Portable Power Tools Safety Compliance & Training Gameplan These are just a few of the common injuries workers can suffer when they use portable power tools like drills, nail guns, chain saws and sanders. According to the Bureau of Labor Statistics, power tool accidents account for 400,000 emergency room visits per year. Many of these accidents can and should be prevented. Electrocution; Eye injury; Severed tendons; Laceration; Amputation; Puncture. OSHA rules specify that employers are “responsible for the safe condition of tools and equipment” that their workers use, including the personal tools and equipment that workers furnish for themselves. Click here to find out about OSHA portable power tool safety requirements. This Program sets out a strategy you can implement over a 30-day period to protect your workers from power tool injuries and ensure that your workplace complies with OSHA portable power tool safety requirements. Defining Our Terms Most workplaces contain a large variety of different tools. This Program addresses the class of tools: known as portable power tools: Power tools, as opposed to hand tools, are operated with external power such as electric, pneumatic, liquid fuel, hydraulic, and powder actuated; Portable, as opposed to stationary power tools, are those that workers can easily carry from one location to another. Step One: Perform Hazard Assessment (Day 1-5) The first step in controlling portable power tool hazards is to conduct a hazard assessment. Methods to use include: Identifying all the different portable power tools used at your workplace, including personal tools that are owned by the worker; Inspecting each of those tools; Observing workers as they use those tools to ensure they follow safe work practices and use appropriate personal protective equipment (PPE); Interviewing workers and supervisors who work with portable power tools; 1 Reviewing written records of worker complaints or safety committee recommendations involving portable power tool safety; and Reviewing OSHA 300 Logs, workers’ comp claims, first aid records, incident reports and other materials that may reveal power tool injury patterns or trends. Implementation Strategy: In carrying out your hazard assessment, be on the lookout for the risk factors that commonly cause power tool injuries, including: Improper tool design or construction; Careless or improper use of the tool; Using the wrong tool for the job; Failure to wear suitable PPE when using the tool; Failure to maintain the tool in safe condition; Improper grounding of electric power tools; Failure to store tools in a safe location or manner. Tools & Implementation * See “Legal Briefing: OSHA Portable Power Tools Rules” to find out what power tool safety measures OSHA requires * Use the “Power Tool Safety Self-Assessment Checklist” to carry out your hazard assessment; * See “15 Questions to Ask to Determine Compliance with OSHA Tool Safety Rules” for further guidance on hazard identification and assessment. Step Two: Select Safety Controls (Day 6-15) Next, select appropriate measures to manage the hazards you identify in your assessment. General approach: First Choice: Elimination: If it’s reasonably practicable, totally eliminate the hazard, e.g., by ending use of power tools at your workplace and/or eliminating jobs that require workers to use such tools. Second Choice: Management & Control: Eliminating power tool use won’t be a realistic option for most employers. If elimination isn’t reasonably practicable and you have to let workers use dangerous portable power tools to do their jobs, you must take measures to control or minimize hazards. Level 1: Engineering Controls: Start with engineering controls, i.e., measures affecting the portable power tool’s: Design; Construction; Components and materials; and Safety features, including guards, switches and insulation. 2 Level 2: Work/Administrative Controls: The next layer of hazard control is use of “work” or “administrative controls affecting how power tool work is actually carried out. At a minimum, you must develop and implement safe work procedures for use of portable power tools. Such procedures should address: Transport and Handling: Tools shouldn’t be carried by the cord or hose and be disconnected by pulling the cord gently from the receptacle by the plug end and not the cord itself; Proper Use: Require operators to use tools in accordance with manufacturer’s instructions and company safety procedures and steer clear of any distracting activities during use; Work Area Restrictions: Require workers to operate their tools in work areas with a level surface and adequate lighting and that are dry and free of explosive or combustible materials; Use of PPE: Require operators and nearby workers to use the appropriate PPE (which we’ll discuss below); Clothing Restrictions: Workers must dress and groom themselves safely when operating power tools. Examples: o Long-sleeve shirts and pants to protect limbs from sharp flying debris during cutting operations; o No loose clothing or jewelry that can get caught in the tool’s moving parts; o Long hair must be tied back or confined; Electrical: Electrical tools must be properly grounded, insulated and kept away from damp and wet conditions; Disconnection: Tools should be disconnected when they’re not in use; De-Energization for Servicing: Power tools must be totally de-energized during servicing or maintenance operations like changing blades or tips. o Most power tools are “cord and plug,” i.e., and can be completely deenergized by unplugging them from the outlet; o Tools that can’t be de-energized by pulling the plug should be deenergized in accordance with your company’s lockout/tagout procedure; Inspection: All power tools, including the personal tools that workers bring to work. Your workers should be trained to inspect all tools before and after each use, looking for defects or damage. Any tool that malfunctions or appears damaged when inspected should be tagged out and placed in an area where it can’t be accidentally used by another worker; Maintenance: Tools must be properly maintained in accordance with manufacturer’s instructions; Storage: Tools and cords should be stored in clean, dry places that are free of sharp edges, corrosive chemicals, heat or environmental conditions that can damage the tool or its safety features; Level 3: PPE & Protective Equipment: PPE is necessary for most portable power tools. Specific PPE required varies depending on tool and operation but may include hard hats, eye and face protection, hearing protection and gloves. 3 General Implementation Strategy: Engineering, work controls and PPE are not mutually exclusive, i.e., not either-or, and should be used in combination with each other. Tools & Implementation * See “How to Use Engineering Controls to Manage Portable Power Tool Hazards” for step-by-step instructions in selecting engineering controls; * Use the “Power Tool Safety Measures Checklist” to select appropriate engineering controls; * See “How to Create Portable Power Tool Safe Work Practices” to find out how to create general safe work procedures for use of portable power tools; * Use the “Model Portable Power Tools Safety Policy” to create safe work procedures and policies for your workplace; * See the Section below for guidance on creating safe work procedures for particular types of power tools; * Use the Models in the Section below to create actual safe work procedures for particular types of power tools. Implementation Strategies for Different Types of Portable Power Tools In addition to the general tool safety measures above, you need to take steps to control hazards associated with six particular types of portable power tools: 1. Portable Circular Saws Saw blades must be fitted with particular kinds of guards and tools must have certain kinds of switches and safety devices. There are different technical requirements for: Portable, power-driven circular saws with blades greater than 2 inches in diameter; Hand-held powered circular saws with blades greater than 2 inches in diameter; Electric, hydraulic or pneumatic chain saws and percussion tools without positive accessory holding means; Hand-held powered drills, tappers, fastener drivers, horizontal, vertical and angle grinders with wheels greater than 2 inches in diameter; Portable belt sanding machines. 2. Pneumatic Tools Pneumatic powered tools must have an installed tool retainer and hoses and hose connections used to transmit compressed air must be able to withstand the air pressure and workloads to which they’re subjected. 3. Abrasive Wheels Portable abrasive wheels (and other portable grinding machines) must have appropriate safety and/or wheel guards and be properly mounted and inspected. 4 4. Explosive Actuated Fastening Tools Explosive actuated fastening tools, i.e., tools that use explosives or similar methods to propel a stud, pin, fastener or other object (not counting devices for attaching objects to soft construction materials like wood, plaster, tar or dry wallboard or stud-welding equipment) must: Have designated safety features (depending on type of tool); Be safely loaded, aimed, fired and used; and Be properly inspected and maintained. 5. Power Lawnmowers Power lawnmowers must meet specific design, marking, use and maintenance requirements depending on whether the lawnmower is a walk-behind, riding-rotary or reel powered. 6. Jacks Powered jacks, i.e., devices used to lift or horizontally move loads by applying a pushing force, must meet specific requirements covering loading, marking, operation and maintenance depending on whether the jack is a lever-and-ratchet, screw or hydraulic device. Tools & Implementation * See “How to Comply with OSHA Circular Saw Safety Rules” to ensure proper guarding of circular saws; * Use the “Model Circular Saw Safety Use Policy” to create your own circular saw safety procedures; * See “How to Comply with OSHA Hand-Held Power Drill Requirements” to ensure safe use of hand drills; * Use the “Model Hand-Held Power Drill Policy” to create your own hand drill safety procedures; * See “How to Comply with OSHA Hand-Held Grinder Requirements” to ensure safe use of grinders; * Use the “Model Hand-Held Grinder Safety Use Policy” to create your own grinder safety procedures; * See “How to Comply with OSHA Portable Belt Sanding Machine Requirements” to ensure safe use of portable sanders; * Use the “Model Circular Portable Belt Sanding Machine Use Policy” to create your own sander safety procedures; * See “How to Ensure Safe Use of Chainsaws” to find out how to prevent injuries and OSHA violations; * Use the “Model Chainsaw Use Policy” to create your own chainsaw safety procedures; * See “How to Comply with OSHA Portable Abrasive Wheel Requirements” to ensure safe use of portable abrasive wheels; * Use the “Portable Abrasive Wheel Safety Policy” to create your own portable grinding wheel safety procedures; * See “How to Comply with OSHA Explosive Actuated Fastening Tools Requirements” to ensure safe use of power actuated tools; 5 * Use the “Model Safe Work Procedure for Explosive Actuated Fastening Tools” to create your own power actuated tool safety procedures; * See “How to Comply with OSHA Power Lawnmower Requirements” to ensure safe use of power mowers; * Use the “Model Safe Work Procedure for Power Lawnmowers” to create your own power mower safety procedures; * See “How to Comply with OSHA Jack Requirements” to ensure safe use of portable powered jacks; * Use the “Model Safe Work Procedure for Power Jacks” to create your own power jacks safety procedures Step Three: Provide Portable Power Tool Safety Training (Day 16-20) The next step is to provide safety training to workers who operate portable power tools. Such training should cover 8 things, at a minimum: The different types of portable tools that workers use; The hazards posed by each of these tools; How to select the right power tool for a job; How to set up the work area when using power tools; Safe work procedures for using different kinds of power tools; What PPE to use when operating power tools; How to inspect power tools; and How to care for and store power tools. Implementation Strategy: Use the SafetySmart training programs and resources, including the samples listed in the box below, to deliver effective and legally compliant portable power tool safety training to your workers. Also keep in mind that simply providing training isn’t enough. You must also ensure that workers actually understand and are capable of applying their training on the job. Methods of verifying the effectiveness of training include: Quizzing workers on the lesson after you deliver it (note that quizzes are included in all of the SafetySmart “Meeting Kits” and e-Learning courses listed in the box below); Making workers demonstrate the safe work procedures covered during the training; Making workers demonstrate proper use of the PPE covered during the training; and Observing workers operate power tools to ensure they’re actually following their training on the job. Tools & Implementation 6 For onsite training, use one or more of the following resources: * Meeting Kit: Using Portable Electric Tools Safely; * Meeting Kit: Sharpen Your Tool Safety Sense; * Meeting Kit: Power Tools Are Not Toys; * Meeting Kit: No-Fault Electrical Equipment; * Meeting Kit: Chainsaws Can Be Friend or Foe; * Meeting Kit: Grinders Pose High-Speed Danger; * Meeting Kit: Great Guns! Powder Actuated Power Tools Are Dangerous; * Meeting Kit: Pneumatic Nailers; * Meeting Kit: Compressed Air Is Dangerous; * Meeting Kit: Use Jacks Safely (Note: Meeting Kits include all the resources about a topic needed to deliver on-site training, including Leader Sheets, Handouts, PowerPoints and Quizzes) For online training, assign the following e-Learning courses: * Basic Electrical Safety Course * Chainsaw Safety—Oil and Gas Course; * Hand and Power Tool Safety—Cal/OSHA; * Hand and Power Tool Safety; * Hand and Power Tools for Oil and Gas Personnel; For video training, use SafetySmart’s videos: * Interactive Safety Video: Hand and Power Tools; * Video: Basic Electrical Safety; * Video: Basic Electrical Safety (Spanish); * Hand & Power Tool: Construction Safety Video; To document power tool safety training, use the: * Model OSHA Training Log to document that safety training was provided and what it covered; and * Model OSHA Training Verification Form to document that you ensured that the training was effective. Step Four: Inspect, Monitor, Reinforce and Improve Your Portable Power Tool Safety Measures (Day 21-30 and forever after) The final step of the Program is to monitor your controls to ensure they’re effective and determine whether adjustments or corrective actions are necessary. Monitoring must be carried out on an ongoing and continuous basis. So even though we “schedule” it as starting on Day 21 and ending on Day 30, the monitoring process never ends. Monitoring should be done on a regular basis, e.g., as part of monthly work inspections and scheduled safety audits, and in response to red flags like: Worker complaints; Incident and injuries; 7 Significant changes to power tool operations etc. that weren’t accounted for or anticipated in the previous hazard assessment. Implementation Strategy: One of the key parts of monitoring is to implement a program for inspecting and maintaining power tools at appropriate intervals. For Best Results, combine this Calendar with your regular preventive maintenance and inspection schedule for portable powered tools covered. TRIGGER Accidents, injuries, illnesses or near misses involving power tools MONTHLY AT LEAST YES NO TASK [ ] Review and verify adequacy of current safety procedures for affected tool [ ] Review and verify adequacy of current training for workers using, servicing or maintaining tool [ ] Provide new, refresher or re-training if necessary [ ] Implement any other necessary corrective actions Comments: Changes in procedures for use of tools [ ] Review and verify adequacy of current safety procedures for affected tool [ ] Review and verify adequacy of current training for workers using, servicing or maintaining tool [ ] Provide new, refresher or re-training if necessary [ ] Implement any other necessary corrective actions Comments: Changes in service/maintenance procedures for tools [ ] Review and verify adequacy of current safety procedures for affected tool [ ] Review and verify adequacy of current training for workers using, servicing or maintaining tool [ ] Provide new, refresher or re-training if necessary [ ] Implement any other necessary corrective actions 8 Comments: Changes in tools or tool equipment [ ] Review and verify adequacy of current safety procedures for affected tool [ ] Review and verify adequacy of current training for workers using, servicing or maintaining tool [ ] Provide new, refresher or re-training if necessary [ ] Implement any other necessary corrective actions Comments: New worker assigned job involving use of tools [ ] Make sure worker has adequate training to use tool safely [ ] Furnish new or refresher training if training is inadequate Comments: Current worker assigned job involving use of tools he/she hasn’t been required to use previously [ ] Make sure worker has adequate training to use tool safely [ ] Furnish new or refresher training if training is inadequate Comments: Outside contractor(s) assigned to use tools [ ] Notify contractor of your safe work procedures for use of tool [ ] Get notification by contractor of its own safe work procedures for tool [ ] Ensure that your workers who use tool understand and comply with contractor’s safe work procedure OR [ ] Ensure that contractor’s workers understand and comply with your procedures for use of tool [ ] Verify that contractor’s workers are properly trained to use tool Comments: 9 Other indications give you reason to believe workers don’t have adequate training in use of tools [ ] Review and verify adequacy of worker’s training [ ] Provide worker training, re-training or refresher training, as needed [ ] Certify training Comments: Tools returned to service after repairs made BEFORE TOOL IS USED, INSPECT TOOL and PARTS TO VERIFY: [ ] Repairs conform to manufacturer’s instructions [ ] Tool is once more fit for service Comments: Jack(s) was sent out of shop for special work, or subject to abnormal load or shock IMMEDIATELY AFTER TRIGGER & IMMEDIATELY BEFORE RE-USE: [ ] Inspect jack to verify repairs conform to manufacturer’s instructions [ ] Inspect repair or replacement parts for defects [ ] Tag any parts found to be defective and remove them from service Comments: TRIGGER At least once every 6 months SEMI-ANNUALLY (AT LEAST) YES NO TASK [ ] Thoroughly inspect jack(s) for constant or intermittent use at one place Comments: TRIGGER At least once a year ANNUALLY (AT LEAST) YES NO TASK [ ] Inspect all portable power tools [ ] Certify inspection [ ] Review and verify adequacy of current safe work procedures for tools [ ] Provide necessary re-training or refresher training to workers that use tool [ ] Certify training [ ] Implement any other necessary corrective actions 10 Comments: Tools & Implementation * Use the “Workers’ Portable Power Tools Safety Questionnaire” and “Supervisors’ Portabe Power Tools Safety Questionnaire” to determine if lsafety measures are working; * Use the “Model Power Tool Incident Investigation Form” to investigate tool injuries and incidents; * Use the “Corrective Actions Form” to determine how to modify and improve tool safety measures. Final Word… Remember that most power tool injuries are preventable. Following the steps of this Plan will enable you to correct the common problems that lead to incidents and help you pass OSHA inspections and avoid citations and fines for violating OSHA portable power tool safety requirements. Need help? Call us anytime to discuss how SafetySmart can help your company improve its power and hand tool safety program. Success programs are a tool to improve safety program success. Use of a success program does not guarantee compliance or elimination of all safety-related liabilities. Every organization’s compliance and training needs differ. SafetySmart and its employees, managers, owners, and other related parties are not liable for any criminal or civil liability, damages, or other negative outcome arising from the use of a success program. 11
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