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ABC CORPORATION ABCTOWN, TX

JULY 23RD – JULY 24TH, 2003

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Introduction

Brady Corporation, Identification Services Group is pleased to provide this Facility Marking Evaluation and On-site Product Audit to support your interest in making your facility more visually instructive. Since 1914, Brady has been providing high quality OEM, MRO and safety identification materials, resources and solutions. In addition, for over 17 years Brady’s Corporation has been providing plant marking and identification support to the industrial community as a value added service. We are a recognized leader in facility and process marking and labeling and have been involved in over 250 labeling projects. We have provided services for a wide range of customers including 3M, Solutia, Monsanto, Dupont, Proctor & Gamble, Hoechst Celanese, Sherwin Williams, Moltech Power Systems, PPG Industries, Motorola, Exxon Mobil, Georgia Pacific, International Paper, Weyerhaeuser, Phillip Morris, Shell Offshore, and others. We have gained extensive experience in data collection, engineering, installation and maintenance of plant marking and labeling solutions. This experience makes us uniquely qualified to provide you with this evaluation of your facility marking and labeling. This report may be used as a foundation in understanding what can be done to improve the pipe, tank, vessel identification, safety and general information signs throughout your facility, and as a first step toward improvement. The evaluation is based on regulatory requirements, industry standards, and good practices. As you review the suggested corrective actions and implement the recommendations in this report we are confident that the improved facility marking will serve to ensure a safer, more efficient, and more productive work place. The report provides you with documentation of the specific issues noted with photographs (when permissible) supporting the comments. The photographs may also serve as a record of the “before” corrective action status and you may wish to take “after” photos to emphasize the changes made. Suggestions on how and where to begin to upgrade your plant marking are also included. This report provides an understanding of your current marking status, a list of materials to order to get started, and a vision for future improvement. With the data provided in this report you should be able to proceed with a logical, step-by-step approach to reaching the goal of creating a more visually instructive work environment. The enclosed report provides a comprehensive review of pipe marking, safety signs, and tank and vessel signs. The review of safety signs includes general safety concerns, personal protective equipment marking, confined space marking, safety shower and eyewash station identification, plant egress route identification, and fire protection equipment identification. Additional comments may be included, which identifies potential safety or compliance concerns noted during the facility walk through. Your facility assessment includes - 1) evaluation and documentation of your existing plant marking with photographs to illustrate the “walk down notes” comments, 2) evaluation of the strengths and weaknesses of your existing labeling and marking program, 3) recommended corrective actions to improve your facility marking and become more visually instructive, 4) suggested priorities for the corrective action steps, 5) identification of the Brady contacts for further support, and 6) a comprehensive list of sign and markers needed to upgrade plant marking.

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TABLE OF CONTENTS

SECTION PAGE I. STANDARDS AND REGULATORY REFERENCES 4 II. ASSESSMENT GUIDELINES 6 III. EVALUATION AND RECOMMENDATIONS 10

Assessment Overview 10 Existing Pipe Marking Strengths and Weaknesses 12 Existing Safety Sign Strengths and Weaknesses 13 Existing Tank & Vessel Marking Strengths and Weaknesses 29 Conclusions 31 Corrective Actions and Priorities 31 Brady Corporation Contacts 33

IV. ADDITIONAL SUPPORT SERVICES AVAILABLE 33

V. ON-SITE PRODUCT AUDIT SPREADSHEET 34

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Standards and Regulatory References I. PIPE MARKING

A. ASME 13.1 (ANSI 13.1) - “Scheme For The Identification of Piping Systems” B. IIAR Bulletin 114 - “Identification of Ammonia Refrigeration Piping and

System Components” C. 29 CFR 1910.6 - “Incorporation by reference.” (ANSI 13.1) D. 29 CFR 1910.119 - “Process safety management of highly hazardous

chemicals” E. 29 CFR 1910.119 Appendix C - “Compliance Guidelines and

Recommendations for Process Safety Management (Non-mandatory).”

F. 29 CFR 1910.261 - “Pulp, paper, and paperboard mills.” G. 29 CFR 1910.262 - “Textiles.”

II. SAFETY SIGNS

General Safety Concerns A. ANSI Z535 B. 29 CFR 1910.102 - “Acetylene” C. 29 CFR 1910.103 - “Hydrogen” D. 29 CFR 1910.104 - “Oxygen” E. 29 CFR 1910.105 - “Nitrous oxide” F. 29 CFR 1910.132 - “General requirements (Personal, protective equipment)” G. 29 CFR 1910.133 - “Eye and face protection” H. 29 CFR 1910.134 - “Respiratory protection” I. 29 CFR 1910.135 - “Head protection” J. 29 CFR 1910.136 - “Occupational foot protection” K. 29 CFR 1910.138 - “Hand protection” L. 29 CFR 1910.144 - “Safety color code for marking physical hazards” M. 29 CFR 1910.145 - “Specifications for accident prevention signs and tags” N. 29 CFR 1910.145(f), Appendix A - “Recommended color coding” O. 29 CFR 1910.176 - “Handling materials - general” P. 29 CFR 1910.178 - “Powered industrial trucks” Q. 29 CFR 1910.179 - “Overhead and gantry cranes” R. 29 CFR 1910.252 - “General requirements” S. 29 CFR 1910.253 - “Oxygen-fuel gas welding and cutting” T. 29 CFR 1910.261 - “Pulp, paper, and paperboard mills” U. 29 CFR 1910.305 - “Wiring methods, components, and equipment for general

use” V. 29 CFR 1910.1001 - “Asbestos” W. 29 CFR 1910.1003 - “13 Carcinogens (4-Nitrobiphenyl, etc.)” X. 29 CFR 1910.1025 - “Lead” Y. 29 CFR 1910.1025, Appendix B - “Employee standard summary” Z. 29 CFR 1910.1030 - “Blood borne pathogens” Confined Space Marking A. 29 CFR 1910.146 - “Permit required confined spaces”

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Standards and Regulatory References II. SAFETY SIGNS (continued)

Safety Shower/Eye Wash Station Marking A. 29 CFR 1910.151(c) - “Medical Services and First Aid” Egress Marking A. 29 CFR 1910 Subpart E Appendix - “Means of Egress” B. 29 CFR 1910.37 - “Means of egress, general” C. 29 CFR 1910.38 - “Employee emergency plans and fire prevention plans” D. 29 CFR 1910.119 - “Process safety management of highly hazardous

chemicals” E. NFPA 101 - “Key Provisions"

Fire Protection Marking A. 29 CFR 1910.157 - “Portable Fire Extinguishers” B. 29 CFR 1910.158 - “Standpipe and hose systems” C. 29 CFR 1910.160 - "Fixed extinguishing systems, general” D. 29 CFR 1910.178 - “Powered industrial trucks”

Electrical Panel Marking A. NFPA 70E - “Standard For Electrical Safety Requirements For

Employee Workplaces” B. NEC 110-16 - National Electric Code C. 29 CFR 1910 Subpart S - “Electrical – General”

III. TANK & VESSEL SIGNS

A. ANSI Z129 - “Precautionary labeling hazardous industrial chemicals” B. NFPA 49 - “Hazardous Chemical Data” C. NFPA 325 - “Guide to fire hazard properties of flammable liquids, gases, and

volatile solids” D. NFPA 704 - “Standard system for the identification of the hazards of

materials for emergency response” E. 29 CFR 1910.1200 - “Hazard Communication” F. 29 CFR 1910.1450 - “Occupational exposure to hazardous chemicals in

laboratories”

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Assessment Guidelines

GUIDELINES AND KEY POINTS:

I. Pipe Marking 1. Pipes are marked in accordance with standards. 2. Labels are sized appropriately - for pipe diameter, for viewing distance. 3. Labels are installed in a neat, consistent, professional manner. 4. Labels materials are appropriate for the application. No temperature, UV, or

chemical damage. No physical damage to labels - rips, tears. 5. Labels are installed so they may be seen from the point of normal approach. 6. Pipe labels are installed:

a. adjacent to changes in direction. b. adjacent to valves and flanges. c. on both sides of wall and floor penetrations. d. at any other point of entry into the line. e. at 50-foot (max.) intervals on straight runs.

7. Label text / descriptions are matched to the correct process lines. 8. Label descriptions are adequate for the application. (“To - From” information

may be more useful than content descriptions, in some facilities.) 9. Labels are color coded in a clear, distinctive manner. (ASME 13.1) 10. Labels are color coded to distinguish between hazardous and non-hazardous

contents. 11. Pipe markers are consistently sized, color-coded, printed (text), and installed in

the various plant areas. All one program! 12. Flow direction arrows (or tape) are included on, or are adjacent to, each pipe

marker. II. SAFETY SIGNS

General Safety Concerns 1. Signs are sized appropriately for hazard identification. 2. Signs are installed in a neat, consistent, professional manner. 3. Signs materials are appropriate for the application. No temperature, UV, or

chemical damage. No physical damage to labels - rips, tears. 4. Signs are installed so they are highly visible (positioned to clearly warn against

potential accident or injury). 5. Sign text is appropriate to the application. 7. Pictograms and symbols are used consistently and appropriately. 8. Signs are color coded in accordance with ANSI Z535.1 - “Safety Color Code” 9. Safety Signs are consistently sized, color-coded, printed (text), and installed in

the various plant areas. All one program!

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II. SAFETY SIGNS (continued) General Safety Concerns 10. All safety concerns are properly identified -- visually, clearly.

Note: Color Codes Danger - red Warning - orange Caution - yellow General Safety - green Notice – blue

Confined Space Marking 1. Danger Signs are used to mark confined space entry points. 2. Signs are sized appropriately for hazard identification viewing distance. 2. Signs are installed in a neat, consistent, professional manner. 3. Signs materials are appropriate for the application. No temperature, UV, or

chemical damage. No physical damage to labels - rips, tears. 4. Signs are installed so they are highly visible even when the access port is open

(positioned to clearly warn against potential accident or injury). 5. Sign text is - "Danger: Permit Required Confined Space, Do Not Enter" or

similar language appropriate to this application. 7. Pictograms and symbols, if used, are used consistently and appropriately. 8. Signs are color coded per ANSI Z535.1 - “Safety Color Code” 9. Confined Space Signs are consistently sized, color-coded, printed (text), and

installed. All one program!

Safety Showers/Eye Wash Station Marking 1. Signs are installed so they are highly visible and the stations are painted

consistently (either yellow or green) with clear area floor marking (positioned to clearly identify locations for quick access in case of emergency and to remind personnel to keep the area clear of any obstructions).

2. Signs are sized appropriately for viewing distances (i.e., must be seen clearly from some distance, should "stand out").

3. Signs are installed in a neat, consistent, and professional manner. 4. Signs materials are appropriate for the application. No temperature, UV, or

chemical damage. No physical damage to labels - rips, tears. 5. Pictograms and symbols, if used, are used consistently and appropriately. 6. Signs are color coded in accordance with ANSI Z535.1 - “Safety Color Code” 9. Signs for each application are consistently sized, color coded, printed (text),

and installed. All one program! 10. All showers and eye wash stations are marked!

Egress Marking 1. Exit signs are sized appropriately to comply with regulations. 2. Signs are installed in a neat, consistent, professional manner. 3. Signs materials are appropriate for the application. No temperature, UV, or

chemical damage. No physical damage to labels - rips, tears.

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II. SAFETY SIGNS (continued) Egress Marking 4. Pictograms and symbols, if used, are applied consistently and appropriately. 5. Emergency escape route signs are used as part of the Emergency Action Plan. 6. Emergency escape route signs use floor plans or workplace maps to clearly

show emergency escape routes. 7. Color coding is used on the emergency escape route signs to aid employees in

determining their route assignments. 8. All exits are marked by "readily visible signs" which are "distinctive in color" . . .

"provide contrast with decorations, interior finish, and other signs. 9. Access to exits are marked by readily visible signs and directional arrows in all

cases where the exit or way to reach it is not immediately visible to the occupants.

10. Doors that are not exits, but could be confused as exits are marked as "Not An Exit", or identify specific room or area on other side of door.

11. Exit signs are not covered or view blocked by "decorations, furnishings, or equipment" nor are there brightly illuminated signs, displays, or objects tha t distract from the exit sign so that it may not be noticed.

12. Internally illuminated exit signs are provided where reduction of normal illumination is permitted.

13. Exit signs have 6" letters with a minimum 3/4" stroke width. Fire Protection Marking 1. Signs are installed so they are highly visible and at in-plant mounting locations

there are red painted backgrounds and floor clear areas (positioned to clearly identify locations for quick access in case of emergency and to remind personnel to keep the area clear of any obstruction).

2. Signs are sized appropriately for viewing distances (i.e., must be seen clearly from some distance, should "stand out").

3. Signs are installed in a neat, consistent, and professional manner. 4. Signs materials are appropriate for the application. No temperature, UV, or

chemical damage. No physical damage to labels - rips, tears. 5. Pictograms and symbols, if used, are used consistently and appropriately. 6. Signs are color coded in accordance with ANSI Z535.1 - “Safety Color Code”. 7. Signs are installed to readily identify all fire protection equipment for emergency

response, and preventive maintenance purposes. (Fire hoses, extinguishers, alarms, standpipes, valves, detectors, panels, etc.)

8. Signs for each application are consistently sized, color coded, printed (text), and installed. All one program!

9. Warning or caution signs are posted inside, and at all outside entry ways into areas protected by fixed extinguishing systems that use agents in concentrations known to be hazardous to employee health and safety. (CO2, Halon, etc.)

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Electrical Panel Marking 1. Electrical panels are marked with voltage levels preferably with an orange label. 2. All electrical panels or transformers with 600 volts or greater nominal voltage

rating are marked with “Danger – High Voltage” or similar signs. 3. Disconnect switches are marked with the load that they disconnect especially if

remotely mounted. 4. Requirements for special protective clothing are posted on entry doors to

MCC/Switchgear rooms or on the MCC/Switchgear in accordance with NFPA 70E.

5. MCC/Switchgear breakers are labeled to identify the load they isolate or supply. 6. MCC/Switchgear panels are marked with “Arc Flash” warning labels. 7. Lighting and electrical distribution panels are identified and the individual

breakers are marked with the load supplied. 8. Electrical panels and distribution equipment are marked in a clear, consistent

manner throughout the facility. 9. Safety related electrical marking is color coded in accordance with 29 CFR

1910.145 III. TANK & VESSEL SIGNS

1. All “containers” containing hazardous materials are labeled. 2. Tank & Vessel signs contain the following information:

• Identification Number • Name or description • Content hazards, including the – 1) chemical name, 2) target organs, and 3)

chronic and acute health and physical hazards 3. Signs are installed in a neat, consistent, professional manner. 4. Sign materials are appropriate for the application. No temperature, UV, or

chemical damage. No physical damage to labels - rips, tears. 5. Signs can be viewed from all approach points. (For large tanks spanning more

than one level - mark at each level and in multiple locations as needed.) 6. Labels are installed on all hazardous chemical “containers”, except those

portable containers only for the immediate use of the employee making the transfer.

7. Tank & Vessel Signs are consistently sized, color-coded, printed (text), and installed. All one program!

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Evaluation and Recommendations I. ASSESSMENT OVERVIEW:

A. On-site Meetings, Interviews, and Walk Through

On July 23rd and July 24th, 2003, Brady Corporation Identification Services Department personnel evaluated your facility with specific regard to safety and general information signs and markings, pipe marking and tank and vessel marking. Two workdays were required for the “on-site” audit and interviews. Additional time, equaling approximately three workdays, was required to compile the information and generate the formal report. Day one on-site began with a short pre-audit briefing and agenda discussion. The purpose of the briefing was to receive instruction on the ABC Corp. safety rules and to provide a concise overview of the Brady evaluation methods and on-site requirements for the assessment. After the briefing an ABC Corp. employee served as escort and tour guide providing an initial plant orientation tour. The detailed assessment walk down and evaluation of the areas of concern began at approximately nine AM. Safety sign and tank data was collected for all outside areas, south addition and main building south to north plant areas. Day one on-site ended at approximately four PM. Day two on-site resumed the assessment walk down at eight-ten AM. Completed safety sign and tank data collection for the remaining plant areas at about ten AM. Evaluation of plant pipe marking was completed for all plant areas at approximately three PM. Held an exit briefing with the Plant Manager at about three fifteen PM and discussed safety issues and provided an overview of assessment report topics. The day two portion of the on-site assessment was completed at approximately three thirty-five PM. Contacts List: John Doe – Manager Facility/Manufacturing Engineering

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B. General Notes

There were several specific safety issues that should be corrected. Some of those issues are listed below:

1. Portable fire extinguishers are required to be “located, mounted and identified” and many were neither located mounted or identified. Ensure that all fire extinguishers have a specifically designated location, that they are mounted and not sitting on the floor or nearby equipment and that each has an identification sign. In addition, recommend painting red backgrounds and floor clear areas for each mounting location to make them “stand out” from the surrounding environment.

2. Recommend adding large signs on the outside of the buildings and structures to ensure that off-site emergency response teams can quickly and easily get to the proper location in the case that offsite emergency response is required.

3. Identification and marking of confined spaces are incomplete! 4. Safety shower and eye wash stations should have identification signs added

and should be painted to “stand out” from their surroundings. The floor should be painted to identify a clear area to help keep parts and materials clear of safety showers.

5. Switchgear and MCC’s need “arc flash” markings in accordance with NEC 110.16 and NFPA 70E.

6. The housekeeping program is good overall. However, there are some areas where reminder signs could support the existing program – especially in the warehouse, electrical compartments, water treatment, gas compressor building and other peripheral buildings, etc.

7. Pipe marking is a compliance issue only for the piping carrying hazardous substances and that piping should be marked to satisfy the process safety management guidelines. Recommend complete pipe identification and marking for efficiency and error reduction purposes.

8. Found compressed gas bottles tied off with electrical wire or in other cases not tied off at all. Recommend chain or heavy-duty wire for tying off gas bottles to prevent a possible missile hazard; or round up and remove the old construction gas bottles.

9. Exits were generally well marked. However, some backlit EXIT signs were replaced with non-backlit signs and the new sign installations appear to be temporary in some cases.

10. Emergency lights are “on” in the upper elevations of the stairwells. The general area lighting is on also. Recommend trouble shooting and testing the emergency light circuits to ensure that they will work properly in case of a loss of all AC.

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C. Facility Labeling (Scale) -

(5) (4) (3) (2) (1) Excellent Good Fair Poor Very Poor……. q q q q q

|ááááááááááááááá Assessment Category Rating Value* Pipe Markers 3

Safety Signs

General Safety Concerns 4 Confined Space Marking 1 Safety Shower / Eye Wash Stations 3 Egress 4 Fire Protection Marking 4 Electrical Panel Marking 3

Tank & Vessel Signs 1

Average Overall Rating 2.88 Rating = "Poor"

*Quantifying Assessment Ratings Definitions: Rating Value Very Poor - little or no marking done, or misleading marking 1 Poor - Some marking done, not complete/haphazard, not maintained 2 Fair - evident effort put forth to some degree, need for marking recognized and acted on 3 Good - well marked, but needing fine tuning or minor revisions or additions 4 Excellent - well marked, no significant changes or additions required 5

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Evaluation and Recommendations I. PIPE MARKING

Program Strengths: _ Plant management and personnel at the ABC Corporation facility have recognized the

need for pipe identification and marking and the utility piping has been marked to varying degrees depending on the plant area.

Program Weaknesses: _ The facility pipe-marking program was evaluated for conformance to the ASME A13.1-

1996 standards and utility piping identification, in most cases, does not meet the standard (i.e., wrong or inconsistent color coding, sized too small for pipe diameter, various types – stick-on, wrap around, missing in some locations, etc.)

Recommended Corrective Actions: a. Using the attached spreadsheet order or fabricate utility pipe markers that comply

with the design requirements of the ASME standard. b. Install pipe markers that are of a consistent style, are properly sized, correctly

color-coded and are installed at regular intervals in accordance with the ASME standard.

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Evaluation and Recommendations II. SAFETY SIGNS

Program Strengths: _ General Safety Concerns

1. Good safety signs and markings have been installed to identify many potentially hazardous situations. Examples include: Eye Protection Required signs, Hazardous Waste Accumulation Site signs, Danger No Smoking signs, Dock Bridge Plate signs, Trash Compactor Warning signs, etc.

2. Compressed gas cylinders were generally well marked and taken care of from a safety perspective: • As a rule, cylinders are legibly marked to identify the gas contained and are

located or stored in areas where “they will not be damaged by passing or falling objects or subject to tampering by unauthorized persons”. 29 CFR 1910.1200(f)(5); .101(b); .103(b)(1)(i)(c); .110(c)(2)(i); .103(c)(2)(iii)(f)

• Generally, compressed gas cylinders were located or stored in a manner to prevent them from creating a hazard by tipping, falling, or rolling. 29 CFR 1910.101(b); .102(a)

• Valve protectors (caps) were in place when cylinders were not in use. 29 CFR 1910.119(b); .110(c)(6)(iii) & (iv): .111(e)(5)

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Program Strengths: (continued) _ Safety Shower/Eye Wash Station Marking

1. Some of the eye wash stations were readily identifiable in case of emergency. 2. Eye wash stations were readily accessible in many cases. 29 CFR 1910.151(c)

_ Confined Space Marking N/A

_ Egress Marking 1. Exits are well marked at the doorways with backlit EXIT signs. Signs are visible

and unobstructed and the letter sizes are 6” or greater with a character width of ¾” per OSHA regulations. 29 CFR 1910.37(q)

2. For the most part exit doors were not blocked and egress routes were generally unobstructed allowing personnel a safe exit route in case of emergency. 29 CFR 1910.36(d)(1); 37(q)

3. Main production and central warehouse floors are somewhat marked to identify aisles. 29 CFR 1910.22(b)(2); .176(a)

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Program Strengths: (continued)

_ Fire Protection Marking Fire extinguisher mounting locations are established and extinguishers are permanently mounted in most cases. 29 CFR 1910.157(c)(1)

_ Electrical Distribution Panel Marking N/A

_ Other Safety Marking 1. Original Equipment Manufacturer (OEM) safety markings are good on many of the

utilities and production machines. Safety instructions, identification of “Pinch Points”, and other safety concerns on the individual machines are well marked in many cases. Examples: Air Compressors, Fab Machines F01 – F09, Air Handling Units on the roof, Expedite Area Equipment A01 – A09

Program Weaknesses: _ General Safety Concerns

1. Compressed gas cylinders should be well marked and taken care of from a safety perspective: • Cylinders should be legibly marked to identify the gas contained and should be

located or stored in areas where “they will not be damaged by passing or falling objects or subject to tampering by unauthorized persons”.

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Program Weaknesses: (continued)

29 CFR 1910.1200(f)(5); .101(b); .103(b)(1)(i)(c); .110(c)(2)(i); .103(c)(2)(iii)(f) • Compressed gas cylinders must be located or stored in a manner to prevent

them from creating a hazard by tipping, falling, or rolling. 29 CFR 1910.101(b); .102(a)

• Valve protectors (caps) must be kept in place when cylinders are not in use or connected for use. 29 CFR 1910.119(b); .110(c)(6)(iii) & (iv); .111(e)(5)

Recommended Corrective Actions:

2. “Caution - Safety Glasses Required” signs are installed on several of the entry

doors into the production area. These signs are missing on some doors but are needed to identify the appropriate protective equipment required for entry to the production floor and various operating areas. Signs should be posted at the personnel entry doors and at the entry to areas requiring special PPE. Example: safety glasses required signs – at entries to the main production floor,

hearing protection signs – at the air compressor room entries, etc.

Recommended Corrective Actions: a. Order or fabricate PPE signs per attached audit list. b. Install consistent safety signs as required to support personnel and equipment

protection. c. Document safety signs installed in such a way that replacements may be

purchased or fabricated again, if needed in the future.

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3. Hand-written, magic marker, and computer printout paper signs are used in many locations. Generally, handmade or computer printout signs are worded poorly, are not easy to read, are black text on white background (or are Xerox copies) causing them to recede and not stand out, and are mounted in poor locations or by inadequate means. 29 CFR 1910.145; ANSI Z535.1 – 5

Recommended Corrective Actions: a. Provide the site with a means to print custom signs on the spot. *{The Brady

Globalmark or Powermark System should be used for this purpose. Custom safety signs from 4” to 10” wide can be created on-site at your facility and paper signs become unnecessary.}

b. Require that facility and contractor personnel not use hand made, home made, computer printout, or copied safety signs.

4. The battery charging area needs additional safety signs, to provide clear direction

regarding safe work practices in this potentially hazardous work area, and must be kept clear of clutter or debris. 29 CFR 1910.178(g)(1) - Battery charging installations shall be located in areas

designated for that purpose. 29 CFR 1910.178 (g)(10) - Smoking shall be prohibited in the charging area. 29 CFR 1910.178 (g)(11) - Precautions shall be taken to prevent open flames,

sparks, or electric arcs in battery charging areas.

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29 CFR 1910.133(a)(1) - The employer shall ensure that each affected employee uses appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation.

Recommended Corrective Actions: a. Fabricate and install “Battery Charging Area”, “Caution - Eye Protection

Required …”, “Danger – No Smoking …”, etc. signs at each charger location per attached audit lists.

b. Clear storage and clutter out of battery charging areas. c. Paint a defined area for battery charging operations and maintain areas clear.

5. Housekeeping is a problem in some areas of the ABC Corporation facility. Proper

housekeeping practices are vital to safe and productive plant operations. The OSHA Labor Regulations reference proper housekeeping as a safety requirement in over twenty chapters. For Example: 29 CFR 1910.22(a)(1) - All places of employment, passageways, storerooms, and

service rooms shall be kept clean and orderly and in a sanitary condition. 29 CFR 1910.22(a)(2); .141(a)(3) - The floor of every workroom shall be

maintained in a clean and, so far as possible, a dry condition. Where wet processes are used, drainage shall be maintained, and false floors, platforms, mats, or other dry standing places should be provided where practicable.

29 CFR 1910.38(b)(3) - "Housekeeping." The employer shall control accumulations of flammable and combustible waste materials and residues so that they do not contribute to a fire emergency. The housekeeping procedures shall be included in the written fire prevention plan.

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Recommended Corrective Actions: a. Establish a daily routine of cleaning and organizing all work and storage areas.

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b. Ensure that all potential fire hazards are removed or stored properly (e.g., aerosol cans at column N-12 should be in nearby Flammable Storage Cabinet).

c. Using 5S principles visually identify locations for production equipment, carts, tools, etc. Then store items in their designated locations.

d. Post housekeeping reminder signs at or near work areas and in problem areas to encourage a culture of routine housekeeping maintenance.

e. Post signs assigning housekeeping responsibility / “ownership” of individual areas to specific plant personnel.

6. Currently outside buildings are not identified. It is a good practice to clearly

identifying major buildings and areas with large highly visible signs to be seen from the roadway. This should be done to support and aid emergency response personnel in case of a site emergency where outside help is required.

Recommended Corrective Actions: a. Order large durable signs (fiberglass for best durability). b. Install signs for easy location of buildings by fire department personnel.

7. Storage or potential storage areas above office and restroom areas should either

be identified as “No Storage” or floor load limit signs should be installed indicating the maximum safe loading for the storage area. 29 CFR 1910.22(d)

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Recommended Corrective Actions: a. Order or fabricate signs. b. Install signs as needed to identify “No Storage” areas or load limit posting.

8. Safety signs are inconsistent on the entry doors to the various booths throughout

the facility. Color-coding and sign headers should be appropriate for the level of warning required for the application. 29 CFR 1910.145

Recommended Corrective Actions: a. Use signs with a header or “signal word” to capture immediate attention to

identify potential consequences if proper PPE is not used.

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b. Order or fabricate consistent signage for all entry doors for any given booth. c. Replace inconsistent signs or missing signs.

9. Bench grinders and other power equipment should have safety reminder signs at

the machines to remind production and maintenance personnel to wear the proper PPE and to observe the safety precautions appropriate to the specific machine. In addition bench grinders are required to be set a specific tolerances for safe operation and most of the grinders observed were out of specification. 29 CFR 1910.215(a)(4) Work rests. On offhand grinding machines, work rests shall

be used to support the work. They shall be of rigid construction and designed to be adjustable to compensate for wheel wear. Work rests shall be kept adjusted closely to the wheel with a maximum opening of one-eighth inch to prevent the work from being jammed between the wheel and the rest, which may cause wheel breakage. The work rest shall be securely clamped after each adjustment. The adjustment shall not be made with the wheel in motion.

29 CFR 1910.215(b)(9)”…the distance between the wheel periphery and the adjustable tongue or the end of the peripheral member at the top shall never exceed one-fourth inch.

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Recommended Corrective Actions: a. Order or fabricate consistent signs with correct color-coding and a header or

“signal word” to capture attention and remind personnel to wear proper PPE and to take appropriate safety precautions for the equipment in use.

b. For bench grinders it is a good practice to install signs reminding machine operators to check and set adjustments prior to each use.

c. Install signage in conspicuous locations at or near the machinery.

_ Confined Space Marking 1. Tanks and vessels, and all other spaces with limited access and presenting a

potential safety hazard to personnel entering the space, should be marked with a “Danger - Confined Space” warning sign at each entry to the confined space. The CFR does allow for “other equally effective means” of informing employees of the existence, location and danger posed by permit - required confined spaces. However, information at the point of need should be the preferred method of keeping employees informed and reminded of confined space entry dangers and permit requirements. 29 CFR 1910.146(b), (c)(2) Examples: Cooling Tower, Diesel Fuel and Motor Oil Storage Tanks, Compressed Air Receiver, etc.

Recommended Corrective Actions: a. Identify all confined spaces in the facility. b. Install danger signs at access points to warn and remind employees of the

hazards. _ Safety Shower/Eye Wash Station Marking

1. Some plant locations do not have eye wash stations within easy reach in case of emergency. In other locations the eye wash stations are blocked and not readily accessible in case of emergency. Safety showers and eye wash stations are required “within the work area for immediate emergency use” where employees are exposed to injurious corrosive materials. 29 CFR 1910.151(c); .1048(i)(3) Examples: No Eye Wash At - 1) Pre-Treat Booth Chem. Add Station, 2) Pool 18

Battery Charging Station, 3) Receiving Area Battery Charging Station, 4) Chiller Chem. Add Station

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Recommended Corrective Actions: a. Add safety showers and eye wash facilities as required for employee protection

and safety. b. Install locator signs. c. It is a good practice to paint backgrounds behind each of the eye wash stations

to ensure that they stand out from the general plant environment and are easily identifiable.

d. It is a good practice to paint 36” clear areas in front of the eye wash stations to remind plant personnel not to block access to the station and to ensure that the station is easily reachable in case of emergency.

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Program Weaknesses: (continued) _ Egress Marking

1. Egress paths are blocked, at some Exits, by material or equipment storage and clutter. In some cases aisles and walkways have materials stored in them partially blocking the paths. Exit doors must not be blocked and egress routes must not be obstructed to ensure that personnel always have a safe exit route in case of emergency. 29 CFR 1910.36(d)(1); 37(q)

Recommended Corrective Actions: a. Clearly mark aisles and walk ways – preferably with durable paint to

accommodate the traffic demands on the surface. b. Install signs to remind plant personnel, including forklift drivers, to keep aisles

clear at all times. 2. Emergency Action Plan assembly areas (outside the building) are not marked.

Recommended Corrective Actions: Clearly identify the assembly locations for plant personnel in case a fire or other emergency situation requires evacuation of the building.

_ Fire Protection Marking

Employers are required to “mount, locate, and identify” portable fire extinguishers “so that they are readily accessible to employees without subjecting the employees to possible injury”. For human factors reasons it is best to identify all portable fire extinguisher locations in a consistent manner. 29 CFR 1910.157(c)(1)

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Recommended Corrective Actions: a. Fire extinguishers must be mounted and not sitting on the ground. b. All fire extinguishers must be kept in their mounting location.

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c. It is good practice to identify fire extinguisher mounting locations with a red painted background for immediate recognition/high visibility – to stand out from their surroundings. For marking columns the red background should be painted all the way around the column to be seen from all directions.

d. Another good practice is to provide a visual reminder to plant personnel not to block the fire extinguishers. To accomplish the visual marking the fire extinguisher mounting locations should have a clear area painted or marked off in front of them (36” clear space recommended).

e. Fire extinguishers must be mounted so that they are readily accessible and not blocked in by other equipment or storage.

_ Electrical Distribution Panel Marking

1. Certain electrical panels are required to have “Arc Flash” warning labels or signs. NEC 110-16 “Electrical switchboards, panel-boards, industrial control panels, and motor control centers that are likely to require examination, adjustment, servicing, or maintenance while energized, shall be field marked to warn qualified persons of potential electric arc flash hazards. The marking shall be located so as to be clearly visible to qualified persons before examination, adjustment, servicing, or maintenance of the equipment.”

Recommended Corrective Actions: Install “Arc Flash” warning labels on MCC/Swgr per attached audit list.

2. Electrical panels are blocked or access is partially limited by storage and clutter in

some cases. NEC 110-16, 370-19, 384-2; 29 CFR 1910.303(g) “Sufficient access and working

space shall be provided and maintained about all electrical equipment (especially panel-boards, safety switches, distribution boards, and motor control centers) to permit ready and safe operation and maintenance.”

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For Example:

Recommended Corrective Actions: a. Install signs on electrical panels to remind plant personnel to keep areas clear

near panels. b. Mark a floor clear area of at least 36” around each electrical panel (Swgr.,

MCC, distribution panel, equipment disconnects, etc.), to provide a visual reminder to facility personnel to keep electrical panels clear of all obstructions.

c. Instruct facility personnel to keep all electrical panel areas clear.

3. Bus duct disconnect switches are not identified with the load they supply, and that load is generally not immediately apparent. 29 CFR 1910.303(f) Identification of disconnecting means and circuits. Each

disconnecting means required by this subpart for motors and appliances shall be legibly marked to indicate its purpose, unless located and arranged so the purpose is evident. Each service, feeder, and branch circuit, at its disconnecting means or overcurrent device, shall be legibly marked to indicate its purpose, unless located and arranged so the purpose is evident. These markings shall be of sufficient durability to withstand the environment involved.

Recommended Corrective Actions: Identify bus duct disconnects with their respective loads – to support safe, efficient maintenance and operations.

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4. Approximately ten (10) electrical boxes/receptacles are improperly supported in the Alignment, Expedite, and Door Buildup – Cabinet Prep areas. Electrical wiring methods must meet National Electrical Code specifications. • NEC 370-13 states that all boxes and enclosures must be securely fastened. • Maximum support intervals for non-metallic sheathed cable are 4 ½ ft. and 12

in. from box or fitting per NEC 336-15; and for non-metallic extensions the maximum support intervals are 8 in. per NEC 342-7(a)(2).

Recommended Corrective Actions: Reinstall receptacles using properly support rigid conduit.

III. TANK & VESSEL SIGNS

Program Strengths: N/A Program Weaknesses: _ The Diesel Fuel and Mobile Motor Oil storage tanks are not identified. At a minimum

the tank should have signs that identify the hazardous chemical contents and the appropriate warnings of the physical and health hazards - for employees “Right-To-Know”. 29 CFR 1910.1200(f)(5), Appendix E - 4.A Note: The NFPA color code and number may be used to indicate the hazard

warnings. However, many employees will not know or remember what the hazard levels or categories are if asked by an auditor. A more “user friendly” sign works hand-in-hand with safety training and acts as a constant visual reminder about existing chemical hazards.

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Evaluation and Recommendations III. TANK & VESSEL SIGNS


Recommended Corrective Actions: a. Define an acceptable layout for tank and vessel hazard information / “right-to-

know” signs. b. Order / fabricate signs that will stand up to the environment in which they are

used.

Sample Tank Signs:

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Evaluation and Recommendations: IV. CONCLUSIONS:

An overall rating of poor was given to the current labeling and marking of the ABC Corporation facility. This rating was assigned using the method as noted in the “Assessment Overview” section above. The poor rating was assigned as a result of the current status of plant marking. Upgrades to the current sign program are recommended and consistency should be emphasized when marking safety issues from one plant area to the next. The corrective actions should be reviewed thoroughly and a consistent, conservative facility-marking upgrade program should be implemented.

As a first step toward creating a visually instructive plant, management should perform a thorough, methodical review and evaluation of each of the suggestions included in this report. The evaluation should include a decision making process with recommended steps as follows:

1) Determine whether or not to take action on each suggestion provided, 2) Review recommended action steps and decide if the recommended actions or

other options are best for the facility, 3) Create a plan of action to implement the recommendations, 4) Evaluate the cost to implement the recommendations, 5) Budget for the action steps, and 6) Set up a tentative schedule of implementation.

Some actions may be as simple as 1) ordering consistent designs of the appropriate pre-made signs and labels, or 2) purchasing do-it-yourself labeling machines that will produce the required signs, tags, and labels, and 3) notifying personnel, through safety training and other appropriate communications, that they are expected to use the standardized signs. In other cases it may take a more involved approach to correct certain non-compliance or safety problems. Each weakness or problem area should be evaluated carefully to determine the specific actions best suited for your facility.

V. CORRECTIVE ACTIONS AND PRIORITIES:

A. Recommended Corrective Actions: 1. For individual action steps see the “Recommended Actions” immediately following

each item identified in the section above. 2. The following action steps and support service options are recommended steps to

bring the facility up to Visually Instructive Plant standards for safety signs, pipes and tanks:

Order prefabricated signs, tags and labels based on the attached On-site Product Audit Spreadsheet.

- Or -

Using the make-it-yourself method, fabricate signs, tags and labels on-site utilizing the Brady Labeling Systems - Power Mark™, Globalmark™, and Handimark™

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Evaluation and Recommendations: V. CORRECTIVE ACTIONS AND PRIORITIES: (continued)

B. Priorities: From an overall labeling program view, priorities should be determined first, by the most urgent actions to be taken to ensure personnel and equipment safety needs are met. Then, the weak or problem areas that are not in compliance with regulations should be corrected. Finally, consistency and productivity issues should determine the next general level of priorities. With this basic logic in mind, the plant labeling and marking areas are listed in the suggested order of upgrade and correction: Priority Category

1 Safety Signs • Confined Space Marking • General Safety Concerns • Safety Shower/Eye Wash Station Marking • Exit & Evacuation Marking • Fire Protection Marking • Electrical Panel Marking

2 Pipe Markers 3 Tank & Vessel Signs

• Right-To-Know Information • Tank & Vessel Identification

Since safety marking and identification relates directly to personnel and equipment safety, all safety sign marking should be a priority. All facets of facility marking for safety are high priority and markers should be purchased or fabricated and installed as soon as practical. The utilities and process systems pipe marking in the various areas of the ABC Corporation facility should be upgraded to conform to the ASME A13.1-1996 standards. The Diesel Fuel Oil and Mobile Engine Oil Storage Tanks should be clearly marked with signs that provide employees with easy to read “right-to-know” information about all hazardous chemicals and personnel hazards. In addition, production and maintenance tasks may be made more efficient by clearly identifying the storage tanks with the tank number and name as identified on design drawings.

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Evaluation and Recommendations: VI.BRADY CORPORATION CONTACTS

Services Project Manager Territory Manager James T. Gables (Jim) Ms. Jane Doe 3816 Snow Creek Drive 210 Appletree Drive Aledo, TX 76008 Houston, TX 50189 Phone/Fax: (817) 560-0279 Phone: (123) 955-9555 Voice Mail: (800) 895-8080, ext. 3539 Voice Mail: (800) 895-8080, ext. xxxx Email: [email protected] Email: [email protected]

Additional Support Services Available:

Graphical Lockout Procedure Services With Graphical, “machine specific” Lockout Procedures, you can eliminate wasted time and maximize your maintenance and operations teams productivity. The most time-consuming and difficult requirement of the LOTO standard is the documentation of the procedures/steps necessary to lockout every piece of equipment in your facility. Brady’s engineering group has developed a suite of tools that coupled with the experience of writing over 15,000 procedures, allow us to create the procedures faster. These visually instructive procedures have been reviewed by OSHA and meet and exceed their expectations as defined in CFR 1940.47. The visually instructive procedures will allow authorized employees to quickly, confidently and safely establish a state of zero energy within a piece of equipment that is completely under control. The Graphical Lockout Procedure Service includes written procedures, machine analysis, graphics/placards creation, placard and isolation point tag fabrication, installation and “zero energy state verification” as needed to support your individual requirements. Contact Brady's Identification Services Team to learn more about how our Graphical Lockout Procedure Services can enhance your required plant Lockout/Tagout program.

Brady’s Identification Services Team

(800) 496-4040

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AUDIT DETAILS

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