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Bill Taylor, CSP
Principal Safety Scientist
Being a long-time woodworker, I was always a big fan of Norm Abram and his show, The New Yankee Workshop. One thing you could always count on was Norm, before powering up a table saw or any other shop equipment, would implore his viewers to “be sure to read, understand and follow the safety instructions that come with your power tools.”
It doesn’t make any difference what the equipment is; forklift, aerial lift, scissor lift, hard hat, respirator, etc., manufacturers all advise potential users to read the instructions that accompanied the equipment.
And yet, getting folks to actually read the manual often proves difficult. The rock band Van Halen was notorious for their oddly specific concert riders. For instance, the band had a disclaimer that no brown M&M candies were to appear backstage in their dressing room as a way to prove whether or not anyone actually had read through their demands.
Consensus standards such as ANSI A92.6 (self-propelled scissor lifts) always require the operator’s manual be stored on the lift. OSHA’s logging standard at 1910.266(f)(1)(ii) and (g)(3) state “Operating and maintenance instructions must be placed in all machines and vehicles and followed by the operator and mechanics.” The implication is that in order for operators to follow the instructions, they must be familiar with them and this is achieved by reading them.
Or take a look at the welding standard at 1910.254(d)(6) which states, “Printed rules and instructions covering operation of equipment supplied by the manufacturers shall be strictly followed.” This means the manual that came with your arc, MIG or TIG welder has been incorporated by reference and thus is law. If the owner is unable to produce the manual because it has been lost, they could be cited. If the users are not following the instructions stated within the manual, the employer could be cited. Now, this may not seem like such a big deal except that most manuals provide similar instructions. For instance, a typical manual for an arc welder states the owner shall replace any missing or illegible instruction or warning stickers on the machine every three months. That implies the owner must inspect the condition of stickers on welders once per quarter. Further, the manual will also state the owner shall vacuum or blow dust out of the cabinet every six months. When was the last time your maintenance workers cleaned dust from inside the arc welders?
Operator instructions should be considered an integral part of any training. Is it reasonable to expect workers to sit down and read the instructions? Sometimes yes. Sometimes no.
Since training is required for virtually any equipment used by employees, a good way to improve operator understanding and satisfy requirements to read instruction manuals is to include vital information contained in manufacturers instructions in the training presentations.
Bill Taylor, CSP serves as a Principal Safety Scientist with The EI Group, Inc. and has over 40 years in the safety industry. If your facility is in need of OSHA compliance consulting, please do not hesitate to contact him at ( 919) 459-5249 or btaylor@ei1com.