Appendix C
OSHA-Day Verification Visits

In 2011 Michigan OSHA conducted five OSHA-Day Verification visits at OSP participating facilities. 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 that the verification visits were performed.

Dearborn Tool and Die Plant; Dearborn, Michigan; February 28, 2011

Data Collected: The site performed an analysis of their injury and illness data and has identified the five most prevalent types of injuries and the top five body parts affected by them. It is clear that a focus has been made on these issues as between 2009 and 2010 the site realized a reduction in numbers of all but one of these types of injuries.

On site Observations: Three machine guarding issues in different locations of the plant were observed. One occurrence of a missing mid-rail in a guardrail system was observed on a working platform. The absence of this mid-rail results in a possible fall hazard. Lastly, one flammable liquid storage and dispensing container had not been electrically grounded and bonded.

Site Best Practices: The verification team reported that more workers in this facility have been provided training as first responders, as had in previous years. This expands the site's abilities to provide response in case of an emergency.

Opportunities for Improvement: Guarding of machinery and equipment was listed as an opportunity for improvement.

Michigan Assembly Plant; Wayne, Michigan; April 12, 2011

Data Collected: The verification team did not collect enough data for comparisons to be made. The Michigan Assembly Plant had only been operational from January 2011 to the verification visit in April 2011. Previous years' data was not presented as prior to January 2011 the plant had been named the Wayne Assembly Plant. The team felt there were enough differences that the injury and illness data from the Wayne Plant could not be compared to that of the Michigan Assembly Plant.

Note from Evaluator: For the purposes of this OSP annual evaluation, OSHA used three full years of data from this location including those years where the plant would have been designated as the Wayne Assembly Plant. No distinction was made by Ford when the data was provided that a separation was necessary due to the plant being considered a "new" facility.

On site Observations: This is the first verification visit conducted at Michigan Assembly now that the plant is in full production:

Hearing Conservation: A noise assessment including monitoring should be conducted to determine if employees may be exposed to noise levels that equal or exceed the action level as required by Part 380. If levels equal and/or exceed the action level, it is recommended that the appropriate provisions of Part 380 be developed and implemented.
- Follow-up procedures should be developed and implemented for employees whose audiograms show they have experienced a standard threshold shift (STS) in their hearing.
- There are employees on the 300 log that have a STS. If the STS is less than 25 decibels below audiometric zero at 2000, 3000, and 4000 hertz, it is not recordable and should not appear on the log.
- We recommend that Parts 11 and 380 be reviewed to ensure proper procedures are developed and implemented with regards to STSs and/or record keeping procedures.
Air Monitoring: Employees were doing spot repair in the paint department. Air monitoring needs to be conducted for paint solvent vapors. Ventilation should be assessed since strong solvent vapors were noted in the area. Michigan Assembly has scheduled air monitoring later in the week of the verification visit.

Site Best Practices: Prior to the retooling, Michigan Assembly had cement floors and used anti-fatigue mats to reduce the impact when employees worked for long periods standing on the cement floors. Although this is a common practice, Michigan Assembly recognized that the ant-fatigue mats were creating an on-going maintenance issue and were actually creating strains and sprains for employees. Consequently, during the renovation, Michigan Assembly looked at this as an opportunity for improvement and removed the mats. Wood flooring was installed which eliminated the strains and sprains from sticking to and tripping over the mats, and allowed for a floor surface that gives relief from a cement floor while being easy to maintain.

Opportunities for Improvement: Continue to examine workplace and work flow to determine if repetitive motion injuries can occur. For example, examine how the fastener bits are removed and attached to pneumatic fasteners in the trim department. This area appeared to have potential for repetitive motion issue(s).

Dearborn Diversified Manufacturing/Dearborn Stamping; Dearborn, Michigan; June 29, 2011

Data Collected: Injury and Illness rates and other measures were provided for a three year period from 2008 to 2010. Although the numbers of hours worked at this facility have remained fairly stable, both the TCIR and DART rate have increased. No casual factors for these increases were provided by the site.

On site Observations: The walk around observations included references to four instances where machine guarding was missing or not functional. Additionally, three minor electrical anomalies were observed.

Site Best Practices: The site report described three best practices this facility uses to impact the workers' safety and health experiences.

PPE: The site has designated specific areas as "100% PPE Zones." These areas of the facility (zones) are marked with signs or floor paint and employees have been provided information that all standard PPE is required to be worn in those areas at all times. The site reports that this BP has been effective in reducing the number of lacerations experienced by the workers.
Ergonomics: As part of their ongoing ergonomics program the site has integrated a Job Rotation Plan that is based on analysis of muscle groupings used to perform jobs in these areas. Employees can be rotated to a job function or an area where they would use different muscle groups thereby reducing or eliminating the strain on different parts of the workers' bodies.
Heat-Related Illness: The site installed two ice machines in areas of the plant readily accessible to workers. This will assist in reducing the potential for workers to experience heat stress or heat related illnesses.

Opportunities for Improvement: The verification team provided two recommendations based on their audit.

Reporting: Workers need to be reminded of the importance of reporting ALL incidents as well as, to report them as soon as they occur.
The verification team has recommended that a system be established that will better identify areas of the facility where the roof is prone to leaks.

Livonia Transmission Plant; Livonia, Michigan; August 17, 2011

Data Collected: Injury and Illness rates and other measures were provided for a three year period from 2008 to 2010. While the TCIR and DART rates are either declining or remaining stable, the calculated Severity Rate has steadily increased. This increase is reflective of a greater number of lost work days and days with restricted activity per incident.

On site Observations: The primary observations were those related to single instances of machine guarding issues in various locations of the plant.

Site Best Practices: The verification report identified the following as BP implemented by the site.

Machine Guarding: The employer is developing and implementing a system to improve machine guarding. This system will track the guarding placement and use of all new machinery from the time that it is installed through the use of the machine. This plant will be using this system. Machine Guarding - Firm has established a "PROTAG" or new equipment buy off program to monitor new machines from installation to production to ensure all hazards are controlled or eliminated.
Ergonomics: Company has formed a Local Ergonomics Committee (LEC) to review all job tasks and job task changes to ensure that jobs are fitted to the employees.

Opportunities for Improvement: An issue in need of improvement was identified as follows:Cable clamps used to support overhead equipment put together in reverse order or referred to as "putting the saddle portion of the clamp on the dead end of the cable" making the connection not as strong as recommended by the manufacturer of the saddle clamps.

Sheldon Road Plant; Plymouth, Michigan; October 12, 2011

Plant Enforcement Background for 2011: Two complaints were filed and addressed.

September 29, 2011 - MIOSHA Enforcement initiated an inspection in response to an employee complaint concerning ergonomic issues. At the time of the verification visit the inspection had not yet been closed.
May 27, 2011 - The site received a letter complaint (d-letter or non-formal complaint) related to carts, recording injuries and illnesses, and ergonomics. On July 24, 2011 the site submitted a letter of response to MIOSHA in response to the alleged complaint issues.

On site Observations: The two most notable site observations were:

Hearing Conservations and Noise Control: Location: Column M4 - A "Hearing Protection Required" sign was mounted in this area. However, employees were not wearing hearing protection at the time of the verification visit. The site has a hearing conservation program (HCP). Recently, a plant sound level survey was conducted and should be used to update areas/jobs to reflect where hearing protection is required. Any non-applicable signage should be removed. Employees with eight hour time-weighted average (TWA) noise exposures that exceed permissible exposure limits must be trained and required to wear hearing protection.
Chemical Safety Training (Hazard Communication): Location: Cab Furnace - About every five years the furnace muffle (lining) needs to be replaced. The muffle is made of stainless steel and comes in two separate pieces that must be welded together. This job takes a full day to complete. Initial personal air monitoring must be conducted to assess employee exposures to hexavalent chromium the next time the furnace muffle is replaced.

Site Best Practices: Two BP used ta this site are as follows:

Noise Reduction: The site has implemented a "Buy Quiet" program to assure that equipment brought into the plant does not generate noise levels above 80 dBA. Employees visit equipment suppliers to take noise readings and assess compliance with this < 80 dBA requirement before the equipment is shipped to the plant. Also, the site switched to using DC electric tools instead of pneumatic screw guns in some areas; which resulted in decreased noise levels.
- Ergonomics: The Company ensures that ergonomic incidents and experiences from one department are shared with other departments that have similar work activities. For example:
- The company noticed a prevalence of ergonomic incidents in one particular location where employees stack materials on racks. Other areas, with similar work activities, were evaluated to identify root-causes of the problem. It was identified that employees working in the area were sustaining ergonomic injuries by pulling empty racks with one hand, instead of using balanced approach of two hands.
- Various engineering modification have been made with ergonomic considerations such as magnetic tools for retrieving screws; this minimizes frequent bending.
- Employee rotation is done and lines are re-evaluated whenever improvement changes are made.
- Supervisors in the plant are expected to report any ergonomic related incidents to the on-site ergonomic contact to be addressed.
- The on-site ergonomic contact works a flexible weekly schedule so she can come in on off shifts whenever needed.
- Risk assessment software tools are used to see if a given job should be adjusted to accommodate an employee. Even if the risk assessment software indicates a job is set up within recommended guidelines, efforts are made to address any employee who is symptomatic.
- On-going training on proper work practices is conducted with employees at their respective workstations.
- When new employees are transferred in from other plants, both HR and safety review medical records to assure the employee will not be placed on a job that could aggravate a pre-existing condition.
- The plant has a full time physical therapist on-site to assist with helping employees return to work and also to determine appropriate work restrictions.
- There are currently no open employee ergonomic cases open beyond six months.

Opportunities for improvement: The one opportunity for improvement noted in this summary follows:

Locations of Emergency Stop Cables: Non-accessibility
- Location - Heater Core 85 40 - The emergency stop cable for the roll form machine is at approximately 6 feet 1 inch from floor level. Part 26 Metalworking Machinery SOP states that the feed rolls are to be protected by a stop cable that can be activated by the body. In order for the body to make adequate contact with the cable, the cable should be between the knees and shoulders of the average individual. This is how MIOSHA enforcement would determine if the height of the cable was acceptable. Currently, an employee's body may not contact the emergency stop cable at 6 feet 1 inch while being pulled into the machine. Ensure that a re-evaluation of this emergency stop cable is conducted and it is subsequently relocated.
- Location - CAB 11 G - The emergency stop cable for the oven conveyor is inadequate. This cable is positioned above shoulder level and does not cover all access into the oven.