Facility safety has been moved to top of mind for many managers, as in August, OSHA increased fines for safety violations involving employee injury. Increased fines are not the only reason to implement safety measures - employee health and the risks they face on the job must also always be considered.
There are often areas in warehouses, distribution centers and manufacturing facilities that pose risks to employees that stand out immediately; open elevated platforms that get a lot of employee foot traffic is just one example. However, there are often other areas that pose risk that are unidentified, and therefore, unprotected. Leaving areas unprotected not only expose risks to employee health, but also to violation of federal OSHA codes, and as a result, significant fines.
Almost every facility has the following three areas - have you made sure that they are secure?
1. Pallet drop areas on elevated structural platforms, or mezzanines, in which pallets are being loaded by a lift truck
Any opening on elevated platforms where employees are working expose them to the risk of falling. All openings in the railing on levels in which employees work should be secured. Often these areas are “protected” with chains or single gate systems like lift-out barriers, but those devices do not meet current ANSI standards, are often left open or do not provide the protection needed to prevent employee injury. To ensure OSHA compliance and meet ANSI standards, secure these areas with dual-gate systems.
2. Picking areas, empty pallet bays or tote return bays on multiple level pick modules
Any facility with multiple level pick modules has a variety of openings on the elevated levels for picking or for empty pallet/empty tote return bays. Just like the openings on a mezzanine, the areas on a pick module where there is access to the exposed ledge should be secured with dual-gate system. This ensures there is a barrier in place between the picker and the ledge while they are working the pallet, and while the bay is being replenished. Another major source of fall-related incidents occurs where the empty pallets or empty totes are stacked so they can be removed by the lift truck. These areas should also be secured with a dual-gate system so a barrier is always there to provide fall protection. There are many options for safety gates designed specifically for rack systems so there are solutions even if space is limited or there is a tight aisle restricting egress; rack-supported versions of these gates will attach directly to the pallet rack to maximize space and provide a rugged connection. Ideally these fall protection solutions should be designed into the system, but solutions can be retrofitted into an area already operational. Either way these areas need to be secured, and proactively securing them before an incident occurs, will prove to be a valuable investment
3. Pallet flow bays
It’s not uncommon for employees to enter the lanes of pallet flow bays. While these areas are not specifically designed for employee access, ledges do need to be secured in the instances that it happens – there have been documented instances of employees entering the lanes of pallet flow bays to retrieve a fallen box or square a pallet, or to signal the lift truck operator below. Some of these instances have resulted in fatalities. To avoid these scenarios, the ledges of flow lanes should be secured with a physical barrier.
One of the two main methods of securing these areas is the use a self-closing pallet swing gate, which swings open when the lift truck loads a pallet into the lane, and then swings closed once the pallet flow down the lane. The gates must be designed so they do not swing outward, creating a fall protection barrier. This is a valid solution; however, you want to make sure the gate system you are installing was designed specifically for the application of loading multiple pallets into a system. There are a number of considerations that must be considered.
(1) It needs to be able to withstand the abuse of the lift truck constantly loading pallets through the gates, as well as the 200 pound lateral force of a person pushing the gate outward.
(2) It should be designed with a solid panel to make for an easy transition for the pallet onto the flow lane.
(3) The pallet flow system should also be designed so the pallet flow lane is long enough so the last pallet loaded into the system can travel far enough down the lane to allow the gate to close when the lane is full. This is easier if bi-parting gates are used so the pallet doesn’t have to travel as far before the gate closes.
The key to success with this solution is to use a gate designed specifically for pallet flow applications, and not to simply install a swing gate that may have been designed for personnel egress or for staged pallets on a mezzanine. A gate designed for pallet flow will better integrate with system and maintain a safe environment without impeding on production.
Another solution, and often the way to create the safest environment, is to use a dual-gate system to secure the entire lane. The safety device should be made deep enough to accommodate all the pallets on the lane so there would be a gate at the ledge and a second gate at the end of the lane; the gates would be counterbalanced and interconnected so when one gate is open, the opposite side is closed. This accomplishes two purposes: one, it ensures there is always a barrier between the picker and ledge, and two, it keeps the picker a safe distance from the pallets while they are being loaded into the lane. This is also the ideal solutions for the empty pallet return bays where the pallets flow towards the ledge to be removed. With a dual-gate system securing these bays, you will always have a safe environment
It’s easy to miss an area that needs protection; make sure to conduct facility safety checks in order to recognize risks and mitigate them with safety solutions and reach out to professionals in the industry for assistance. The ProGMA, which is a safety guarding group of the MHI is a valuable resource.
Falls from elevated work platforms are a reality. Unfortunately, they happen. Material handling systems are getting bigger, the platforms are getting taller, and the speed of the operation is increasing. A fall-related incident will have a massive negative effect on a company. It will cost them significant money; the entire plant can be closed down while the matter is being investigated, and the negative publicity, the loss of income, and an injury or loss of a member of the team will do great damage to a company. But, the thing is, these areas can be secured.
Soon OSHA is expected to publish its final rule for Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems) in General Industry (Subpart D and Subpart I). It’s taken OSHA decades to push this proposed rule through and has been updated and changed various times to reflect current practices in the industry, as well as make sure it aligns with other OSHA standards.
The proposed rule from OSHA aims to give companies more flexibility in the safety devices that they implement, as well as prevent injuries and fatalities from falls. Here’s a bit of language from the proposed rule:
“The existing OSHA general industry standards recognize the use of guardrails and physical barriers as the primary methods for employee protection against falls...OSHA believes that the proposed rules will give employers the necessary flexibility to decide which fall protection method or system works best for the work operation being performed, while ensuring employees receive a level of protection that is effective and necessary. OSHA believes that many of these slips, trips and falls can be prevented and has devoted many years to assembling and analyzing information aimed at the elimination and prevention of hazards that cause these incidents.”
Given that OSHA is allowing employers to determine what safety devices may work best in their operations, it is important to have everyone who works in the facility be able to discuss their own day-to-day concerns with people in management so these concerns can be addressed. Many times, the work that employees are doing is repetitive and tiring, so it is important that management takes the time to access all the steps in the operation and look to determine how they can make all these steps safer. It is always a good idea to consult with professionals in the industry to help determine what areas are unsafe and how to make them safe. The ProGMA group in the MHI is an excellent resource for safety in the warehouse.
In our opinion, the best solution, and the solution now recommended by ANSI standards is to have a barrier in place where employees are exposed to ledges at all times. This is best accomplished with a dual-gate system, which essentially creates a box, or controlled-access area, around the pallet drop location. This system will consist of a gate at the ledge and a second gate behind the pallet, and the gates are interconnected so when one gate is open, the opposite gate is closed so the area always remains safe.