Planning

OSHA requires written plans on many safety subjects and on safety itself.  The more written plans employers have that are actually followed, the better prepared you will be. 

Not all employers need to write a safety plan for every subject.  If a construction company never encounters trenching, they may not need a full written plan dealing with trenching. Trenching should, however, be mentioned in some section as a recognized hazard that the company will deal with on a case basis.

A full, strategic, operational business plan contains dozens of categories such as marketing, finances, competitive, HR and more.  We focus here on three specific plans: Safety, Emergency, Contingency.

A good plan should be written, should name the person/department responsible for developing, maintaining and enforcing the plan.  A plan identifies risks, goals and the action that shall be taken to minimize or eliminate hazards. Think about the three P’s: Plan, Prevent and Protect.

A full Safety Plan should include 20 to 50 sub-plans that each cover a specific hazard or action.  A Fire Plan, for instance covers the risks at the facility for fires or explosions. How fluids or compressed gasses are received, labeled, stored and handled. Include how Hot Work (welding, cutting, grinding) are handled and the permitting process.  The Fire Plan should refer to the Emergency Plan which includes what to do in case something goes wrong.

An Emergency Plan is exactly what it implies: what shall be done in case of emergency – if something goes wrong. What part of the building or work site is to be evacuated, who is in charge of deciding on the evacuation and who manages the process.  Where are the exits?  … the alarms?  … the gathering points after evacuation?  How are workers accounted for at the gathering point(s)?

A Contingency Plan is what to do after an emergency.  Most insurance companies require a Contingency Plan.  The best way to write a Contingency Plan is to begin as if everything has been totally destroyed then work backwards to more confined destruction.  Start as if a hurricane, tornado, explosion has just destroyed everything in the company.  Is your data protected by back-up in another part of the country?  [Small business should consider backing up on one of the online pay services such as Mozy or Carbonite.  Google and Amazon offer more limited, specialized storage, but it is free.] 

In the Contingency Plan, answer where you will store equipment that has not been destroyed – a suitable facility may be hundreds of miles away. Who will do the work – employees and contractors may be trying to survive themselves.

Protect your employees and other assets the best you can.  In any case, do not fail to have written plans to cover all of your business.

See our Web site: SafetyRich

Breaking Rules Legally.

Are employers required to follow the rules 100% of the time? Absolutely – except when OSHA says they don’t have to.  It is possible to get variances from OSHA for several reasons: temporary, permanent, experimental, or national defense purposes. There are a few other reasons an employer can present to OSHA which are too complex to discuss here.  One of these is that, following the rule as written would create a condition more hazardous than an alternate method.

Several important considerations apply:

1. The variance must be applied for before the work and granted commences.

2. The conditions must provide a working environment “…as safe and healthful as those required by the standard from which a variance is sought:”

3. Employer is required to train the worker in a) that a variance has been used in meeting the rules of worker safety and b) the hazards they will now face and how to work protected from those hazards.

A company told me that they were only going to be on the roof for 15 minutes to take measurements. Rigging up fall protection would take as long as the work and add an expense that did not exist by not following the rules. They asked if they could just get up there, then get right back down.  My response was that I could not waive the rules, they need to make their case to OSHA. They replied that no worker had been hurt since they had been in business – See: No Trends in Safety below.

It is possible to get a variance (see 29 CFR 1905. 10, 11, 12), but specific conditions must be met. As always, the safety of the worker is the most important factor. It is always easier and cheaper to work safe, by the rules, than to make the call to the new widow or explain to the kids why mommy or daddy is not coming home tonight.

See our Web site: SafetyRich

Before You Hire.

How much do you check out new employees before you hire them?  Ask an employment attorney what is legal in your state or country, but do everything you can to understand who you are hiring.

One client was in a rapid growth mode.  The founder is a publicity hound. He decided it would be good to open a factory in an area of town where he could get some positive press.  The company needed to hire about 50 people right away.  I was working on getting their training program up to date, including the forklift licensing program, so they called me to do a safety class for their new forklift operator and verify his driving skills.

The guy walks in to the office I was using … he is obese.  We had to find a chair with no arms so he could sit down.  When we go to the lift, he could barely fit in the seat.  But that guy could drive.  He played the controls like a fine guitar and he aced the written test. So we licensed him.

On the third day of work he fell (unseen, of course) stepping down a 3” step out of a storage room carrying a case of water.  He hurt his knee and the costs mounted rapidly.  The doctor discovered it was not his first injury to a knee, the insurance carrier found out the guy had been frequently hurt at work.  A few weeks later, the founder decided he was wasting his money, the factory was closed, but the bills for the guy’s knee keep coming on a regular basis.

Being in a hurry cost the company a lot of money.  Be sure to vet your employees. This article gives you a few ideas on what to do: http://goo.gl/QcoKE

After you check them out, train them and make sure your facility is safe!

See our Web site: SafetyRich

Enforcing Real rules.

We stepped in to the factory.  A sign proclaimed “Safety Glasses Required.”  The guy conducting the tour said no, you don’t need glasses if you stay behind the yellow line.  That is a bogus rule.  A yellow line on the floor does not have magical powers to protect your eyes.  A bogus rule is a rule that is enforced only when certain conditions are met by certain people.  A bogus rule is one set to appear to meet the letter of the law – not to protect workers.

Our idea of a safety glasses rule is if you are inside the building you shall wear glasses.  The factory we were touring is a machine shop doing repairs on oil well drilling and casing pipe connectors – heavy pieces of steel. Yet I observed no hard hats nor safety shoes.  Very few of the workers wore gloves.

Which rules are set and how they are enforced can tell you a lot about the culture of a company.  If rules are set because it is the law, much effort will be made to break the rules or only enforce the rules under certain conditions.  If the rules are made to protect workers, the entire culture changes.

See our Web site: SafetyRich

The ROI of Safety.

In the article below (http://safetyrich.blogspot.com/2011/05/cost-of-injuries.html) we point out the true cost of the direct and indirect costs of injuries.  Can money spent on safety actually provide a return on your investment?  Absolutely!

In fact, we can identify several areas of any business which are affected by proper Risk Assessment and Management. Here are 10, you can probably think of others.

Data Management

Contingency Plans       

Workplace Violence (preventing)           

Workplace Culture (behaviors)   

Unions  (exposure to)               

Production                   

Profits                         

Insurance Costs           

Recruiting

Competitive Advantages

At a recent pre-bid meeting, our client (construction company) pointed out that his company had a 2+ year record without a single reportable injury.  No competitor could match that.

As we have said, effective safety programs return four to six times their cost.  Effective is more than putting up a banner saying “We are Safe!”  Effective does not have to be complex, but it does need to include Plan, Prevent, Protect.  Identify hazards at the earliest possible step (see: http://safetyrich.blogspot.com/2011/05/four-levels-of-protection-from-hazards.html below), then train your workers to identify, avoid and report hazards.

Every product or service you produce must make a return on your investment.  Safety is no different.

See our Web site: SafetyRich

Reacting to Fatalaties and Injuries.

Last week, an explosion at Foxconn, a factory that manufactures iPads and iPhones for Apple, killed two people instantly.  Another worker has died since then.  What struck me was the reactions of the companies involved.  Most of the quotes had to do with production continuing.  Really?!?  How about the workers?

Both Foxconn and Apple were quoted as saying they did not expect for production to be greatly affected. A headline at Apple Insider blared: “Foxconn explosion won't greatly affect iPad 2 production for Apple.” The world can breathe easier knowing the supply of the electronic equipment will proceed as planned or nearly so.

As of the time of writing, we have not found a report even listing the genders of the workers who gave their lives.  Not a single interview with the worker’s families has been published: No statements about missing a mother, father, sister, brother, son or daughter.  Somebody misses them.  Are they not as important as production of gizmos?  Apparently not.

In November 2010, Rich Folaron, 57, was welding on a tank at a DuPont facility was killed when the tank exploded.  His  manager said: “…all the safety precautions had taken place that were supposed to take place.” No they weren’t.  If you had done everything right the tank would have had only inert air, the incident would have never happened. All the boss could think of was saying something that would not get him in trouble.  The manager had to call the new widow. Mr. Folaron’s four children wish daddy could come home.

If you have employees – people that report to work every day and put their lives and welfare in your hands, think of them first.  Keep your workers safe and send them home to their families at the end of their work day.

See our Web site: SafetyRich

Safety Meetings.

The first line of a Simon & Garfunkel song is: “When I think back on all the [stuff] I've learned in high school, It's a wonder I can think at all.” A university study showed that college grads, when given the exact same final exams they passed in school, could not score a passing grade five years later. People retain knowledge only as long as they need it and use it frequently.

The same theory applies to safety.  Workers need to be reminded frequently of hazards and protection from hazards. A worker may remember his hard hat, but forget his gloves when handling a sharp piece of steel.  Worse, they forget how to operate a fire extinguisher months (or years) after a class.  Even worse, hey figure something that has not been mentioned for a while is no longer important!  Workers need to be reminded frequently.

One way to keep safety at the front of their minds and awareness is to conduct safety meetings.  Weekly is good, daily (in smaller groups) is better, monthly is the very longest interval.  Get all of your workers together on Monday morning for just five minutes for what is called a “Toolbox Talk” or a “Tailgate Talk.”  Go over a single subject important in your work. 

If someone has been injured since the last meeting, talk about the cause and prevention, but mostly the effect on the employee, their family and on the company.  If the injured employee is in attendance, have them do the talking.  Discuss near misses with equal importance to injuries.

Have your Safety Committee (see: Safety Committees below) involved with the meeting.  Their daily presence is important as a reminder to work safely.

See our Web site: SafetyRich

Making Workers Want to be Safe.

On the side of almost every police car in the US you see the words “To Protect and to Serve.”  Not a hint at catching you doing something wrong, because their first goal should be to keep people safe.

Every person working in safety should have the same goal: to protect workers from harm so they can return to their families.

Every company should have exactly the same goal: First be safe, then be compliant with regulations.

In a previous article here I wrote about the four levels of protection (see below: http://safetyrich.blogspot.com/2011/05/four-levels-of-protection-from-hazards.html).  The fourth level is the worker.  We call that Behavior Based Safety – making sure the worker wants to be safe. 

I made some new friends yesterday who work for a company that manufactures gas detectors (http://www.ldartools.com/). They mentioned that some workers will actually shut off an alarm so they can continue working.

The worker needs several elements to be fully in charge of their own safety:

1. The training to recognize hazards.

2. How to report hazards so they are corrected.

3. Full understanding that the employer would rather have a hazard reported than for the worker to continue with risks.

4. Empowerment to report the hazard without repercussions.

5. What is likely to happen or is going to happen if the hazard is not reported.

An employer should work just as hard at making sure the final level of protection – the worker – is as effective as the other three.

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OSHA Updated Training Requirements.

Even OSHA will admit that safety material is not the very most exciting thing you can teach.  Hard as we try, some things are simply not fun.  When you combine the dry material with trying to make active workers sit for long periods, a safety class can make you want to pull your own teeth with pliers.

Only once did I try to present a 10-hour class in a single day.  Keep in mind that OSHA only allows us to count actual contact hours, so for a 10-hour class, we needed11+ hours.  I decided that would not happen again.  I have refused work where the client demanded a 10-hour course in one day.  Now I can point to OSHA guidelines for Outreach Trainers.  We cannot teach a class more than 7-1/2 hours in a day.  A 10-hour class must be taught over at least two days.  A 30-hour class can be presented in a minimum of four days.

Another new rule is the requirement for training in worker’s “language of understanding” which includes educational level. Make sure they get it, not just hear it.

Many new rules have gone into effect during the past year, including max/min class size, curriculum, limits on use of videos and more.  Make sure your trainer is current and compliant with all regulations.

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Four Levels of Protection From Hazards

US employers spend over $50 Billion on pay & med care for injured workers. By making safety a priority - it can also lead to higher profits.  According to OSHA and ASSE, each $1 invested in safety returns $4 to $6 by lowering costs and improving conditions.  Risk Assessment, followed by proper Management affects many elements of business.

To identify the Return of Investment (ROI) on Safety, we consider each activity of a safety program individually.  The safety industry generally considers three levels of activity: Engineering, Work Process Design, Personal Protective Equipment (PPE) – SafetyRich adds a fourth: the Worker.

Beginning with Engineering, the earlier we assess and manage risk, the greater the return. The concept is easy to understand because the earlier we address potential hazards, the less we have spent on the project and the easier it is to eliminate danger.  When we pass the Work Process Design and issue PPE, it appears as if we have done as much as possible to protect the worker.  But consider one last step we can take toward safety.

Regulations require training to make the worker aware of hazards.  The critical part of this training is to make sure the worker does not blindly wade into a dangerous situation.  The worker must be able to recognize hazards and hazardous situations, then prevent and report them.  No worker should have to trade their life or health for a paycheck.  The worker’s knowledge and empowerment should prevent injuries – the final line of defense.

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Bystander CPR

Each year, almost 300,000 people suffer out-of-hospital cardiac arrests in the United States. Survival rates from these events tend to be extremely low.  Research has shown that bystander CPR can double or triple survival from out-of-hospital cardiac arrest.

Chest compression-only CPR, also known as hands-only CPR, has been shown in studies to be at least as effective as standard CPR with mouth-to-mouth ventilation for adult primary cardiac arrest victims.  Because of its simplicity, hands-only CPR may be quicker and easier for lay rescuers to learn, remember and perform than conventional CPR which is attempted only about a fourth of the time.

From OccupationalHealth & Safety (OH&S) magazine:  Read full article here.

Additional resources:

• Hands Only™ CPR video demonstration: www.youtube.com/watch?v=zuJkRpJ7Fxg&feature=relmfu.
• 2010 Guidelines for CPR and Emergency Cardiovascular Care: www.heart.org/cprguidelines.

Visit our Web site: SafetyRich

Cost Of Injuries.

The true cost of an injury is, of course, human.  In my article posted on www.safetyphoto.co.uk/blog  (see Articles 2), I talk about exactly that concept.  We need to keep in mind that the most important element of safety is for the worker to home to his or her family every evening.  Hilda Solis, the current head of the DOL, says: “With every fatality and serious injury, a worker's family is shattered, changed forever.”

As any business should, it is prudent to pay attention to dollar costs, so let’s look at how much it will cost to get someone hurt.  Use the information here to determine how much you will need in profit to pay for an injury.

According to the National Council on Compensation Insurance, the total direct and indirect cost of an injury is 1:4.5.  An injury with a $1000 costs $4,500 by the time we add in all of the other associated costs.  The average cost of a lower back injury claim is $23,820 according to the National Safety Council.  Using the multiplier, a back injury would cost over $100 grand.  Do you imagine that training on how to lift and some equipment to help with the heavy stuff would be cheaper?

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The Effects of Being Unsafe,

Looking through the online version of a newspaper from Beaumont, Texas, I ran across an article about a demolition company from Houston that had been awarded a contract to tear down an old hotel. Accompanying the article were several large pictures of the work in progress. Someone at the demolition company took time to prod the newspaper to write an article about their success.

On close inspection of the pictures I noted almost a dozen safety violations.  Despite working with jagged concrete and steel, none of the workers wore hardhats, gloves, safety glasses or (ones I could see) boots.  Some were working close to a crane including under the boom.

What does that say to the community, competitors, prospective clients or OSHA?  What is the image they portray?  I called the contractor several months ago, the guy has yet to return my call.

Between appointments two days ago I drove by a small shopping center where two men were working in a truck-mounted boom lift removing a sign about 12’ above the ground level.  Neither of the young men wore fall protection, but they did have cool sunglasses.  I drove around to take pictures and noted their truck emblazoned with the company name.  I found the company online and wrote the owner a note telling him what I had observed.  He called me within a few minutes. Now that guy cares about the image of his company.

What does your safety program or record say?  “We care about our workers and quality so you can rely on us to do a good, safe job.”  Or: “We do not really give a flip about safety so we can be the low bidder and expose you to a lawsuit.”

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No Trends in Safety

"Success is a lousy teacher. It makes you think you know what you're doing." - Bill Gates

A few years ago I was asked to spend some time with a company that had recently fired its safety manager.  For two years or more the guy had simply been marking time, taking credit for other’s work.  One of the first things we did was to implement a policy of the workers wearing safety glasses.

A manager of one manufacturing department told several of his people that they did not have to wear glasses because they had never had an eye injury.  He prepared a very impressive spreadsheet for me to demonstrate that they had not had an eye injury in the past few years.  That is very nice, but completely meaningless.

Injuries are not like horse races – history is absolutely no predictor of the future.

The four levels of protection from hazards is the subject of another article, but most agree that Personal Protective Equipment (PPE) is effective.  Bulky, hot, uncomfortable, possibly.  But effective in protecting the various body part which are commonly exposed to danger.

A vehicle seatbelt is probably the best example of PPE we wear daily.  I had driven for over 20 years before manufacturers began installing seatbelts as standard equipment.  When the government began mandating that we actually wear them, many grumbled about how they were restricting, uncomfortable, etc.  I would venture that most of you know at least one person who has had a car accident where injury was minimized or death prevented by the seatbelt.

But it never had before.  Like Mr. Gates said, not being hurt made many think they knew what they were doing.  Make sure you and your workers are protected the first time something happens.  Their family is waiting for them at the end of the day.

See our Web site: SafetyRich

Job Hazard Analysis

A Job Hazard Analysis (JHA), sometimes called a Job Safety Analysis is a detailed breakdown of individual work tasks, the recognition of associated hazards and preventative actions to be taken to protect the worker.  You can make a JHA as simple or as complicated as you wish.  There is only one absolute: it must be complete.

While I make no argument with those who want to make a complex, complicated JHA, I tend to the simple.  Simple to make, simple to follow.  Albert Einstein said: “Everything should be made as simple as possible ... but not simpler.”  And he was way smarter than I am. I like to use a three-column Excel spreadsheet.  Column 1 is Activity/Operation. Column 2 is Hazard.  Column 3 is Preventative Action.  As long as the worker goes home safe, it really does not matter what you call them.

For illustration, I will use job I demonstrate in my classes on doing JHAs: making a sandwich – let’s say a peanut butter & jelly sandwich.  We shall begin with two pieces of bread, so Col 1 says: open the bread wrapper, Col 2 says: muscle injury (from twisting), Col 3 says: minimize turns, use a tool to assist.  Go on from there.  The important element is that you must see every single action necessary to make the sandwich. 

In my class I ask for someone to call out the first step in making the sandwich.  Almost always, someone says: “Put the peanut butter on the bread.”  I take the full jar of peanut butter and cram it down on the loaf of bread. They say: “No, you must get the bread out first.” So I rip the plastic bag open (imagine bread flying), grab several slices out of the middle, cram the jar of peanut butter down on them.  By this time, everyone has the idea that it might be better to break everything down.  And that is exactly the point.

No step is too small.  Every single action by a worker has associated hazards and the actions we should take to prevent injuries.  Do not forget the activities that can protect from many hazards over time: proper PPE, housekeeping.

Every worker deserves to be safe. Part of our job with a JHA is to figure out what will harm him or her, then prevent the hazard or protect from damage the hazard can cause.

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General Duty Clause

OSHA’s General Duty clause is just a few words with a simple meaning, yet sweeping in power and importance.  The General Duty clause is intended to cover everything not covered by other regulations.

Section 5 of the OSH Act of 1970 says simply that a) the employer shall furnish a workplace free of recognized hazards and b) shall obey the law.  Read it here…  (http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=OSHACT&p_id=3359)

In every class I teach, I ask the students learn to walk in to work every day, look around and ask: “What will harm me here, today?”  The employer should continually ask what hazard is in the workplace that is likely to cause death or serious physical harm to the employees.

Learn to spot all hazard regardless of how small or innocent-looking the situation may be.  Look carefully at the picture below.  List the hazards you spot.  I see six definite hazards and four more which possibly exist.

My list:

1. Cleats on roof are not proper fall protection after June 2011. Not very good before, but a violation after.

2. Two men on roof not wearing proper fall arrest harnesses.

3. One man on roof has no hard hat.

4. The makeshift “scaffold” is prohibited.

5. The site is a housekeeping mess.

6. None of the workers have safety glasses.

Possible hazards:

7. Ladder type and use.

8. Do not see a Ground Fault Circuit Interrupter (GFCI) in use.

9. Appears to be loose gear or tools on the roof.

10. Workers are wearing shorts – significant exposure to cuts and abrasions.

How many did you spot?  Did you see any hazards I missed?

Some of the hazards we come across on a daily basis seem so small, but can cause significant injury. If one of the men on the roof slips even a little, he could fall to the ground where he could hit his head on the way down or on the mess of trash under him.

Many will complain that OSHA will find something.  They probably will because they are looking for all hazards, not just the obvious ones.

Have a safety professional look carefully at your facility and show you how to spot hazards.  Learn what the law allows and prohibits.  More important, protect your workers.  You want to go home each night to your family – so do they!

See our Web site: SafetyRich

Safety Committees

Safety Committees greatly expand the presence and influence of the safety department.  A Safety Committee can act as a two-way communication device for the safety department: taking information and the safety message to workers, bringing input back for action.

The Safety Committee:

• notes areas of potential improvement in the safety environment
• makes recommendations for the implementation of changes that improve the safety environment
• influences other employees to comply with safety requirements
• encourages other employees to work in a safe manner
• influences management support of the safety effort by the EHS Department

Select a small number of employees. One client of mine with 800 employees invited over 25 people to participate – that is too many, but there is no exact formula.  Normally, a group representing 2% to 5% of the employees will be just about right.  Select people who have influence over others.  Select lead employees vs supervisors.  Supervisors are OK if they are supportive of safety, but inviting conflict is not the best choice.

Have the Safety Committee meet regularly.  Once each month should be about right unless they are assigned a special project.   Having the Safety Committee wear distinctive dress is good – hat, vest, badge, etc. – something to make them stand out.

Caution:  Do not ask questions you do not intend to answer.  If you sell the Safety Committee as a solution, treat everything they bring you seriously.  You will get a share of goofy suggestions, but you do more harm by not addressing an issue than you do by ignoring it in the first place.

Train the Safety Committee to do inspections of their own work are and those around them.  At the start of your monthly meeting, do a walk-through of a section or the entire facility.  Discuss the inspection findings at the meeting.

Contact us at: SafetyRich@gmail.com

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Fall Protection For Residential Builders.

In June 2011, the OSHA regulations requiring residential builders to use proper fall protection begin.  It is not actually a new rule  The way OSHA explains it is a “new directive withdrawing a former one that allowed residential builders to bypass fall protection requirements.”  Since 1995 residential builders, because of concerns about the feasibility of fall protection in residential building construction, have been able to legally ignore fall protection requirements citing feasibility, cost and other arguments against safety.

Late in 2010, OSHA issued compliance directive STD 03-11-002 Fall Protection in Residential Construction. This directive rescinding compliance directive STD 03-00-001 which gave residential builders permission to essentially ignore 29 CFR 1926.501(b)(13).  Although, the directive also says where residential builders find that traditional fall protection is not feasible in residential environments [the regulation] still allows for alternative means of providing protection.

“Fatalities from falls are the number one cause of workplace deaths in construction. We cannot tolerate workers getting killed in residential construction when effective means are readily available to prevent those deaths,” said Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels. “Almost every week, we see a worker killed from falling off a residential roof. We can stop these fatalities, and we must.”

We see much of the flexibility in compliance – “alternative means of providing protection” – as relating to the limited availability of tie-off points for the workers.  Many companies have developed creative, moderate cost solutions to the tie-off issue.  Some new homes are being built with tie-off points at the roof peaks for use during the new construction, then left in place for tying off during future repairs.

The bottom line is that residential builders will have to comply with a law they have been able to ignore for the past 16 years.  And they are not happy at all about being forced to protect the workers.  One builder association recently took the case to the Supreme Court – and lost.

On the other hand, for a few hundred dollars, everyone goes home to their families each evening.

SafetyRich