First Aid or Recordable

First aid is not a recordable. Recordables are injuries that
require treatment beyond first aid.’

by Miles Free III

Director of Industry Affairs, PMPA

Published November 1, 2024

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Does your company treat all first aid incidents as recordables? Do you require that every dispensed bandage or pain reliever be reported to management? Should you? As a former plant manager, I have had to deal with decisions like this. Given our commitment to continuous improvement, it is obvious that we should want to track first aid incidents so that we can address and eliminate their causes.  But that does not mean escalating them to, or treating them as, recordables.

The first thing to do is to recognize that first aid is different from a recordable. Recordable events involve any medical treatment required beyond first aid. Thus, it follows that “mere first aid” is not recordable. If you feel it necessary to have your employees report even first aid incidents to you, that is your discretion. But first aid is not recordable.

How does OSHA define first aid?
First aid refers to medical attention that is usually administered immediately after the injury occurs and at the location where it occurred. It often consists of a one-time, short-term treatment and requires little technology or training to administer. First aid can include cleaning minor cuts, scrapes, or scratches; treating a minor burn; applying bandages and dressings; the use of non-prescription medicine; draining blisters; removing debris from the eyes; massage; and drinking fluids to relieve heat stress. OSHA’s revised recordkeeping rule, which went into effect January 1, 2002, does not require first aid cases to be documented (bit.ly/PMPA-PM1124a).

OSHA has posted a First Aid List on its recordkeeping page (bit.ly/PMPA-PM1124b):

• Using a non-prescription medication at non-prescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes);
• Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment);
• Cleaning, flushing or soaking wounds on the surface of the skin;
• Using wound coverings such as bandages, band-aids, gauze pads and so on; or using butterfly bandages or Steri-Strips (other wound closing devices such as sutures, staples and so on are considered medical treatment);
• Using hot or cold therapy;
• Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts and so on (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes);
• Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards and so on);
• Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister;
• Using eye patches;
• Removing foreign bodies from the eye using only irrigation or a cotton swab;
• Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means;
• Using finger guards;
• Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes); or
• Drinking fluids for relief of heat stress.

These are classified as first aid by OSHA, and so they are not recordable. If they do not need to be recorded, why do you need them to be reported? You have the authority and discretion to insist that any and all such incidents be reported to management. Or not.

How does OSHA define a recordable injury or illness?

• Any work-related fatality;
• Any work-related injury or illness that results in loss of consciousness, days away from work, restricted work or transfer to another job;
• Any work-related injury or illness requiring medical treatment beyond first aid;
• Any work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth and punctured eardrums;
• There are also special recording criteria for work-related cases involving: needlesticks and sharps injuries, medical removal, hearing loss and tuberculosis.

A good rule to use — and I used this when I was plant manager at a steel mill —  is if the application of the first aid required another person to provide it, management needs to be informed as soon as possible. The reasoning is that if it was so serious that it required assistance, management had a duty to know. And, to ensure that blood-borne safety protocols, washing and cleaning are taken to protect the person providing assistance as well as the person needing first aid. It also helps management help the team find and eliminate the root causes for the need for first aid in the
first place.

So as long as you and your team are able to distinguish between first aid versus more serious recordables, I think that we can all, in good conscience, relax the “report every bandage or pain reliever dispensed” requirement. Let’s focus on the significant few, not the trivial many.

Author

Miles Free III is the PMPA Director of Industry Affairs with over 50 years of experience in the areas of manufacturing, quality and steelmaking. Miles’ podcast is at pmpa.org/podcast. Email Miles

Do You Have Single Points of Failure?

Plans need to be in place before a catastrophic event occurs.

by David Wynn

Director of Technical Services, PMPA

Published October 1, 2024

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The CrowdStrike event showed how having a single point of failure (in this case, a coding mistake) can have cascading effects. Services of companies worldwide were halted until issues could be resolved. We are in no-fail industries, so it begs the question … Do you have single points of failure in your shop?

Failure
Failure can come in many forms. Production can stop in a shop due to running out of coolant, lost tools or late arrival of raw materials. All these are failures that affect one job or one machine that can be remedied. We can always try alternate tooling. Jobs can be moved to another machine. Parts could even be made from larger diameter material for expedited production. They are not catastrophic single points of failure because contingencies are already in place. At the very least, solutions can be found quickly.
However, an event that takes days, weeks or longer to recover from is considered catastrophic. Solutions may not be readily apparent, so when catastrophic events occur, plans need to already be in place; plans that were communicated to all parties involved to get mission-critical processes moving.

Power Outages
Power outages can stop production. Do you have alternate sources of power in case of emergency? Companies use battery backup on electronics all the time. Have you ever thought about using them on a machine? A small power outage for just a few minutes can interrupt production across a shop. The air compressor needs to be restarted. All the machines and bar loaders must be reset. If machines were in the cut, they must be carefully backed out and restarted. There might even be scrap associated with the outage, because a machine was in the middle of an operation that can’t easily be restarted — I am thinking of threading. Who is responsible for restarting the shop during a power outage? Is there a procedure? What happens if this outage continues for days or weeks? I know of a member shop whose area was devastated by a tornado. They were first told that the power would be out for a month. Fortunately, this shop already had a plan in place to rent a large generator from a local electrician. Luckily, power was restored within a week, but what would have happened if they did not have a plan?

Equipment
Our equipment can fall into this category as well. Think about having only one of a top-of-the-line Swiss machine running critical parts. What happens when that machine is down? Parts cannot be shipped to the customer because of this single point of failure. Having at least two of every machine is the best solution; however that is not always economically feasible. At least have an alternate process to produce parts until the machine can be repaired. It is better to make production doing three operations than to fail our customers. It is important to have contingencies on all aspects of producing parts down to having alternate outside vendors. What if a plater has a massive fire? Are there other vendors pre-production approval processed and ready to fill the void?

Physical Plant
A shop could be a single point of failure in and of itself. Are there backup plans to serve customers if a catastrophic event destroys the building and equipment? For instance, a tornado, hurricane or earthquake could prevent a shop from operating for months. How will the customers be served during this time? Do you have backup suppliers that can fill the void until production is up and running?
Planning for disaster is important. Hopefully, we never have to use the plans. If there are no plans for disaster, high-pressure scenarios can result in fatal failure. Build plans around the worst-case scenarios. Know what to do when an event happens. Building out disaster plans gets to the root of what our FMEA process should look like. Go out and build real FMEAs that have actionable solutions.

Author

David Wynn is the PMPA Director of Technical Services with over 20 years of experience in the areas of manufacturing, quality, ownership, IT and economics. Email David

Domain Mastery for Mastering Change

What are the positions on your team’s roster to ensure that you win the game of ‘change?’

by Miles Free III

Director of Industry Affairs, PMPA

Published October 1, 2024

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I just wanted to do my job, but they closed the plant and used dynamite on the blast furnace at which I worked. I just wanted to report the daily iron production, but then they made us do it using a computer. The list of changes over my career is endless.

After 50 years in the steel and manufacturing business, I continue to be amazed at the rate of change. Change continues to accelerate throughout the economy, our markets and our technology. And sadly, every steel plant that I ever worked at physically has been shuttered. The steel industry did not do change very well. Here are some thoughts so that our precision machining shops do not repeat the experiences of my former employers.

Regulatory Change
When I first started at U.S. Steel, in an iron ore screening station in Youngstown, Ohio, the PPE available included a respirator authorized for use by MSA (Mine Safety Administration.) That was because there was no OSHA (Occupational Safety and Health Administration) at the time. OSHA was signed into law in December of 1970, and was enacted in April of 1971. In 1970, there was no OSHA requirement or standard for PPE. Today, OSHA enforces nearly 1,000 standards. In 2023, OSHA charged American businesses over $132 million for violations of just the top 10 most-cited regulations.
Who is the master of the domain of Occupational Safety and Health compliance in your shop? What is their budget to continuously improve their understanding, knowledge and ability to minimize the risk of an OSHA violation in your operation? Where can they go to get industry focused resources to level up your shop’s compliance?

Technology Change
When I first started calling on shops in the precision machining industry, the technology universally employed was cam automatic bar machines. I needed to be knowledgeable about how the additives or treatments in the steel my company made contributed to the successful machining of parts. I also needed to understand my customer’s operations if I was going to be an effective advocate for our steel and a problem solver in their shop. The first “emergency claim” that put me on a same day flight to the customer. Our premium free machining steel was wearing a groove into the side of the form tool being used by our automotive customer. Fortunately, I knew that the side of the form tool shouldn’t be doing the cutting, and I was able to help my customer. My knowledge of the steel domain would have been insufficient, but knowing how the customer’s equipment functioned — or more correctly, was supposed to function — enabled me to lead their problem solving.
Who on your team is the domain master for how your customer uses the components that you produce? Who on your team is the domain master for the sourcing of materials and the implications for your operation if that sourcing changes ? Where can they go to stay current besides making another customer or supplier visit?

Technology Change, Part II
Today, while cam automatic machines continue to be one method of producing high-precision, high-volume parts, there are a host of different technologies using computer numerical controls (CNC) rather than cams. Machines that can handle multispindle, high-volume production. Machines that might do turning, milling and rotary transfer, as well as offer a host of different ways to present tools to generate features including sub-spindles, synchronized sub-spindles, B-axis and Swiss technology — some of which now add laser capabilities on machine.
Who is your domain master for each and every one of these machining domains, and yes, where do they go to get the latest information to stay current and understand where those capabilities are headed? Attending the Precision Machining Technology Show every other year is one way, but what else is available?

Market Change
When I started serving companies in the precision machining space, the single largest market was for turned parts for automotive. Mostly hose fittings, but also parts for fuel and brake systems as well. These parts were produced primarily on multispindle cam automatic bar machines, typically using free machining materials. There is still a role for these machines and these parts, but today, more shops that I visit are using CNC turning and CNC Swiss machines to produce sophisticated parts for medical, dental, firearms and electronics applications. And the growth in automotive is in new components from non-free machining materials for electric vehicles. Leaded steels, once the mainstay of our production processes, are no longer melted here in North America.
Our current domain knowledge is not enough. Just “doing the job” is no longer sufficient. All the domains are changing. Our jobs are changing as well. This means that the skills and abilities of our performers need to change.
Do you have a process for helping your people stay current and get ahead with changes in the technology that they use and the markets they serve? Do you have a process or pathway to grow the expertise you need in critical but non-production domains such as safety, regulatory, HR and IT/cyber systems and security? Quality requirements are becoming more challenging as well. A failure in any one of these areas could result in penalties and reputational damage that could cause the loss of your business.
PMPA is proud to provide programming and speakers at our various meetings and through webinars, podcasts and other deliverables to help shops identify challenges and find resources to help meet those challenges. Is your firm taking full advantage? Do you have a cadre of up and comers that are actively “changing their game” to keep your shop up to date with all of the changes? Or are you going to wait until the crisis arrives and then improvise? Or try to find and hire expensive outside expertise? Anticipation is the greatest value of management. How is your shop anticipating? Managing? What is your plan for developing the people to lead you through the inevitable change that is on its way?

Author

Miles Free III is the PMPA Director of Industry Affairs with over 50 years of experience in the areas of manufacturing, quality and steelmaking. Miles’ podcast is at pmpa.org/podcast. Email Miles