Almost a year ago, under its new National Emphasis Program, the Occupational Safety and Health Administration (OSHA) began sending inspectors into warehouses and distribution centers (DCs). With injury rates in these facilities two times higher than private industry, OSHA’s surprise inspections support its objective of reducing or eliminating hazards—including those associated with pallet rack. Obviously, operations managers can’t prepare for an unscheduled inspection from an OSHA representative. But it is possible to reduce the risk of associate injuries by adding rack inspections to a facility-wide health and safety program.
“OSHA’s NEP focuses on several areas with potential hazards,” said Jonathan Hirst, Vice President and General Manager at North American Storage. The company is a member of the Rack Manufacturers Institute (RMI). “Among them are material handling and storage systems, as well as walking and working surfaces. Implementing a program for routine rack inspections can help an operation significantly lower its risk for accidents and injuries resulting from rack damage.”
RMI’s Recommendations for Rack Inspections
RMI’s Considerations for the Planning and Use of Industrial Steel Storage Racks does not dictate a schedule for rack inspections, noted Hirst.
“Instead, the publication provides guidelines to help a rack owner determine how often to perform them,” he said. “Best practice is to conduct a rack inspection annually, but if a facility or rack area has higher damage risk characteristics, then assessments should be more frequent.”
Damage risk criteria include:
- High volumes of forklift traffic. The more fork trucks traveling through a rack system, the more likely damage is to occur.
- Narrow aisle rack layouts. Tighter aisle space makes maneuverability more difficult, increasing the risk of a rack impact.
- Aisles used for transfer. Rack sections with transfer aisles are more likely to sustain damage.
- Previously damaged rack. A rack area damaged before is more likely to experience an impact again.
- Freezer or cooler storage areas. Material handling equipment is more likely to impact rack in these high-density refrigerated or sub-zero storage spaces due to operators’ decreased visibility from protective gear.
RMI’s frequency recommendations for rack inspections include:
- Monthly inspections for racks that meet four or more of the above criteria, as they have a high degree of damage risk.
- Quarterly (every three months) inspections for racks that check three or more of the criteria detailed above, as they are at a medium degree of damage risk.
- Biannual (twice a year) inspections for racks with a low degree of damage risk because they meet any single criteria listed above.
- Immediately after any seismic activity or a forklift impact.
The following best practices can help a warehouse or DC integrate rack inspections into their health and safety program to minimize rack hazards and improve OSHA compliance.
Best Practice # 1: Get Professional Training in Rack Inspections.
Because every rack system is unique, so too is every rack inspection program. For that reason, it’s wise to engage a qualified rack inspection professional to learn the steps involved as they pertain to the system at hand, advised Hirst. They often provide detailed checklists that help ensure a thorough evaluation.
“Having a professional training session, preferably from an inspector who offers a certified course, will likely be the most thorough option,” he said. “They will help associates learn the correct part names, what to look for to identify damage, and how to properly record findings.”
Additionally, professional rack inspection training typically provides a certification at the conclusion of the sessions, Hirst added. “That documents the course completion, making it traceable and verifiable for OSHA inspections.”
Best Practice # 2: Develop and Document Policies and Procedures for Rack Inspections.
For consistency, the rack owner should create policies and procedures surrounding both rack inspections and the corrective measures that result from identifying damage. Details include who performs the rack inspection, how often, and what happens after finding an issue.
“Tailor these processes to match the needs of the operation,” Hirst said. “For example, if an inspection discovers rack damage, how should managers address that? Perhaps it’s immediate decommissioning and replacement of severely damaged rack components, while a list of minor issues—like scratches—gets repairs once a quarter.”
Whatever the ultimate policies and procedures are, Hirst advised documenting them in writing. Additionally, keeping records of each inspection—when it occurred, who performed it, damage found, and so on—is important. “In the event that OSHA arrives for an inspection, managers can show documentation on policies, procedures, and inspection records,” he explained.
Other key components of the written policies and procedures for rack inspections include:
- An up-to-date facility drawing which depicts all the rack positions in the building.
- Labels that identify rows and individual rack bays to help identify damage locations.
- Load application and rack configuration (LARC) drawings that illustrate all approved beam configurations and the load capacities each can safely support.
Best Practice # 3: Foster a Culture That Prizes Associates’ Rack Observations.
A big part of improving safety through rack inspections are timely reports from associates about rack damage or other concerns, such as overloading or missing fasteners. As the persons who are actively working among the aisles day-in and day-out, they’re the ones most likely to spot rack issues first. Therefore, it’s critical to train all employees on what to look for and how to report rack problems. Emphasize that employees should inform their supervisors or managers immediately when they see evidence of a rack impact to prompt an inspection.
“However, if associates fear reprisals, then they won’t report damage. Likewise, if nothing happens to address their reports, they will stop mentioning rack damage to their superiors,” said Hirst. He recommended collaborating on a reporting system to alleviate employee concerns. “Also, if managers receive information about rack damage, they must act on it quickly. That reinforces how important safety is to the operation,” added Hirst.
Best Practice # 4: Utilize Professional Rack Repair Service Providers.
Upon discovering rack damage, the owner must decide between repairing the damaged component or replacing it with a new part. To help determine which direction to go, RMI offers the Guideline for the Assessment and Repair or Replacement of Damaged Rack — Version 2.0. It includes recommendations for assessing and recording damage and repairs, plus how to develop and install an engineered solution for repair or replacement of the damaged component.
Best practice is to engage a qualified rack engineer to evaluate the rack and supervise the selected remediation, Hirst said. “This could be an engineer from the rack’s original equipment manufacturer, or a professional third-party service provider,” he noted. “It’s critical, however, that whoever performs the repair or replacement is both qualified and experienced. Don’t assume that in-house maintenance and repair technicians can properly fix damaged rack. It’s a unique skill set.”
Best Practice # 5: Engage a Professional Engineer to Audit Rack and Inspection Processes.
At least annually, certified rack inspector or engineer should audit an operation’s rack inspection process as well as the rack itself.
“An independent, qualified rack engineer or inspector offers an unbiased perspective on a facility’s rack and its inspection practices,” said Hirst. “That outside expert can help identify any unintentional oversights in an inspection process, as well as observe a system with fresh eyes. They can also answer questions about how to classify damage, how to address different issues, and more.”
Learn More About Performing Rack Inspections
RMI offers numerous rack inspection resources, including a video and frequently asked questions, on its website: www.mhi.org/rmi. Additional details about the rack inspection process are in Section 6 of RMI’s publication Considerations for the Planning and Use of Industrial Steel Storage Racks.
