Chilton Consulting Group
P.O. Box 129
Rocky Face, GA 30740
Office: 706-694-8325 Fax: 706-694-8316 email: chilton@alltel.net
December 2009
Facility Safety Update
“Your Partner for Compliance and Performance”
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A COMPILATION OF NEWS ARTICLES
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Announcements from Chilton
Consulting Group
Chilton
Consulting Group wishes all our clients a very happy and blessed holiday season!
1.
As we wind down 2009
and look forward to 2010, we are reflecting on our most successful year and
preparing for an even greater year coming. I would like to thank all our clients
for the privilege of assisting with your needs to help assure you are producing
the safest and highest quality products. These services assist in protecting
your business by reducing your risk of a foodborne illness outbreak, damaging
product recalls, and assuring continuous operations in full compliance with
regulatory requirements.
2.
Our successful year
has been a result of maintaining our core business of HACCP Plan Reassessments
while fully implementing new services to facilitate preparations for SQF audits
and conducting SQF audits.
3.
To build upon this
foundation, Chilton Consulting Group plans to offer new services in 2010 to
assist clients with Lean Manufacturing, 5 S Processes, and Six Sigma. Please
contact Jeff Chilton if you are interested in learning how these processes can
improve your operations to increase efficiencies and reduce costs.
4.
In addition, we will
be promoting new services to assist clients with workplace safety and OSHA
Compliance with the expertise of David Rowe on staff. Our Safety and Health
Audits will assess your compliance with regulatory standards to reduce your risk
of OSHA fines and workplace accidents. These services will help clients protect
your business, reduce workers compensation cost, and improve your employees
safety. Please contact Jeff Chilton to schedule a Safety and Health audit at
your facility.
5.
Watch for our
redesigned web sites at
www.chiltonconsulting.com and
www.sqfconsulting.net to be launched next month!
6.
Chilton Consulting
Group will be exhibiting at the 2010 Poultry Show in Atlanta. Please plan to
stop by our booth to discuss how we can partner to improve your business.
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SERVICES AVAILABLE
With this growth there has also been an expansion of services. The list below outlines many of these services. If you don’t see what you need on this list, call and talk to us and we will do our best to see to your compliance and safety needs.
* Food Security Plan Development
* Safe Quality Food (SQF) Consulting
* HACCP Plan
Reassessments
* HACCP Plan Developments
* Workplace Safety – OSHA Compliance and Workman’s
Comp Cost Reductions, Training
* Food safety &
Quality Audits
* Sanitation / GMP Audits
* Audit Preparation – Silliker, Cook & Thurber, AIB * SPS / SSOP Separation Project
* IVT Preparation /
Listeria Assessment
* Quality Process Improvements
* Operations Management Improvements (TOPS) * HACCP Training Workshops
* Product Recall /
Crisis Management Planning
* Food Security Plans
* Manpower Reductions / Efficiency Improvements * Waste Water Control / Cost Reductions
* Animal Welfare
Audits
* Small Plant Layout and Design
* Training Seminars – Food Safety, Regulatory, Quality Topics
* Regulatory
Compliance – EIAO Prep Audit or NOIE Response
Contact Jeff Chilton for more
information on any of these new services. Chilton Consulting Group will be
expanding considerably in 2008 while continuing to provide exceptional service
as always for HACCP improvements and regulatory compliance.
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OSHA News and Enforcement
There are numerous
announcements from OSHA for 2009 going into 2010.
The bulk of this newsletter will be devoted to these changes that are
coming, how they may affect your business and how we can help to make the
transition easier.
NEW ANSI Standard on Slip,
Trips, and Falls
· Falls are the leading cause of emergency room visits in the U.S?
· Falls are the leading cause of accidental death for people over the age of 85?
·
Less
than 10 percent of all fall related claims are fraudulent?
ANSI has approved the ANSI/NFSI
B101.1-2009 Testing Method for Measuring Wet SCOF (Static Coefficient of
Friction) of Common Hard-Surface Materials.
This is a new testing method to ensure that your
walking surfaces are not slippery to cause an accident.
OSHA publishes GHS/HazCom Proposed Rule
The proposed modifications to the HazCom standard include:
OSHA is proposing a 2 year phase-in for this new
regulation. But you will be
responsible for ensuring that your chemical inventory is current and up to date.
It is
critical that before this standard is enforced that companies do an inventory of
their chemicals and ensure that this is correct and that you have the necessary
documents to make this conversion.
OSHA requires that you retain documentation for 30 years.
If you have questions, would like help with your inventory or assistance
with the implementation of the new GHS policy and conversion of the MSDS to the
new SDS.
NEW ANSI Standard for
Eye/Face Washes and Showers - ANSI Z358.1-2009
Eye/face washes and showers must:
1 – be accessible within 10 seconds unobstructed and on same floor
2 – have a highly visible sign,
3 – the flow rate for an Eye/Face wash should be 3gpm for 15 min and for eyewash only 4gpm for 15 min
4 – the wash must be tepid water (60° – 100°),
5 – new documented training is required and mandated on any and all new equipment,
6 – the is to be a foot treadle to activate the system,
7 – the eyewash is to be 33-45” off floor and 6” from wall,
7 – the shower flow rate of 20gpm 20” wide and 60” off floor,
8 – the eye wash and shower are to operate individually or simultaneously,
9 – testing has changed to a weekly test with a surface area test (< 8” above
nozzle) and chart has changed
The biggest changes are: the requirement that the
water be tepid. If you can test and show
that your tap water is never below 60° or above 100° then your current systems
may be acceptable. They must also
have the proper flow rate and be tested weekly.
Any questions, please contact Chilton Consulting Group.
OSHA Enforcement
and Regulatory Changes for 2009 and 2010
1) A planned increase in the number of OSHA inspectors. Specifically, the fiscal year 2010 budget request was in part designed to fund the hiring of 130 new inspectors. OSHA intends to further supplement its inspectors with “partnerships with businesses and nongovernmental organizations.”
2) Addressing ergonomics “in some way, shape, or form.”
3) Reviewing OSHA’s penalty structure. Specifically, OSHA’s Acting Administrator, Jordan Barab, has remarked that “the average serious penalty is now below $1,000” and “that doesn’t provide much of a disincentive.”
4) Increasing the speed of the standard-setting process, which has been described by Barab as “way too slow.”
5)
Making unannounced inspections of up to 4,500 of the
“most dangerous workplaces” in the country. The inspections will be conducted
under OSHA’s
2009 site-specific targeting program, which includes sites that had injury
and illness rates considerably higher than the national average.
If you
would like to know how your company stands Chilton Consulting can calculate your
incident rates and compare them to the published numbers,
6) Continuing the enforcement of combustible dust standards. In June 2009, OSHA announced that it had issued a total of 667 citations against companies in several Southern states for alleged worker safety violations during inspections for unsafe hazardous dust conditions. The most frequently cited were for violations of housekeeping, hazard communication, personal protective equipment, and electrical standards, and the general duty clause.
“Under the Obama administration, OSHA intends to become more active in regulation promulgation and enforcement. “ To these ends the new administration has set aside an increase of $41.6 million (7.5%) for more enforcement officers and compliance officers.
OTHER OSHA CHANGES:
1)
Airborne Infectious Diseases -
In March 2010, OSHA intends to publish a
Request for Information to help examine how to improve worker protection from
exposure to airborne diseases.
2) Occupational Injury and Illness Recording and Reporting Requirements (Musculoskeletal Disorders) - OSHA is proposing to revise its regulation on Recording and Reporting Occupational Injuries and Illnesses (Recordkeeping) to restore a column on the OSHA 300 Injury and Illness Log that employers will check when recording work-related musculoskeletal disorders (MSDs). The Agency will issue a proposed rule in January 2010.
3) Cranes and Derricks - On October 9, 2008, OSHA issued a comprehensive proposed revision of the Cranes and Derricks standard. The proposed rule addresses electrocution hazards, crushing and struck-by hazards, overturning, procedures for ensuring that the weight of the load is within the crane's rated capacity, and ensures that crane operators have the required knowledge and skills by requiring independent verification of operator ability.
4) Combustible Dust - OSHA is engaged in the early stages of rulemaking to develop a combustible dust standard for general industry. OSHA published an Advance Notice of Proposed Rulemaking in October 2009 and is preparing to hold stakeholder meetings this month.
5) Diacetyl - The Agency plans to initiate a peer review of the health effects and risk assessments in October 2010.
6)
Walking / Working Surfaces -
Subparts D & I - The Agency plans to issue a
proposal in March 2010.
7) Process Safety Management – modifications will be made in 2010
Accidents / Injuries and Fatalities that Occurred During the Last Month
|
LO/TO is vital to a
safe facility. Not just for
OSHA or the cleaning crew but for maintenance and even operations. |
LOTO/GUARDING on BAKERY MIXING BOWL Inquiry into bakery accident (a worker, in his 20's, crushed his arm in equipment at a bakery - he was airlifted to a Hospital after getting his arm caught in a industrial mixing bowl - his injuries are not thought to be life threatening - fire crews used hydraulic equipment to make some space to he could be freed and treated by paramedics before he was flown to hospital) |
|
Combustible dust –
this is a very dangerous hazard with multiple deaths possible. |
DUST EXPLOSION Dust explosion rocks North Portland Land O' Lakes plant (an explosion at the plant at about 8:30 p.m. caused about $100,000 - the explosion was on the third-floor of the plant - a machine called "corn cracker" had created a dust explosion - no employees were in the area of the blast |
|
Make sure that people
are aware of their surroundings and that there are designated walking
areas. |
LOADING DOCK Worker Crushed Between Two Semi-Trucks (an accident at a dairy processing plant left a man fighting for his life - worker was crushed between two semi-trucks around 3 pm as the driver was backing the truck up to unload for the day - the man suffered life-threatening injuries to his head and upper body - he was taken to a Medical Center) |
|
Another refrigerant
rears its head. CO2 can be
deadly as it replaced the oxygen in the body. |
CARBON DIOXIDE Workers sickened at Lindsay citrus plant (at least two workers at a fruit plant have been airlifted to a hospital after they were sickened by carbon dioxide gas while cleaning a cold storage facility - about 4:30 p.m., firefighters responded to the plant where the workers, one man and one woman, had been exposed to the gas - the pair were airlifted in separate helicopters to a Regional Medical Center - condition was not known - one of the employees was said to be unresponsive upon firefighters arrival at the plant - carbon dioxide is often used as a refrigerant in commercial cooling systems) |
|
Ammonia – Process
Safety Management must be followed and written. |
AMMONIA Firefighters tackle ammonia leak at dairy (firefighters donned protective suits to tackle an ammonia leak at a dairy - a total of seven fire crews, including a hazardous materials team, were called to the dairy just after 12am - on arrival, firefighters evacuated the dairy after finding there had been a leak involving 2.5 tonnes of ammonia - two firefighters with protective clothing entered the building to check on the gas levels through the early hours of the morning - incident was under control by 7.52am, and gas levels were due to be monitored again later in the day) |
|
Ammonia – Process
Safety Management must be followed and written. |
AMMONIA Ammonia release reported in Belle (about 25 pounds of ammonia gas was released at 11:12 p.m. - firefighters responded to the leak - the leak occurred in an ammonia unit at the plant as crews were getting ready to pump dimethylamine - crews had pressurized the system to check for leaks and found none prior to pumping the chemical - a leak occurred when the pressure in the system reached 220 pounds per square inch - plant officials estimated about 25 pounds of chemical was released - the leak was contained within an hour) |
|
Ammonia – Process
Safety Management must be followed and written. |
Evacuation over after chemical leak in Iowa (an evacuation is over after an anhydrous ammonia leak - six homes were evacuated because of the chemical leak at a farmer co-op - no injuries were reported - no word on cause) |
|
An explosion at a Slim
Jim plant in Garner, NC is having large repercussions on the lives of
those in the area, not just the ones caught in the accident. |
UPDATE on FATAL EXPLOSION - This is how an accident can have a MUCH FARTHER reaching impact than on just those injured in the accident!!!!! conagra workers to lose jobs (an explosion at the plant claimed lives - now, it is claiming jobs - workers at the plant will be entering the gates a little less starting this week - many had their shifts reduced - and they are the lucky ones - others got laid off - company officials say they have no other choice but to cut jobs - an explosion in June took out more than just part of the building - officials say the blast, which killed three people and left dozens of others injured, cut the plant's production capacity in half) |
|
Ammonia – Process
Safety Management must be followed and written. |
AMMONIA Ammonia leak at Dean's Ice Cream sickens 12 workers (twelve employees were hurt during an ammonia leak inside the facility - paramedics took five of the workers to a Hospital for treatment of ammonia inhalation - the other seven employees were treated at the scene - a small ammonia leak was discovered inside the loading dock area - the 12 employees were the only people inside the plant at the time - maintenance workers were able to isolate and contain the leak and quickly ventilated the building) |
|
Ammonia – Process
Safety Management must be followed and written. |
AMMONIA Operations at pig abattoir halted due to ammonia gas leak (operations were halted at a pig abattoir due to an accidental ammonia gas leak in one of the pork chiller rooms - no other details) |
|
Ammonia – Process
Safety Management must be followed and written. |
AMMONIA 3 treated for ammonia exposure after fire at Lilydale plant (when fire crews arrived, flames and smoke were coming from a shed that houses the plant's refrigeration units - the fire was under control in under an hour, but fire crews then had to deal with an ammonia leak, which continued throughout the morning - two people, including a firefighter, were sent to hospital to be treated for exposure to ammonia - a third person was treated at the scene - a cause can't be determined until the ammonia leak is fixed - fire is still under investigation - it did originate in a compressor room and it was pretty confined to that room) |
|
Ammonia – Process
Safety Management must be followed and written. |
JBS investigates small ammonia leak (some contractors were working on the plant’s roof-top refrigeration unit when ammonia leaked out and a small amount was sucked into the ventilation system - five people working in the area were evacuated and transported to a Hospital, where they were observed and later released - the ammonia leak was reported by the workers on the roof, and that workers inside the plant had not reported any issues) |
|
Head of OSHA says that
OSHA’s fines are too low.
This story shows that they can get serious with their fines. |
Teen Death
Draws $1.6 Million Fine -
Grain storage accident kills youth. OSHA and the Department of
Labor’s Wage and Hour Division fined Tempel Grain Elevators LLP of
Wiley, Colo., more than $1.6 million following the May 29 death of a
teenage worker at the company’s Haswell, Colo., grain storage operation.
The youth suffocated after being engulfed by grain in one of the
facility bins. The company also exposed three other teenage workers to
the cited hazards. |
EPA News & Enforcement
We are going into a new year with
a new administration whose goal is increased enforcement in both OSHA and EPA.
Climate change will become a focus regardless of the politics.
Industry Took an Enviro Hit in
2009. What Can We Expect in 2010?
http://enviro.blr.com/news.aspx?id=110297
Pressured Congress to change the Clean Air Act and the Clean Water Act to give the Agency more authority to regulate industry practices.
DEP and the Chocolate Factory : The Pennsylvania Department of Environmental Protection (DEP) calculated a $165,572 fine for a Lancaster County company that manufactures chocolate candy. According to DEP, much of the penalty is based on the increased economic benefit the company realized by allegedly violating limits on how long several pieces of machinery may be operated. Specifically, DEP claims that the company exceeded the permitted hours of operation for its Barth cocoa bean roasting system from 2005 to 2007 and its Jetzone I cocoa bean roasting system in 2007 and 2008. By operating more than their permit, they risked excess releases.
Quality (
Davis Balestracci - 12/09/2009 - http://www.qualitydigest.com/inside/quality-insider-column/pareto-principle-coming-home-roost.html
Will the Pareto principle (the 80/20 rule) inevitably apply to the quality profession? I think so. It’s time to “connect the dots” for executives regarding the integration of quality improvement into organizational culture.
Denise Robitaille - 11/10/2009 - http://www.qualitydigest.com/inside/quality-insider-column/why-we-do-it.html “Although people understand that they’re required to do root cause analysis, they don’t comprehend three issues:
1. What root cause analysis is
2. How to conduct effective root cause
analysis
3. What the results of root cause analysis should yield “
3 -
Let Chilton Consulting take a look at your OSHA logs and calculate your incident
rates. From that we can help you to
address various issues at your facility with the intent of reducing your
insurance premiums in addition to costs associated with injuries.
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CHILTON
CONSULTING GROUP – PROFILES
In each issue a
different person will hold the top spot in an effort to make everyone aware of
the diverse nature of this group and the wide range of services and expertise
that we have to offer. I have
included everyone’s email address so that if you have questions you can go
directly to the person of interest.
Jeff Chilton chilton@chiltonconsulting.com
HACCP Plan Reassessments IVT/Rlm Audits
Regulatory Responses to NOIE or Notice of Suspensions
Audit Preparations Services / Food Safety and Quality Audits
HACCP Training Quality Improvements
TOPS: Total Operational Performance System
Dr. Estes Reynolds
agfood@charter.net
HACCP Training HACCP Plan Reassessments
Microbiological issues, Pathogen trouble shooting,
Process improvements Quality improvements,
Plant Layout and Design for Small Processors.
Bobby Pace bobbypace@knology.net
HACCP and Food Safety Consultant
HACCP Plan Reassessments
Quality Improvements ISO Implementation / Auditing
David Rowe
safety01@hughes.net
Facility Safety Training Mock OSHA Inspections, Safety Audits
Mechanical Integrity Tracking HACCP Plan Reassessments
ISO Implementation / Auditing Website / newsletter development
China Reed c.reed@uyconsulting.com
FDA
Reassessments
Audit Preparation
SQF
Documentation
Research and Development
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Chilton Consulting
Group will provide affordable expertise in the areas of regulatory compliance.
The cost of non-compliance can be enormous.
Keeping compliance issues in-house can cause deficiencies to be
overlooked. We will work with your
company to ensure compliance and reduce employee injury and exposure.
In doing so, you will save money with fewer (or no) citations, decreased
liability, and reduced insurance costs as well as fewer lost time accidents.
We offer your Company our expertise in matters regarding OSHA, EPA, ISO
and USDA compliance as well as a wide variety of compliance related activities.
The following list outlines the areas in which we can help.
OSHA:
Safety Plan development or modification.
Mock OSHA Audits to evaluate your level of
compliance.
Safety training for many different topics. –
Email us with your needs.
Process
Safety Management (PSM) Needs: Audits, PHAs, Training, Development or
Modifications
OSHA Requires Safety Plans (manuals,
documentation). We are able to develop these for you or modify your
existing ones to ensure they are complaint without being burdensome.
Let CCG handle the safety aspect of any large
project, rebuild or new construction.
We have experience from Contractor approvals, to Safety training, to
LOTO, to monitoring.
EPA:
Good Laboratory Practices (GLP) Audits, Plan
development or modifications
Risk Management Plan (RMP) Compliance Audits
ISO:
Plan development or modification.
Third party audits to ensure compliance
Please feel free to call us with any questions, concerns
or to schedule a meeting or training class.