Spring is in the Air and Maintenance Activities are Growing

As the temperatures begin to climb and nature springs to life, so does the need to repair lingering damage from winter months and tackle those larger projects. Your Alliant Risk Control Consulting, team would like to offer some advice on preparing for a busy maintenance season. This Maintenance Alert is designed to provide some ideas to assist your organization with preparing for maintenance activities while reducing potential injuries along the way. Areas that will be reviewed in this alert include:

Current hazard assessment and standard operating procedures
Refresher on training and communication
Six key programs to protect your maintenance team

Hazard Assessments and SOP’s–Are they Current?

Maintenance planning must start with the proper assessment of known or anticipated hazards resulting from maintenance activities. Before the busy maintenance season gets into full-swing, it is an important time to review your current job hazard assessments (JHA’s) used to ensure they still adequately address the hazards and necessary controls for your common maintenance activities and equipment. As you plan the maintenance activities, a few items that should be reviewed include:

Scope the task and hazards—what needs to be done and how will it affect the maintenance workers and other workers and activities in the location? When it comes to maintenance activities, there is the routine variety and the non-routine variety. For routine maintenance activities, it is important to review the tasks and identify known or anticipated hazards regularly to avoid assumptions that there are no new hazards present. For non-routine maintenance activities, a thorough planning process that includes identification of hazards, assessment of the risks, and methods to control is recommended. Consider the “what if” scenarios to reduce the chance that a risk is overlooked.
Assess the risk—potential hazards have to be identified (i.e., dangerous substances, confined spaces, working from heights, moving parts of machinery, chemical/dust hazards), and measures need to be taken to eliminate or control the hazards to minimize the risk. Assessing the risk is an important way to prioritize risks based on exposure frequency (likelihood or probability of exposure) and severity of injury or illness. Using a risk assessment matrix can assist in ranking and prioritizing risk in the maintenance activity.
Control the hazards—how are you currently controlling the hazards and are the controls effective? This is the question to be answered as you prepare and plan your maintenance activities. Are you using the hierarchy of controls in your decision making for control strategies? Too often training and personal protective equipment (PPE) are the primary controls that are used. While these controls can help reduce risk, they are low on the hierarchy of controls and may not be effective for moderate to high risk hazards. For the non-routine maintenance activities, using the hierarchy of controls can assist as you define controls needed based on risk assessment.
Document the procedures—ensuring you have documented procedures that identify the authorized personnel, known or anticipated hazards, controls used to manage hazards, and steps to safely complete the task are a very important piece of the maintenance planning process. Regularly reviewing your current procedures is needed to ensure any changes in maintenance activities, equipment used, or other modifications.

Be sure all permits required to conduct work and systems to control energy are in place and verified. As employees can change in your operations, it is also important to ensure that only authorized employees are involved in maintenance activities.

Planning for the Right Level of Training Before the Work

Several safety trainings require the annual re-training of employees. Do your maintenance employees have the skills and experience needed to carry out the tasks? Are they knowledgeable on all safe work practices/procedures? Do they have understanding of what to do when a situation exceeds their competence? These are questions to consider as you evaluate the training of your employees. A few suggestions to consider for training include:

Establish or update training matrix
Does your organization know what safety training is required for each job role (based on hazard assessment)? Do employees know what training they are supposed to take and how often? If you struggle with ensuring that safety training is correctly assigned to employees and completed on time, a potential way to manage this is to establish a departmental safety training matrix. The safety training matrix objective is to identify unique job activities/roles within each department and identify required safety training and frequency. Frequency for retraining can be found in the regulatory standards, and can also be more frequent as determined by the organization (as long as it meets the regulatory minimum frequency).

An example of a safety training matrix can be a simple spreadsheet that lists across the top all potential required safety trainings, and down the side lists the unique job titles within the department.
Utilize Learning Management System (LMS)
Keeping track of safety training courses (online/on demand, live webinar, instructor-led), what safety training is required for each department or job function, and providing communication (training reminders, status reports, completion information) can take a significant amount of time to manage. The best approach is to utilize a “Learning Management System” (LMS) as a database that can automate and align training assignments, management reporting, and serve as a repository for on-line training content.
Timing of training and re-training
Another key consideration is when to schedule training. For example, based on weather in your location, the best time for heat illness prevention training would be a month or so before the temperatures are normally expected to be above 80 degrees fahrenheit. Be sure to review your safety training and identify if there is a natural timing of completion of training or re-training (based on time of year, based on work activity cycles, or based on anticipated projects).

Don’t forget about communication planning for your maintenance workers and all parties impacted and concerned (production staff, management, line employees). As part of your maintenance work preparation, identify the communication plan for each maintenance project.

Communication considerations should include:

Identifying your primary and secondary audiences (those directly and indirectly affected).
What information needs to be communicated for primary and secondary audiences.
How will information be communicated (ex. direct: call/meeting, indirect: email, or multiple ways).
When will information be communicated (timing of communication to target audiences).
Once maintenance activities are completed – don’t forget to communicate.

Six Key Safety Programs to Protect your Maintenance Team

While there are many safety programs and regulations that may apply to maintenance activities, below are 6 common safety programs that are involved in maintenance activities and links to resources to assist in evaluating the programs.

1. Lockout/Tagout:

https://www.osha.gov/OshDoc/data_General_Facts/factsheet-lockout-tagout.pdf

2. Confined Space Entry

https://www.osha.gov/SLTC/confinedspaces/

3. Fall Protection

https://www.osha.gov/SLTC/fallprotection/

4. Heat Illness Prevention

California: https://www.dir.ca.gov/dosh/HeatIllnessInfo.html

https://www.osha.gov/heat/

5. Person Protective Equipment

https://www.osha.gov/SLTC/personalprotectiveequipment/

6. Hearing Conservation