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Appendix B
OSHA Day Report Summaries
2012


In 2012, nine OSHA Day verification visits were conducted at participating facilities as part of the OSP. Federal OSHA and Michigan OSHA conducted three and six OSHA-Day Verification visits, respectively. Below are summaries of those reports. While OSHA maintains the full reports, they are not provided in their entirety as part of this evaluation. The summaries are presented in order of the dates the verification visits were performed. The injury and illness information for all participating plants can be found in Appendix A.

Ford Van Dyke Transmission Plant; February 14, 2012

Data Collected: Injury and Illness rates and other measures were provided for a three year period from 2010 to 2012. The numbers of hours worked at this facility have remained fairly stable over the three years and the plant injury and illness rates are decreasing. However, the 2012 TCIR for the plant remains above the industry's TCIR compared to the BLS TCIR for 2011 but the plant's 2012 DART rate is below the BLS Dart rate for that same year.

On Site Observations: Two machine guarding issues in different locations of the plant were observed. One occurrence of a deficiency on a portable ladder was observed and the ladder was immediately removed from service; a few instances of deficiencies in labeling of permit required confined spaces were observed and these were also addressed immediately; lastly, two powered industrial vehicles were observed to be deficient in the labeling and operation of controls.

Site Best Practices: The verification team reported the plant's leadership team's active involvement in the safety and health process as a best practice. Supervisors participate on the safety committee, and are well versed in plant safety and health issues and committed to the immediate correction of observed hazards.

Opportunities for Improvement: Guarding of machinery and equipment is listed as an opportunity for improvement. Additionally, the team believes that safety information needs to be more readily shared between the participating plants. Two similar machines at two different plants were observed with the same machine guarding deficiencies.

Ford Rawsonville Plant; March 28, 2012

Data Collected: Injury and Illness rates and other measures were provided for a three year period from 2010 to 2012. The numbers of hours worked at this facility have remained fairly stable over the three years and the plant injury and illness rates are decreasing. Both the plant's 2012 TCIR and the DART rates are below the industry's BLS TCIR and DART rates for 2011.

On site Observations: Two machine guarding issues in different locations of the plant were observed. Additionally, one occurrence of a guarding deficiency on a floor fan and one missing guard on a belt conveyor nip point were also observed.

Site Best Practices: The verification team reports many best practices including the following: outstanding inter- and intra-departmental communication of safety and health issues. The plant utilizes multiple forms of media to promote plant safety and health including TV monitors safety talks and newsletters; the plant also uses its heat stress team to communicate safety and health information. The team is comprised of labor and management representatives that meet regularly to assess and mitigate potential areas where heat stress hazards exist.

Opportunities for Improvement: The evaluation team recommended that enhanced injury and illness trend analysis be performed. Additionally, recommendations were made to provide labeling of compressed air lines located along the floor of the plant as they are in the ceiling.

Romeo Engine Plant; April 25, 2012

Data Collected: Injury and Illness rates and other measures were provided for a three year period from 2010 to 2012. The numbers of hours worked at this facility have remained fairly stable over the three years and the plant injury and illness rates are decreasing. The 2012 plant TCIR was slightly above the BLS 2011 industry TCIR and the 2012 plant DART rate is slightly below the industry's DART rate for 2011 as reported by the BLS.

On site Observations: Noise induced hearing loss has been the top illness experienced by plant workers and sprains and strains have been the top injuries. A more critical analysis of these occurrences is needed. This was communicated to the OSHA-Day verification team.

Site Best Practices: The plant has an active first aid program that includes posted information on the use of AEDs.

Opportunities for Improvement: The evaluation team recommended the parking lot surfaces are in need of repair.

Sterling Axle Plant; June 14, 2012

Data Collected: Injury and Illness rates and other measures were provided for a three year period from 2010 to 2012. The numbers of hours worked at this facility have remained fairly stable over the last three years. The plant injury and illness rates are vacillating; the plant 2012 TCIR and DART rates are well above the BLS industry TCIR and DART rates for 2011.

Onsite Observations: The facility does trend analysis to identify hazards and affected employees. The Job Safety Analysis performed at this plant is very detailed and closely followed. Management is aware of the health and safety issues in the plant and works actively to address them. There is strong support for the health and safety process from all levels of management.

Site Best Practices: None referenced in the report.

Opportunities for Improvement: Machine guarding by-pass issues were observed (toggle pressure switches). These need to be corrected so they cannot be left in an "on" position. This is a safety guarding and energy control issue.

Ohio Assembly Plant: June 201, 2012

Data Collected: Injury and Illness rates and other measures were provided for a three year period from 2010 to 2012. The numbers of hours worked at this facility have remained fairly stable over the last three years. The plant's TCIR and DART rates were reduced from 2011 to 2012. More importantly, both the plant's TCIR and DART rates remain well below the 2011 BLS rates for this industry.

The site performed data analysis and identified same surface falls as being causal factors for 40% of their 2012 injuries. Plans are being made to perform further analysis and implement corrective actions.

Onsite Observations: A walkthrough was conducted in three departments (Paint, Body and Final Assembly). The site's housekeeping was observed to be excellent. The use of PPE and engineering control implementation (ventilation) were identified as comprehensive protective measures. The site performs job safety analyses for all tasks as well as, onsite incident reviews and root cause analysis for incidents. The site's machine guarding was observed to be excellent, as was the condition of hoists and rigging.

Site Best Practices: The audit team listed the facility ergonomics program as a Best Practice. The report stated that several examples were observed during the evaluation and innovative solutions have been implemented where possible. The site has a policy banning the use of cell phones, which is believed will reduce the number of observed distracted walking and driving incidents. The plant also has an active Pedestrian Safety Committee.

Opportunities for Improvement: A recommendation from the team was provided to better track completion of issues from observations made on the site's daily audits (for example missing fire extinguishers and damaged welding screens had been reported and tracking the completion of the correction of these items would be useful). A second recommendation was made to update Non-Standard Work (Non-Routine) task forms with a more detailed explanation of the PPE required for the specified task, and to increase observations of appropriate use of PPE for those situations. An overall recommendation is made for the site to work on fall hazard observations and the use of fall protection in various locations.

Sharonville Transmission Plant: September 18, 2012

Data Collected: Injury and Illness rates and other measures were provided for a three year period from 2010 to 2012. The numbers of hours worked at this facility have remained fairly stable over the last three years. The plant's annual TCIR has been slowly reducing and the DART rate has been fluctuating over the last three years. However, the plant's three year average TCIR and DART rates (2010 through 2012) are lower than the 2011 BLS rates for this industry.

Onsite Observations: The walkthrough audit included all areas of the site except for the dock area. For all meetings, safety is the first topic of discussion prior to quality and delivery. A plant -wide comprehensive walking and working surface survey was conducted in 2011 and visual reminders for related protective standards have been posted in each department.

Site Best Practices: Employee Involvement is an example of one Best Practice for this site. Daily, each employee is required to complete a safety start up card, these cards are reviewed and all hazards identified are abated. Depending on the seriousness of the hazard, the operation may be shut down by the employee; the Safety Process Review Board meetings incorporate hourly employees; and, each functional team has one person who volunteers to be the Star Point. The Star Point appointee attends global meetings every month where discussions include safety metrics, ergonomics training and a discussion of incidents that occurred over the prior month. The Star Point takes this information back to his/her team.

Opportunities for Improvement: None were reported by the audit team

Woodhaven Stamping Plant October 12, 2012

Data Collected: Injury and Illness rates and other measures were provided for a three year period from 2010 to 2012. The numbers of hours worked at this facility have increased each year, for the last three years. The 2012 TCIR and DART rates for this facility are below the respective rates for the plant for 2011. While the plant's 2012 TCIR remains above the industry's 2011 TCIR reported by the BLS, the plant's 2012 DART rate is well below the BLS reported DART rate for 2011.

The Woodhaven Stamping Plant monitors trends with regard to illness and injury data and uses this information to develop programs and processes that reduce exposure to hazards that may arise in the plant.

Onsite Observations: The Woodhaven Stamping Plant has identified numerous issues with regard to walking and working surface conditions and has addressed several of these issues. This process is ongoing and is expected to improve and become more comprehensive over time. The site's "Interactive Safety Talk" process was observed in action. This process appears to go a step beyond just having a tool box safety talk. Employees are taken off the floor monthly by their supervisor and given a test on a specific subject involving safety, and the answers are reviewed with the employees by their supervisors. This process actively involves the employee and the supervisor in the safety process. This goes beyond just having supervisors read a pamphlet to the employees; it ensures active participation by the employee and promotes learning. This process was also noted as a Best Practice by the audit team.

Best Practices: The interactive Safety Talk described above was listed by the audit team as a Best Practice. Another Best Practice relates to fork truck pre-use inspections. The fork trucks in the plant are equipped with the IVIS system, which allows drivers to complete the pre-operation checklist electronically. Employees are given four chances to complete the checklist within the first hour of the shift. When an item affecting the safe operation of the vehicle is checked a notice is sent to vehicle maintenance. The vehicle will not operate until the item has been repaired and the check item cleared on the system. Lastly, the site uses an electronic process for bringing new equipment into the plant. The system is a visual indicator to let the staff know when the machine is safe to put into production. No machine is released for production until all hazards identified by this process have been addressed and the proper personnel have signed off on the tag.

Opportunities for Improvement: Machine guarding issues were observed in the facility to include saw guarding, by pass of hydraulic press actuation mechanisms and exposed rotating shafts. All of these items were addressed during the audit and corrective action is in progress. Another area needing improvement is related to fall protection devices. For example: Fixed ladders cages going to the building roof need a standard barrier at the openings. A recommendation was made to develop better cross communication between the Mechanical Engineering teams and the Plant Ergonomic team to identify ergonomic issues prior to launching a new piece of equipment for use in the plant.

Dearborn Truck Plant: October 30, 2012

Data Collected: Injury and Illness rates and other measures were provided for a three year period from 2010 to 2012. The numbers of hours worked at this facility have increased over the last three years and the plant has reduced their TCIR and DART rates slightly from 2011 to 2012 by 14% and 12% respectively. Overall however, the plant 2012 TCIR and DART rates remain well above the BLS industry TCIR and DART rates for 2011 for this industry.

The Dearborn Truck Plant monitors trends with regard to illness and injury data and uses this information to develop programs and processes to reduce exposure to hazards that may arise in the plant.

Onsite Observations: Machine/Equipment guarding issues were observed at this site during the visit. MIOSHA has been working with this site on these issues. Pedestrian safety was observed to be excellent as a result of a program implemented to reduce vehicle/pedestrian accidents in the plant. The program includes having clearly marked aisles for pedestrian and vehicle traffic. Some aisles are designated as "truck free aisles." The plant layout is such that employees are able to use mezzanines to access restrooms, break areas, and administrative areas. This aids in keeping vehicle/pedestrian accidents at a minimum.

Best Practices: The site utilizes a process called "Manage the Change" (MTC). MTC is a process used at the facility where problems that need to be addressed with regard to the safe operation of equipment are electronically tracked to completion. It involves all levels of management, including supervisors, engineers, safety, and maintenance. Problems are tracked electronically and sign offs are required to ensure the necessary items are being addressed before equipment is put into production. The electronic Fork Truck Pre-Use Check System is also used at this facility. Employees are given four chances to complete the checklist within the first hour of the shift. When an item affecting the safe operation of the vehicle is checked, a notice is sent to vehicle maintenance. The vehicle will not operate until the item has been repaired and the checked item cleared on the system.

Opportunities for Improvement: The tracking of training hours for the site emergency response team needs to be upgraded. Adequate records were not available to reflect that the all members of the team had received the appropriate training. The company has developed a training tracking system and it is being implemented. The facility needs to improve the fixed ladder cages leading to the roof with appropriate standard barriers at the top. Lastly, the employer needs to better implement their Hearing Conservation Program. Areas were identified as being high noise areas and equipment needed to reduce the noise has not been installed. The company has scheduled additional noise monitoring to identify the scope of the problem.

Kansas City Assembly Plant: November 14, 2012

Data Collected: Injury and Illness rates and other measures were provided for a three year period from 2010 to 2012. The numbers of hours worked at this facility have reduced over the last three years as the site was under a major construction renovation. The plant has reduced their TCIR and DART rates from 2011 to 2012 by 6% and 29% respectively. Overall however, the plant 2012 TCIR and DART rates remain above the BLS industry TCIR and DART rates for 2011 for this industry.

In the review of the OSHA 300 log, a number of sprain and strain injuries (some related to ergonomic hazards) were recorded. Additionally, there were 24 cases of noise-induced hearing loss (with approximately 50% of these reports attributed to trade workers). Lastly noted, were a number of slip/trip/fall incidents and eye injuries.

Observations from Walk-Around: During the OSHA Day, the upper management and the UAW plant chairman were very active in the process. In past site visits, upper management and the UAW plant chairman only attended the opening and sometimes the closing. The Plant Safety and UAW Safety Representatives were the major participates in this year's OSHA Day. The walk-around consisted of a walk-through of the truck body final assembly; the new stamping Plant; and the truck body assembly. On previous OSHA/Ford Day visit, a fall hazard had been observed on the SUV commercial line, moon buggy mezzanine platform. At the time of this audit, that condition had been corrected by the implementation of a fall restraint system located, prior to the ending of the SUV line.

The lack of use on seat belts when operating fork trucks in all areas was observed. The seat belt usage has been discussed during previous OSHA Day visits in 2008 and 2010. It was reported by the Ford Regional Safety Director that the policy remains in effect, referencing the Corporate Office's written letter/memorandum addressing the Ford policy of not requiring the use of seat belts due to the increase in the ergonomic hazards while turning in the seat to see behind. The memorandum dated September 28, 2009, references a discussion at the steering committee with OSHA and outlines the Ford Policy on seat belt use on Fork Lift Trucks. OSHA Region VII doesn't believe this Ford seat belt policy is compliant with OSHA requirements.

Note: The above issue was the subject of collaboration between OSHA National Office, OSHA Region VII and Ford/UAW representatives. The Ford corporate policy on the use of seatbelts on powered industrial vehicles was revised based on this collaborative effort.

Best Practices: The plant has implemented a Contractor Safety Program due to the ongoing construction of a new product line. As of the end of October 2012, the project has completed 860,980 hours worked, with a Total Case Rate of 2.09 and no lost time injuries. The project has had two OSHA recordable injuries and one near miss incident. This record is attributed to the following: A third party company for the oversight of construction safety was hired and all contractors on site must complete a 45-minute construction safety orientation. At the time of the audit, 903 workers had completed the orientation and approximately 106 contract workers have completed a 10-hour Construction course. The contractor safety program provides for strong worker participation through pre-task processes and daily safety talks.

Opportunities for Improvement: During this OSHA Day, the plant personnel presented some opportunities for improvement based on their ongoing self-auditing process. These opportunities for improvement include the following: The plant has implemented a process to better track corrective actions of safety hazards identified through daily observations. Each department receives a report of open safety items and all work orders are categorized by priority or hazard level and are addressed accordingly; the plant is working on doing a better job of tracking near miss incidents, and has identified that powered material handling vehicles are the greatest factor involved in near miss incidents. The plant is using a three phase approach to address this issue, including hands-on training, medical evaluation, and implementation of a pre-use inspection checklist; the plant has identified the need to conduct a noise survey. The last noise survey was conducted in 2009, and has started up two new manufacturing processes since then. The Transit Line and completion of the Stamping Plant necessitate the need for additional noise monitoring. The plant is also working on a training program to comply with the new Hazard Communication requirements to address the Globally Harmonized System.

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