06/01/2023

Safety Programs - The Missing Piece of a Good Operation

By Andy Kelly, Principal
Sierra Self Storage Consulting, LLC

One of the missing pieces of a good operation is safety program requirement for your employees. In my travels, it is amazing how many owners are lacking safety training/ equipment and/or the proper documents to be in compliance. Should the site have an accident with an employee and/or tenant, the site owner and possibly the management company will be held liable for damages including the not so friendly OSHA (Occupation Safety and Health Administration) visit. This governmental agency will show when there has been a death or serious injury or upon an employee contact for unsafe conditions. OSHA will evaluate all safety programs in place, training, ongoing training, safety memos and MSDS (Material Safety Data Sheets), Right to know documentation, chemicals on site, safety equipment on site and labeling to name a few. Depending upon the accident or injury and what is in place is where the fines begin, and whether the violations were willful, ignorant of requirements, lack of training and safety equipment and required documentation on site. This is no laughing matter and should be taken seriously as fines can range from the thousands to hundreds of thousands for being ignorant non-compliant.

Often, if you have never had an issue and depending on what caused the OSHA visit, OSHA may allow the site to correct the issues quickly and drop the amount of the fine, unless there was a death or serious injury. Make no mistake about it, the site will be fined for non-compliance.

If the site is using a payroll leasing company, many of them have a safety department that will consult with the site on the necessary steps to comply. They may have safety webinars which document employee participation to prevent the employee from saying no training was ever done. If OSHA knocks at the door, this is crucial to softening the government fines and penalties. The site’s insurance company may offer another opportunity to have training for employees as they have a vested interest in not paying out money for things that could have been dealt with from the get go. There are many safety companies that can be hired to come to the site for evaluation. These types of safe guards not only help the employee from getting injured but proves to OSHA that the site was diligent in trying to prevent accidents. If you are an independent owner, this is a must again, to prevent a disaster or large fine by OSHA, which may or may not be covered under the site insurance policy. If the site has a management company, it is both the owner and management’s duty to make sure safety precautions are in place along with employee training, or be brought into the party of fines.

If site owner or management company does not recognize the following terms and what to do about them, its only a matter of time before the door knock. These terms include, MSDS sheets on site and knowledge on each chemical on site and how it works, first aid for accidents, safety equipment, safety operations manual, types of safety equipment on site and how it’s used and when, safety cabinets for chemicals and what can be stored together, Right to know document for employees, proper labeling for all chemical containers and how to note reactions, safety equipment required for use, first aid, unlabeled containers with unknown chemicals and their disposal, safety chemical inventory to name a few.

If  the site has safety procedures in place at the storage site, congratulations, if the site is behind the eight-ball, it’s ticking time-bomb. How do I know so much about this topic? I was the supervisor of a building early in my career that had a maintenance person sprayed from head to toe with the pest control by accident by the vendor. The employee had a severe reaction and had gone to the hospital for treatment. The pest control company was asked for the MSDS sheet and the employee spraying had no idea what was requested. The building got a visit from OSHA who fined the company for not having a MSDS sheet on hand even though we hired the pest control company. Once OSHA found this slight glitch, the fine-tooth comb came out and found everything we were not doing correctly. The fine was massive just short of six-figures, but we were given a reduced fine of $5000 to $10,000 and a timeline to get the safety violations fixed. The employee was released the hospital the same day with no lingering issues upon treatment. This incident was  a wakeup call to everyone in the company. Upon fixing the errors, OSHA gave the company a follow up visit at our request and passed with flying colors. The company had slim to no claims going forward and was rewarded by the insurance company for a noted safety program and reduced site premiums. Once the site/ building has been visited by OSHA, you are now on radar for any further injury visits and will not be given the benefit.

The solutions to many of the above scenarios? Hire safety trainer/consultant, contact the management company, your site insurance agent or the Employee leasing company for recommendations. Meanwhile, there are many safety supply companies in just about every city, they may come out in addition. These safety supply companies will have posters on how to read the MSDS( Material Safety Data Sheets) Chemical labeling posters and requirements for using chemicals in containers, fire safety cabinets, safety equipment and guide you in the requirements for a having a “Employee Right to Know Manual” that describes on how, what and prepare for using chemicals onsite. All employees should have their own eye protection, chemical resistant gloves, ear protection and respirators with cartridges that protect against chemical exposures. Before buying respirators make sure your employee can wear one without causing breathing distress. One eye wash station can be put in the shop for outside more and where the employee is likely to be exposed. Generally, employee leasing companies or larger storage companies have their own safety manual to use. Every new employee should be required to read the safety manual whether they are inside or outside as chemicals that can harm can be on both locations. The manual must be signed off by the employee to prove they have been informed of the safety requirements from ladders to chemicals. If you are a supervisor, make sure to check this equipment each visit including the eye wash station. If a turnover occurs buy new safety equipment for the new employee, do not have them use previous employees equipment for obvious reasons.

Given the industry has turn over from time to time, it is imperative that each new employee is trained in safety requirements, equipment and how to label and understand chemicals. Always buy chemicals that are less hazardous and in smaller amounts. DO not have unlabeled liquids or solids laying around and no one knows what the substance is in the container. Always dispose of any unknown liquid or solid by taking to an approved hazardous chemical drop off, NEVER dump or pour down the drain. All liquids such as pest/weed control/ chemical put into another container other than what they came in, must be labeled. The rule of thumb is put enough liquid or a solid that can be used in one use instead of stored on a shelf unlabeled and ready for an accident or OSHA inspection. Never, put a chemical or solid into vessel that has been used for another use, an example, pouring a pest control liquid into a container that was used for weed killer, there may be an unknown release of a gas, explosion or burns. Although, rare, these incidents do occur and harm and kill people. Any container that has been used for any substance, should be thoroughly cleaned according to the MSDS sheet. When in doubt about any container or unknown substance dispose of properly. If employees are trained to read MSDS sheets on the hazards, first aid and chemicals being used, it will create a safer environment for all. Although sweeping a unit seems elementary, what is lying on the floor and looks dusty, is it a chemical or some other unknown? It is always a good idea for the employee to wear the respirator to make sure they stay safe while disturbing the unknown substance. The initial purchase of safety equipment can be more than the site may want to spend; however, the lack of the items mentioned will cost the site more in penalties and injuries in the long run.

Safety training should occur quarterly at the minimum or as required by the state, your storage company and insurance company. Subscribe to a safety online company for training to make sure the employee stays informed and most of all safe. Safety should always be the highest priority at the site.

Contact your insurance agent today, payroll company or a safety consultant on these matters and how to prevent employee or tenant accidents and  sleep a little easier.