Conveyor Safety — Managing the Risks
By Jeff Sturges

Same conveyor, different safety levels.

Safety first! You have heard that everywhere. Its echoes bellow down the tunnels of car washes all over North America and the world. Are they hollow words, or are they the rudimentary pillars of a well thought out safety program?

This article speaks mainly to conveyor safety; there is no less expensive way to prevent a major catastrophe from finding its way into your business than managing the risks associated with conveyors. Having a well-developed safety program can save plenty. It can also prevent tragedy from potentially striking at your car wash.

Sadly, there are many horror stories that have circulated around the industry related to conveyor mishaps. I’d like to share a few, not to scare or intimidate, but to bring the realization to the forefront that the importance of a safety program is paramount to success.

IT’S PERSONAL

Wiping hubcaps for nickel tips back in the late ‘60s was my idea of a great way to spend a weekend at the family car wash. Some customers even gave me a dime. I thought I was in heaven. Despite my early success in cleaning wheels, there was an allure in the tunnel that almost always mesmerized me by its movement — the conveyor. Now, this was an old log chain type, driven by a large electric motor, where the cars were pulled by a hook, rope, and block that was inserted manually into the chain. I would watch its operation for hours, captivated by all the moving parts. I believe that captivation still resides today in most young car wash employees’ minds.

Standing too close one day, a loose shoelace got caught in the chain pulling me along until an alert employee pulled out a knife and cut me free. What a relief to all involved. I could have been seriously hurt. Suffice to say that my family was not pleased with my antics — and to this day, I have a profound respect for conveyors. Quite a few years later, despite my best efforts, a loosely misplaced pit grate got the best of me and I wound up wet, muddy, and taking a trip to the local hospital for a few dozen stitches and a tetanus shot. I still bear the scar.

REGULATORY COMPLIANCE

In a case reported on the CDC.gov website, Cal/OSHA investigators a few months ago issued $25,085 in citations for safety and health violations at two Los Angeles car wash businesses. The companies were inspected on July 28, 2008 after the Los Angeles Cal/OSHA office received complaints filed by the Southern California Coalition on Occupational Safety and Health on behalf of the employees working at the businesses.

“Car washes and other operations using energized machinery and hazardous chemicals have specific requirements they must meet to control exposure and prevent accidents,” said Cal/OSHA Chief Len Welsh. “Serious injuries or even fatal accidents can be caused by this kind of work if employers fail to protect employees from the types of hazards we found.” The inspections revealed serious and general violations at both locations. Serious safety hazards found included exposed moving parts on the belt and pulley of a conveyor at the car wash1.

As a point of interest, in 2003, the California legislature passed Assembly Bill 1688 establishing a registration system for all car wash and car polishing businesses. Known as the Car Wash Worker Law under Labor Code sections 2050 - 2067, the law protects the wellbeing of employees in the industry. Under the California Labor Code, car wash businesses are also required to register with the Labor Commissioner’s office and follow the labor laws that govern all employers in the state. As of December 11, 828 car wash registrations were issued in 2008, an increase of 125% over registrations in 2007.

These enforcement actions resulted in 503 citations being issued to employers in the car wash industry totaling $3,742,472 in penalties according to The New York Times Business Wire published December 24, 2008.

Additionally, Cal/OSHA (case report 05CA004) reported in December 2008, that a 23-year-old Hispanic car wash attendant died when he was pulled into a side-arm rotating brush in a car wash. The victim was washing down the floor of the car wash tunnel with a hose. He had turned on the car wash equipment in the tunnel to flood the floor to make it easier to clean. The hose the victim was using got caught in the side-arm brush and it pulled him into the rotating motion of the brush. The company did not have a specific lock-out/tag-out program or a written wash down procedure that indicated that the wash equipment must be turned off when employees enter the tunnel to clean the floor. The CA/FACE investigator determined that, in order to prevent future occurrences, employers, as part of their Injury and Illness Prevention Program (IIPP), should implement training and develop safety procedures for lock-out/tag-out2.

NO SAFETY STANDARD

Lastly, a company in Wisconsin is facing a $150,000 fine because an employee suffered several fractures of his pelvis, leg, and both hips while performing maintenance on a conveyor last year. Could the company have prevented this tragedy by following OSHA’s conveyor safety standard? Probably not, because OSHA doesn’t have a conveyor safety standard. To this date, OSHA has no specific standard that covers conveyor safety. As a result, conveyor accidents are typically cited under the General Duty Clause.

Since the ‘70s, consultant George Schultz has called for a conveyor safety document from OSHA, to no avail. Schultz’s proposed standard would cover safe equipment and safe personnel, as well as maintenance. Unfortunately, OSHA probably will not devote any time or resources to conveyors, and certainly not to a standard. OSHA limits its effort to mostly ergonomics guidelines3.

Bernie Krill, a material handling engineer, says that OSHA comes close to a safety standard for conveyors with the Control of Hazardous Energy (lock-out/tag-out) standard, CFR part 1910.147. This standard was promulgated in 1989, and OSHA tells us that its enforcement is being updated. While lock-out/tag-out applies to all types of machinery, it is especially applicable to conveyors4.

There has been loss of limbs, crippling damage, and numerous lawsuits caused by improper conduct around car wash conveyors. I’m sure most of you have seen or heard about employees “surfing” on the conveyor? There have been reports about employees spraying tire cleaner on the track, popping up a dollie, and stepping on the track to be pushed by the roller to see how long they could stay on. It is not enough to say that having a safety program and training specifically for moving equipment in the car wash is imperative.

SAFETY PROGRAM

Obviously, conveyor design and safety has come quite far in terms of closing chain gaps on top plates, designing safer over-ride functions, and requiring warning alarms prior to start-up. These are just a few. Some safety features are incorporated in the design of a conveyor or conveyor system; some depend on installation; some depend on maintenance by the user; some depend on the operator. Many safety features can be part of a building and are not an actual part of the conveyor or conveyor system itself. Other safety features are dependent upon rules and regulations set up by the operating management and/or application of local codes.

A quick look at some of the industry specifics regarding conveyor safety can help ensure a safer working environment. Although there could be books written on the topic, we offer a few main points to help you develop and implement a conveyor safety program at your wash.

Service

Do not service the conveyor without following lock-out/tag-out procedures:

1. An authorized employee will notify all affected employees that a lock-out or tag-out system is going to be used and the reason why. The authorized employee shall know the type of energy that the machine or equipment utilizes and understand the hazards associated with it.
2. If the machine or equipment is operating, it will be shut down by the normal stopping procedure (depress stop button, close toggle switch, etc.). The authorized employee will operate the switch, valve, or the energy isolating device(s) so that the equipment is isolated from its energy source(s).
3. All electrical equipment isolation will be verified with electrical meter testing. Stored energy (such as that in springs, rotating flywheels, hydraulic systems, air, gas, steam, water pressure, etc.) must be dissipated or restrained by methods such as repositioning, blocking, bleeding down, etc.
4. Lock-out or tag-out the energy isolating devices with authorized and assigned individual locks or tags. Additionally, all other safety methods or procedures shall be indicated on the standard lock-out tag.
5. The authorized employee shall check to ensure that no personnel are exposed.
6. The authorized employee shall operate the switch or the normal operating controls to make certain that the equipment will not operate and ensure disconnections.
7. The authorized employee will then return operating controls to the “neutral” or “off” position after the test.
8. The equipment is now locked out or tagged out for servicing or maintenance.

Annual reviews should be conducted by the manager/owner who has employees that perform lock-out/tag-out procedures. The review shall be recorded in writing and maintained for at least five years. The review shall involve interviews with employees and their supervisors in an effort to identify unsafe practices that have been observed and to discuss questions and concerns that arise4. All questions or concerns that are identified shall be addressed upon the completion of the annual review, including the need for improved communications, the need for additional training, and the need for policy procedure changes.

Updating
Owners of older car washes should consider modifying their systems with safer, more updated equipment.

Since the 1980s, there have been significant improvements in the safety features of car washes. Older systems typically are turned on and off by a single wall-mounted switch. Newer systems have safety features such as vehicle-activated pressure plates, sensors controlled by microprocessors, and torque-limited motors. When owners of older car wash systems update their equipment, they will likely significantly lessen the chances of an incident occurring.

With new equipment, the conveyor designer/manufacturer is responsible for using current standards in order to provide functional equipment that will perform effectively and can be safely operated and serviced. The owner is responsible for the safe operation and maintenance of the equipment4.

Absent standards, innovation in conveyor design is the best approach to safety. Modularity, flexibility, and speed do not necessarily detract from safe operation of conveyors. Neither does that staple of conveyor selection: reliability. Conveyor suppliers can provide equipment that is modular, flexible, fast, and safe, as well as offer maintenance support and single-source shopping.

SAFETY INSPECTION PROGRAM

Here are simple steps to take when developing and implementing an audit and safety inspection program:

Written Program
The car wash should have a written workplace safety program that includes an assessment of the workplace hazards and methods and procedures for correcting those hazards. It should also state that supervisors/managers/owners are responsible for the implementation of the program. The program should also have an audit and inspection program, which documents any findings, whether safe or unsafe. A documented audit and inspection program will give the owner a current picture of the safety program as well as a history of past events, and identify unsafe acts being performed and allow corrective action to take place before serious injury or death occurs.

Standards
Analyze available conveyor safety standards. A variety of such materials are available. Some standards and sources apply specifically to conveyors, while others cover general safety.

Identify Hazards
Identify conveyor hazards. Most conveyor accidents occur at action points, such as drives, vehicle loading and unloading points, and areas where workers perform repeated or unplanned actions. To identify potential hazards, the operator must consider the conveyor type, its configuration, and its location in relation to other equipment.

Eliminate Hazards
When developing the program, the first step is to try to eliminate any conveyor dangers that involve both hazard and risk. That is, if a particular hazard is present, steps should be taken to minimize the chances that a worker will be exposed to it. For example, if a conveyor requires manual lubrication, a central lubrication system can be installed so workers need not climb all over the conveyor to lubricate it.

1. Use warning signs or alert workers to hazards. Warning signs or labels alert workers to obvious safety hazards. Although these signs cannot compensate for unsafe design, they can help modify worker behavior, which in turn may reduce injury severity and frequency. A car wash’s insurance plan also typically requires the posting of signs.
2. Establish training requirements, develop training materials, and train workers. The original manufacturer should have supplied an operations and maintenance manual to the first owner. This information should be located, upgraded, and/or rewritten.
3. Keep up with proper interval maintenance. Developing a maintenance program to record the tasks is important to documenting actions and allowing the operator to see trends. Different conveyors need different preventive maintenance (PM). Consult your manufacturer for specifics regarding your type of conveyor.

Aside from the regularly scheduled basic PM tasks, developing a comprehensive safety program can help manage the risks of conveyor operation.

1. Unknown (2008). Retrieved February 3, 2009, from Centers for Disease Control and Prevention: http://www.cdc.gov/niosh/face/stateface/ca/05ca004.html
2. Wire, B. (2008, December 24). Cal/OSHA Cites Los Angeles Carwash Businesses for Unsafe Practices. The New York Times.
3. Schultz, G. A. (2001, May 5). Conveyor Safety. Professional Safety , 46 (5), p. 27.
4. Krill, B. (2004). Innovate for Conveyor Safety. Summitt Business Media .

Jeff Sturges is the director of North American sales for the tunnel division of Arvada, CO-based Mark VII Equipment Inc., the US subsidiary of WashTec AG of Germany. You can visit the company on the web at www.markvii.net.