Many of you are aware of my passion for working with carriers to identify problem drivers and develop team-based solutions for improving safety management systems. In fact, this column is frequently devoted to issues such as driver training, performance monitoring, fatigue management and incident management.
But every once in awhile something completely different catches my attention. This month, I'd like to talk about shop safety policies for welding and cutting.
There are lots of things on a truck that require “a little heat” or other “innovative” repair measures. Let's take trailer spring replacement as an example. Typically, we spot broken, cracked or missing spring leafs during preventive maintenance inspections. While mechanics are pretty careful about lifting and blocking the trailer body, other safety steps are overlooked during spring replacement.
Mistakes often happen when mechanics try to loosen those pesky U-bolts, which secure the spring to the trailer axle. They generally reach for the 3/4-in. impact wrench to loosen the frozen or rusted nut. When that fails (as it typically does), they reach for what's known as the gas axe, green wrench or cherry bomb, i.e., an acetylene torch with a large rosebud tip, to heat the offending nut till it turns cherry red. The nut may yield to the wrench, but not without a shower of sparks or red-hot particles flying around. Similar fireworks can occur when you grab the MIG welder to repair a broken mud-flap bracket or under-ride protection device, otherwise known as an ICC bumper.
It's these firework displays that led our friends at OSHA to establish the “Welding, Cutting, and Brazing” standards, which are defined in 29 CFR Parts 251-255 (Subpart Q). These standards require fire protection, personal protective equipment, health protection and ventilation. Based on what we've seen, most maintenance shops should study these rules, which are posted on the agency's web site, www.osha.gov. The National Fire Protection Assn. also makes recommendations (Standard 51B-1962).
Are you aware that the OSHA rules require an inspection and evaluation of precautionary measures, preferably in the form of a written permit, prior to authorizing any cutting or welding? At a minimum, that means you need to designate one area of your shop as safe for such operations and obtain a written permit that documents your evaluation.
The evaluation should answer these questions:
Can the work be avoided?
Can the job be moved to a safe area where the “hot” work can be performed?
Are fire protection systems in working order, and are they capable of suppressing any fire that could arise?
The OSHA standards also require cutters and welders, as well as their supervisors, to be “suitably” trained in the safe operation of their equipment and safe use of the process.
Do yourself and your employees a favor. Take a walk around your shop and identify the locations where welding and cutting operations typically take place. Are these activities confined to one designated bay or wherever the heat is needed? Remember that government rules require a 35-ft. safety zone around the work area. This means an area free of combustible liquids, dust and debris.
Next, find out whether anyone has prepared a written document that satisfies the permit requirements in 29 CFR 1910.252 (a)(2)(iv). Finally, ask if anyone can document the training requirements in subparagraph (xiii)(C) of that rule.
All too often we've seen complete ignorance of these issues — until an accident happens. Once someone is yelling “fire” or, worse yet, a deadly explosion occurs, it's too late. The resulting damage could cripple your operation or alter the lives of your employees.
Jim York is a senior risk engineering consultant at Zurich Insurance, Fredericksburg, Va.