“I spend a lot of time with these people, and at the end of the day, they’re like family. Safety isn’t just covering your bases for the business. You do all of this because you care about your people and are invested in their well-being.”
When John Peschel, owner and President of Valley Linen, says he spends a lot of time with his 15-member team in Kalispell, Montana, he’s not kidding around. In the winter, the demands made by his nearly 500 customers are maxed out by nearby ski resorts. In the summer, the area’s proximity to Glacier National Park makes it an attractive getaway and keeps the hotels in the area busy as well as the restaurants, health clubs, and other local destinations. “Our business almost doubles during the three months of summer,” Peschel notes.
You might think that with what amounts to a lot of hard work for Peschel and his entire staff – almost all of whom work year-round and clock considerable overtime during the three-month winter season and the three-month summer onslaught – Valley Linen would have a hard time staying up-to-date with safety requirements and needs. On the contrary, Peschel has simply built some best practices into his yearly workflow to keep his team safe and Valley Linen in compliance with all applicable rules and regulations.
“I’ve built the business to meet the demands of my high seasons, so when we have a slower pace, in spring and fall, we use that time to check all of our equipment thoroughly, do any needed maintenance and/or improvements to our infrastructure, and go through training and retraining on various practices and issues.
“Additionally,” Peschel notes, “the State of Montana does quarterly workshops on different aspects of safety – a recent one was on workplace violence, for example. We always send someone to these meetings, and then when they return, we use that as a point of departure to both discuss any new information they’re bringing back and to do a periodic review of our safety process and any particular elements we need a refresher on at that time.”
Pressing Issues for Laundries
What processes should be trained and retrained in this manner? Perennially among OSHA’s top five when it comes to violations cited in industrial laundries, lockout/ tagout tops Ed Foulke’s list. Foulke is a partner in the Fisher & Phillips LLP law firm and co-chair of its Workplace Safety and Catastrophe Management Practice Group.
“I find quite often in the laundry industry that lockout/ tagout procedures aren’t very clear,” says Foulke, who served as head of OSHA from 2006-2008. “Or a given laundry didn’t have a procedure for a particular machine, or they haven’t done the periodic inspection.
“Once a year, as a matter of standard operating procedure, laundries need to inspect all of their lockout/tagout equipment and do an internal review of what processes are in place. Then, all of this should be reviewed with all employees. Finally, document and certify that all steps in this process have been completed,” says Foulke. “That last step is important: Make sure to have everything in writing, and keep these records on file. This kind of due diligence is going to be your best defense in the event of an inspection.”
Among the hazards for which laundries are continually prone to citation, Foulke highlights fall protection, and bloodborne pathogen exposure control as areas to watch for forthcoming regulations updates.
“I signed off on a walking/working surfaces package when I was head of OSHA, and my judgment is that this package is about to come out,” says Foulke. “You’ll see that, as a whole, it includes more regulations on fall protection, so that’s an issue that will take increasing prevalence in the near future.
“Another thing I’d highlight relates to those laundries dealing with materials that may contain blood-borne pathogens. It’s critically important to have an exposure control policy in place and to train and retrain employees on avoidance as well as on appropriately containing the potential harm done by an accidental exposure,” Foulke says. “Additionally, as of 2011, it’s mandatory to offer hepatitis B vaccines for any workers who may come into contact with these materials. Employees have the right to decline the vaccine, but if they decline, the employer needs to make sure a declination form that includes the standard OSHA verbiage for this situation is signed and kept on file.”
Foulke also highlights reporting and recordkeeping itself as one function that may trip up laundries and earn unwanted attention – and fines – from OSHA.
“All employees are covered by OSHA’s Recordkeeping Rule, and even though it went into effect January 1 of last year, it’s surprising how many companies don’t know about these new regulations,” Foulke says. “Also, OSHA Form 300A, the Summary of Work-Related Injuries and Illnesses, must be posted in the workplace every year from February 1 to April 30.“ (See box on page 16 for a rundown on OSHA reporting requirements.)
Naturally, all these regulations are in place to prevent exposure of employees to health and wellness risks that can potentially be catastrophic not only for them but for the business. Economic loss comes in the form of stoppage time, interrupted workflow, and potential criminal and/or civil liabilities, including penalties.
“Of course, the ‘stick’ to the issue of compliance is penalties, and a big change passed as part of the Bipartisan Budget Act of November 2015,” Foulke adds. “Penalties are increasing by upwards of 70%, which is obviously quite a leap, so it clearly pays to do your research and stay up-to-date.”
Make Safety a Healthy Habit
In addition to staying up-to-date and keeping detailed records, Dana Horne of training company Performance Matters notes that planning safety into your workflow is key to ensuring successful compliance with OSHA rules and regulations.
“It’s just like exercise. Getting started, you can’t imagine how you can afford to make that time commitment, “ says Horne, an authorized OSHA Trainer and Six Sigma Green Belt. “However, when you plan it into your schedule, and just get started, you slowly realize that you can make the time to do it and that you feel better – or in the case of safety, that you feel much more secure and less vulnerable.”
Is there an easy way to make safety compliance and reporting part of your routine? Make OSHA.gov your first stop, Horne says.
“OSHA offers a lot of resources through their website, everything from safety plan and exposure plan templates, to training PowerPoints, to a wide range of downloadable and printable posters, flyers and quick-reference cards to help you educate your employees,” Horne says. “Most of these references are available in multiple languages – examples include Spanish, Vietnamese and Portuguese in addition to English – and are designed to ensure that all members of your team, regardless of their comprehension level, will understand the material presented.”
OSHA also offers electronic tools to help you manage safety issues and educate your team. Examples include a Flash-based tutorial on 300A reporting, and an iPhone app on heat safety. Horne says that other interactive tools are available – such as iAuditor from SafetyCulture – and are becoming an increasingly important asset.
Who’s That Knocking at My Door?
So what do you do when OSHA comes to call? David Friday, owner of Wilkins Linen & Dust Control Service in Conroe, Texas, experienced an inspection several years back.
“One thing that will never change is that OSHA is simply a fact of life,” Friday says. “There are certainly some things you must do and some you shouldn’t do when they show up, however.”
Here are Friday’s steps to managing an inspection:
(1) First of all, of course, let them in. “There are simply no two ways about this, obviously,” says Friday. “However, don’t bring them in the door and start showing them around – show them to your office or a conference room immediately.”
(2) Once the OSHA personnel are in a controlled environment, review with them the particular item or process they want to expect. “Make sure you know exactly what it is they’re there to see because that’s going to make a big difference in the next step in your game plan,” Friday says. Which is…
(3) Escort them to the piece of machinery or the area that’s in question – carefully. “You need to show them to what they want to look at directly as opposed to expediently,” says Friday. “That may mean you have to walk out in the street and around to the back door. It may mean you go in an entrance you don’t usually use. It may mean you take them over the roof,” Friday says, chuckling, “Just don’t walk them through your whole operation. Confine what they can observe strictly to what they’re there to see.”
(4) If they take pictures, you take pictures. The same pictures. Same with written notes. “This is a big part of establishing the paper trail of what is happening, so that you can do your due diligence on the results.”
(5) Get them back to your office or conference room. “Maximize the amount of time you spend meeting with them,and minimize the amount of time you’re on the inspection itself,” Friday notes.
(6) Ask for a written preview of their report. “If possible, this will allow you to begin addressing whatever issues exist.”
(7) Refer to the OSHA website for help in the post-inspection process. “The OSHA site provides a lot of resources for managing the process of responding to a complaint. Don’t just fire off a letter or an email or pick up the phone: Follow the procedures to the letter.”
What to do to avoid such an incursion into your business day? Friday offers pointers from the field.
“Many times, you can get an associate from your workman’s comp insurance carrier to come out and do a preinspection to see if they can spot any issues or potential violations,” Friday says. “Alternately, consider having a peer in your state with whom you don’t compete do a walk-through of your facility. It’s easy to get so caught up in day-to-day business, when you’re looking at your physical facility and your machinery all the time, and just lose perspective. A second set of eyes can be a terrific asset in ensuring your operations are fully in compliance.”
In the laundry industry, as in football, the best offense is often a good defense. Leverage this information, and you’ll have an effective game plan for a win at OSHA compliance and reporting.