Unpacking Common Mistakes with 1910.66(f)(5)(v)(D) in Pharmaceutical Manufacturing

In pharmaceutical manufacturing, precision is paramount—not just in the products we produce, but also in the safety measures we implement. One area where I often see companies struggle is with compliance to OSHA's 1910.66(f)(5)(v)(D), which addresses intermittently stabilized platforms, specifically building face rollers.

Let's dive into the specifics. This regulation states that intermittently stabilized platforms must be equipped with building face rollers that maintain a continuous contact with the building face. The purpose is to ensure stability and prevent potential falls or equipment damage during operations.

Common Misinterpretations

One frequent mistake is the assumption that any type of roller will suffice. In my experience, I've seen companies use rollers that are not designed to maintain continuous contact, leading to hazardous conditions. The regulation is clear: the rollers must be specifically designed for this purpose.

Another common error is neglecting regular maintenance and inspection of these rollers. I recall a situation where a pharmaceutical plant had not inspected their rollers for over a year, resulting in a near-miss incident when a roller failed during use.

Best Practices for Compliance

To stay compliant with 1910.66(f)(5)(v)(D), consider the following best practices:

• Select the Right Equipment: Ensure that the building face rollers are designed to maintain continuous contact with the building face. Consult with equipment manufacturers to verify compliance.
• Regular Inspections: Schedule routine inspections of all intermittently stabilized platforms and their components. Document these inspections meticulously.
• Training: Provide comprehensive training to all employees who operate or work near these platforms. Emphasize the importance of equipment integrity and safety protocols.

Based on available research, individual results may vary, but implementing these practices can significantly enhance safety and compliance in your facility. Remember, the goal is not just to meet the regulation but to foster a culture of safety that protects your workforce and your operations.

Additional Resources

For further reading and to deepen your understanding of OSHA's 1910.66 regulations, consider the following resources:

• OSHA's official guidelines on powered platforms for building maintenance.
• The National Institute for Occupational Safety and Health (NIOSH) publications on fall prevention in the workplace.