What does the term "manufacturers' recommendations" really mean in the real world?
I’ve spent more than 35 years in safety, first as a compliance officer with Maryland OSHA, then as independent consultant. My work has given me the opportunity to review hundreds of written safety and health programs, on a wide range of topics in a plethora of industries ranging from small “mom and pop” operations to multinational conglomerates.
One thing I’ve noticed about many written programs is that they contained as statement like, "All equipment shall be maintained in accordance with the manufacturer’s recommendations." Now that sounds perfectly reasonable, doesn't it? Who knows better than the manufacturer what maintenance is required?
After reviewing a fall protection or confined space program, I would ask, “What maintenance do you perform on your retracting lifelines or your toxic gas monitors?” I often was met with a blank – or at best – quizzical look.
When I saw that look, I would respond, “Well, it says right here that you “will maintain equipment according to the manufacturer’s recommendations,” so I'm asking you: what does the manufacturer recommend?” In most cases, I got a mindless shrug. Rarely could anyone track down the original manual or instructions.
What good does it do to have a high-minded requirement in a written program if there is no practical way of achieving the stated objective?
Perhaps it would be a better idea to replace the generic statement about manufacturers’ recommendations with a two-column table. The first column would list the frequency that particular maintenance operations are performed on equipment – for example, daily, weekly, monthly or annually. In the second column, the specific work to be performed should be listed.
This simple digest would stand a much better chance of being followed than some clichéd statement. Moreover, the table could be printed, laminated, fitted with a grommet and wired to the equipment so it is readily accessible for all users to follow.
Next time, I’ll discuss if it is a good idea to follow manufacturers’ recommendations with respect to calibrating toxic gas monitors.
John Rekus may be reached at [email protected]