Issue link: http://palletcentral.uberflip.com/i/666889
palletcentral.com PalletCentral • March-April 2016 25 greatest loss or impact potential, and the greatest probability of occurring. With identified hazards, the employer must determine appropriate techniques to eliminate or mitigate hazardous exposures, and then implement and monitor the controls. Don't forget to include loss reduction measures such as sprinkler systems, alarms, and emergency action plans as part of your portfolio of corrective actions. The high hazard/high probability situations need to be addressed first, with those having lower probability or loss potential handled in descending order. However, regardless of what level of "risk" you perceive, if a condition (e.g., a moving machine part that is not fully guarded) is out of compliance with OSHA requirements, it must be fixed ASAP since the likelihood of pallet companies being inspected has increased. There are several steps to hazard identification and mitigation. First, of course, is the identification process itself. As a practical matter, the employer (perhaps in consultation with a safety and health professional, if the company lacks in-house expertise) should walk the workplace and consider activities, processes, and substances that could injure workers or harm their health. Check equipment manufacturer instructions on things like clearing blockages in production, and check Safety Data Sheets for the latest information on chemicals used in the workplace, what maximum exposure limits are for the chemical, what ventilation might be required, and what PPE workers should use (respirators, gloves, eye protection etc.). It is helpful to examine past accident and health records to identify less obvious hazards, such as those that can cause occupational hearing loss, and remember to include non-routine operations, such as repairs, maintenance and cleaning, in your evaluation. The employer should also consider how employees, contractors and visitors could be harmed, and it is helpful to ask employees what they consider hazardous. Also consider unique populations, such as non-English-speaking workers, new workers, and short- term temporary workers, when determining what should be included and how hazard prevention should be addressed in terms of engineering changes, work practice controls, warning signage and worker training. OSHA will expect the employer to do everything reasonably practicable to eliminate the hazards before resorting to use of personal protective equipment. Actions will need to be taken unless they are technically or economically infeasible. While employers are not expected to eliminate hazard completely (which is impossible), all foreseeable risks should be addressed and controlled so harm becomes unlikely. This is not a one-time process, either. The hazard assessment should be reviewed periodically and revised as needed because