Topic: Pedestrian Traffic Under Open Roll-up Doors
Question: Is it a violation of a MIOSHA standard if employees walk under open roll-up doors in a manufacturing facility?
Answer: The answer to this question cannot be specific to all roll-up doors as a general statement. There are many different types of doors. Generally speaking, overhead doors are not recognized as a path of travel if shared by vehicle traffic and a designated exit door is immediately available. There are however instances where overhead doors may be the only option for movement from one area to another. There could potentially be a violation of MIOSHA Standard under Part 1 General Provisions if a Caught In/Under, or Pinch Hazard is a potential that could lead to injury of an employee. Many employers install soft doors, or soft door devices to reduce or eliminate the hazard of an employee being injured by the door. Other options that have been able to reduce hazards is to remove remote operation devices (remote control) from service to over head, or roll up doors in conjunction with safe door devices. Or, by removing the remote device and installation of a constant pressure control, the employee is in a safe location while the door is in motion, as well as controlling the doors operation.
Without such engineering protective devices, administrative controls, are a secondary consideration and may be permissible in some locations. Administrative control is implementation of policy or work practice to dictate a specific condition and action, such as prohibiting the use of overhead and roll-up doors for access where there is a safer nearby entrance/exit, and holding staff accountable for following those policies.
Lastly, every employer has the responsibility to assess hazards associated with any workplace or operation. This includes the use of travel routes where employee safety and health may be affected. Violations may exist if the employer has not taken steps to protect employees where there exists a hazard of caught in/under or pinched by an overhead, or roll-up door.
General Industry Safety Standard Part 1 General Provisions Rule:
408.10034(9) When an employee is exposed to a hazard created by a pinch point other than point of operation, the hazard shall be guarded or the employee otherwise protected.
Applicable Construction Safety Standard/Rule: N/A
Applicable General Industry Safety Standard/Rule: General Industry Safety Standard Part 1. General Provisions
Applicable Occupational Health Standard/Rule: N/A
Date Posted: January 9, 2017 /