The dynamics of food manufacturing, from regulations to supply chains and labor shortages, present continuous challenges. A risk assessment program identifies opportunities for operational efficiency by lowering the likelihood of an unplanned event as well as the expenses that could result from it. Reduced insurance premiums, increased goodwill and being prepared for the unexpected are three returns on such an investment.¹
Ranking the risks
Risk assessments utilize predictive analytics by scoring the known hazards and their likelihood on a basic 5x5 heat matrix.
Although there are multiple methods to quantify and rank the scores in a risk ranking, the color coding of green, yellow and red for escalating risk rankings provides quick visual information on where to prioritize. Ideally, the tasks would be simplified and scored on their basic movements or steps, allowing for each at-risk action to be assessed. Tasks ranked 0-10 require little to no intervention. Tasks ranked 11-15 require additional controls, which usually follow the hierarchy of controls in order of preference. When the score is 16-25, the risk requires even more controls to address the hazard or gaps in controls and is generally prohibited or exceptionally rare, requiring extensive precautions and controls.
Companies in the food manufacturing industry can apply controls to mitigate hazards and get closer to the “zero score,” which indicates that the hazard has been removed. One smart way for companies to improve their score is to migrate tasks that have a high impact on their risk ranking from engineering controls led by humans to controls that are not human-dependent for functionality. Administrative controls such as procedures, documented instructions and safety training have less effect on scoring. Lastly, personal protective equipment (PPE) gets the least weight for reducing severity scores depending on its design and function for the intended hazard.
Consider, for example, the environmental services team’s preparation of chemicals and equipment for decontamination. First, score the basic task of mixing chemicals without any controls in place — no ventilation equipment, no splash guards, no pumps, no operating procedures, no training, no safety data sheets and not a single piece of PPE. Alternatively, consider the same scenario with all the controls in place. With increased controls, there is a decreased likelihood and severity of an unplanned event.
A comprehensive risk view of all levels of hazards, including natural, manufactured and technological hazards, needs to be considered in risk assessment task planning. Areas with vulnerabilities that can be found during risk assessments within food manufacturing include building construction, raw food materials, hazardous energy from machinery and processes, process byproducts or wastes, and end products. Start by considering hazards according to OSHA’s most frequently cited standards within food manufacturing, including lockout/tagout (LOTO), machine guarding, powered industrial trucks (PITs), process safety management of highly hazardous chemicals and wiring for general use.
Potential hazards in the food manufacturing workplace
Employees in the meat and food processing industries face numerous workplace health and safety hazards regulated by OSHA: slips, trips, falls, musculoskeletal disorders and machine-related injuries. Between October 2018 and September 2019, OSHA issued a total of 1,168 citations resulting in $7,171,513 (USD) in fines to the food manufacturing industry.3
When LOTO is not performed on machines or energy sources, employees can face injury or death by falling into or being pulled into machinery, getting struck by moving components or electrocution. The release of stored energy and/or the unexpected operation of equipment during maintenance or other activities that require de-energization injures or kills hundreds each year. From 2003 to 2013, 28 fatalities and 227 serious injuries (such as amputations) stemmed from LOTO procedures in food manufacturing, with the largest number of incidents occurring in meatpacking and poultry slaughtering and processing.4
LOTO programs should undergo regular audits for compliance or potential improvements. The risk assessment process for machine-specific LOTO procedures not only identifies risk, but can also serve to audit the LOTO program for improvement opportunities while documenting regulatory requirements.
General machine requirements include the use of machine guarding through permanently attached or removable machine guards. These guards work to reduce hazards present during machine operation from moving parts, spraying or splashing chemicals, dust and flying chips, high-intensity light, noise, vibration, pressure, electrical shock hazards, and areas that are hot or cold to the touch. Removing guards is tempting for equipment that requires frequent access. However, that convenience negatively affects risk ranking scores. When scoring on the heat matrix, consider the risk assessment of having machine guarding in place versus its removal while the equipment is operating.
PITs, including forklifts, enable employees to efficiently move materials and products that are too large or heavy to move by hand. As a powerful tool for workplace logistics, PITs come with their own hazards related to unsafe operating practices that can lead to injury or death. Risk assessments for PITs start with deference refueling or charging, PIT weight and lifting capacity, load securing and moving, traffic hazards, and safety features. Aligning the preventative maintenance schedule with the manufacturer’s recommendation improves efficiency and lowers downtime by addressing issues before they impact operational efficiency and safety.
How to increase workplace health and safety
To help promote workplace health and safety, OSHA issued the Process Safety Management (PSM) of Highly Hazardous Chemicals standard (29 CFR 1910.119), which contains requirements for the management of hazards associated with processes using highly hazardous chemicals. A PSM program provides a plan of action that identifies, evaluates and prevents or mitigates chemical releases that could result from the failure of procedures, processes or equipment. PSM helps manage against catastrophic outcomes of events related to special hazard chemicals such as bulk refrigerant gases and chemicals associated with on-site water and wastewater treatment processes typically found across the food industry sector. Each employee must receive PSM training that includes safety and health hazards, applicable safe work practices, and emergency operations, including shutdown. Documented refresher PSM training should take place at least every three years. Failure of an employer to comply with the PSM standard can result in significant penalties. In addition to scoring individual tasks within PSM-scoped activities, scoring can also apply to the 14 program elements of process safety management to quantify regulatory risk.
All stages of food production present a contamination risk. Facilities must use materials and products that provide effective sanitization at acceptable exposure levels. Every task in the decontamination cycle can be assessed for a risk assessment score. From source to disposal, every stage presents a quantifiable risk that can have actions assigned for improvement. By evaluating multiple controls for risk reduction potential and relative cost, operations may wisely choose where to apply scarce resources for maximum benefit.
Audits provide a mechanism to measure the risk assessment effectiveness of worker adoption of the supplied controls in place. Risk assessment planning provides a road map for creating operational efficiency while proactively managing risks.