By Lisa Larson
Managing Editor

PHOENIX — Environmental, health and safety issues are important to any business in a manufacturing industry, and as Peg Schmitz, vice president of print operations at The Gazette in Cedar Rapids, Iowa, testified to at SuperConference in January — when OSHA comes knocking, you’d better be ready.

In her presentation, “Surviving an OSHA Inspection,” Schmitz described how the Occupational Safety and Health Administration arrived at The Gazette’s Cedar Rapids plant unannounced on July 3, 2001 at 8 a.m. The inspection was initiated by an employee complaint based on four allegations.

First, the complaint stated, an overhead conveyor that transports newspapers from the pressroom to the packaging area could drop papers on an employee’s head. Second, according the employee, there were a large number of foot injuries at the plant. Third, the complaint alleged that The Gazette did not keep sufficient accident and injury history records. And fourth, the employee complained that there was not adequate protection provided to employees working nearby a press tower and folder installation that was being done at the time by Goss International Corp.

All issues listed in the complaint were found to be compliant with OSHA regulations, but The Gazette was still issued a citation by OSHA due to something the inspectors saw during their visit that had nothing to do with the original complaint, and Goss and one of its subcontractors were cited on licensing issues. During the visit OSHA inspectors toured the plant, took photographs, reviewed copies of records and policies, and conducted spontaneous interviews with employees on the plant floor out of earshot of management.

On the charges in the complaint, OSHA found that regarding the overhead conveyor, there was not enough weight to a newspaper for there to be any chance of injury if one fell off the conveyor onto a worker’s head.

“The OSHA inspectors took a look at the overhead conveyor and said, ‘This isn’t a danger at all,’” Schmitz said.

As far as the “numerous” foot injuries were concerned, there had actually been only two in past four or five years, one caused by a skid mover bumping into the side of a worker’s foot, and one caused by a roll of newsprint rolling back onto an employee’s foot. Both foot injuries were documented and did not occur in the same area of the plant.

Regarding the injury history not being kept accurately, the OSHA inspectors actually complimented The Gazette for its meticulous record keeping and depth of history.

“At the time we were being inspected, our safety coordinator was also still doing all the documentation and follow-up on work comp cases, so there were extensive records,” Schmitz said.

And finally, the area around the press tower installation was adequately cordoned off with barriers and caution tape, and clearly marked as a hardhat area with boxes of hardhats available near the installation. The windows near the press tower installation were even covered with plywood.

Getting an OSHA citation

However, while the OSHA inspectors were touring the areas cited in the complaint they viewed an employee working on a strapper who did not follow correct lock out/tag out procedures. When mechanical or electrical work is being done on any piece of equipment, the lock out/tag out procedure must be followed.

Lock out/tag out is the process of completely disconnecting the piece of equipment that is being worked on from its energy source if it would be able to engage and injure the person working on it. The Gazette uses locked caps that fit over the plug. The person doing the maintenance puts the cap in place, locks it, and then tags it with their picture ID. If more than one person is working on the equipment, each person must tag out the lock out. Then they keep the key to the lock until they finish the work and are ready to engage the power again.

The employee working on the strapper was actually only tightening the bolts on the base of the strapper, but because he was laying down on the ground to do it, he had duct taped a tag on the strapper’s start button so other people could see that it was being worked on. Even though the situation didn’t require him to use the lock out/tag out procedure, OSHA cited The Gazette because he had begun the procedure and only completed it halfway.

The OSHA inspectors noted that the lock out/tag out situation occurred within sight of supervisors. Lack of enforcement by management was a common problem, Schmitz said in her presentation, and the inspection was a “wake-up call” for all supervisors and managers. The Gazette issued the employee in the situation a written warning and provided him retraining on procedures and policies. He now assists other employees in enforcement of correct procedures, Schmitz quipped.

The OSHA inspectors also found equipment vendor violations during its visit. Goss and its subcontractor were cited on licensing issues: specifically, that neither company was licensed to do installations or construction in the state of Iowa. This situation was cleared up during two follow-up visits by OSHA inspectors specializing in licensing. These vendor violations were out of the scope of The Gazette’s responsibility, Schmitz stated.

A close look at inching the press

One thing that the OSHA inspectors paid a great deal of attention to was the use of the inch/stop buttons on the press. As the inspectors were walking through the plant, they viewed press operators moving the press while doing remedial maintenance work on the Goss Community pressline. They were printing a glued and trimmed book and were trying to clear a clogged glue line.

OSHA questioned this procedure, and The Gazette contacted the Newspaper Association of America requesting some type of documentation to show that there are times when workers have to move the press while working on it — while putting plates on the press, for example. NAA supplied The Gazette with a copy of a letter describing best practices while using the inch button.

It stated that “minor tool changes and adjustments and other minor servicing activities that take place during normal production operations” are not covered by having to lock out and tag out. Activities that “are routine, repetitive and integral to the use of the equipment for production … provided that the work is performed using alternative measures, which provide effective protection” do not apply to the lock out/tag out procedure.

OSHA accepted this documentation, but Schmitz stated: “I’m sure [the use of the inch/stop buttons] is going to be an ongoing battle with the printing industry and OSHA.”

Keys to surviving OSHA

The Gazette reviewed the report on the lock out/tag out citation and developed documentation with the help of NAA and a local insurer to assist in their rebuttal. The newspaper requested an informal hearing with OSHA in the form of a conference call with the supervisor and the inspector. The Gazette requested and received a 50-percent reduction in its fine, in the end paying $1,100 for the infraction.

“We outlined that we feel we’ve made a good faith effort to ensure the safety (of employees) … and we outlined the different initiatives that we have going … and the reduction in accidents and injuries that we’ve seen,” Schmitz said. “We’d also been working with OSHA Consultative, so it’s not like we were ignoring safety whatsoever. They were highly complimentary of how well we had articulated what we were trying to do in defense of the [citation].”

OSHA Consultative is a separate division of OSHA that provides free health and safety consulting services, including plant inspections, training and reviewing documentation. OSHA Regulatory sees no documentation on what OSHA Consultative is doing because it wants to encourage companies to use the consultative side.

“We had them come in and they did a whole plant tour with our employee safety team. They went through the whole plant and developed a list of things that they made recommendations on that we needed to improve or change,” Schmitz said. “They did a 10-hour OSHA training course on-site for our employee safety team so we had some higher degree of expertise here in the plant. Then we did follow-up, kept them posted on what we were doing and what we’ve resolved. They helped us prioritize what to focus on. We intend to keep in contact with them.”

Schmitz offered the following advice for surviving OSHA inspections:

• Keep well-organized information

• Conduct regular internal inspections and training

• Have simple and concise policies that are well communicated

• Prepare employees for what it’s like to be interviewed by OSHA — Tell them not to defend something they’re uncertain of and not to offer editorial commentary to the inspectors.

Also key to surviving an OSHA inspection is having a strong safety program already in place.

“Focus on your program proactively. Have a really focused initiative on supporting safety from an executive level on down,” Schmitz said. “No. 1, you’re going to have a heightened sensitivity to any type of compliance issues and safety issues, and No. 2 … having a strong program shows that you’re making a good faith initiative."