Thursday, January 14, 2010

Manufacturing Sector is Not General Industry

The absurdity of including the manufacturing sector in the OSHA General Industry Standards really hit home the other day while working the graveyard shift at the refinery. A co-worker and I were having a discussion concerning the Sub-Parts of the General Industry Standards in which housekeeping, hazardous communication, ventilation, and PPE have the same requirements for refinery workers as they do for restaurant/fast food workers. This is were I had a bit of difficulty in justifying to Steve that the occupational hazards that we are exposed to in our 12 hour shifts our similar to food service workers as outlined in the General Industry Standards.

So why does construction, agriculture, and the maritime trades have separate OSHA Standards, yet manufacturing doesn't? Each of these sectors have their own unique occupational hazards in the workplace. In 2007 there were 400 fatalities in the manufacturing sector. Leading cause of fatalities in 2007 were from contact with objects and equipment (140), transportation incidents (102), and falls (48).

In 2008, Bureau of Labor Statistics (BLS) reported 689,700 recordable injury or illness cases in manufacturing industries with more than half of these requiring days away from work, job transfer or restriction.. The nearly 14 million workers in this sector had the highest numbers and rates of occupational illnesses with more than 25% of these were hearing loss. So what is so general about this, to be referred as General Industry?

Manufacturing workers have specific risks to hazards that others in General Industry are not exposed to. Such as contact with machinery and equipment, physical exertion, repetitive motions causing musculoskeletal disorders, hazardous exposure to toxic substances, organic solvents, pesticides, dust, isocyanates, chemicals, aerosols, nanoparticles, carbon monoxide, explosions, structural failures, and noise. For example, manufacturing sector fatal work injuries involving fires and explosions was up 14 percent in 2008.

What other General Industry sectors are exposed to as much risk? All the above are specific hazards that are not general in nature and must be addressed accordingly so as to minimize fatalities, injuries, and illnesses. Utilizing these General Industry Standards, relics of the 1970's when the Rubik's Cube was cool and the drive-in movie was still in fashion is not the solution for the 21st Century.

An earlier post with the example of the Ventilation General Industry Standard that is mostly occupational hygiene in nature and not occupational safety concerning inherent fire and explosions hazards in the manufacturing sector is only the tip of the iceberg. Currently OSHA's answer to address this inadequacies is to develop separate standards for different fire and explosion hazards such as combustible dust. So whats next, a Vapor Cloud Explosion Standard.?

After-all, there are many, many more fatalities and injuries as the result of these sort of incidents such as the BP Texas City Refinery incident. It's quite evident that Process Safety Management (PSM) has not had stellar results. So lets have a Vapor Cloud Explosion Standard next. Of course this is not the appropriate solution but only further illustrates the absurdity of the manufacturing sector referred to as General Industry.

The appropriate and most obvious solution is to revise the current OSHA Standards to reflect current occupational hazards that workers are exposed to on a daily basis. Manufacturing is vital to the economic health and security of our nation, which had gross output of $4.5 trillion in 2005, and the most important sector of the U.S. economy in terms of total output (Bureau of Economic Analysis 20081). It's long overdue for manufacturing to be have it's own OSHA Standard like construction, agriculture, and the maritime sectors. Until then all stakeholders can expect additional red-tape and bureaucracy of separate standards included in the OSHA General Industry Standards. Is that the course desired?


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