Loading Dock/Shipping and Receiving Blitz Industrial Health and Safety Program - February, 2011
Why this Blitz? Interior and exterior loading/unloading areas of workplaces may be overlooked by both employers and MOL inspectors e.g. focus might typically be more on the primary business function is a manufacturing process Serious injuries and fatalities in these areas associated with known high-risk, cross-sector hazards e.g. falls, forklifts, etc. Loading/unloading areas found in many workplaces and most sectors
Scope One month (February 1 – 28, 2011) Target of 10 inspections per inspector Workplaces may be selected from any industrial sector Parallel Blitz will be conducted by the Health Care inspectors
Key Hazards The key hazards of this Blitz have been organized into 3 main parts to reflect the movement of materials and goods in and out of industrial workplaces: Part 1: Entry/Exit of Vehicles Carrying Materials & Goods Part 2: Positioning, Immobilization and Securing of Vehicles Part 3: Loading and Unloading Activities
Key IHSP Operational Issues – What is a loading dock? U.S. National Institute of Building Sciences describes a loading dock as “the arrival and departure point for large shipments brought to or taken from a building by trucks and vans” In the context of O. Reg. 851 s.13, IHSP considers loading docks to be the areas used for the movement of materials to and from a vehicle, rail car or vessel (in provincially regulated workplaces) where it would be impractical to have a permanently installed guardrail and the risk of falling is typically reduced by the positioning and securing of a vehicle, railcar or vessel. Other areas, even if connected to a loading dock, are not exempt Intent of s.13 is to address permanently installed features of a building that must also meet the requirements of the Ontario Building Code
Key IHSP Operational Issues – Role of MTO MTO inspects vehicles and conducts facility audits under the Highway Traffic Act (HTA) to address: adequate securing of loads for road transport Maximum load capacity for vehicles is not exceeded Transportation of Dangerous Goods (TDG) Roadworthiness of vehicles e.g. tires, brakes, floor integrity, etc. MOL may enforce WHMIS or the above hazards that relate to vehicle maintenance if they expose workers to hazards in the workplace
Part 1: Entry and Exit of Vehicles Carrying Materials and Goods Pedestrians and Traffic Hazards When would signallers be appropriate? What types of PPE are appropriate? Which workers might be in the vicinity of vehicular traffic? General Work Environment floor and ground surfaces obstructions and clearances pedestrian access to hazardous areas lighting extreme cold maintenance carbon monoxide exposures and vehicle idling policies hazardous substances
Part 2: Positioning and Securing of Vehicles Vehicles Immobilized and Secured against Accidental Movement both tractors and trailers all types of accidental movement in any direction worker training to use vehicle restraints, dock locks, trailer jacks, tire chalks, etc. Guarding and Lockout skirts and shields, vertical guard plates, sensor lights for shrink wrap stations lock out procedures for overhead doors, compactors, conveyers, balers, scissor lifts, dock levellers, dock locking systems blocking of temporarily elevated machinery or equipment e.g. overhead doors, dock plates
Dock lock – view from dock plate on warehouse floor
Empty cargo area of a trailer at a loading dock - note the lighting
Landing gear to secure trailer of truck against side to side tipping and front end collapse
Vehicle may not be secured if powered dock locking system cannot engage a rear bumper bar on smaller, lower trucks
Part 3: Loading and Unloading Activities Material Handling Equipment stacking on racks, in staging areas and in trailers/trucks records of previous near misses, injuries or orders maximum rated loads training to use equipment (including contract carriers) propane powered equipment and ventilation system PPE, eye wash stations and deluge showers storage bins with doors under pressure
Part 3: Loading and Unloading Activities cont’d MSD Hazards related to Manual Material Handling manual placement or securing of dock plates slope of truck (carrying, pushing and pulling up hill/down hill) work surfaces and transitions (forklift operation, carts) manual unloading of materials/products in the trucks (e.g. above shoulder height) Falls heights less than 3 m e.g. flatbed trucks, storage bins, storage racks, portable ramps, etc. fall protection such as guardrails on tanker trucks
Contact an engineer if not sure about maintenance of dock fixtures
SPS - Regional Ergonomists Seek assistance as needed for: Adequacy of lighting Slope of truck – push/pull forces Manual stacking above shoulder height or other manual material handling – consult ergonomist to confirm a suspected material handling risk where there is no history of injuries or worker complaints
Enforcement Options beyond Compliance Orders No new direction beyond the existing range of enforcement options outlined in the Operations Division Policy and Procedures Manual Inspectors should consult with their RPC/manager if they require assistance on pursing any of the standard enforcement options including stop work orders, Part I Offence Notices (tickets), Part I Summonses or a recommendation to prosecute under Part III of the Provincial Offences Act. Inspectors may also wish to consider the range of enforcement options available to address any repeated non-compliance in shipping and receiving areas related to the high-risk hazards addressed in previous blitzes.
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