OSHA 28 inch Egress Requirement - Attn: Reloaders --OSHA Violation

Discussion in 'UPS Union Issues' started by InsideUPS, Mar 16, 2013.

  1. InsideUPS

    InsideUPS Active Member

    One of the most common OSHA violations I see at our UPS facility occurs on the reload. As UPS eliminated the older "drop frame" trailers and went to the solid floor trailers, facilities that use a single set of rollers to load the trailers often violate OSHA regulation 1910.36(g)(2) as defined below:

    "Pickers" under pressure of high production often results in packages falling off to the left and right of the rollers, completely blocking a loader in the trailer with no egress out. While the remedy to this type of unsafe condition appears simple, which is turning off the belt; many young people are either too intimidated or proud to stop production until the trailer egress routes are properly cleared.

    This past week, I had our CHSP representative read the following OSHA regulation at the PCM. For some reason, our supervisors were not quite as thrilled as when they simply request us to repeat the 8 keys to lifting and lowering : )

    1910.36(g)(2)
    An exit access must be at least 28 inches (71.1 center manager) wide at all points. Where there is only one exit access leading to an exit or exit discharge, the width of the exit and exit discharge must be at least equal to the width of the exit access.


    Remember, this is not only a requirement of UPS, it is an OSHA rule. IF your facility is not complying with the 28" egress requirement, I suggest you contact your safety representative. If the trailers continue to be loaded with limited egress in and out of the trailer, I then suggest you file an OSHA complaint by going to:

    How to File a Complaint with OSHA

    Remember, you can stop harassment, safety concerns, and unrealistic production expectations by adhering to the 28" egress requirement. OSHA will be more than happy to assist you with your concerns if for some reason UPS supervisors don't care to listen. ​
     
  2. I wonder if this go for unloading p.c. with the unload device in the truck and it brick loaded to the bulk head door there is no exit.
     
  3. Inthegame

    Inthegame Well-Known Member

    Great post. Every inside employee (including short staffed management)should utilize this info.
     
  4. Dracula

    Dracula Package Car is cake compared to this...

    Should, but never will. Read my "Feeder Bitching" post and see how cavalier this company is about DOT laws regarding securing trailers before they hit the road.
     
  5. nate4027

    nate4027 New Member

    Great info, now if a center if found in violation do you file a grevience or sumbit a complaint to OSHA or both?
     
  6. notcoolman

    notcoolman Member

    lol I love how supervisors come to break jams and just push it all in the floor and I sometimes yell
    EGRESS!! loud and annoying! UPS doesnt care about safety they just make sure we no all the language so if we do get hurt they can say we knew how to work safe and blame an accident on us
     
  7. UPS Preloader

    UPS Preloader Active Member

    My recommendation - The first few should be on a grievance form. Then, if still no responce file a complaint with OSHA along with the past grievances so that you have a history of egress issues.
     
  8. balland chain

    balland chain Member

    UPS has there safety committee, safety meetings, etc. for one reason. They want it to appear on paper. The company's stand on safety is laughable. Has the company ever thought about the harassment and stress they place on it's workers creates a very unsafe workplace. No they could give a rats as about it. THEY created this hostile work environment, and continue to make things worse for all hourly workers. I have quite a few friends that work for large companies, IBM, GOOGLE, American airlines, (pilots & crew) when we talk about our companies and working conditions, UPS and there mid-evil management style fares the worst. I do not exaggerate when I speak of the company, I TELL THE TRUTH, (something ups says we never do) and my friends are shocked at the situations I tell them of. Managers and sups, think it is ok to treat us in such a way, claiming it is "their job." Having my manager look at me and tell me that I am a dishonest thief, when actually HE is the dishonest one, well SIR, when you meet your maker, I pray to witness, the ALMIGHTY SEND YOU STRAIGHT TO HELL.
     
  9. InsideUPS

    InsideUPS Active Member


    UPS Preloader has excellent advice...create a paper trail via the grievance process if at all possible. If for some reason your Local Union is not supportive of your actions, submit an OSHA complaint. The OSHA complaint will definitely get attention if all else fails.
     
  10. InsideUPS

    InsideUPS Active Member

    Work right slow and safe...... I believe that that this OSHA regulation would apply to the unloading of a package car as well. I'm not absolutely certain how OSHA would look at the fact that the unload device can telescope in at anytime... I personally believe that the package car should be "hollowed out" before an unload device is used. It may take additional time but at least you have immediate egress out of the package car in case of an emergency.
     
  11. andyb03

    andyb03 New Member

    I will bring this up at my sorts safety meeting and have it put on the concerns log.
     
  12. nate4027

    nate4027 New Member

    What article and section of the contract should this be filed under? Since it is a OSHA violation.
     
  13. sortaisle

    sortaisle Livin the cardboard dream

    The above OSHA violation is taken out of context. The context of the 28 inch rule pertains to permanent emergency exits ie. doors or egress windows. There's no part of 1910.36 that is meant for trailers. By all means there should be an egress and there should be/possibly is a proper OSHA standard for trailers but 1910.36 is meant for permanent emergency doors/exits.
     
  14. nate4027

    nate4027 New Member

    I think you need to re-read the section sortaisle. Even the supervisors at my center preach 28" of egress at all times in all work paths.
     
  15. UPS Preloader

    UPS Preloader Active Member

    Keep it basic stating that UPS put it's employees at risk by violating Article 18 as well as the OSHA VIOLATION and that you are asking for this to be looked into so that it doesn't happen again.
     
  16. sortaisle

    sortaisle Livin the cardboard dream

    Fair enough...it's titled Design and Construction Requirements for Exit Routes. Design and Construction. Does not pertain to trailer doors...they are not exit routes. In fact it's a violation to exit from a trailer door. Like I said, there's should be an OSHA requirement for this, but 1910.36 isn't it.
     
  17. InsideUPS

    InsideUPS Active Member

    http://www.osha.gov/OshDoc/data_General_Facts/emergency-exit-routes-factsheet.pdf

    FROM OSHA DOCUMENT Link Above

    "How would you escape from your workplace in an emergency? Do you know where all the exits are in case your first choice is too crowded? Are you sure the doors will be unlocked and that the exit access, such as a hallway, will not be blocked during a fire, explosion, or other crisis? Knowing the answers to these questions could keep you safe during an emergency.


    What is an exit route?


    An exit route is a continuous and unobstructed path of exit travel from any point within a workplace to a place of safety. An exit route consists of three parts:


    ■ Exit access – portion of an exit route that leads to an exit.

    Exit – portion of an exit route that is generally separated from other areas to provide a protected way of travel to the exit discharge.
    Exit discharge – part of the exit route that leads directly outside or to a street, walkway, refuge area, public way, or open space with access to the outside.

    An exit access must be at least 28 inches wide at all points. Where there is only one exit access leading to an exit or exit discharge, the width of the exit and exit discharge must be at least equal to the width of the exit access. Objects that project into the exit must not reduce its width."

    If you are working in a trailer......."how would you escape from your workplace in an emergency?... You state that it is a violation to exit from a trailer door?........ so..if there is an emergency the employees must stay in the trailer?....

    Just to clarify....if you were working in a trailer.....and the UPS emergency alarm sounded..... do you not exit the trailer? NOT what we were taught... By definition and instruction, if you were loading or unloading a trailer....the alarm sounds....you exit the trailer walking through what is defined as the "Exit Access".... which by OSHA standards must be 28 inches wide...

     
    Last edited: Mar 28, 2013
  18. InsideUPS

    InsideUPS Active Member


    And....for ANY safety concern that does not fall under the OSHA specific rules and guidelines..


    the Almighty... "OSHA GENERAL DUTY CLAUS"

    OSH Act of 1970

    [TABLE="width: 800"]
    [TR]
    [TD][TABLE="width: 640"]
    [TR]
    [TD="class: blueTen, colspan: 3"]SEC. 5. Duties[/TD]
    [/TR]
    [TR]
    [TD="class: blueTen, colspan: 3"](a) Each employer --

    [/TD]
    [/TR]
    [TR]
    [TD="width: 20"] [/TD]
    [TD="class: blueTen, width: 520"](1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees;

    (2) shall comply with occupational safety and health standards promulgated under this Act.

    [/TD]
    [TD="class: blueEight, width: 100, align: right"]29 USC 654[/TD]
    [/TR]
    [TR]
    [TD="class: blueTen, colspan: 2"](b) Each employee shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct.[/TD]
    [/TR]
    [/TABLE]
    [HR][/HR][/TD]
    [/TR]
    [/TABLE]
    [TABLE="width: 800"]
    [TR]
    [/TR]
    [/TABLE]
     
  19. sortaisle

    sortaisle Livin the cardboard dream

    Now this is more like it. This is not 1910.36. I would file it under this article, not 1910.36. And of course you would exit the trailer...I'm not a :censored2::censored2::censored2::censored2:ing idiot and it's insulting for you to think I am. I merely stated that 1910.36 is the incorrect article to file for and the OSHA act of 1970 would be the proper article.
     
  20. nate4027

    nate4027 New Member

    Nobody said you were anything sortaisle, I just told you to reread the section.