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Section A: Machinery & Equipment

Section A1 - Cleanliness

  • Piles of rags and oil absorbent materials around the base of leaking machinery.

  • Excessive leaking fluids: water, oil, solvents, etc., on or near machinery and equipment.

  • Spill trays full of leaking water, oil, solvents, etc.

  • Trash, debris, and unnecessary materials on or near the machinery or equipment.

  • Large amounts of process materials (scrap foil, UBC, dross, fluxing salts, dust, etc.) spilled around the process equipment.

  • Excessive and unnecessary tools and materials hanging on, leaning against or around machinery and equipment.

Section A2 - Machine Guarding

  • Point of operation guarding that is hinged, not interlocked and/or does not require a tool to open.

  • Machine shop tolls that are not guarded, i.e. lathes without chuck guards.

  • Guarding that is not in place while the machine is running, i.e. tied back guards.

  • Grinders with incorrect tool rest and tongue guard adjustments

  • Machine shop tools not anchored to the floor.

  • Any recognized hazard not adequately guarded.

Section A3 - Electrical Equipment

  • Open electrical boxed, or any unprotected energized parts that non-qualified employees can be exposed to. This would include missing junction box covers, breaker panel covers, open knockout plug holes, etc.

  • Unrestricted general employee access to areas where unprotected energized parts are located, i.e. motor control rooms with open buses.

  • Electrical disconnect equipment that lacks free and unobstructed access.

  • Electrical equipment that does not have 36 inches of clear working space in front of it.

  • Flammable or combustible materials stored within 36 inches of transformers and electrical equipment that may spark.

  • Water on the floor in electrical equipment areas.

  • Unlabeled emergency disconnects.

  • Note: It is unacceptable to use motor control rooms and other electrical equipment rooms for general storage, unless flammable and combustible materials can be significantly isolated. Also, storage in these areas increases the likelihood that non-qualified personnel will be in these high hazard areas.

Section A4 - Material Handling Equipment (Fork trucks, Cranes, Conveyors, etc.)

  • Modifications to any lifting device without written approval from the original equipment manufacturer.

  • Vehicles missing brakes, lights, horns, other warning devices, etc.

  • Vehicles in obvious unsafe conditions, i.e. bad fluid leaks, damaged load bearing parts, damaged cables, fuel leaks, etc.

  • Lack of 'No Smoking' signs, face shields, and applicable warning and PPE signs in battery charging stations (areas where battery-operated vehicles are charged and fluid addition to batteries is likely).

  • Damaged hooks and missing safety latches on cranes and hoists.

  • Confusing or non-labeled crane pendant and radio controls.

  • Lack of weight capacity labels on crane bridges, hoists, and hooks.

  • Capacity labels that are not visible or readable from the operators level.

  • Inconsistent capacities on cranes, hoists, and hooks, i.e. a 5-ton hook installed on a 1-ton hoist.

  • Seat belts not provided on all powered industrial trucks (fork trucks, mules, heavy equipment, etc.) that are provided with rollover protection.

  • Damaged conveyors.

  • Conveyors lacking emergency stop cables.

  • Start-up alarms on automatic conveyors.

Section A5 - Slings and Below the Hook Lifting Devices

  • Cut, punctured, abraded, knotted, damaged, etc., synthetic, wire rope, and chain slings.

  • Damaged C-hooks, slab handlers, forks, etc.

  • Below the hook lifting devices lacking capacity labeling.

Section A6 - Emergency Equipment

  • Poorly stocked first aid kits and equipment, i.e. outdated supplies, missing supplies, opened and non-sterile supplies, etc.

  • Prescription medication should not be available in first aid cabinets or stations.

  • First aid kits and stations lacking personal protective equipment for first aid personnel to prevent exposure to bloodborne pathogens.

  • Medical and/or first aid supplies that are not readily available to all employees on all shifts.

  • Medical and/or first aid supplies that are not regularly inspected.

  • Obstructed eye washes, safety showers, and stretchers.

  • Obstructed fire extinguishers, fire hoses, fixed fire suppression system manual dump stations, fire alarms, etc.

  • Fire fighting equipment lacking regular inspection.

  • Obstructed access to other emergency equipment, i.e. environmental response carts, etc.

  • Insufficient number, type, or location of fire extinguishers.

  • Unsanitary, non-serviceable, or obstructed emergency escape respirators.

Section B - Stock, Material & Chemicals

Section B1 - Raw Material, Work0in-Progress (WIP) and Chemicals

  • Unstable or otherwise unsafe storage of process materials (raw materials, product, scrap, etc.)

  • Damaged containers that allow materials to spill out on the floor.

Section B2 - Storerooms, Stockrooms & Storage Areas

  • Poor housekeeping in storerooms, stockrooms, and storage areas.

  • Storage of materials on top of cabinets and shelf units where employees can pull objects off onto their head.

  • Damaged storage racks.

  • Storage racks that are not anchored to the floor or building structure.

  • Storage racks (other than small commercial rack units) lacking loading capacity.

  • Poor access through storage areas that require employees to climb over materials.

  • Old equipment and material boneyards that are not well maintained.

  • Excessive storage of flammable and combustible materials in store rooms.

Section B3 - Chemical, Oil and Flammable Liquid Storage

  • Lack of or illegible 'No Smoking' signs in flammable and combustible liquid storage areas.

  • Lack of grounding and/or bonding straps for flammable liquid storage, handling and transfer areas.

  • Mixed and otherwise unsafe storage of acids and bases.

  • Unsafe storage of chemicals in lab areas.

  • Old, expired, and/or obsolete chemicals in Lab(s).

  • Lead or chromate paints.

  • Asbestos garments, gasket materials, insulating materials, etc.

  • Lack of appropriate PPE in chemical storage areas and laboratories.

  • Secondary containers are not labeled, i.e. buckets/pails, cans, bottles, spray bottles, etc., not labeled to indicate contents.

  • Hazardous materials are not stored properly considering material hazards and compatibility with other materials.

Section B4 - Drum/Tote Management

  • Individual drums/totes are not labeled. Drums/totes are not easily identifiable as to contents or empty conditions.

  • Stored drums/totes are not properly sealed. In outside storage areas, bungs are left open, tops are left off so that rain and/or snow can accumulate inside the drums/totes, etc.

  • Drums/totes are stored in areas within 75 feet of interior drains or storm drains.

  • Drums/totes are not stored in an orderly fashion.

  • Drums/totes are in poor condition, dented, broken, or leaking.

Section B5 - Compressed Gases

  • Uncapped and unsecured cylinders, i.e. cylinders secured with light gauge wire.

  • Oxygen and fuel gas cylinders, in storage, that are not separated by 20 feet, or a 5 foot high wall with a ½-hour fire rating.

  • Damaged compressed gas cylinder gauges or hoses.

  • Cutting and welding units without flashback arresters in the lines.

  • Unattended oxygen-acetylene equipment with pressure left on gauges.

Section C - Tools

Section C1 - Hand Tools

  • Tools with cracked or broken handles and other parts.

  • Tools with mushroomed heads.

  • Screwdrivers and chisels with dull tips.

  • Homemade tools that have not been designed and approved by a qualified engineer (auditors should evaluate the tool's likelihood of failure during use).

  • Air nozzles lacking tips that restrict deadhead pressure to 30 psi.

  • Unsafe use of tools, i.e. employee using pliers instead of a wrench.

Section C2 - Hand Held Power Tools & Power Cords

  • Portable grinders without proper guards.

  • Damaged or cracked electrical tool cases.

  • Damaged or unsafe power cords, i.e. cut, spliced, crushed, punctured, etc.

  • Power cords pulled out of tool housing or plugs that expose wires.

  • Electric hand tools that are not grounded or are not double insulated.

  • Electric hand tools and extension cords with grounding prong removed.

  • Homemade extension cords made from parts that were not recommended for that application by the
    manufacturer.

  • Electric tools and extension cords lying in water or wet areas.

  • Lack of ground fault interrupters (GFI) in areas prone to have water present (bathrooms, kitchens, exterior construction sites).

  • Extension cords used in lieu of permanent wiring.

  • Extension cords left in doorways where they can be damaged by a closing door.

  • Grinding non-ferrous metals with inappropriate stones.

Section D - Walking Working Surfaces

Section D1 - Floors

  • Water, oil, and other liquids creating slipping hazards on the floor.

  • Cracked, damaged, or severely uneven floors that present tripping hazards.

  • Tripping hazards created by power cords, hoses, etc., on the floor.

  • Slipping hazards created by welding rod stubs, shot, trash, etc., on the floor.

  • Material and equipment stored in aisleways.

  • Floor and wall openings and holes are protected to prevent a fall to a lower elevation.

  • Emergency aisles that are less than 28 inches wide.

  • Aisleways used for pedestrian travel and material transported by fork trucks that are not 24 inches wider than the expected load on the fork truck.

Section D2 - Stairs, Ladders & Platforms

  • Stair angles outside 30 to 50o angles.

  • Stairs with four or more risers without standard stair railings.

  • Power cords, hoses, tools, gloves, and other materials left on stairs that create tripping hazards.

  • Damaged ladders or stair treads.

  • Ladders placed in an unsafe position while in use.

  • Fixed ladders outside 75 to 90o angles.

  • Portable ladders lacking safety feet.

  • Platforms that are 4 foot high or higher lacking standard railings and toe boards.

  • Power cords, hoses, tools, gloves, and other materials left on platforms that create tripping hazards.

  • Scaffolds unsafely erected or used, i.e. missing standard railings and toeboards, missing cleating on planks.

  • Elevated work platforms and crane bridges without standard railing or personal fall protection provided.

Section E - Buildings & Grounds

Section E1 - Exits

  • Unmarked or incorrectly marked exits.

  • Exit ways lacking emergency lighting or illuminated signs.

  • Exit doors fitted with locks, sliding bolts, hooks, or any other device that prevents free discharge in an emergency.

  • Insufficient number of exits or poorly located exits.

  • Inspect overhead and man doors for damage to tracks, damage to door, missing / incomplete seals, open and close properly, all sets of switches work (overhead doors), door crash bar, knob, closure, glass, strike-plate, etc. are in good, working condition.

  • Exits are not locked in a way that restricts an occupant's ability to use the exit in an emergency. Panic bars and doorknob locksets are acceptable. Dead bolts, sliding bolts, hooks, hasp, and other similar door securements are not acceptable.

Section E2 - Emergency Lighting

  • Poor interior and exterior lighting conditions.

  • Nonfunctional or inadequate emergency lighting.

Section E3 - Piping Systems

  • Unlabeled piping and valve systems (color coding, flow direction indicators, labels, etc.)

  • Poorly supported piping.

  • Piping installed such that it creates a significant tripping hazard or is placed so employees can bump their heads.

  • Unlabeled emergency utility shut off valves.

Section E4 - Interior Housekeeping

  • Haphazard storage of tools, equipment, hoses, power cords, materials, etc., inside buildings.

  • Haphazard storage of tools, equipment, hoses, power cords, materials, etc., inside small out buildings.

  • Accumulations of cigarette butts, ear plugs, debris, and spent materials on floors inside buildings; including, but not limited to, motor rooms, coolant cellars, mezzanines, above furnaces, basements, crane bridges, maintenance shops, contractor areas, vehicle garages, security buildings, water treatment facilities, training buildings, exercise rooms, conference rooms, etc.

  • Unsanitary conditions associated with food storage and preparation areas (cafeterias, kitchens, refrigerators, microwave ovens, vending machines, food storage cabinets, etc.)

  • Unsanitary water fountains.

  • Unsanitary conditions in bathrooms, locker rooms, and shower rooms.

Section E5 - Exterior Housekeeping

  • Haphazard storage of tools, equipment, hoses, power cords, materials, etc., on the ground outside buildings.

  • Accumulations of cigarette butts, ear plugs, debris, and spend materials on the ground outside buildings; including, but not limited to, parking lots, grounds, roadways, service roads, contractor areas, vehicle storage, etc.

  • Accumulations of cigarette butts, ear plugs, debris, and spend materials on roof tops.
    • Unsafe accumulations of snow and ice on parking lots and sidewalks.

Section 6 - Offices

  • Poor housekeeping in office areas, including: private offices, meeting rooms, copier rooms, computer rooms, restrooms, boiler rooms, electrical rooms, HVAC rooms, basements, storage rooms, closets, etc.

  • Overloaded extension cords and power strips.

Section F - Environmental

  • There are signs of releases of fugitive emissions on siding of overhead doors in plant (i.e. black staining or oily residue).

  • Roof areas adjacent to vents and stacks have accumulations of dust material or oil.

  • The plant has excessive visible emissions (i.e. violations of permit or 20%) from stacks and/or vents.

  • There are detectable odors at the plant's property line.

  • Volatile products are not kept sealed when not in use.

  • If indicated on recording devices, operating parameters are not within appropriate limits.

  • Ventilation hoods are not maintained.

  • Air pollution control equipment and/or facilities are not in good operating condition.

  • Chemicals, oils, solids, and other pollutants are stored such that a spill could reasonable reach storm water or process water drain.

  • Visual appearance of water discharge is not good (i.e. there is visible oil sheen or free oil floating on the water surface, there are floating or suspended solids in the water discharge, turbidity (cloudiness) of the discharge is high, or any other deleterious impacts).

  • The sampling location is not properly designed for gathering adequate or proper samples (i.e. depth should be at least 1.5 times the length of the sampling jar so the sample is not contaminated during collection).

  • Sampling locations for process and/or storm water are not easily or safely accessible.

  • There is staining found in and/or around the discharge area showing evidence of past excursions.

  • Waste water treatment equipment and/or facilities are not in good operating condition.

Section F3 - Spill Prevention & Containment

  • Secondary containers of hazardous materials are placed within 75 feet of an access to a storm or waste water sewer drain.

  • Hazardous materials storage areas are not designed in a manner that minimized risk of release or exposure (i.e., access to sewers, in adequate secondary containment, exposed to weather elements, stored on bare ground).

  • Transfer areas are not properly labeled (i.e. pipe connections are not labeled, instructions or proper transfer procedures are not posted, emergency response procedures are not posted).

  • Remote transfer areas are not equipped with visual or audible overfill alarms and product level monitor displays.

  • Transfer areas do not have adequate secondary containment to prevent spills from entering the
    environment.

  • Secondary containment at transfer areas is not properly designed to contain spills associated with transfer operations (largest compartment on delivery vehicle and plant mobile equipment).

  • Tank material is not compatible with the fluid stored.

  • Tanks are not equipped with one of the following level sensing devices:
    - High level alarm with an audible or visual signal
    - Hi level pump cut-off devices
    - Manual gauges visible from pumping station
    - Direct signal from the tank gauge and pumping station

  • Tank systems are not provided with adequate secondary containment.

  • Tank surfaces are not clean or are in poor condition with visible signs of rust and deterioration.

  • Secondary containment systems are not clean and empty of rainwater or oil/hazardous material spillage. *Allowance made for rain/snow accumulation that has developed just prior to the audit.

  • Secondary containment areas do not have locked and valved drainage syst ems for 110% storage capacity of the largest container.

  • Storage tank containment system drainage hardware is not maintained properly (i.e. valves are not locked in the closed position, valves are left open, valves do not open and close easily).

  • Secondary containment structures are not constructed/maintained in a manner to prevent release to the environment (i.e. structures are cracked or broken, dikes have earthen bottoms, tank bottoms are not in contact with impervious material).

  • Spill kits are not located within 75 feet of bulk chemical/oil transfer areas.

  • Phone do not have emergency phone numbers posted on them.

Section F4 - Waste Management

  • Wastes are not stored in the proper designated area.

  • Wastes are not properly segregated (i.e. incompatible wastes are stored together such as waste acids and bases; recyclable wastes are mixed with trash).

  • Waste storage areas are not designed to reduce or minimize risk of release (i.e. floor drains or storm drains are easily accessible to spills; ignitable or reactive wastes are stored less than fifty feet from the property line).

  • Hazardous wastes are not properly labeled or packaged per legal requirements.

  • Non-hazardous waste containers used to accumulate specific wastes (i.e. specific industrial waste,
    recyclables, scrap metal, fluorescent bulbs, etc.) within the plant are not labeled.

  • Waste containers are not adequate or compatible to the type or quantity of waste.

Section F5 - Energy

  • Remelt and recycle furnace doors are maintained properly and are properly seated in the furnace sill

  • Furnace refractory is in good condition with no apparent hot spots

  • There is no apparent heat leakage on annealing and homogenizing/pusher furnace surfaces

  • Doors and windows are operational and seal properly

  • Compressed air systems and tools are in good condition with no apparent leakage

  • Insulation on process equipment and heated building space is in good condition

  • Energy awareness communications are posted

Section G - Work Practices

Section G1 - Critical Practices

  • Employees not following lockout/tagout procedures.

  • Employees not following confined space procedures.

  • Employees operating equipment with machine guarding defeated (tied back, light curtains turned off, limit switches taped down, etc.)

  • Non-qualified persons working on or around live energized parts.

Section G2 - Compliance & Rules

  • Employees not complying with plant PPE rules (head, eyes/face, hearing, body, hand, arm, foot, etc.)

  • Contractors, truck drivers, and visitors not complying with plant PPE rules (head, eyes/face, hearing, body, hand, arm, foot, etc.)

  • Contractors, truck drivers, and visitors not complying with general plant EH&S rules.

  • Employees not complying with general plant EH&S rules.

Section G3 - Crane Operation

  • Employees operating cranes that have not had a pre-shift inspection. Employees will be required to show the equipment has been inspected through documentation or demonstration.

  • An employee operating a crane that is not in safe working condition (defective brakes, lights, warning devices, hydraulics, etc.)

  • Employees operating cranes in a way that puts themselves or others at risk.

  • Transporting loads over others.

  • Making lifts with damaged slings and below the hook lifting devices.

  • Exceeding equipment capacity.

  • Shock loading (sudden jerking lifts).

  • Side pulling loads.

  • Failure to maintain safe truck (transport) restraints systems at docks.

  • Failure to use safe truck (transport) restraints; e.g. Doc Lok, chocks, etc.

  • Trucks drivers use fall protection for truck drivers untarping, loading, and tarping trucks.

  • Employees failing to use all protection (full body harness, shock absorbing lanyard, engineered anchored points) when working above ground.

  • Employees using fall protection that is not in good condition.

Section G5 - Mobile Equipment

  • Operator not wearing seatbelt while operating mobile equipment (fork truck, scooters).

  • Operator traveling with forks 4-6 inches off the ground.

  • Operators are not obeying traffic signs.

  • Operators not parking in designated areas and are parking in pedestrian walkway.

  • Operators are not slowing down at corners and intersections.

  • Operator has not completed a pre-operation inspection of the equipment.

  • Pedestrians not using designated walkways.

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