Facility Auditing to Ensure Regulatory Compliance

Good afternoon everyone and welcome to the facility auditing webinar. My name is Will Ikpi. Alongside me today is Brett Polito and we are excited to talk about an important topic for every business and employee. Essentially the goal today is to shed light on how understanding and implementing key standards from some safety organizations not only ensures compliance but also encourages a culture of safety and operational excellence.

So for the agenda today, I will start by covering a general overview of facility auditing. I'll then dive into the roles of a few organizations and how their standards apply to audits. Brett will then touch on leading versus lagging indicators in safety, review some case studies, and discuss the cost-benefit analysis of auditing. We'll then wrap things up and allow time for some questions at the end. So without further ado, let us begin.

Facility auditing is a fairly broad term. The specific standards that apply to your business may not apply to someone else's. It really depends on a couple different things such as the industry you're in, the types of facilities you have, the hazards that are present in your work setting, and the purpose of the audit, whether that be safety, quality assurance, environmental compliance, or something else entirely. Now, it is important to note that there are a plethora of different organizations that contribute to workplace safety standards and practices, but for the purpose of time today, we're going to be diving into three specifically: OSHA, ANSI, and ASME. Each of these organizations plays a distinct but often overlapping role in the landscape.

Starting off with OSHA, which stands for the Occupational Safety and Health Administration, they are a prominent and powerful agency that not only sets mandatory regulations but conducts compliance inspections. If you don't meet their standards, you can be subjected to significant fines. The American National Standards Institute focuses on voluntary consensus standards and best practices often related to management systems. And last but not least, ASME, the American Society of Mechanical Engineers, provides voluntary specialized codes, especially for mechanical engineering and conformity assessments. It is important to remember that ANSI and ASME are voluntary, but they can become mandatory if they are incorporated into OSHA regulations.

So starting off with OSHA, their role is to be the US regulatory agency that sets and enforces mandatory occupational safety and health standards. They achieve this by conducting inspections, which are essentially audits to ensure employers are compliant. Beyond their direct inspections, many OSHA regulations also require employers to conduct their own internal assessments, evaluations, and reviews, which effectively function as internal audits. At the core of OSHA's mandate is the general duty clause, which is the foundation of workplace safety in the US. It essentially is a big safety promise that employers make to their workers to always try their best to keep them safe from serious harm, even when there isn't a rule for every single possible danger.

Now, let's look at some key OSHA regulations that mandate or relate to auditing. We'll start off with part 1910, otherwise known as the general industry standards. This is a wide-ranging, broad set of OSHA regulations. Audits under this part assess compliance with various subparts, many of which Brady is quite familiar with, such as machine guarding, lockout tagout (which explicitly requires periodic inspections), confined spaces (which requires evaluation and review of written programs), and hazard communication. Hazard communication is otherwise known as the right to know law, because its purpose is to ensure employers and employees have the necessary information about hazardous chemicals they may be exposed to in the workplace.

Similarly, we have part 1926, which is much like part 1910, but this covers specific regulations for construction sites. Then there's 1904, which focuses on specific forms employers must fill out when reporting injuries or illnesses in the workplace. Form 300 is actually the main log of all recordable work-related injuries and illnesses throughout a calendar year and it's designed to classify and note the extent or severity of these incidents. Form 300A is typically completed at the end of the year and summarizes all the entries from that 300 form. Lastly, form 301 is a very detailed investigation report for one specific incident.

Finally, we have 1910.119, process safety management of highly hazardous chemicals. In layman's terms, it's essentially saying that if you have a lot of really dangerous chemicals in your facility, you need a detailed plan and a strict system in place to make sure those chemicals don't accidentally escape or cause a disaster such as explosions, fires, or toxic release. It is nice; I actually had the privilege a couple weeks ago of visiting an organization that makes chemical solutions for water treatment companies. And while I was on site, they actually had us perform a brief training and I was notified of the wind socks that they have on campus. For those unfamiliar, a wind sock is a light flexible cone mounted on a post to show the direction and strength of the wind. This is a crucial safety tool because it helps us determine which way to face downwind in the unfortunate event of hazardous chemicals being released into the environment. So, that's just a great example of a company doing their due diligence to make sure that not only their workforce is safe while on site, but also the visitors that come to their site as well.

Now, let's shift our focus on to the American National Standards Institute. Their primary role is to recognize other organizations known as accredited standards developers or ASDs that develop voluntary consensus standards. ANSI itself conducts audits of these ASDs to ensure that they adhere to its essential requirements, due process, essentially guaranteeing fairness and consensus in standard development. Now most ANSI standards for auditing are actually standards developed by these ANSI accredited bodies. These standards usually define management systems that in turn require both internal and or external auditing, and they are widely adopted as industry best practices and are frequently referenced in contracts or regulations.

So let's look at some key ANSI accredited standards that are vital for auditing. We'll start off with ISO 19011 which provides foundational guidelines for auditing management systems, making it a universal tool for auditors. We also have ISO 9001 which requires audits to achieve and maintain certification for quality management systems. Then there's ISO 14001 which mandates audits to verify the effectiveness of environmental performance and compliance. Moving forward, we have ASSP Z10, which requires regular audits to assess the effectiveness of occupational health and safety management systems, and ISO 45001, which is essentially the international counterpart to that Z10 standard. Then finally, we have NFPA standards such as the National Electrical Code and Life Safety Codes, which are crucial for fire and life safety audits.

So, as you can see on the bottom of the screen, I've included some examples of different organizations that contribute to workplace safety standards and practices. Kind of like what I was talking about before when I mentioned the plethora of different organizations that make such standards. An important thing to note, the ISO is actually an international body that creates international standards and ANSI is the official US member body to ISO, essentially meaning ANSI represents the US in ISO. So how that works, ISO creates the original standard and then ANSI ensures it meets US due process requirements for adoption, which is pretty cool.

So when dissecting the similarities and differences between OSHA and ANSI, it is important to note the key differences. OSHA receives government funding. They also have OSHA officers that can arrive unannounced for inspections and OSHA has the power to enforce regulations with fines and punishments. On the other side, ANSI is a private nonprofit organization. They offer guidelines that companies can adopt on a voluntary basis, and being non-compliant with ANSI does not result in fines. However, violations could lead to a loss of ASD status or membership.

And then we can talk about the similarities between both; it's pretty self-explanatory. Both aim to improve safety and health in the workplace by issuing guidelines and standardizing things such as safety signs and symbols. They're both really recognized nationally and internationally as authorities on safety and health in the workplace and they work with a variety of industries such as construction, manufacturing, healthcare and transportation. Not to mention both actually provide educational resources and training on safety and health.

Now we can turn our attention to ASME, the American Society of Mechanical Engineers. ASME is actually a leading organization for developing codes and standards in mechanical engineering with a particular focus on pressure technologies: boilers, pressure vessels and nuclear components. Now ASME's auditing approach is most prominently seen in conformity assessment programs through joint reviews or surveys. This just means that they have specialized audits conducted to authorize manufacturers and assemblers to use the ASME certification mark, otherwise known as the ASME stamp that you can see on the right hand side of your screen.

Now, looking at a couple of their key standards, we'll start off with the boiler and pressure vessel code. This basically is a very detailed rule book that explains how to design, build, inspect, and maintain high pressure containers and equipment. This is obviously important because it prevents catastrophic failures of equipment that operate under immense pressure. Then we also have the NQA-1 standard which is a comprehensive set of rules and guidelines that says for anything related to nuclear facilities you must have a meticulous system in place to guarantee everything is done perfectly every single time. Now I won't go into the importance of this. I'd like to assume you all understand the implications of not properly containing nuclear energy. If not, no worries; please go watch the Oppenheimer movie and refer back to this webinar. Can't hear any of you, but I'd like to think that I got some laughs from that.

All right, so moving on. How do these three organizations come together in facility auditing? Well, as I mentioned before with OSHA, they provide the mandatory baseline for safety and health compliance. These are the rules you must follow and if you don't you could be subjected to fines. ANSI offers frameworks for management systems covering quality, environmental and safety. They also provide best practices often leading to valuable certifications that demonstrate your commitment beyond basic compliance. And finally, ASME addresses specific requirements for critical mechanical equipment and their manufacturing or repair processes. So ultimately effective facility auditing requires understanding and integrating the applicable standards from different areas. This is a holistic approach that actually ensures comprehensive compliance, promotes safety, and drives overall operational excellence. Now I know that was a lot and some of you may be thinking where the heck do I start? How do you get your workforce to come in and leave work safely every day? Well, my right-hand man, Brett Polito, is right here to help you answer that question.

Hey, thanks, Will. So, that's a great question. I'm sure many are asking yourselves where do I start and how do I get started with auditing. So, first thing you want to do is you want to start with an honest self assessment of yourself and your own facilities. An effective journey towards safety excellence really begins with that self assessment. Think of it like taking stock in your own safety foundation. Now, in order to do this, you may need to ask yourself a couple critical questions: Things like, what are the common pitfalls we're currently facing? Is our training inadequate? How are our written programs? Are they up-to-date? Are they reflective of our actual operations? Are they understood by everyone who needs to follow them? This self assessment isn't about pointing fingers. It's about establishing a baseline and it's about knowing where you are so you can plan where you want to go.

All right, so to dive in a little bit further to go beyond that self assessment, we're going to define two fundamentally different approaches to safety: reactive and proactive safety. So let's first jump into reactive safety. Reactive safety is really about looking backwards and is focusing on what has already happened. So some common themes that you'll find in reactive safety programs include phrases like: "We don't have time for safety." We've all probably heard that at some point in time; a big safety event comes up and you hear, "We simply don't have the time to do it." But people don't feel that they have the time to do safety until it forcefully demands their time, like someone getting hurt or facing a regulatory inspection from someone like OSHA, or maybe there's some other type of significant operational disruption. In these environments, it's often perceived that the safety manager is the only person responsible for safety and safety programs. Finally, reactive safety programs are often hyperfocused on compliance. Their main goal is to simply adhere to existing regulations to avoid penalty. And while compliance, yes, is essential, it's the bare minimum; it isn't the aspiration.

Now, conversely, let's take a look at proactive safety. Proactive safety is about looking forward and anticipating. Common themes that you'll find within proactive safety programs include people saying things like, "We don't have time to not make safety a priority." Safety is seen as an integral and important part of operational efficiency. Other common themes would be everyone is responsible for and actively participating in the safety programs. It's not just the safety manager; it's everyone from the plant manager to the new hire you just made last week. And then finally, this often leads to viewing safety as an investment. If you invest time, resources, and effort upfront, knowing that in the long run, it will save lives, reduce costs, and improve operational efficiency. So, a couple quick analogies: Reactive safety would be like driving, but only looking in the rearview mirror, whereas proactive safety would be similar to using a GPS and planning your route before your journey begins.

So to dive a little further into reactive safety, as I mentioned, reactive safety is really focusing on lagging indicators and it's a reactive approach because in order for that corrective action to occur, the bad result has to have occurred first. So, this often leads to things like limited foresight; focusing on past events can lead to overlooking potential future hazards. Also, while seemingly less effort upfront, reactive safety is definitely more costly in the long run. It can lead to higher costs due to injuries, downtime, fines, and of course, reputational damage. Now, I'd like to point out that the time bar on the bottom of our graph here isn't necessarily linear. That means that once that bad accident or injury has occurred, it may take significantly longer to get back into compliance. And in the same sense, once you have reached compliance, it may take a much shorter amount of time to have that next accident or injury occur.

Now, why does it take so long to implement corrective actions in reactive safety programs? Ultimately, there's usually insufficient resources and prioritization. Other operational demands such as production targets or cost cutting can overshadow the urgency of implementing those corrective actions. And then finally, resistance to change or organizational culture played a part. Have you ever been out on the floor in your own facility and you observe a specific action and you go up to someone and you ask, "Hey, why did you do such and such this way?" And the response you get is, "Well, that's the way we've always done it." So, a culture resistant to change can actively impede the implementation of these new procedures or controls even if they are safer. Now, ultimately, what does that lead to and what does it mean? It can oftentimes lead to low employee engagement. If employees feel that their input isn't valued or their past safety suggestions haven't led to any action, they become disengaged, and ultimately that reduces the flow of critical information from the plant's floor to you, potentially the safety manager.

Now, let's take a look at a quick case study involving a reactive safety program. We're going to be looking at a facility as it relates to their lockout tagout procedures here in the Midwest. Ultimately back in 2003 and 2004, this company did a really, really good job of writing machine specific lockout procedures for all of the equipment across their huge campus. But once they met compliance in 2004, they kind of brushed their hands of it and didn't stay up to date with some of the requirements in the 1910.147 standards such as your review of your written procedure. Every year you should be inspecting your written procedures, so they did not do this. They didn't stay up to date for 15 years and due to machine modifications, process changes, and work cell changes, after a while, the majority of the procedures were no longer accurate. Also, since they weren't doing their periodic inspections, they didn't notice they had a problem until injuries started occurring. Basically, they had some very long tenured maintenance staff who started to retire, and only when they started to bring in some of the new folks did they start to have accidents and injuries occur from following those older, outdated procedures. So it took them until 2019 to realize that they had that problem and then they went about trying to fix it themselves internally. Well, that was not very successful and in 2022 they reached out to a third party for assistance. And at the end of the day, they had to have over 1,600 new lockout tagout procedures created for them to the tune of about a quarter million dollars. So, this is a good example of reactive safety because, one, their main goal was simply to meet compliance, and once they met compliance in 2004, they didn't do any type of annual reviews of their programs, so they ultimately didn't know that they had a deficiency or were lacking until they started having accidents and injuries.

So in that same sense, let's dive now into proactive safety. This approach focuses on using leading indicators, those forward-looking signals that allow you to act before those incidents or accidents occur. And again, a common theme in proactive safety is really meeting compliance; those OSHA standards are the bare minimum, the bottom rung of the ladder. What these safety programs are really looking to do is define a world-class safety approach. And some key indicators of an effective proactive safety program include things like a high rate of near miss reporting. Your workers are going to feel empowered to speak up when they run into hazards out there in the facility. Also, there's a pretty high focus on safety inspections and audits; the goal of frequent or comprehensive audits is to catch these unsafe conditions before any accidents or injuries occur. And then finally, the average time to incident resolution is usually significantly shorter than a reactive safety program.

Now, why is this and why does it take the proactive folks less time to implement their corrective actions? Well, small problems equal quick fixes. Addressing minor hazards or unsafe conditions identified through leading indicators like audits or near miss reporting is typically much quicker and less resource intensive than reacting to a major incident. Other ways they're able to help lower the time to incident resolution include clear processes and accountability and likely some sort of centralized tracking system to make sure that none of the tasks fall through the cracks or get forgotten about.

So, another quick case study here about a proactive safety program. Ultimately, it was at a wastewater treatment facility as it relates to their confined space program here in the Midwest. They had a couple near misses reported as it relates to entering confined spaces. And after a review of their written program, they decided that they needed to make all of their confined spaces permit-required confined spaces. So once this decision was made, they went out into the field and did an audit to update their inventory of confined spaces and make sure that they had all of the confined spaces on site that they said that they had and that they were properly identified as a permit-required confined space. Once this was done, then and only then after they reviewed their spaces did they go through and perform all their training for the new employees and to update those folks on the changes in their written program. So, why is this a good example of proactive safety? Because they were able to identify an issue or a problem before any injury or accident had taken place, followed through with steps such as updating their written programs, and notified all of their workforce that those changes were in fact taking place.

So at this point, just to go over some cost-benefit analysis, I'm sure many of you have seen this diagram before: the safety iceberg. The idea of the safety iceberg is ultimately when we see injuries or accidents happen in the facility, a couple of things really come to mind first, and that's the part of the iceberg that everyone can see, the part that's protruding from the water surface. Obviously, when you see an injury happen in the facility, first thing that comes to mind is the physical pain that's associated with those injuries, as well as often OSHA fines, OSHA visits, and OSHA inspections. Those are almost always the first two things that folks like to talk about when they see an injury happen in a facility. However, those are not the only complications to a workplace accident or injury. In fact, everything that's kind of hanging out below the water surface aren't really on the forefront of everyone's mind. However, they should be because when we take a look at them, the other things that are associated with injury are workers' comp claims, litigation, insurance premiums, medical costs, reputation within your community, as well as the reputation of your safety culture within your own facility. And one other thing I'd like to point out is downtime. More and more companies are hyper-aware of the financial impact of downtime. And as safety people, we can feel the pressure from other areas of business to bypass things like audits and continuous improvement to minimize downtime or maximize production. But if you remember the point I made a few slides back about small problems equal quick fixes, the downtime needed to do your audits is going to be minimal compared to the downtime associated with some other catastrophic incident.

Okay, so you know that performing audits is right for you. So what are some key steps into performing a successful audit? Well, first, anytime I do an audit, I'm going to follow some form of the plan, do, check, act system, which is a four-step management tool for continuous improvement; ultimately, it's known as the Deming cycle. Now, you always start with getting your plan in place, and if you're new to this, try and make sure your scope and objectives are as defined as possible. From there, gather resources that may help you along your journey; things like past audit reports would be really helpful, and other documentation like SDSs and SOPs. I would like to draw specific attention to people. Again, as we talked about earlier, safety is not just the responsibility of the safety manager. Everyone should be pulling their weight within the safety program from the plant manager all the way down to that new hire that just joined last week. So feel free to see if you can't get an extra set of eyes with you when you're out there on your audits. An extra set of eyes is helpful for obviously being able to view things that you may miss, but those people may have a different set of experiences, someone like maybe a department supervisor, and may have more knowledge about the area that you're working in and could be ultimately very helpful to your safety goals.

So, next up, once you've got your plan in place, it's time to do the audit. Go out there; I would start with observations, even watching a line for 30 minutes and just seeing how it runs. What are their problems? What's going well and what isn't? If you do see something during your observation and you think to yourself, "Huh, that seems a little strange; I wonder why it's being handled this way," feel free to do interviews. Pull those employees aside and ask, "Hey, why are you doing such and such this way?" And then of course documentation: photos, notes, videos, training records, anything that's going to be able to bring back to the office with you and at a later state is going to be able to help tell your story about your findings when you're out in the field conducting your audits. Absolutely, documentation is very important.

Next, once your documentation is complete, go ahead and analyze those findings and compile reports. I would draw some attention to trend analysis. So, I would try to compile your results in some sort of spreadsheet, whether it's Microsoft Excel or Google Sheets. This is going to be helpful, especially once you've been auditing for a while, to determine some of your long-term trends. Do any of our audit findings have anything that's in common with one another? Also, it's great to quantify your results within Excel or Sheets or something like that because in the future, if you are having to present to say your boss or maybe a different department your findings within these audits, it's very easy to turn your data into a chart or graph that makes the data you collected now more visual and again really helps tell your story. And then finally, trend analysis is also going to help in determining your root causes. Once your root causes have been determined, then you can go ahead and act, develop and implement your solutions, but again, monitor your progress and if it helps create some SMART goals. We don't want to get into that kind of reactive safety trend of thinking, "Oh, I'm in compliance now; it means I don't have to pay attention." Nope, you still have to monitor your progress and make adjustments as necessary.

Awesome, great information, Brett; much appreciated. So, to tie some things together with audits and visual workplace safety importance, visual workplace safety isn't just a set of guidelines. It's a dynamic approach that transforms your work environment into a safer, more productive, and more efficient space. Kind of touching on Brett's iceberg, first and foremost, you're safeguarding lives. It's any business's ultimate priority to ensure everyone goes home safe and sound every day. Beyond that, you can also protect your assets. BWS helps prevent damage and/or downtime for equipment, machinery, or your facility as a whole. And over time, once processes are clear and concise, time management will directly be affected, saving time in daily operations. This in turn can lead to reduced errors, increased efficiency and organization, and overall enhanced awareness and communication by fostering a proactive safety culture. And lucky enough for all of you today, the company that Brett and I work for offers a plethora of different safety services to help you start that journey to compliance. And while we'll get you to where you need to be, it should really be where you guys want to be because being known as a company that always has safety in mind and puts it first for its workforce is a company people will always want to work for. We appreciate your time today.

All right, thank you, Will, and thank you, Brett; great job. To those on the call, thank you for joining us today. We do want to open it up for questions. We actually did have one come through during the webinar asking if you guys would be receiving the slide deck for the webinar. The slide deck itself will not be available, but a recording of the webinar will be available on the Brady YouTube page in the coming weeks here, if not sooner. So, I ask if you've been on this call writing down questions, now would be the time to type those in. While you do that, we'll just take a quick look ahead to what's upcoming in this webinar series. Coming up on August 20th, we will have something that's near and dear to my heart: lockout tagout, OSHA number five, control of hazardous energy. So, we will be doing a similar webinar August 20th on lockout tagout. Looking ahead to September, we will be diving more into the pipe marking requirements, more into the ASME standards that Will had touched on earlier in the hour here. And then we'll be rounding it out in October, just in time for snow here in Milwaukee, talking about winter and cold weather and preparing your parking lots and your facilities, focusing on slips, trips, and falls. So, that's what you can expect coming up, and with that, it looks like we do have some questions coming in.

All right, so we've got a question in here that says, "How do you determine what is a valid safety concern versus an excuse?" And Brett, I think you tagged that one, so I'll let you take it.

Yeah, absolutely. So, I know it can be tough sometimes really making that determination. I think it would be best just to have a good faith effort approach to every situation as if it is a valid safety concern. And I know that can be tough sometimes because you can have some people kind of really on you sometimes. But I would approach everyone as if it is valid. But then also do your due diligence, and we talked about kind of bringing in some other folks, so I would absolutely do some interviews around if you've got one person that's really hammering you on a couple things that you're not certain is really a valid safety concern. If you have other people in similar roles, I would bring them in, see what they have to say if they have similar types of concerns, as well as doing some observations out in the field. What is that person's concern and can it be recreated? Can you see it happen? And that might be something that could help you along, but I know that's a tough one, so just try and, if you can, approach everything as if it is that valid safety concern.

All right, and then we had someone ask if we could go back to the plan, do, check, act slide; they missed the act. We'll pull that up while I get the next question loaded up. Yeah, looks like they had missed the end of it with someone coming into the office, so we'll give them a moment to digest while I pull up the next question here. All right, so the next question that came through is, "Is the lockout tagout procedure for a specific piece of equipment required to be available to the worker at the job site where the equipment is located?" Do you want me to answer?

Yeah, you can go for it; I know you got that one.

Yeah, so lockout tagout, OSHA 1910.147, does require equipment specific procedures. Now in the question about does it need to be available to the worker: yes. And that's going to tie directly to the program. There's no right or wrong way, I should say, to how you can make those available. I mean, you know, Brady writes lockout tagout procedures for companies all year, every year, and there's a number of ways we make them available, either putting physical procedures up on the equipment, putting them in binders, or we've even gotten into putting QR code labels on equipment that can be scanned to pull up read-only access to the procedure. So, there's a number of different ways that you can make those procedures available. What I always say is the right answer and the right way to do it is what's detailed in your written program and what you train your people to. So, for example, having those procedures in a binder is absolutely okay, especially if you have a harsh environment where hanging those procedures on the equipment means they may get lost or they may get destroyed. Sure, you can put them in a binder; the important thing is that the people who need to access those procedures know where to access those procedures. But again, just to circle back to the first part of that question, it is required to have equipment specific procedures. So when you have a bunch of like procedures or, I should say, like pieces of equipment, that's fine, but those procedures need to call out the equipment that they're for. You can include equipment ID numbers or asset names, whatever it may be, but yeah, the procedure does need to be equipment specific and the people who need it need to know where they're going to access it or how.

All right, Brett, you threw me a curveball there. Do you have another question lined up?

Yeah, I do. We had a question come in asking about whether there are any civil or criminal lawsuits sometimes involved with injuries due to delinquent safety protocols. So, I can give a good example here. I would say that ultimately, yes, sometimes there can be. As someone that is not a compliance officer from OSHA, I won't dive into a whole ton of what is or isn't, but I can bring up that sometimes these accidents make national news. So, I will bring up one specific incident that happened around 2012 in Southern California at a tuna fish manufacturer. I'm not going to name the specific manufacturer, but ultimately it was canned tuna that you buy on the shelf at your grocery store, and it was a lockout tagout related incident. And what happened was that they would load these big racks of tuna into their ovens and they would close the oven and cook the tuna. They'd pull the tuna out of the oven and then they would send a cleaning crew into the oven to clean out the oven and prep it for the next batch. Now, what happened that day? They pulled out a load of tuna, the cleaning crew went into the oven and started their cleaning, and then someone thought, "Oh, we're all done," brought in the next rack of tuna, closed the oven door, and fired up the oven. Now, you might be wondering, did they forget something in that oven? Yes, they did; absolutely, they forgot one of the employees in the oven. Now, of course, that employee perished and it was a pretty gruesome story that did in fact make national news, so feel free to go back and look this one up. But ultimately, I believe it ended with the plant manager as well as the plant safety manager having criminal charges and serving some time. Again, I believe the specifics were that OSHA was there and fined them numerous times before for lockout tagout, and it was a knowing and willful violation that resulted in someone's death. So short answer to that would be yes, and there's a bunch of examples out there through local news etc. that you'll be able to find.

All right, thanks Brett. Another question that had just come through: "If some of these standards and regulations are referenced in law, then why are some of them not free for the public to view?" Will, I'll let you take that one.

Yeah, for sure; that's a pretty good question. I had that question myself at one point. Basically, it's due to a couple different reasons. Essentially, to make these standards and regulations, it takes a lot of expert contributions that involve extensive research and testing of these standards and regulations to make sure that they fit the specific needs of these companies and these organizations, so on and so forth. Also with that, a lot of these organizations can be nonprofits, so depending on that, they really base their organization off selling these standards and membership fees to keep their operations going. Also with that, standards are considered intellectual property, so they can be copyrighted, which allows for these organizations to charge for access, but nonetheless, there are different sources that can provide free access to some of these standards. So you should still be able to access some of them, of course, obviously.

All right, thanks Will. With that, I think it seems like the questions have slowed down; I think we got just about all of them. So, again, I just want to thank everybody for joining the webinar. Thank you, Will, and thank you, Brett; great job. Again, I'll just kind of end with a look ahead, and if you're on the call now, save the date: the next one will be lockout tagout on August 20th. All right. Thanks, everybody.