OSHA Hazard Communication Standard and Program

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When the Hazard Communication Standard (HCS) was published by OSHA in 1983, it represented a decade of painstaking, but vital, rulemaking activity.

More than thirty years have elapsed since the rule was published. And yet, HCS remains one of the most important and relevant US occupational safety and health standards. The Hazard Communication Standard (29 CFR 1910.1200), last updated in 2012 for GHS alignment, applies to a wide spectrum of workplaces and industries, and is considered one of the crown jewels in OSHA’s mission to protect workers on the job.

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Come See Us at the 2017 National Safety Council (NSC) Expo September 25-27 in Indianapolis, IN


We’re looking forward to attending the National Safety Council (NSC) Expo in Indianapolis, Indiana this coming September 25-27 and hope to see you there.

We’ll be in booth 1723, so stop by and say hi.

As always, we’ll be demonstrating our Convergence LMS for managing your safety training needs (plus MSHA safety training/compliance needs) and our online courses for health and safety and mining safety.

But we’re also excited to have available two new products you may not yet know about.

We’ll have all the information there for you at our booth. Come by and ask some questions, view a demo, and pick up some brochures to learn more.

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Washington Governor’s Industrial Safety and Health Conference–Presentation on Evaluating Online Safety Training


Hello, readers.

This blog is a supplement or related resources center for a presentation on Evaluating Online Safety Training Solutions I recently gave at the Washington Governor’s Industrial Safety and Health Conference. We have a second blog that functions as a related resources center for the presentation on Effective Safety Training.

If you’re reading this after the conference and you did attend, here are the materials I promised. I hope you find them helpful.

And with that, let’s go on to the good stuff.  Click the MORE button to get started.

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Washington Governor’s Industrial Safety and Health Conference–Presentation on Effective EHS Training


Hello, readers.

This blog is a supplement or related resources center for the presentation on Effective EHS Training I recently gave at the Washington Governor’s Industrial Safety and Health Conference. We have a second blog that functions as a related resources center for the presentation on Evaluating Online Safety Training Solutions.

If you’re reading this after the conference and you did attend, here are the materials I promised. I hope you find them helpful.

And with that, let’s go on to the good stuff.  Click the MORE button to get started.

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Come See Us at the Washington Governor’s Industrial Safety & Health Conference, September 19-20, 2017


We’ll be exhibiting at the upcoming Washington Governor’s Industrial Safety & Health Conference in Tacoma, WA on September 19-20, 2017 and we hope to see you there.

In addition, Jeff Dalto of Convergence will be leading two presentations–one on each day. On September 19, Jeff will lead a presentation on Evaluating Online Safety Training Solutions. On September 20, Jeff will lead a presentation on Effective Safety & Health Training.

You’ll be able to find us at Booth 108 (which is very close to the entrance), except when Jeff is leading presentations. Come see us to learn more about our safety and health training solutions, including:

Go here for more information about the presentation on Evaluating Online Safety Training Solutions.

Go here for more information about the presentation on Effective Safety Training.

And don’t forget to download our free guide to effective safety training, below!

See you at the conference!

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Effective EHS Training: A Step-by-Step Guide

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It’s Flu Season: Here’s a Free Avoid the Flu Course

Flu Image It’s fall in the United States, which means it’s time to think ahead toward flu season, which is coming soon.

Most importantly, because now’s the time to get your flu shot, which takes a little while to kick in before it gives you as much protection as it can.

But also because it’s a good reminder to do things like wash your hands and cover your mouth when you sneeze and stay away from people who don’t do that kind of stuff 🙂

We’ve used some information from our friends at the  Centers for Disease Control and Prevention (CDC) to pull together a free “Avoid the Flu” online course that you can watch as many times as you wish from this blog article as well.

Hope this helps!

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Who Has Hazard Communication Duties on the Job?

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OSHA’s Hazard Communication Standard (HCS) is a broad, horizontal regulation, meaning it impacts almost every workplace and numerous employees within those companies. According to OSHA, that boils down to roughly five million US workplaces and approximately forty-three million employees who are affected by the standard. (1)

Most employers are aware HazCom is an essential element in their safety management systems. They’ve made Hazard Communication part of required onboarding training through safety orientations. And when the standard updated to align with the Globally Harmonized System (GHS) in 2012, employers followed through on mandatory training, to inform workers about the changes in labeling, Safety Data Sheets (SDSs), and terminology.

But the next questions are:

  • What do you do beyond that?
  • Are your employees following through on various aspects of HazCom or is it a somewhat dormant and overlooked safety program in your workplace?

We’ll consider those questions and more in this article.

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GHS Label Requirements, Symbols, and Classifications

OSHA Hazard Communication Label Elements

When OSHA aligned the Hazard Communication Standard 1910.1200 with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) in 2012, it was with good reason. Prior to these modifications, numerous internal and external chemical labeling systems existed, which often meant confusion for workers, delays in shipping and loss of business revenue. This was especially true when products had to be shipped or received across national borders.

Moving to a harmonized system allowed a uniform structure for labeling, as well as hazard information, to be disseminated. Today, over 65 countries share the GHS system. And while each have country-specific versions, the increasing use of the GHS worldwide has brought greater ease and transparency to chemical safety use and shipping.

The merging of GHS with OSHA’s Hazard Communication Standard (HCS) did not replace the regulation. Instead, it augmented the main HCS purpose, which was to convey hazard information to workers in an effective and meaningful way.

That included changes to chemical labeling. Understanding the GHS-aligned chemical labeling that’s now part of OSHA’s HazCom Standard is quite simple, but there are key terminologies and components you’ll need to learn to use the system in your workplace. 

We’ll explain those in this article.

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Convergence Training Wins ISHN’s “Best Safety Training” Attendee’s Choice Award at ASSE Safety 2017

We’re excited to announce that we won the 2017 ISHN “Best Safety Training” Attendee’s Choice Award, a result of voting held during the ASSE’s Safety 2017 conference, for our MSHA Safety Training.

This award is in addition to the earlier 2017 ISHN “Best Safety Training” Reader’s Choice Award, which our MSHA Safety Training won before the ASSE conference.

So as they say, two out of two ain’t bad!

We’d like to thank all the folks at ISHN for putting on the vote, the ASSE for hosting the attendee’s choice voting at their recent Safety 2017 event, and of course all the voters who took part. Especially those voters who felt strongly about our safety training materials. We appreciate the tip of the hat–we work hard on making safety training that makes a difference.

For those of you who don’t know, our MSHA Safety Training includes three different components:

Check out the links above for more detailed course and LMS sample and overview videos, or check the two videos below.

Here’s a short overview of some of our online safety and health training courses:

And here’s a short overview of our Convergence LMS with the MSHA Compliance Package.

Finally, feel free to download the free guide to Online MSHA Safety Training, below.

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Online MSHA Compliance Guide

Download our free guide to learn how online tools can help you create safer work conditions at a mine site, stay compliant with MSHA Part 46 regulations, and manage your training program more efficiently.

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How to Watch a Solar Eclipse Safely

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As you’ve probably heard, there’s a total solar eclipse coming this way soon.

By “this way,” I mean it will be visible in the US from coast to coast. It will first be visible around the Oregon Pacific coast, then it will cross the country until exiting the national stage off the South Carolina Atlantic coast.

And by “soon,” I mean on August 21, 2017. The “totality” of the moon’s shadow will strike around Lincoln City, Oregon at 10:16 am Pacific time and will exit the continent at Charleston, South Carolina at 2:48 pm Eastern time. The entire journey of the totality will take about an hour and a half to cross the nation, and the final glimpses of the moon’s shadow will be visible from the eastern seaboard as late as 4:09 pm eastern time.

An eclipse is an amazing thing to see, and most or all Americans will be able to see this eclipse. Even better, some Americans within a band that’s about 70-miles wide along the path of the eclipse will see its totality–a complete eclipse of the sun. Some say that viewing a full eclipse from within the path of the totality is even more amazing–even spiritual or mystical. Just ask this guy.

The video below explains what an eclipse is. Below the video, we’ve got some tips for watching an eclipse safely. Because remember, you should never look directly at the sun without special protection, even during a solar eclipse, and doing so can severely damage your eyes. 

How to Watch a Solar Eclipse Safely Without Harming Your Eyes

We said this earlier, but it bears repeating: NEVER LOOK DIRECTLY AT THE SUN WITHOUT SPECIAL PROTECTION AT ANY TIME–DURING “NORMAL’ CIRCUMSTANCES OR DURING AN ECLIPSE. Why? Because it can harm your eyes and even cause blindness. You wouldn’t poke your eye with a sharp stick, would you? No-because it can hurt your eye. The same goes with trying to look at an eclipse of the sun without special protection. And NO, sunglasses aren’t good enough.

Are we good with that?

If so, here are some more tips:

  1. Spend a few bucks and buy some specially designed, protective solar viewers. This model is made of paper, costs $10-14 for two (because it’s always best to watch a solar eclipse with a friend!), and is ISO certified: Celestron Eclipse Smart Viewers.
  2. Spend even less and buy some solar eclipse viewing glasses. This article in the USA Today lists 5 reputable, safe pairs, and here’s a larger list from the American Astronomical Society.
  3. Make your own pinhole projector out of two pieces of cardboard. Here are instructions from the Jet Propulsion Lab on making a pinhole projector to view a solar eclipse.
  4. Be extra-safe and watch it on TV. Our friends at NASA will be broadcasting the eclipse live.

Here is more information about this from the American Association of Ophthalmology and the American Astronomical Society.

Hope the eclipse is cool, amazing, awesome, and even spiritual or mystical to you–or whatever you want it to be. But most importantly, we hope you watch it safely.

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Effective EHS Training: A Step-by-Step Guide

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Distracted Driving: Don’t Do It in Washington Or Anywhere Else!

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Distracted driving, including of course texting or holding a phone to talk while driving, is always a bad idea.

We here at Convergence Training wanted to call out the issue in particular for our customers who come out to visit us at our headquarters in Camas, WA. And that’s because the state of Washington recently passed a tough new distracted driving law that can lead to a hefty $136 penalty if you violate it.

According to the article from the Seattle Times linked above, here’s what’s illegal:

The law forbids handheld uses. Not just phone calls, but composing or reading any kind of message, social media post, photograph or data.

Drivers may not use handheld devices while at a stop sign or red-light signal.

All video watching is illegal, even in a dashboard or dash-mounted device.

But this hazard is a serious problem all over the nation, not just in Washington. For example, the National Transportation Safety Board (NTSB) is suggesting a national “no call, no text, no update behind the wheel” ban on this kind of stuff.

Here’s what the NTSB has to say about handheld devices and distracted driving:

New connectivity has enabled new safety technologies. But it has also enabled new forms of distraction, leading to accidents and deaths, even in the most strictly regulated transportation enterprises. Since 2003, the NTSB has found PED distraction as a cause or contributing factor in 11 accident investigations. Those crashes resulted in 259 people injured and 50 people killed. And the NTSB does not investigate the majority of highway crashes. The National Highway Traffic Safety Administration (NHTSA) reports hundreds of such deaths on our highways in 2012 alone. According to NHTSA, drivers engaging in visual-manual tasks, such as dialing or texting, triple their risk of a crash.

So put the phone down and pay attention to the road and the cars and people around you. You’ll be happy you did, and we promise–there’s nothing all that important going on in your phone.

Our Alert Driving Online Training course covers the dangers associated with using hand-held devices while driving plus a lot more. For example, check out the video sample below, which covers the 2-second rule for keeping enough space between your vehicle and the vehicle in front of you.

And hey, if you’re having trouble putting down your phone while driving, you might want to review this article on cell phone addiction.

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Benefits of Preventive Maintenance

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Maintenance can be a major effort at a company, and maintenance costs can chew up a lot of dollars.

And I’m probably telling you nothing new when I say that when maintenance isn’t done, and something breaks, the cost of downtime can be even more significant.

One way to spend less on maintenance in general, and to lose less on maintenance-related downtime, is to practice a preventive maintenance approach.

In this article, we offer a Q&A on some basic topics related to maintenance and preventive maintenance.

Before you begin, you might want to check this short sample from our online Equipment Maintenance and Reliability training course.

Preventive Maintenance: Question & Answer Session

The questions below should give you a good introduction to the practice of preventive maintenance and some reasons to perform it. Our expert for this article is Greg Squires of Maintenance Connections.

Question: Could you tell us what preventive maintenance is, how it’s different from “normal” maintenance, and pick up the relationship of preventive maintenance to asset management?

Yeah, they’re definitely related. So, just to start, if I am a maintenance manager in any type of facility, whether it be a real estate facility with hundreds of units that have assets, or if I am responsible for all of the facilities at a university, with large buildings and electronic equipment that runs the screens in the classrooms, or if I am responsible for a hospital, I am the engineering director, then I have got all kinds of equipment that needs to be managing real life and death, or if I’m running a manufacturing facility and I’m responsible for production lines and heavy equipment, and all kinds of things, and lastly with fleets, cars and trucks and vehicles that need to move around, all of those are simply called assets, and so if I am responsible for those assets, they need to be maintained, right, and so how do I maintain those? I need to follow the instruction manual, every asset for a manufacturer has a recommended preventive maintenance schedule, and that comes in the handbook, or a digital version of a user guide, and it describes that this activity needs to be performed at this interval, on this machine, and here’s how you do it.

So the preventive maintenance on those assets is being proactive to perform those activities before they need to actually get done, and so how do you know when something breaks, when something fails, because you didn’t perform that activity that needed to be done, to replace that belt, to replace that transistor, or whatever it may be. And so preventive maintenance is simply working ahead of schedule and fixing things before they break. It’s very much like replacing the oil in your car, and the air filters in your engine, in order to keep the engine running smoothly, and preventing downtime or breakage.

There is a cost in downtime, especially in manufacturing. Every minute you can equate to an amount of dollars or units you can put out the door, and every minute you’re not up has a discrete cost. And so maintaining your equipment and keeping your systems running is sort of an unsung, heroic job. When everything’s going well, nobody complains, and when things go down, all the fingers get pointed, so that’s a main driver for implementing and driving a really strong maintenance management program, is around uptime.

Question: Can you explain the difference between unplanned maintenance, preventive maintenance, and predictive maintenance? 

Sure. Let’s start with unplanned. Simply put, this is maintenance that hasn’t been previously planned and that is performed because of equipment breakdowns, repairs, etc. It can also be referred to as corrective or reactive maintenance.

Now, let’s consider preventive. Preventive maintenance is performed so that equipment breakdowns, repairs, etc., don’t happen in the first place (or at least less frequently and severely).

And lastly, predictive. Predictive maintenance is based on continuous monitoring and assessments of equipment to understand when maintenance needs to be performed.


Question: What are some metrics companies might want to consider when evaluating their maintenance program? 

The ratio of reactive and preventive maintenance is important. We’ve learned performing more preventive maintenance correlates strongly with increased asset/equipment life and with return on investment (ROI) of maintenance software purchases.

A variety of other metrics can be introduced to understand program performance, from backlog of work orders to percent of scheduled work that was completed (i.e. schedule compliance) to overall equipment effectiveness (OEE) and beyond.

Question: When workers are performing preventive maintenance facilities, especially in a manufacturing facility, what are some of the things they’d be doing?

Repairing and/or replacing defective parts; inspecting equipment using measuring/testing instruments to understand wear and tear; and making adjustments and modifications to functional parts of devices and control instruments.

Question: What are some benefits a company would be likely to see as a result of using preventive maintenance? 

There are many, including fewer machine breakages and downtime, lower costs associated with machine breakages and downtime, increased efficiency of machine operation and therefore production, and longer-lasting machines/equipment. Performing more preventive maintenance can result in increased asset/equipment life, decreased asset/equipment downtime (also known as “uptime”) and other unexpected benefits such as return on investment (ROI) of maintenance software purchases.

Question: What percentage of companies would you say are using preventive or predictive maintenance instead of purely unplanned maintenance?

The data in the chart below comes from roughly 1,000 organizations that participated in our State of CMMS research. We separate the companies into seven different levels, based on their ratio of Reactive Maintenance to Preventive Maintenance.

  • All Reactive (95% or more): 6% of organizations in study
  • 20% Preventive/80% Reactive: 22% of organizations in study
  • 40% Preventive/60% Reactive: 18% of organizations in study
  • 50% Preventive/50% Reactive: 11% of organizations in study
  • 60%Preventive/40% Reactive: 17% of organizations in study
  • 80% Preventive/20% Reactive: 22% of organizations in study
  • All Preventive (95% or More): 4% of organizations in study

The studies shows that few organizations are entirely or nearly entire reactive (only 6%) and few organizations are entirely or nearly entirely preventive (only 4%). Most organizations blend both reactive and preventive maintenance.

Question: I imagine one people talk or think about maintenance, it’s easy to forget the related issues of parts and supplies. How can setting up a preventive maintenance schedule help ensure a proper inventory of replacement parts and supplies? 

Having a well-organized preventive maintenance plan can contribute to better inventory management because naturally, as you noted, you’ll know what work needs to be done in advance, and you’ll know the requirements to complete that work, such as any necessary parts. But, this is just one among many integrated approaches to proper inventory management. And, ultimately…there is a strong correlation with improved parts availability and repair time.

Question: If you’re a company that’s just beginning to set up a preventive maintenance schedule and program, what should you address first? 

There’s not a right and short answer to this question. The first step is nuanced, depends on many factors, and varies depending on who you ask (i.e. maintenance experts/consultants). Some suggest the first step is to assemble a team of key stakeholders; others suggest starting with the end in mind and establishing goals around what you hope to achieve.


Question: Beyond the general concept of “it’s a good idea to do preventive maintenance,” do you have any kind of quantifiable financial benefits of performing preventive maintenance?

Yeah, yeah, there definitely is a tie-in. We have recently done a study that has asked that very question, of over 1,000 maintenance professionals, so you have implemented the software and you’ve worked to become more preventive, so those things sort of go hand-in hand, it is difficult to be preventive without software, and so how would you quantify the savings you’ve had in your program?

Maintenance is a cost center, right? You could spend millions of dollars doing things–like, let’s replace the oil in my car every day. But that would be overboard. So if you think about preventive, you do have decide where you draw the line and so one of the measures is how much savings have you had. So a manufacturing facility can measure savings by uptime vs. downtime, and so, “how much downtime did I have last year, how much downtime did I have this year.” Every minute of downtime has a cost, and so, has our downtime decreased, because we’ve kept our systems running? That is a quantifiable “we’ve prevented millions of dollars of loss by keeping our systems maintained. And then I’ll add one more thing…in a hospital, in a health care environment, this is an environment that is strongly regulated, and so the joint commission is responsible for performing audits of these type of processes, as a in a hospital, you sit there and you’re attached to these machines that are keeping you alive: has that machine been maintained? Has it gotten its regular service? Is it something I can rely upon to keep me alive? That’s why it’s regulated, right? So what is the cost to a hospital of a machine going down? It’s lawsuits, it’s things that they do not want to have to deal with. So there’s a very strong, compelling reason to have good, reliable machines, and to do that you need good reliable maintenance processes, and to do that, you need a good system to manage all that. So, in some ways, you know, the cost is really high, for those types of environments and there’s a great risk, so it allows for appropriate amounts of investments in people, processes, and systems to set your environment up for success.

Question: In addition to managing all the different manuals and recommendations and getting the work done on time, what are some of the challenges that companies face when they decide to go forward on a preventive maintenance program?

We’ve asked that question of our customers as well: what challenges are you facing today, as you’re looking for something to improve, and as you have a program in place, what are your ongoing challenges. So there are a few things. I would say one thing is data: if you’re moving from a place of spreadsheets and access databases, you have to have a way to list all your assets and all your preventive maintenance activities, and get those things loaded into a system in such a way that they’re easy to find and it makes sense to the technicians, so they’ll know “room 202 has asset X that needs to have this valve replaced,” right?

And training is a key, and that’s something relevant to what you guys do and deliver, making sure maintenance technicians know how to perform the maintenance procedures, and providing easy access to the how-to documents, and procedures, for how to perform this replacement of belt in machine X in room 202, and so those procedures are really important, and again, the better they’re written, the better this system can be transferable to 10 and 50 and hundreds of maintenance technicians that may be new to the job or there may be turnover and you need a reliable system in place and not just rely upon domain knowledge of the silver-haired guy who’s been around for 40 years but knows how to fix everything. So training is key.

And I would also say that access to information and reporting is a challenge, right? So I am running some kind of maintenance system, and I’m the CIO, and in the leadership meetings, we’re saying “hey, how’s our uptime, how are we doing with our preventive v. reactive activity, what are we investing? And if the CIO or COO has no way to answer that question, then they are challenged in this discussions, and the business can’t make the decisions they need to make to make things better.

And so that sort of speaks to one other thing that I think is really important in talking about preventive vs. reactive maintenance, and how you progress toward more preventive, and as you asked, well what’s the benefit in doing so. So one of the key benchmarks in maintenance is preventive to reactive ratio, and it is called corrective v. reactive in other environments, but simply put, of all the maintenance activities that were performed in a given month, how many were the ones you planned to do, and how many were unplanned? And that is a measure of how much volatility you have in your systems and whether systems are running well or not, whether assets are healthy or not, and so if you have a bunch of issues, then you’re very reactive, and you don’t have time for the proactive unless you just put in more people. But it is really working, it is a continual process improvement, to work to get the unplanned work to be as small a percentage of your total activity. And what we find is that there is a relationship between higher preventive ratios and greater savings, and so for maintenance programs that are approaching 60 and 80 percent preventive, which means again of all the activities the maintenance team performs, we had 60-80 percent of it dedicated to preventive maintenance, were planned as part of our preventive maintenance process, then you’re seeing the hundreds of thousands and the the millions of dollars being able to be verifiably reported that our program is working well, we’re saving money, and we’re improving our operations and keeping our systems up and running.

Question: Any tips for coordinating efforts throughout departments within an organization?

Yes. If you’re responsible for asset management in your organization, data is critical, so get your data in order. One of the things that I would recommend is, as you think about data, is tying in access and visibility to inventory, and this can be done through a variety of systems, but if you think about this maintenance manager, and he’s responsible for making sure that “belt A” is going to be replaced in Part X in Room 202, then how do you make sure that belt is available in 90 days when you need that preventive maintenance scheduled? So that’s really good data because it will allow you to make sure that you have that product in hand, right?

And to do that, you’ve got to have your systems integrated, so that involves IT, and sometimes maintenance and IT are in the same group, and sometimes they’re in separate groups, operations and engineering and technical, so my recommendation is you need to build allies, you need to work together, you need to have internal stakeholders that have buy-in to make this program better, so if you’re in charge of assets, part of your job is to sell the value in preventive maintenance, and to sort of get ahead of the finger pointing, because what happens when things break is fingers get pointed, and it’s not just that you’re trying to save your tail, but you can’t get stuff done if you don’t have allies, so go build rapport with the technical teams to say “Hey, it would sure be nice if I had greater visibility to that belt in inventory that I’m going to need in 90 days, I can tell you all the things I’m going to need, because I’ve got my preventive maintenance schedule, and let’s make sure those things will be on hand and we have good back-up stock, because what happens is when that belt fails, in an unplanned environment, what if you don’t have that one on hand? You’re not just down for an hour, you’re down for a week until you get it airflighted back to you. So those are a couple of things–data and collaboration with technical teams and building allies makes for a really strong performing maintenance program.

Question: Your company makes a maintenance management software. Can you tell us more about your company and your product?

Yeah. So Maintenance Connection was founded in 1999 and we have built a maintenance software, with over 1,500 companies in health care and manufacturing and city/state government, power plants, are able to manage fleet organizations, so in many verticals, we have delivered a software platform that allows for managing of assets, managing of work orders, the inbound request of work requests, right, a service requester is a critical part as someone in the plant or field or office can effectively raise their hand and say “hey, I need this thing done, can you help?” and that gets routed to the right people and gets done quickly and allows for your service satisfaction to improve. And then of course, moving more toward preventive is an objective and goal of every one of our customers, and so we partner very closely with our customers to work on growth plans to move from their current state of managing assets, managing work orders, and doing what they can with what they have, to having better planning, better labor management, better reports, to be able to know “Hey, these assets are really important for us, these are our critical assets, and if they go down, we’ve got big problems” to prioritize preventive maintenance on those assets.


Conclusion: Preventive Maintenance–It’s Good for You and Your Equipment

We hope you’ve found this introduction to preventive maintenance useful, and we thank Mr. Squires for sharing his knowledge with us.

Let us know if you have any other questions. Otherwise, have a great day.

 

Download the free guide below before you go!

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