Production control: right or necessity?

Production control is implemented through a set of measures aimed at ensuring the safe operation of hazardous production facilities, as well as preventing accidents at these facilities and ensuring readiness to localize accidents and incidents and eliminate their consequences (see Rules for the organization and implementation of production control over compliance with industrial requirements safety at a hazardous production facility, approved by Decree of the Government of the Russian Federation of March 10, 1999 No. 263).

Responsible for organizing and implementing production control is the head of the operating organization and the persons assigned such responsibilities in accordance with the legislation of the Russian Federation.

Production control is carried out through regular inspections by a responsible employee or production control service of all aspects of industrial safety.

Recommendations for assigning the functions of the person responsible for the implementation of production control:

• If the number of employees at a hazardous production facility is less than 150 people, then one of the deputy heads of the operating organization is appointed as the person responsible for production control.
• If the number of employees at a hazardous production facility ranges from 150 to 500 people, then a separate specialist is appointed to perform the functions of those responsible for production control.
• If the number of employees at a hazardous production facility is more than 500 people, then a production control service is created, and the head of such a service is appointed responsible.

Requirements for the person responsible for carrying out production control:

• Higher technical education that would correspond to the profile of educational institutions.
• At least 3 years of work experience in a relevant job at a public utility.
• Availability of documents confirming successful completion of industrial safety certification.

The purpose of the inspections is to ensure the guaranteed and high-quality implementation of all measures and work to ensure industrial safety, as well as to objectively confirm the fact of their timely and high-quality implementation.

Safety audits should ensure effective control over the activities of all structural units whose work is related to ensuring the industrial safety of hazardous production facilities. The scope and frequency of inspections are determined taking into account the significance of the activity being inspected for ensuring industrial safety.

Production control

This is a set of measures (laboratory research and testing) to ensure compliance with sanitary and epidemiological requirements in the process of performing work and providing services.

Production control is an integral part of sanitary and anti-epidemic (preventive) measures aimed at ensuring the safety of production, storage, transportation and sale of products, work performed and services provided.

Simply put, production control is the control of the employer (legal entity or individual entrepreneur) to ensure that sanitary rules are observed in his organization.

Regularity of inspections

There are no strict deadline requirements; there are recommendations from supervisory authorities reflected in regulatory documents. Checks should be done regularly.

The frequency of the procedure is mainly determined by the hazard class of the PC object. Typical programs provide:

1. A check of class 1 hazardous educational establishments must be done once every 10 days.
2. The frequency of studying class 2 sites is 1 per month.
3. Grades 3 and 4 are studied once a quarter
4. Determination of noise, infrasound, illumination and other physical factors, in addition to aerosols, is carried out annually, microclimate indicators - once every six months (during the warm and cold periods).
5. The vibration level must be checked at least once every 5 years.
6. Diagnostics of potentially dangerous electromagnetic fields are carried out every 4 months.

The organization of production control at particularly hazardous enterprises involves 3 levels:

• operational inspections - determining compliance of workplaces with sanitary legislation;
• targeted inspections - allow you to evaluate the effectiveness of ongoing industrial safety measures and the structure of the program;
• comprehensive verification activities by a specially created service commission.

To objectively assess the degree of compliance with sanitary rules and compliance with standards, it is worth contacting specialized certified centers operating in Moscow and any other region of the Russian Federation.

Who needs production control?

In accordance with Article 11 of the Federal Law of March 30, 1999 No. 52-FZ, the responsibility for organizing and implementing production control lies with all employers.

Those who do not understand very often confuse production control with conducting a special assessment of working conditions in the workplace. Here you need to understand that production control must be carried out even if the organization has carried out a special assessment of working conditions with the presence or absence of harmful and dangerous factors.

Only an expert from the organization conducting the SOUT can decide to use or not use the PC results when conducting an SOUT.

So, the following objects are subject to production control:

• enterprises (catering, industrial and food industries);
• food trade enterprises;
• medical institutions;
• medical and preventive institutions;
• children's health facilities;
• entertainment centers (swimming pools, water parks);
• beauty salons;
• dry cleaners and laundries;
• drinking and domestic water supply facilities;
• waste disposal sites.

Thus, almost all employers are required to carry out such controls.

Inspections of state labor protection authorities

Inspections by supervisory and labor protection authorities in Russia can be scheduled or unscheduled. The main reasons for unscheduled inspections:

• complaints, statements, appeals from employees, representatives of public organizations, foundations, and other persons about violations of labor safety requirements by the employer; • expiration of the period for eliminating violations identified by the previous inspection; • a requirement to conduct an inspection received from a higher organization, prosecutor, or the Government of the Russian Federation; • a worker’s request to monitor his working conditions; • accident, breakdown, other sudden event that shows that the organization has problems with labor safety.

When everything is good in an organization with regard to occupational safety, state supervision of occupational safety in it is carried out as planned. Each of the labor safety supervision and control bodies draws up an inspection schedule, which it introduces to representatives of the enterprise. The legislation establishes the frequency of control measures. For example, inspectors from the Ministry of Labor visit organizations regularly once every 3 years.

Production control in preschool educational institutions and schools

Mandatory for educational institutions as well.

The nomenclature, volume and frequency of laboratory tests are determined taking into account the sanitary and technical condition of the facility.

If there is a swimming pool in preschool organizations, laboratory and instrumental studies of the premises are carried out in accordance with SanPiN 2.1.1.1188-03 “Swimming pools. Hygienic requirements for design, operation and water quality. Quality control".

Industrial instrumental control in premises for children's activities using computer equipment is carried out in accordance with SanPiN 2.2.2./2.4.1340-03 “Hygienic requirements for personal electronic computers and organization of work” (with amendments and additions).

When using bactericidal installations indoors, the procedure and frequency of monitoring their operation is determined in accordance with the recommendations of R 3.5.1904-04 “Use of ultraviolet bactericidal radiation for disinfection of indoor air.”

Complete list of all SanPiN and regulations

1. Federal Law No. 52 dated March 30, 1999 “On the sanitary and epidemiological well-being of the population.”
2. Federal Law No. 29 of 02.01.2000 “On the quality and safety of food products.”
3. SanPiN 2.4.1.3049-13 “Sanitary and epidemiological requirements for the design, content and organization of work in preschool organizations.”
4. SanPiN 1.1.1058-01 “Organization and conduct of production control over compliance with sanitary rules and implementation of sanitary and anti-epidemic measures.”
5. Federal Law of the Russian Federation dated February 23, 2013. No. 15-FZ “On protecting the health of citizens from the effects of environmental tobacco smoke and the consequences of tobacco consumption.”
6. SanPiN 2.3.6 1079-01 “Sanitary and epidemiological requirements for public catering, production and circulation of food raw materials and food products in them.”
7. SanPiN 2.3.2.1324-03 “Hygienic requirements for shelf life and storage conditions of food products.”
8. SanPiN 3.5.3. 1129-02 “Sanitary and epidemiological requirements for deratization.”
9. SanPiN 3.2.1333-03 “Prevention of parasitic diseases on the territory of the Russian Federation.”
10. SanPiN 3.1.094-96 “Prevention and control of infectious diseases common to humans and animals.”
11. SanPiN for disinfection.
12. SanPiN on intestinal infections.
13. Guidelines for laboratory quality control of public catering products. 1-40/3805 dated 11/11/91.
14. GOST 50-763-95 “Public catering. Culinary products sold to the public."
15. Federal Law of the Russian Federation dated June 12, 2008 No. 88-FZ “Technical Regulations for Milk and Dairy Products”
16. Technical Regulations of the Customs Union TR CU 027/2012 “On the safety of certain types of specialized food products, including dietary therapeutic and dietary preventive nutrition”, approved by the Decision of the Customs Union Commission dated June 15, 2012. No. 34;
17. Technical Regulations of the Customs Union TR CU 022/2011 “Food products regarding their labeling.”
18. Technical Regulations of the Customs Union “On the safety of food products” (TR CU 021/2011)
19. Technical Regulations of the Customs Union TR CU -023/2011 “Technical Regulations for Juice Products from Fruits and Vegetables”
20. Technical Regulations of the Customs Union TR CU 024/2011 “Technical Regulations for Fat and Oil Products”
21. Order No. 2106 of December 28, 2010 “On approval of federal requirements for educational institutions in terms of protecting the health of students and pupils”

The legislative framework

Industrial control (PC) includes a set of mandatory measures to minimize the negative impact of enterprises on the environment. It allows you to organize verification of compliance by entrepreneurs with technical regulations, sanitary rules, labor protection standards, and the requirements of other regulatory documents.

The concept, procedure, and frequency of production control are enshrined in several regulations:

1. Federal Law No. 52 Federal Law “On the Sanitary and Epidemiological Welfare of the Population” (Articles 11, 32) - regulates the mandatory nature of compliance with sanitary legislation, determines who is responsible for monitoring the production process , what responsibilities are assigned to him.
2. Law No. 116 Federal Law “On Industrial Safety of HPFs”.
3. Sanitary rules 1.1.1058-01 (as amended on March 27, 2007) - regulates the inspection procedure.
4. Resolution of the Chief State Sanitary Doctor of the Russian Federation No. 26 dated July 30, 2002 - includes examples of developed standard PPCs at enterprises in various industries.
5. Code of Administrative Offenses of the Russian Federation (Article 6.3) – establishes administrative liability for violation of sanitary legislation.

Each organization, legal entity or individual entrepreneur, regardless of the type of economic activity, is entrusted with developing, formalizing and approving a detailed plan of inspection procedures, determining the order of when and how to carry them out.

If you do not develop PC Regulations, a detailed program, and do not keep logs of inspections and research, companies are not allowed to conduct business activities. The list of required documents for applying to Rospotrebnadzor depends on the business sector of the business entity.

It is necessary to distinguish between definitions of PC and assessments of the system of working conditions. The mechanisms are quite similar, but their methods are independent of each other, although each system is required. If SOUT refers to post-facto research, then PC is a mechanism for continuous improvement of work, a guarantee of timely response from employees who are responsible for labor safety.

Organization of production control or how does it work?

The organizing document for the employer is SanPin 1.1.1058-01 “Organization and conduct of production control over compliance with sanitary rules and implementation of sanitary and anti-epidemic (preventive) measures.”

There are 3 types of production control: visual, laboratory and instrumental.

The employer, as part of production control, must organize:

1. Monitoring the provision of sanitary and epidemiological requirements for working conditions; 2. Control over laboratory tests: - production factors in the workplace (noise, chemistry, vibration, etc.); — harmful factors on the border of the sanitary protection zone of the enterprise; — manufactured products; — other tests (raw materials, technologies, etc.). 3. Control over medical examinations; 4. Control over the availability of certificates, medical records, sanitary passports and other documents; 5. Monitoring the implementation and effectiveness of disinfestation and deratization measures; 6. Control over air pollution, as well as the order, conditions, methods of collection, use, neutralization, transportation, storage and disposal of waste to the requirements of sanitary rules; 7. Monitoring the provision of radiation safety; 8. Implementation of disease prevention measures; 9. Control over accounting and reporting for production control; 10. Providing reliable information to Rospotrebnadzor authorities and local authorities about accidents that pose a threat to the life and health of citizens.

Production control includes laboratory studies of such factors as:

• physical (temperature, humidity, vibration, radiation, lighting and radiation);
• chemical (aerosols, dust);
• biological (pathogenic microorganisms).

The volume and frequency of laboratory tests for each organization will be different and determined taking into account:

• specifics of the organization's activities (production);
• the presence of certain harmful production factors;
• the degree of influence of production factors on humans.

Laboratory tests at workplaces must be carried out at the frequency established by sanitary rules.

Let's consider how often measurements should be taken:

If you decide to conduct production control in your organization, remember that the laboratory involved in research and testing must be accredited in the prescribed manner (Federal Law “On Technical Regulation” No. 184-FZ). There is no other way. It will be illegal to buy measuring instruments such as a sound level meter, psychrometer, lux meter and take measurements yourself.

Although, just for fun, without filling out any paperwork, outside the framework of production control, such a procedure can be carried out if you know how to use the instruments

System for monitoring the state of working conditions and labor protection

The goal of monitoring labor conditions and safety is to prevent industrial injuries and occupational diseases through the implementation of a set of measures.

The organization must, in a timely manner, create and adjust methods for periodically assessing the compliance of the state of labor protection with the current legislation of the Russian Federation and state regulatory requirements in the field of labor protection, organize the development and ensure the functioning of processes for regular monitoring (measuring or recording) the effectiveness of operations that can have an impact on the conditions labor.

These processes should address:

• Carrying out the required qualitative and quantitative assessments in accordance with established requirements and goals of the organization in the field of labor protection;
• measuring the achieved results for compliance with their standard performance indicators and state-established regulatory requirements for labor protection;
• recording of accidents, occupational diseases, emergencies and other evidence of insufficient efficiency of the occupational safety management system;
• taking into account the results of control and measurements for subsequent analysis for the purpose of operational control and development of the necessary corrective and preventive actions;
• examination of the health status of the organization's employees;
• tracking and recording data on the health of employees in hazardous industries.

The organization must have information on the regulatory requirements for verification of equipment and control (measurement) equipment, while ensuring timely maintenance and verification of these equipment. Records of all verifications performed must be recorded and retained.

Monitoring the state of labor protection at an enterprise is one of the main elements of an OSMS and is aimed at:

• checking compliance of workers’ working conditions with state regulatory requirements in the field of labor protection;
• performance by both managers and specialists of their job responsibilities on labor protection;
• identification\prevention of all violations and deviations from the established requirements of state safety standards, as well as rules, norms and instructions on labor protection;
• adoption of a set of effective measures aimed at eliminating identified deficiencies.

It is worth mentioning that in the process of monitoring the state of occupational safety conditions, it is necessary to analyze the results of certification of workplaces, assess the safety of production as a whole, and the effectiveness of collective and individual protective equipment.

Main types of control:

• administrative and public\operational control;
• departmental control;
• state control;
• public control.

Administrative and public\operational control

As a rule, this control is two- or three-stage.

The first stage should be carried out by the direct supervisor of the work, who can be a foreman, shift engineer, mechanic or foreman, directly on the site, every day before the start of work\during the shift. The inspection covers the condition of workplaces and the serviceability of equipment, tools or fixtures, the operation of ventilation units and the condition of sanitary facilities. To this we will add checking the availability of instructions and posters on labor protection, the availability and serviceability of individual and collective protective equipment, work and medical clothing. If deficiencies are detected, measures must be taken to eliminate them, followed by an entry in the journal.

The second stage - operational control is carried out by the head of a structural unit, for example the head of a workshop, laboratory or medical service, with a representative of the occupational safety committee/commission and occupational safety specialists or other services of the unit. The frequency of this inspection is at least once a month, and the day is selected based on the inspection schedule.

Monitoring the state of labor protection conditions at the second stage, in addition to the list of items at the first stage, includes checking:

• serviceability and compliance of production\auxiliary premises, equipment and transport (lifting) equipment with safety requirements;
• timeliness of the required surveys or tests of protective equipment and equipment, work and medical clothing, lifting machines and mechanisms;
• timeliness of preventive inspections, repairs, etc.;
• timely implementation of activities in accordance with certification of workplaces, etc.;

Deficiencies discovered during this inspection are eliminated and subsequently recorded in the journal. If it is impossible to carry out certain activities, a memo must be issued addressed to the chief engineer.

The result of the inspection is an order for the unit, including specific measures and conclusions.

The third stage is operational control carried out by the chief engineer of the enterprise or its technical director together with the chairman of the labor protection commission (with the head of the labor protection service and other specialists of the organization). Frequency: at least once a quarter.

Monitoring the state of labor protection conditions at the 3rd stage, in addition to the list of positions of the 2nd stage, checks:

• implementation of a set of measures to eliminate deficiencies identified during the II stage of control;
• implementation of planned measures carried out to improve conditions and labor protection, including measures from the “Labor Safety” section of the collective agreement, measures to respond to accidents. Here we need to add the implementation of orders, regulations and instructions on labor protection, regulations of control and supervisory authorities and recommendations of the commission on labor protection;
• training and testing the knowledge of managers and specialists of the organization’s structural divisions;
• medical examinations and similar therapeutic and preventive measures;
• performing similar tasks included in the functions of heads of structural divisions.

Based on the results of the survey/inspection, an act is drawn up with the subsequent issuance of an order for the organization, which is considered at a production meeting of the inspected structural unit of the organization.

The manager must conduct a comprehensive survey of the state of labor protection of all structural divisions of the organization at least once a year with further discussion of the results of inspections at a meeting or general meeting. The result of the check is an order.

Departmental control

Must be carried out by a higher organization:

• when conducting comprehensive audits of organizations;
• when conducting targeted inspections of the state of conditions in the field of labor protection in subordinate organizations;
• based on statements from employees of subordinate organizations.

State control

State supervision and control over compliance with labor legislation and other legal acts of the Russian Federation containing labor law norms by all employers on the territory of the Russian Federation is carried out by the Federal Labor Inspectorate.

State supervision and control over compliance with the rules for the safe conduct of work in certain industries and in a number of industrial facilities, together with the federal labor inspectorate, is carried out by authorized federal executive bodies, which exercise control and supervision functions in this field of activity.

Intradepartmental state control over compliance with labor legislation and other legal acts that contain labor law norms in organizations subordinate to them is carried out by federal executive authorities, government authorities of constituent entities of the Russian Federation, with the assistance of local governments in accordance with federal laws and laws of constituent entities of the Russian Federation.

State supervision over the precise implementation of labor legislation and related regulations, which contain labor law norms, is carried out by the Prosecutor General of the Russian Federation and the prosecutors subordinate to him in full compliance with the Federal Law of the Russian Federation.

Public control

Based on Art. No. 370 of the Labor Code of the Russian Federation, trade union organizations have the right to monitor compliance by employers and their representatives with labor legislation (and regulations containing labor law standards) and compliance with the terms of collective agreements and agreements.

Employers must, within a week from the date of receipt of the request to eliminate violations identified during inspections, inform the relevant trade union body about the results of consideration of this request and the measures taken in connection with this.

Trade union labor safety inspectors or authorized persons from trade unions have the right to:

• exercising control to ensure that employers comply with labor legislation and other regulations containing labor law norms;
• conducting independent examinations of working conditions at the enterprise to ensure the safety of its workers;
• participation in the investigation of industrial accidents and identified occupational diseases;
• obtaining operational information from managers and other officials of organizations and employers - individual entrepreneurs about the state of labor protection conditions and all occupational accidents (occupational diseases);
• protection of the rights and legitimate interests of trade union members regarding issues of compensation for harm caused to their health at work;
• requiring employers to suspend work in cases of immediate threat to the life and health of workers;
• sending employers submissions for prompt elimination of identified violations of labor legislation and other regulatory legal acts that contain mandatory labor law norms for consideration;
• checking the state of conditions and labor protection and fulfilling the obligations of employers, which are provided for by collective agreements and agreements;
• participation in the work of commissions assembled for testing and commissioning of production facilities and means of production as independent experts;
• participation in the consideration of emerging labor disputes that are related to violations of the labor legislation of the Russian Federation and other regulations relating to labor law or obligations under collective agreements and agreements related to changes in working conditions;
• participation in the development of draft federal laws (FL) and other regulatory legal acts of the Russian Federation, its constituent entities, local governments, which contain labor law standards;
• participation in the development of draft by-laws, which contain state regulatory requirements in the field of labor protection, their coordination in the manner established by the Government of the Russian Federation;
• appeal to the relevant authorities to bring to justice persons who are guilty of violating labor legislation and other related acts, concealing the facts of industrial accidents.

In order to ensure public control over the observance of the legal rights and interests of workers in an occupational safety organization, authorized or trusted persons in the field of occupational safety from a trade union or work collective must be elected in all its structural divisions.

These authorized persons have the right to unimpededly verify compliance with labor protection requirements and make proposals for elimination of violations of labor protection requirements identified during inspections, mandatory for consideration by the management of organizations or employers - individual entrepreneurs.

When using the recommendations of the Ministry of Labor of the Russian Federation, organizations can develop regulations on authorized representatives who can fully take into account the specifics of forms of ownership and economic activity.

In the process of organizing public control over labor protection in an organization, it is not superfluous to take into account that the successful implementation of assigned tasks (functions) by authorized representatives may be possible subject to the provision of the necessary assistance to them by the management of the organization, trade unions and other representative employees authorized for this purpose. bodies, state control and supervision bodies, as well as trade union inspections.

The institution of authorized representatives is necessary to organize public control over compliance with the legal rights and interests of enterprise employees in the field of labor protection, regardless of the scope of their economic activity, departmental subordination or number of employees.

The number of authorized representatives may increase - it depends on the specific production conditions. The number, procedure for electing authorized representatives and their term of office are stipulated in a collective agreement or other joint decision of the employer and the representative body of employees. Elections of commissioners, in most cases, are held at a general meeting of the labor collective for a period of at least two years. You should not elect authorized employees who, due to their positions, should be responsible for labor protection in the organization.

Authorized representatives are often members of the labor protection committee/commission in the organization. They organize their work in cooperation with the heads of departments, elected trade union bodies or similar authorized employees, with the labor protection service, with state labor protection supervisory authorities and inspection from trade unions.

Authorized representatives report to the general meeting of the team that elected them and can be recalled before the expiration of their powers in accordance with the decision of the body that elected them, provided they fail to fulfill the functions assigned to them or do not show due demands for protecting the rights of workers in the field of labor protection.

Occupational safety representatives of trade unions and other representative bodies authorized by employees of organizations must undergo mandatory training and testing of knowledge in the area under consideration in training organizations of federal executive authorities, executive authorities of constituent entities of the Russian Federation in the field of labor protection.

Necessary documents for organizing production control

What documents will you need?

• production control program (plan);
• report (laboratory research protocols) of production control.

Production control can be carried out only in accordance with the production control program (plan) (hereinafter referred to as PPK) , approved by the head of the organization.

What should the PPC include?

• a list of methods for controlling production environment factors in accordance with the activities performed;
• a list of production control objects, indicating the control points at which samples are taken (laboratory tests are carried out);
• a list of chemicals, biological and physical factors for research;
• frequency of sampling;
• list of employees subject to medical examination;
• list of accounting and reporting forms;
• a list of preventive measures, the implementation of which is necessary to comply with sanitary rules and hygiene standards.

The production control program (plan) is drawn up taking into account the type of activity. Therefore, it would not be correct to simply copy it from another enterprise.

You can also order the development of a Production Control Program from our company.

Necessary changes or additions to the production control program (plan) are made when production technology changes, or other changes occur in the activities of a legal entity, as well as sanitary legislation.

Stages of production control at a hazardous production facility

The procedure for analyzing the state of production and searching for problem areas can be carried out either by the company’s own engineers or with the involvement of third-party specialists. The specific procedure for conducting production control at hazardous production facilities will be developed individually for each project. It takes into account the technical features and nuances of the field, but the general scheme is as follows:

• preparation of a control program within the framework of the legislation of the Russian Federation and in accordance with industry rules;
• carrying out chemical and physical calculations. Analysis of operating parameters of industrial premises: temperature, noise, humidity, radiation, vibration. Checking the condition of consumables and waste with control of the order of maintenance and disposal;
• checking working conditions and health status of workers. Determination of possible occupational diseases and the level of injury to personnel, assessment of the current state of health, determination of possible potential damage, verification of sanitary standards and working conditions;
• generation of the final report. Displaying the results of tests and inspections carried out, preparing a final assessment of the condition of the facility and working conditions, providing data on possible fines for production control in the organization in case of serious violations, developing measures to eliminate problem areas, the implementation of which is mandatory.

The finished document will be prepared in accordance with the standards of government services (Rospotrebnadzor, etc.), signed and provided to the manager. It is important to note that the organization of production control at hazardous production facilities is aimed primarily at correcting possible violations, which allows one to avoid penalties and dangerous consequences. Ignoring the results of the work done can lead to serious problems in the future, even threatening the lives of workers.

Responsibility for failure to comply with control

Violation of the requirements of regulatory documents regulating the PC sphere in an enterprise entails administrative liability. Legal entities and individual entrepreneurs are responsible for the timing, completeness and accuracy of organizing production inspections (Article 32 of Federal Law No. 52).

Failure to comply with the current sanitary rules, hygienic standards, or failure to implement preventive measures may result in an administrative fine. The size of the sanctions depends on the category of persons who are held responsible (from 100 to 20,000 rubles). Individual entrepreneurs and legal entities are responsible for suspending the production process for up to 3 months.

Production control issues are an important subject for managing any business area. This is a mandatory and necessary mechanism for every enterprise, requiring a competent approach to organization, selection of responsible persons for the development of documentation, a plan of preventive measures, laboratory tests, and timely response to emergency incidents.

All these issues should be resolved by highly specialized specialists from certified centers. A competent approach shows the importance for management of how effectively production control is carried out. And this is a guarantee of the loyalty of the inspecting authorities, the trust of business partners and a comfortable environment within the team.