(This article first appeared in the May-June 2017 issue of The American Postal Worker magazine.)
By Maintenance Craft Directors
The Lehigh Valley Processing & Distribution Center was issued a fine of nearly $100,000 by OSHA for extensive “willful” safety violations. OSHA found the $99,630 violation willful because the Postal Service failed in their “ongoing responsibility [to] ensure the adherence to the machine specific procedures to affect the necessary energy control for each system component.”
More specifically, OSHA charged a violation of 29 CFR 1910.147(d)(2) because “the machine or equipment was not turned off or shut down using the procedures established for the machine or equipment.” Those procedures are contained in the Electrical Work Procedures Maintenance Management Order (MMO) and machine specific Energy Control Procedure MMOs, such as MMO 037-15, which applies to the Automated Package Processing System (APPS).
A ‘Running’ Example
Reportedly, the Postal Service required repair work on the induct line of an APPS machine while the equipment was running.
The Maintenance Division sent out information earlier to the field about a safety issue on the APPS. It was highlighted in a Safety Bulletin, sent as MMO 069-08, dated July 3, 2008. This was necessary because, as the title of the MMO said, there could be an unexpected startup of the induction belts under certain conditions.
These conditions involved maintenance work and the bulletin warned that, “To prevent personal injury or death, the following precautions are to be followed…” The bulletin continued with four bullet points outlining the safety issues and the statement that USPS Engineering and the vendor were working on a solution.
By April 26, 2010, management issued MMO 039-10, rescinding the prior MMO regarding the unexpected start-up of the induction belts. After the unexpected start-up problem was fixed, specific safety procedures were listed. These included admonitions to not defeat an interlock switch without authorization, to stop the machine before opening any access door and to follow the prescribed safety procedures. Other requirements included that auto induction lane 1 should be stopped prior to entering and working in the area. This was to prevent the risk of personal injury beyond the interlock controlled induction area access gate.
Unfortunately, local management wanted our mechanics and technicians to perform maintenance functions on the auto inductions lane inside the APPS while the machine was running. Local management believed that the Maintenance Technical Support Center (MTSC) in Norman, OK supported their position.
Thankfully, a rightfully concerned mechanic contacted the local union, resulting in consultation and information from the Maintenance NBA and headquarters Maintenance Division officers.
As a reminder to all, you can find further information on the Hazardous Energy Control Program (Lockout) in MMO 033-05 and the Electrical Work Plan in MMO 023-13. The document which “establishes policy and requirements for an electrical work plan (EWP)” is Management Instruction (MI) EL-810-2013-5.
All the documents listed here should be available locally.
Safety is Serious Business
It should be obvious that safety is its own reward. Following the sometimes inconvenient procedures required ensures your own safety and health, providing the best chance of avoiding injury at work. It is easy to engage in a kind of gallows humor about how the employer will put the bottom line ahead of individual well-being, but safety is serious business.
Employers are serious about cost avoidance, and we must be serious about enforcing our rights to a safe and healthful work location and procedures. Rushing to shortcut things is NOT in the best interests of anyone, employer or employee. The extra time and cost, if any, necessary to perform your duties in a safe and effective manner is an investment for which the reward is not being injured or killed.
Our sincere thanks go to the officers and members of the Lehigh Valley, PA Area Local and to Vice President Chris Day for swift and appropriate action. We hope and trust that the citation for a repeated and willful violation, with a hefty monetary cost, will deter the Postal Service from putting us at risk. But, to ensure our own safety, we must, as the members did in Lehigh Valley, insist on enforcement of the safety and health rules.