How to Avoid MOL Work Orders for Racking

Who wants to get an MOL Work Order for racking?  Don’t know of any company that is thrilled about receiving an MOL Work Order for racking.  MOL refers to the Ontario Ministry of Labour.

Getting an MOL Work Order is not something to look forward to.  For one thing, it usually comes with deadline(s).  And, the timing of the Work Order might not be the most convenient time for your manufacturing or warehouse operation. 

Also, the scope of the Work Order could likely result in higher costs than would otherwise be the case if proactive steps were taken, in order to ensure that basic rack maintenance and proper documentation were taken care of.  

Based on personal experience with racking safety, racking inspections and PSRs, all of the MOL Work Orders for racking that the writer has been contracted to address so far, were more or less justified, i.e., there were valid reasons why the MOL Work Orders were issued. 

This article provides general ideas and suggestions on some of the things that can be done in order to reduce the likelihood of getting stuck with an MOL Work Order for racking.  Important things to consider include documentation and optics, and this article sheds some light on both.  

When an MOL inspector shows up at a manufacturing or warehouse operation and observes that there is racking, the inspector would likely ask to see documentation.  If there is some documentation, preferably signed and sealed by a Professional Engineer, it might help in avoiding an MOL Work Order for racking. 

Of course, the documentation has to be up-to-date, i.e. it has to address not only the original installation of the storage racks, but also changes that might have been made to the racking configuration over time. 

It is understandable that, in some situations, where racking might have been installed prior to October 2000 and no major changes were made over the years, there might not be any meaningful documentation to present to an MOL inspector. 

In this scenario, the rationale that the racking system has been ‘grandfathered’, i.e., installed prior to regulation related to Pre-Start Health & Safety Reviews, which came into effect in October 2000, does not really help.

So, what documentation are we talking about?  Appropriate documentation for racking includes a layout drawing of the storage racks, racking specifications, and allowable load capacities for beam levels. 

If there is no documentation and load capacity labels are not applied to beam levels, there is a high probability that an MOL Work Order for racking might be issued, should an MOL inspector show up at the facility. 

Commonly seen in warehouse and manufacturing operations are Selective Racks, with upright frames, beams, safety bars and/or wire decks.  It is worth noting that there are several other types of storage racks, including Drive-in/Drive-through, Pallet Flow, Pushback, and Cantilever Racks, each with its own unique characteristics that need to be addressed. 

It is worthwhile to document existing storage racks in warehouse or manufacturing operations with the view that, over time, some racking components might get damaged and need to be repaired or replaced. 

In this regard, it is helpful to have drawings prepared in a way that racking components in the entire facility can be referenced, so that deficiencies can be easily identified, located and corrected. 

In addition to layout drawings, there is a need to know the maximum allowable load capacities for various storage levels.  If the racks were installed a long time ago, and there are no records that indicate what the load capacities were at the time of the original installation, some outside engineering assistance might be needed.  Due diligence is required. 

Labels indicating the maximum allowable load capacities per beam level should be placed on the racks so that they are visible to plant and warehouse personnel. 

When obtaining racking documentation, it might be a good idea to consider having the racks inspected at the same time so that deficiencies can be noted, and corrected. 

The matter of racking inspection brings to mind another important issue to address before an MOL inspector shows up at your facility, and that is optics. 

It is fair to say that optics can be a factor.  What is the general appearance of the racks?  Are there obvious signs that some things are not quite right about the racks?  For example, missing safety pins are easily detected by MOL inspectors and, combined with a few other questionable items, such as damaged or modified front posts of upright frames and missing load capacity labels, could easily trigger an MOL Work Order for racking. 

It is common in warehouse and manufacturing operations for forklifts to impact storage racks.  It is likely a daily occurrence in some operations.  At times, forklift impact is minor; at other times, forklift impact causes severe damage to storage racks. 

Generally, forklift impact that causes damage to storage racks is not reported by forklift operators.  As such, periodic inspection of the racking becomes a necessity. 

While racking inspection services are available from outside sources, there are some basic things can be done in-house in order to keep your racking in good repair.  A visual overview of the racks, performed on a periodic basis, in order to identify damage that might have occurred, as well as missing safety pins, can help with optics, i.e. elimination of obvious deficiencies by identifying and correcting them on an on-going basis. 

Inspection of existing storage racks, identification and correction of deficiencies, as well as updated documentation, play an important role in keeping racking in warehouse and manufacturing facilities well-maintained.  Proactive measures, such as these, can help your company avoid the hassle of dealing with an MOL Work Order for racking.

Jack Jagernauth, P.Eng. is a project engineer with Rack Inspections Ontario, an engineering company providing services related to racking safety, racking inspections and PSRs. He may be reached at 905-847-3640 or jack@rackinspectionsontario.ca, or through the company website: www.rackinspectionsontario.ca