OSHA Compliance and Printing Operations
Understanding how OSHA regulations apply to small businesses
There are several significant misperceptions regarding the Occupational Safety and Health Administration’s (OSHA) regulations and the printing industry.
One is that OSHA’s regulations do not apply to small printing operations. This is not an accurate assumption. The legal authority for OSHA comes from the Occupational Safety and Health (OSH) Act, and its coverage extends to all employers and their employees in the 50 states, the District of Columbia, Puerto Rico, and all other territories under federal government jurisdiction. Coverage is provided either directly by Federal OSHA or through an OSHA-approved state occupational safety and health program in states that have approved programs.
Another misperception is that OSHA’s regulations do not apply to companies with fewer than 10 employees. This is also an inaccurate assumption. While it is true that some of OSHA’s requirements do not apply to operations with 10 or fewer employees, there are not that many. For example, OSHA states that businesses with less than 10 employees do not need to have a formal written emergency action plan. However, they still must have a plan that must be communicated verbally to all employees. There is a recordkeeping exemption as well for businesses with less than 10 employees.
OSHA has two principal functions: setting standards and conducting workplace inspections to ensure that employers are complying with the standards and providing a safe and healthful workplace.
OSHA standards require that employers adopt certain practices, purchase equipment, and develop and implement programs as necessary to protect workers on the job. It is the responsibility of employers to become familiar with the standards applicable to their establishments and to eliminate hazardous conditions to the extent possible. Compliance also includes ensuring that employees follow rules and policies that are applicable to their own actions and conduct.
Even in areas where OSHA has not promulgated a standard addressing a specific hazard, employers are responsible for complying with the OSH Act’s “general duty” clause. The general duty clause of the OSH Act [Section 5(a)(1)] states that each employer “shall furnish … a place of employment which is free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.”
Below is a summary of several key OSHA regulations that apply to small operations.
- Recordkeeping– Every employer covered by OSHA who has more than 10 employees, except for certain low-hazard industries such as retail, finance, insurance, real estate, and some service industries, must maintain records of job-related injuries and illnesses. The records include OSHA Form 300, an injury/illness log, Form 301, and Form 300A. Form 300A is a summary of the incidents on Form 300 and must be posted in the workplace from February 1 through April 30 each year.
- Reporting – Each employer, regardless of number of employees or industry category, must report to the nearest OSHA office within eight hours of any accident that results in a fatality or with 24 hours for any incident resulting in hospitalization, amputation, or loss of an eye.
- Lockout/Tag-out – The lockout/tag-out regulation protects employees from unexpected machine startups or hazardous releases during servicing and maintenance, which includes many production-related activities. The regulation requires a formal written program, machine-specific procedures, employee training, and conducting annual inspections.
- Hazard Communication - OSHA’s Hazard Communication Standard requires information be communicated to employees about the chemical hazards they are exposed to and protective measures to ensure their health and safety. This includes having a formal written program, safety data sheets for all chemicals, employee training, and secondary container labels.
- Machine Guarding - There are several standards designed to protect employees from exposure to hazards such as ingoing nip points, point of operation, flying sparks and chips, driveshafts, pulleys, chains, and other moving components. This regulation requires that physical guards be provided to protect employees from exposure and contact the hazards associated with moving parts. Plus, there is no grandfathering of old equipment, which may not have been originally sold with guards. It is the employer’s responsibility to provide guards when they are necessary and absent from the equipment.
- Personal Protective Equipment - OSHA requires all employers to conduct a formal written workplace hazard assessment to determine what personal protective equipment is required to protect employees from injuries. In addition, employers must provide personal protective equipment and employee training in its proper use. Failure to conduct the assessment and certify it is a commonly overlooked requirement.
OSHA Compliance Action Plan
The above identified regulations are only a sampling of several of the key ones. OSHA has many more that apply to printing operations. While it may seem overwhelming, the best approach is to break the process down into smaller steps. Start by educating yourself on your organization’s overall safety and health program. This will help you identify those regulations applicable to your situation and what steps need to be taken to ensure compliance.
The following provides a starting point:
- Identify and coordinate the development and implementation of programs with the person(s) who is responsible for OSHA and safety compliance at the parent company.
- Ensure that any general safety requirements are understood and being followed.
- Survey the workplace and equipment for hazards including, but not limited to, those associated with chemicals, equipment, sharp objects, trip and slip hazards, material handling, etc.
- Based on the results of the survey, create job- or task-specific safety protocols that incorporate OSHA’s requirements. For example, using inch-safe-service or locking out equipment that needs to be accessed for servicing and maintenance.
- Provide well-maintained tools and equipment.
- Provide appropriate personal protective equipment along with training on how to properly use it.
- Provide and document all training required by OSHA standards.
- Conduct regular inspections of the workplace to ensure compliance with requirements is being met and any new hazards are discovered.
- Have your supervisors lead by example to reinforce that safety applies to everyone.
- Report to the internal responsible party or OSHA within eight hours of accidents that result in fatalities or within 24 hours any accidents that result in the hospitalization of an employee, amputation, or loss of an eye.
- Keep records of work-related accidents, injuries, and illnesses and use them to take measures to prevent them from reoccurring.
- Post the OSHA poster (OSHA 3165) prominently informing employees of their rights and responsibilities if it is not already posted.
- Do not discriminate against employees who exercise their rights under the OSH Act.
Summary and Conclusion
Because your operation is covered by OSHA, you must provide your employees with jobs and a place of employment free from recognized hazards that are causing, or are likely to cause, death or serious physical harm. This is accomplished through establishing a safety and compliance program.
The PRINTING United Alliance’s Government Affairs Department has many resources, such as written program templates, designed to assist printing operations address their compliance programs. Please contact the Government Affairs Department at email@example.com to start your safety journey.