Risk Management - Part 3 of 4

In a Trade News Release issued on 15 February of 2011, OSHA issued the Enforcement Guide for PPE to provide enforcement personnel with instructions for determining whether employers have complied with OSHA personal protective equipment (PPE) standards.

OSHA's PPE standard (29 CFR 1910.132[h]) says that employers must pay for most types of PPE when used by employees exclusively in the workplace – not for personal or off-hours use.

The general rule is that the employer must pay for PPE whenever an OSHA rule explicitly requires it, such as for respiratory or hearing protection.

OSHA's "employer pays rule" also mandates that you pay to replace required PPE on a regular basis. But you don't have to pay to replace PPE  still in safe condition.

Sometimes an employee decides to buy their own PPE. If an employee buys their own PPE and it is suitable (compliant) to use at work, you are not required to reimburse the employee. For instance, an employee may decide to upgrade the quality of their safety shoes.  The employer is not required to reimburse the employee for the upgrade nor to replace the boots with a similar product when worn.

You also don't have to pay for replacement PPE if the employee has lost the item due to negligence or has intentionally damaged the PPE (1910.132[h][5]).

OSHA recommends that you establish a policy to clarify PPE payment and replacement rules so that both employees and supervisors understand requirements concerning matters such as:

• Define normal wear and tear - what service life to expect.

• PPE which is lost or damaged due to negligence (vs. uncontrollable circumstances).

• How to properly use, maintain and store PPE.

• Company position on use of PPE for personal activities which are not related to work.

OSHA’s final rule to revise the personal protective equipment (PPE) sections of its standards: http://edocket.access.gpo.gov/2009/E9-21360.htm

http://www.osha.gov/OshDoc/data_General_Facts/ppe-factsheet.pdf

http://www.osha.gov/OshDoc/data_BloodborneFacts/bbfact03.pdf

See our Web site: SafetyRich

Spotted! #3.

This was taken at a historic high school just a few blocks for my house. I heard two men talking and turned around to see this scene.  The building is a beautiful Art Deco style which was recently remodeled.  The word “Auditorium” in large aluminum letters can now be seen on the overhang where the men are standing.

Simply, the two primary violations are:          1. The wrong ladder was used for access. an extension ladder would have been a safer choice. When the worker is stepping between the roof and the ladder, there is a good chance the ladder will fall away from the structure.

2. The second obvious violation is that the men are working more than six feet above the lower level without Fall Protection.  The roof of the structure is easily accessible and has several suitable anchorage points.

The other violations are not so obvious. A simple assessment of the hazards of this work could have been completed in very little time. The workers could then be trained in the hazards they would face and how to protect themselves from the hazards. Proper planning, supervision and training would have prevented these workers being exposed to serious hazards.

The building is on the campus of Lamar High School, a part of the Houston Independent School District – one of the largest school systems in the country. It is surprising that a school system would have such a failure to address safety issues and protect its workers.

These men have families who would love for them to come home at the end of each day. What project completion schedule was so important that it overruled common sense and the need to protect the workers?

See our Web site: SafetyRich

Risk Management - Part 2 of 4.

From Engineering in Part 1, we move to Work Process Design in the progression of eliminating or minimizing hazards to the worker. Each step is increasingly more difficult, complex and expensive than the prior step. Where we looked at the overall project in Step 1, we now look at the individual tasks with the goal of minimizing worker exposure to specific hazards we could not eliminate.

In the Engineering step we identified the safest possible material which could be used. In Work Process Design we consider tools, aids and guards (below) to isolate the worker from direct contact with the work or material; or to isolate the worker from the work point where the tool contacts the material.

Tools might be the actual tool to do the work such as cutting, scraping; or a power tool to replace a hand tool. Select tools which are effective in doing the work and isolate the worker from hazards wherever possible. A tool might be used to reach into a machine to insert or adjust material. A tool might be a large machine such as a crane or forklift.

Aids are items which not only minimize obvious hazards, but reduce the chances or ergonomic injuries such as proper seating/positioning and lift tables. An aid in Work Process Design might be simple common sense such as storing heavy objects on lower shelves to minimize lifting.

Guards may be on the machine or equipment, or they may be work on the person, such as a face shield. Face shields come under the category of PPE which we cover in Part 3 of this series. Guards are required on machines to protect the worker from exposure to hazardous tools and work points. See http://safetyrich.blogspot.com/2011/06/spotted-2.html for an extreme example of the failure to use guards to protect the worker.

If you have an example of a task where you are deciding on a solution to protect the worker, let us help.  Send your question to: SafetyRich@gmail.com. If it is an existing situation, a picture or video can help. This service is to help the worker, so we conduct the analysis at no charge, with no obligation.

The process of Risk Management is to protect the worker from harm. We begin by Engineering safety into the project. Then we do Work Process Design to make the task safer. When we reach a point where hazards can no longer be eliminated or minimized, we provide Personal Protection Equipment (PPE) to protect the worker.  Part 3 of 4 discusses the selection use and maintenance of PPE.

See our Web site: SafetyRich

Risk Management - Part 1 of 4.

In May 2011 (http://safetyrich.blogspot.com/2011/05/four-levels-of-protection-from-hazards.html), we wrote about the four levels of activities which will protect workers. We called the first one Engineering because it comes in at the very start of a project. The best time to introduce this step into the process is as the bid is being prepared.

A primary axiom in Risk Management is that the earlier you consider action, the cheaper and more effective it is.  That speaks directly to the benefit of considering actions to improve safety.

When the Project Manager (or whoever is preparing the bid) looks at the specifications and other details of the project, the site, type of work, equipment and material is considered.  Required worker skills are determined. This is the time to focus on safety – early, before money has been spent and other resources committed to the project.

We begin by identifying the Probability of Occurrence – how likely it is that an event will occur. The next step is to identify the Severity of the harm or danger should the event occur. A fatality typically has a low probability of occurrence, but a high severity. On the opposite end of the injury spectrum, a small cut or abrasion has a high probability of occurring, but a low severity.

Now let’s get to the task of making the job safer. First, list all aspects of the work from high to low risk. Second, list everything that could go wrong – include worst case scenarios. Finally, decide how the risk is to be eliminated or minimized – Risk Management – in the next two steps: Work Process Design and protecting the worker with PPE when the hazards cannot be totally eliminated. We will cover those two in later articles.

See our Web site: SafetyRich

Incident Investigation from 350 Miles.

As a witnesses in court cases, and as safety consultants, we are often required to analyze incidents from a distance. Monday (20 June 2011) morning, a Suspended Scaffold fell onto a Self-Supported Scaffold in Abilene, Texas. This analysis is based on written and televised accounts.

According to the accounts, a Suspended Scaffold (also called Swing Stage) fell onto a Self-Supported Scaffold, trapping two workers, causing minor injuries to both.  One televised account is here: http://www.ktxs.com/news/28302198/detail.html.

Note that the “eyewitness” interview in the report has his hard hat on backwards. That is a violation because the helmet was not designed to worn like that, so it prevents the suspension system from properly protecting the worker. Worse than putting the worker in danger is that it can be an indicator of the safety culture (or lack thereof) of the contractor.

Most important is what we see involving the Suspended Scaffold.  It is a near impossibility for a Suspended Scaffold to fall if the anchor system and installation are done according to OSHA and industry regulations. A Suspended Scaffold has a lifting hoist connected by cables to beams on the roof. The beams are counter-weighted and should have a safety line anchored to the building.  The entire system has at minimum a four times (4X) safety factor. For a Suspended Scaffold to fail, several redundant, over-designed systems must all fail.

The workers are, by law, required to have a Personal Fall Arrest System consisting of a harness and a lanyard, connected to a lifeline which is anchored separately from the scaffold rigging. If the worker in this incident had been properly tied off, he would not have fallen with the scaffold.

It does not take a trained safety professional to see that these workers were extremely fortunate.  They were very likely not properly trained, they were certainly not properly rigged.  Their employer simply put profits, speed and expediency ahead of any concern for their lives.

Don’t be that company. Follow the rules designed to keep workers safe and allow them to return home after their work shift.

See our Web site: SafetyRich

Predicting incidents.

We love to use this poignant quote whenever anyone says “we’ve never had an accident/fire/injury/claim/problem”:

“When anyone asks me how I can best describe my experience in nearly forty years at sea, I merely say, uneventful. Of course there have been winter gales, and storms and fog and the like. But in all my experience, I have never been in any accident … or any sort worth speaking about. I have seen but one vessel in distress in all my years at sea. I never saw a wreck and never have been wrecked nor was I ever in any predicament that threatened to end in disaster of any sort.”

Edward J. Smith, 1907
Captain, RMS Titanic, 1912

Captain Smith was planning to retire after the maiden voyage of Titanic.  He is also quoted as saying: “This vessel could be cut in halves and each half would remain afloat almost indefinitely. The non-sinkable vessel has been reached in this wonderful craft.”

Not too much has changed in 100 or so years and we still find a lot of ignorance and a lack of risk awareness at the site level (We’ve never had a fire, claim, Lost time injury etc).

See our Web site: SafetyRich

Spotted #2

This is why people get hurt: Because their employer simply does not care.

Watch this video demonstration by JWC Environmental (http://www.jwce.com/products/) showing the awesome power of an industrial shredder that will destroy everything:  http://www.youtube.com/watch?v=ibEdgQJEdTA&feature=player_embedded then come back and read what should have happened.

Machine guards: Except when they were feeding canned goods, there was no guard in place to protect the workers from being pulled into the machine.  Several excellent solutions are on the market to protect workers from being exposed to harm.  Also note the loose clothing which can catch in the machine.  Several workers each year suffer amputations and fatalities from being pulled into shredders.

PPE: The workers, for the most part, had no Personal Protective Equipment such as gloves and safety glasses.

I cannot vouch for JWC’s products, but I can vouch for their total disregard to the safety of their workers.  I am sure they had fun making the demo videos. That fun would have come to a sudden and dramatic end had something happened.

They knew the hazards, yet chose to ignore them.

They knew the rules – in some of the shots workers were protected – but chose to ignore them.

The company knew the hazards of exposing workers to the machine, yet chose to ignore those hazards because it was more impressive.

Place the health and safety of workers first.  They want to go home after every shift to their families and hug them with both arms.

See our Web site: SafetyRich