In our competitive environment, every manufacturer struggles to do more with less and to find capital for “nonproduction” areas, such as maintenance, safety, training, housekeeping and HR. If done in a shortsighted fashion, the employer learns through painful experience the sacred law of “unintended consequences.” Plant Engineering magazine (yes, a lawyer can read such stuff) ran a brief instructive story on harm to production and profits resulting from gradually shifting almost all maintenance functions to production employees. You’re probably thinking that “I wouldn’t do that,” but many employers have eliminated certain housekeeping workers and relied upon production employees to clean up their area or machine. One of the contributing factors to the deadly Imperial Sugar combustible dust explosion was accumulation of material in work areas … in part because operators were supposed to clean up after their shift, and did not do so.
I have linked to an Interview by the good folks at Chem.Info.com, an excellent publication and provider, especially for food processors and related businesses.
We represented construction employers at the 2008 Port Wentworth Sugar Plant (Imperial Sugar) explosion and both before and since that explosion, we have handled many combustible dust matters in food processing, wood and paper, coal products, plastics, foundries and for numerous other manufacturers. Combustible Dust compliance remains one of the most understood and most dangerous of safety compliance areas. For more information on the Imperial Sugar explosion, which remains highly instructional, go to the Savannah Daily News archived special coverage
Let’s continue our discussion of employer “Willful” behavior. OSHA can be inconsistent in its application of the classification, and it is often up to the employer to establish the distinction between “serious” and “willful” behavior during and after an OSHA inspection.