Dealing with Administrative and Work Practice Controls
The next level of controls to prevent exposure to hazards is administrative and work practice controls, which are procedures, plans and policies that employers put in place.
“Social distancing, for example, would be an administrative control, because you tell people according to policy, they can’t get within 6 feet of somebody else,” Hody says.
However, even with protective administrative and work policies in place, employers can't always control an employee who decides to stray from the rules.
“The reason that administrative and work practice controls are less effective than engineering controls is that people don't have to necessarily listen or follow your procedures,” Hody says.
“Accountability is key, so once you put a procedure in place and appropriately train your employees, you have to hold people accountable to make sure that they are following the procedures,” he adds.
Read more: Best Practices for Reopening Safely After COVID-19: What Manufacturers Need to Know
The COVID-19 safety procedures at Joe Gibbs Racing include several administrative controls, and according to Bringle, every employee has to sign off on this guidance before being allowed back to work.
For example, to get into the building, employees must be listed on the schedule. Then they must go through a screening process, have their temperature taken, and answer questions about their health and exposure to the virus. None of the break rooms, conference rooms or workout rooms are open, and employees are urged to bring in their lunch and eat at their workstations or outside (but within the fence).
“Once you’ve entered the building, you're required to wear a mask and there are sanitation stations and COVID-19 signs reminding everybody of the code of conduct all over the building,” Bringle says. “Internally, we've set up all of our workstations so that there's as much distance in between each person as possible, and everybody's required to stay at their machine or workstation.”
The company also changed to a 12-hour, four days on, four days off schedule, partly to keep up with a heavy racing schedule, but also to reduce some of the COVID-19 hazard.
“Normally, we'd have a first and second shift in the CNC department, so you'd have one person coming in, then later a second person come to run machines in that same area, so that would be a greater risk of transmitting disease,” Bringle says. “But this way, only one person works the same area for four days, and then our janitorial staff does an extensive cleaning of that area, so that when that second group comes in, everything's totally sanitized.”
The Use of PPE Controls
On the hierarchy of controls for preventing workplace hazards, the least effective method is the last line of defense: using personal protective equipment, or PPE.
For protection against COVID-19, PPE can include gloves, face shields and N95 respirators.
Essentially, it’s anything a person puts on and wears to protect themselves, Hody notes.
According to the Centers for Disease Control and Prevention, N95 FFR respirators can filter out airborne particles, including the COVID-19 virus. However, an N95 respirator with an exhalation valve does not provide the same level of protection because the valve allows unfiltered exhaled air to escape.
Technically speaking, cloth face masks are not true PPE, according to Hody.
“The cloth mask is not really there protecting you, but it’s protecting others from you if you are shedding the virus but don’t know it,” Hody explains.
“So, the requirement to wear them is more of an administrative policy control that businesses put in place to protect everyone in the building.”
Social Distancing in a Machine Shop
Recently, a large machine shop asked Hody for ideas on ways to keep 6 feet of separation between employees. On his advice, the shop is now mandating that a person works the same piece of equipment every day, rather than possibly spreading the virus across other equipment.
“That way, if someone tests positive for COVID-19, you can almost contact trace employees because you know that ‘Bill’ was assigned to CNC machine 5,” he says. “Then, maybe once you do a deep cleaning, you can switch him up to work, say, Grinder 3, so that he doesn't get bored.”
The shop also has broken down its large number of employees into smaller work groups to further help with hazard control.
“If you have morning meetings, it’s easier to social distance in a smaller group, and if an employee tests positive, you hopefully can contain that spread, and makes it easier to narrow it down where the infection came from,” Hody says. “And since you know which machine that they were on, you can specifically clean that machine and it helps you contain everything better.”
What unique challenges have you faced as you reopen your shop? How have you managed them?
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Who do you think is gonna work under these bullshit agenda democrat conditions, everyone will quit working!!!
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