damage risk curve to help in determining the maximum
allowable unprotected noise exposure. This information assists program
administration and can help reduce workers compensation claims.
Engineered Noise Controls
Under OSHA's Noise Standard (1910.95),
personal hearing protection can be considered a temporary solution only
after engineering and administrative solutions prove inadequate or
unfeasible. Lamb's engineered noise controls include architectural
systems, HVAC isolations, precision isolation systems, shock control
systems, floating floors, enclosures and panels, free standing,
restrained, and housed spring isolators, isolation hangers, fiberglass
and neoprene isolators, inertia base frames, high pressure pipe
isolation and a variety of barrier materials and sound absorbers.
Audiometric Testing
Lamb Group offers the best quality,
most cost-effective, one-on-one, on-site audiometric testing possible.
All Consultants are certified and only manual testing equipment is
employed, to ensure accurate, reliable test results. Tests are scheduled
to minimize work interruptions and all testing is done at your plant.
Management reports are comprehensive and clear, providing specific
information on potential liability from possible hearing loss claims.
Employees are provided with memoranda concerning their results and any
Standard Threshold Shift (STS) results are retested.
Respiratory Protection
Lamb's expertise in respiratory
protection is both extensive and comprehensive, involving the
development of formal programs, personnel exposure monitoring, selection
and proper fitting of respirators, and pulmonary function testing with
medical clearance.
Respiratory Program
This OSHA compliance program
(1910.134) identifies those areas and tasks which require the use of
respirators. It details the criteria for selection of respirators and
the responsibilities for program administration. It sets forth the
methods and frequency of industrial hygiene exposure monitoring. It
details the requirements for medical evaluation and on-going
surveillance. It defines the procedures for issuance, care and
maintenance of respiratory protection equipment, including the
requirements for individual fit testing. The program identifies the
nature of respiratory hazards and the administrative, engineering and
protective controls to be employed. It sets forth the requirements for
record keeping and provides master forms for all aspects. The written
program also details the requirements and methods for employee training.
Contaminant Exposure Testing
Lamb Consultants can complete thorough
and reliable sampling and analysis for any type of airborne
contaminants. Such testing and analysis is required for respiratory
programs and for compliance with numerous vertical standards, including
those for lead, cotton dust, and cadmium, to name just a few. All
samples are analyzed by AIHA - certified labs and results are routinely
available in 10 working days, less if the situation requires. Reports
detail the levels of airborne contaminant by specific work area or job
function and specify the level of individual exposure, in order to
determine whether worker exposure exceeds limits.
Pulmonary Function Testing
Lamb offers high-quality,
cost-effective, on-site pulmonary function testing. Whether PFT's are
required as part of a respiratory protection program, in response to
exposure incidents, or as a key aspect of an in-plant wellness program,
testing can be arranged to ensure minimal disruption of daily work
routine. Our Consultants are qualified to administration of Pulmonary
Function Tests. Test results are reviewed by a physician. Management
reports are comprehensive and clear, allowing early intervention if
problems are detected.
Indoor Air Quality Assessment
Lamb Consultants can conduct a
complete analysis of indoor air quality. This includes analysis of
specific substances as well as broad range analysis by such methods as
gas chromatography. Ventilation analysis can determine the effectiveness
of both supply and exhaust hoods. Chronic complaints of headache, sore
eyes and throat, respiratory stress, nausea and the like may be an
indication of poor indoor air quality or Sick Building Syndrome. Our
Consultants can conduct a thorough analysis of indoor air quality and
ventilation effectiveness in order to identify problems and implement
corrective actions.
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