Feature Article


MIOSHA Collaboration: An Investment Caster's Experience


by Bob Johnson, Shellcast, Inc.


hen thinking about getting a visit from OSHA, (MIOSHA in Michigan), it hasn’t always been a pleasant thought. History might say that we could expect an inspector to arrive in the lobby and we would then proceed to the shop floor. As we toured the facility, the inspector would point out areas that needed improvement some being minor details but others classified as major. There would be discussions before our citations would be handed to us. In Michigan, it has been the practice of the state to allow protests which would be submitted in writing for review. Those protests that were denied carried full financial penalties. If you chose to simply accept the findings without protest, fines would be cut in half. Clearly the trend says to accept them and cut the losses by paying the reduced fines. Our last surprise visit was approximately 12 years ago and we had 2 citations that we accepted at the reduced rate. That made me wonder if there was a way to work with MIOSHA to better educate ourselves and use their expertise to our benefit. As it turns out, the State of Michigan MIOSHA organization works with a program designed to assist employers and their employees at NO COST. The organization works by invitation from the employer and conducts on-site visits that are the same type of walk- through reviews that inspectors would normally perform. Inspectors are just as detailed and they share their observations in real time. Upon completion there is a detailed de-briefing but there are no citations written and no financial penalties tied to them. The employer must however agree to address the findings within a 90-day period after formal notification from MIOSHA. If corrections are completed within the allotted period no penalties will be


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charged and the employer joins a list of companies that have participated in the collaboration program which identifies the company as one that works with the State to assure a safe work environment. I am proud to say that Shellcast, Inc. has participated in these events six times now and has scored highly each time. Foundries rarely have high scores with many showing poor air quality, very high noise exposure areas, high lost time accident rates, and crystalline silica exposure. Naturally many outside of our business hear the word “foundry” and think of huge green sand operations with heavy smoke, dust, and deafening noise. As we know investment casting is a real departure from that world and while still a foundry operation the two are radically different.


Because of our experience with MIOSHA, we have set a higher standard for operating conditions. Air quality in all manufacturing areas has been shown to be well below regulation limits. This includes shell, melting and pouring, cutoff and cleaning areas. Noise abatement efforts are effective and employees that work in high exposure areas are subject to annual hearing tests. Importantly the facility has been shown to be free of crystalline silica which, along with the other testing results, is now certified by the State of Michigan. The health and safety officer that does these tests has been at our facility three times now and our relationship with him is excellent. We are open with each other and clearly share the goal of making and the workplace safer. During that discussion, he brought up the fact that the US Government is working to issue regulations to employers that focus on heat exposure. MIOSHA offers a template of what is considered to be an outline of a legitimate heat abatement program. This template is a guideline


for all employers to follow to assure that those who work in hot areas have the resources needed to avoid heat related illness.


Lastly, I have to mention that


our insurance carrier that handles our worker’s compensation policy is also a strong supporter of the MIOSHA collaborative programs. Their representative visits us annually and conducts mock MIOSHA facility audits. Travis Halstead with MTMIC is very thorough in his reviews and it is because of his efforts that we keep abreast of latest regulations that MIOSHA is looking to enforce. I consider Travis to be a key component in our success with MIOSHA audits and maintaining a safe workplace.


(MIOSHA) Sample Program can be found on the opposite page.


A page from the Michigan OSHA A full


copy of the template may be found on the ICI website at https://www. investmentcasting.org/free-reference- materials.html.


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