Some Things to Consider in Facility Safety Programs

Facility safety programs are essential for identifying, managing and mitigating various hazards, ensuring compliance and integrating safety into broader management processes.

• By Greg Zigulis
• Sep 10, 2024

People with facility management responsibilities want to be sure they are doing the right things to ensure safety compliance while also effectively managing their other obligations. And they often ask, “What should we be doing?” Some might even wonder if facility safety should really be a priority issue. The real hazards are mostly from operational processes, right? Wrong!

There are many aspects and nuances to facility safety. For example, there can be hazards to workers who maintain facilities. There can be hazards stemming from the presence, absence or state of physical structures, passageways and things related to general occupant and visitor safety. And yet other facility hazards can come from ongoing operations like the movement and loading of forklifts, facility traffic and warehouse considerations.

Let’s discuss the identification of hazards and requirements, some general considerations and a few items that deserve special attention. 

Ways to Approach Facility Safety Issues

First of all, how can someone know what to pay attention to and what requirements apply?

Technical answers regarding OSHA requirements depend upon the industry the organization is in, the exact processes and operations in place, tasks performed by workers, locations of work and other factors. There can be hazards for which there is no specific OSHA standard but for which an employer is obligated to protect workers from under the OSH Act’s general duty clause (or state equivalents), section 5(a)(1). This requires employers to provide a work environment free from recognized hazards that could cause death or serious physical harm.

Organizations should have processes to identify what hazards might exist, what OSHA regulations apply, and what hazards could be newly created. Do you see things that, if something doesn’t go right, might cause someone to get hurt?

To learn about frequent OSHA citations, one can search the osha.gov website using NAICS (North American Industry Classification System) codes.

One can find focused safety checklists on the web and start learning more about what might apply. Many State OSHA program websites have excellent information and checklists. Trade publications often discuss hazards, impending regulations and trending issues. Some companies offer inspection and auditing software that can be tailored to your situation. There are also online subscriptions that provide checklists, technical information, discussion forums and other services.

Information available through artificial intelligence (AI) driven searches is getting better. At least one service is geared for use by safety professionals. However, even for-fee AI searches generate incorrect information and must be checked.

Not all hazards or risks are addressed by specific OSHA standards. Consider referencing safety-related consensus standards; these can provide excellent information. Some are built into (incorporated by reference) OSHA regulations, although usually not the current version. 

ANSI/ASSP Z590.3, Prevention through Design (Guidelines for Addressing Occupational Hazards and Risks in Design and Redesign Processes), is a good standard to know about. It provides a comprehensive approach to the integration of safety into the design and redesign of workplaces, tools, equipment, machinery, substances and work processes.

Consensus occupational health and safety management systems (OHSMS) standards use systems approaches and describe a management framework that people can learn from. They describe processes for hazard identification, assessment of risk and other things. OHSMSs, if adopted, can provide “the glue” between otherwise stand-alone safety procedures.

Common Facility Safety Considerations

OSHA regulations apply to persons working in facility safety or facility maintenance just as they do for persons working in the rest of an organization. Obviously, the exact standards that apply depend on where people work and what they are doing, but the point is that just because someone has less visibility or a high skill level, does not mean that OSHA does not apply.

This includes requirements pertaining to things like 29CFR1910.147, the control of hazardous energy (lockout/tagout), and many others. 

Special Attention

That said, there are some hazards that can center around facility management and facility maintenance functions that require attention. Some examples: 

Working alone and remotely. Some tasks can result in isolated and hazardous work, such as climbing and work at elevation, or other processes with extra risk when performed alone. Without monitoring or communication with others, bad things happen that might not be discovered until too late.

Contract employees and temporary workers. Some processes may utilize contractors for various durations. Work conducted by the host can impact the contractor and vice versa. Some things require extra coordination, like for hazardous energy control (lockout/tagout). Also, contractors performing routine facility services might be asked by the facility staff to perform tasks outside their area of authorization or skills, and conversely, contract employees may take risks to “prove” themselves for employment.

Combustible dust considerations. Some processes create combustible dusts that pose risks in the air or after settling on surfaces. These are not always on a facility’s radar. OSHA has a National Emphasis Program (NEP), revised in 2023, and the NFPA has several standards about this. Some describe fundamentals including conducting Dust Hazard Analysis (DHAs).

Warehouse and logistics center considerations. OSHA has a current NEP on this topic as well (see CPL 03-00-026). The focus is on hazards common to those operations. Forklift issues, as well as rack damage and integrity, are cited frequently.

Workplace violence prevention. This is a leading cause of death on the job in the U.S. Facility design, physical tools, proactive assessments and emergency procedures can influence this. Organizations should be sure they are addressing this adequately. 

Spread of infectious diseases. The country is likely to face infectious disease pandemics again. There are standards that facilities staff should be aware of and use appropriately. These include ISO 45006:2023, a management guideline about preventing and managing infectious diseases at work, and ASHRAE 241, a standard about Control of Infectious Aerosols describing airflow requirements in various building types.

Is Someone Handling This?

Sometimes it can be easy to presume that certain hazards are being handled by others. Verifying those assumptions can be important.

For example, one organization had processes with the significant potential to generate high levels of carbon monoxide. Area sensors were present. However, checking found that sensors had not been calibrated in many years and that output was not monitored.

Summary 

Facility safety considerations can be nuanced and are important. Organizations should use intentional approaches to identify, stay on top of, and control related hazards and risk. Many options are available. Certainly, organizations need to identify applicable regulations and ensure compliance, but they should also think about how they choose to manage safety beyond that. The method is important. The integration of facility safety considerations with other management processes can help ensure compliance as well as create other improvement opportunities.

This article originally appeared in the September 2024 issue of Occupational Health & Safety.