Preventing OSHA 1910.151(c) Violations in Corrugated Packaging with Targeted Training

Corrugated packaging facilities face unique challenges in maintaining compliance with OSHA's emergency eyewash and shower equipment regulations under 1910.151(c). These facilities often handle hazardous chemicals and materials, making the need for immediate access to emergency equipment critical. Ensuring that all employees are trained not only in the use of this equipment but also in the procedures surrounding its maintenance and inspection is vital.

Understanding OSHA 1910.151(c) Requirements

OSHA regulation 1910.151(c) mandates that where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use. In a corrugated packaging environment, this means that eyewash stations and emergency showers must be readily accessible and fully functional at all times.

Key Training Components

To prevent violations, corrugated packaging facilities must implement comprehensive training programs. Here’s what should be included:

• Location and Accessibility: Employees must know the exact location of all emergency eyewash and shower stations. Training should include drills to ensure employees can reach these stations within 10 seconds from their workstations.
• Proper Use: Detailed instructions on how to use the equipment correctly, including the duration of flushing required for different types of exposures.
• Maintenance and Inspection: Regular training on how to inspect and maintain the equipment to ensure it is always in working order. This includes understanding the weekly activation and annual maintenance requirements.
• Emergency Response: Training on what to do after using the equipment, including first aid procedures and reporting the incident.

Implementing Effective Training

I've seen firsthand the difference a well-structured training program can make. In one corrugated plant, after implementing a robust training initiative focused on emergency eyewash and showers, the facility reduced its non-compliance rate by over 70%. The key was regular, hands-on training sessions combined with clear, concise instructional materials. Utilizing tools like our Pro Shield platform can streamline this process, ensuring all employees are trained and records are meticulously kept, but remember, the focus here is on the training itself, not the tool.

Based on available research, individual results may vary, but integrating practical drills with theoretical knowledge has proven effective across various industries. Consider incorporating third-party resources like the American National Standards Institute (ANSI) guidelines on emergency eyewash and shower equipment, which provide detailed standards that can enhance your training program.

Continuous Improvement

Safety training is not a one-time event but a continuous process. Regular refresher courses, updates based on new regulations or incidents, and feedback from employees can help refine and improve the training. Engaging with safety consultants or using safety management software can provide insights and keep your training up to date with the latest best practices.

By focusing on these key areas, corrugated packaging facilities can not only prevent OSHA 1910.151(c) violations but also foster a safer work environment for all employees.