ATLANTA — Edwin Foulke Jr. knows a thing or two about safety.
He is a partner in the Fisher & Phillips LLP law firm, and co-chairs its Workplace Safety and Catastrophe Management Practice Group.
Before that, Foulke was assistant secretary of labor for occupational safety and health, and the head of the Occupational Safety & Health Administration (OSHA) under President George W. Bush.
During an educational session here at Clean 2015, Foulke revealed that the laundry industry isn’t as safe as it needs to be.
“I do a lot of inspections with my clients, and a lot of times I get called in after they get the citations,” says Foulke. “You’re in an industry that’s targeted. Like it or not, OSHA is targeting you and your facility.”
Too many laundry operators, in Foulke’s view, think they have great safety because they have safety manuals. They have 4- to 5-inch thick manuals filled with procedures that employees and management are supposed to follow—and those manuals sit on the shelf.
“Don’t try to pretend that you have great safety, because like it or not, you don’t have great safety,” Foulke says. “You may not have had lost time due to injury this year, but it may be just by luck.”
He adds that, statistically, a facility can have no injuries, fatalities or illnesses in a year or two years but the company still can have an inadequate safety program.
“It is critical to have a great safety program if you want to maximize your profits and be as competitive as you can possibly be,” says Foulke.
WHAT IS “SAFE”?
Foulke says that if safety is practiced just when somebody is watching or when the boss is there, if it’s just a “sometimes” thing, laundry facilities are never going to have “great” safety.
Without a full-time focus on safety, according to Foulke, companies won’t maximize profits and are not going to be as competitive as possible.
Even worse, there is the potential that employees can be injured or killed.
“I’ve heard companies say, ‘If we can get our incident ratio down to 0.4, we’re going to have a great year. Our goal is 0.4. That means it’s OK if somebody gets injured,’” Foulke says. “You need to have a goal of zero year in and year out.”
We all make mistakes, Foulke acknowledges. And when mistakes are made, management has to make sure that the worksite is such that the employees don’t get killed or seriously injured. The responsibility for this falls on the owner, manager and supervisor.
“That’s the basis of safety,” he says. “Identifying workplace hazards and then eliminating or lowering them so that employees won’t get killed or seriously injured.”
TOP 20 CITATIONS
To get an idea of what OSHA is checking at a laundry facility when the agency conducts inspections, Foulke lists the 20 standards most frequently cited in the laundry services industry.
Why go over the top 20 citations? Foulke finds that many employers don’t adequately understand the regulations pertinent to the industry and their facilities. This list provides a road map to the things OSHA keeps finding and citing in laundries—to help a laundry facility create a road map to safety.
The top 20 cited OSHA violations in laundries, according to Foulke, are:
- Hazard communication
- Wiring methods, components, equipment for general use
- Control of hazardous energy (lockout/tagout)
- Electrical—general requirements
- Personal protective equipment—general requirements
- Bloodborne pathogens
- Maintenance, safeguards and operational features for exit routes
- Sanitation—general environment
- Respiratory protection
- Machine and machine guarding—general requirements
- Walking/working surfaces—general requirements
- Guarding floor and wall openings and holes
- Permit-required confined spaces
- Medical services and first aid
- Portable fire extinguishers
- Laundry machinery and operations
- Powered industrial trucks
- Mechanical power—transmission apparatus
- Forms—record keeping
- Design and construction requirements for exit routes
“I find quite often in the laundry industry that lockout/tagout procedures aren’t very clear,” says Foulke. “Or they didn’t have a procedure for a particular machine, or they haven’t done the periodic inspection.”
Foulke adds that many companies in the United States don’t have simple safety requirements such as first aid stations, or the employees aren’t trained to use them. OSHA has figured this out.
Check back Thursday for the reality check of why safety needs to be number one.