Contingency Planning.

As we mentioned in our 31 May post (http://safetyrich.blogspot.com/2011/05/planning.html), OSHA requires written plans on several subject. While OSHA requires an Emergency Action Plan (EAP), Contingency plans are required mainly by insurance companies to ensure their clients are prepared to mitigate loss in the case of a catastrophe.

Experts are reporting the Hurricane Irene that raked up the East coast at the end of the third week in August 2011, caused more loss than any other natural disaster in history. At one time, more than 7.4 million folks had no electricity. One restaurant owner from South Carolina spoke in an interview about how he had more than 80 employees waiting for him to reopen. Thinking about the economic impact of the storm will boggle the mind. Dealing with a disaster is even more difficult if no plan is in place.

Imagine being able to open a plan and start going down a series of checklists and plans that were made when all was well. Plans to restore data, rebuild facilities and restart cash flow.

When writing a Contingency Plan, start with the assumption that a total loss has occurred: a hurricane, tornado, fire or explosion has wiped out everything. Although, as we shall see, all is not lost regardless of the level of destruction – IF planning for the worst case has been done properly.

This list of items is not intended to be complete, but to create a starting point – all companies are different.

DATA – Backing up data to a tape drive that your IT person takes home once a week is a good start, but inadequate in real emergencies. Back up your data as often as possible (how much work not backed up can you recreate in a reasonable time?) to a distant location which is less susceptible to catastrophic events. An online backup to a place 1000 miles away is no farther than across the street.

FACILITIES – Assume your offices, warehouses and storage facilities are completely gone. Where will your employees work? Chances are, their homes are also severely damaged, or without power. By making plans to temporarily move inland, a suitable location can be identified: a hotel, vendor or client’s office. Contact a Realtor in several cities at least 50 miles way, have them identify office/warehouses with vacancies, have agreements in place that trigger short-term occupancy. By making a deal when the sun is shining, you beat everyone else during the scramble.

PRODUCTION: Equipment, tools, raw materials – identify vendors by name, make plans for them to provide you with an emergency supply. If possible, pay for a cache stored at the vendor’s facility or in a storage facility 100+ miles away.

EMPLOYEES – Assume that most of your employees are working on their own homes or with their families. Identify key employees to manage activities using the Contingency Plan, after the disaster. Make plans on communications and make sure everyone has everyone’s phone numbers.

Consider also how you will clean up and rebuild. Companies and residents in the area are also cleaning and rebuilding, the companies that make plans and agreements in advance are the ones that get serviced first, right after the storm.

Now go make the same plans for your own home and family.

See our Web site: SafetyRich

Changing Behaviors – 2 of 2.

In this part we discuss specifics on demonstrating the benefits and affecting the behavior of employers and employees.

For employers, our approach is in three steps.

1. Demonstrate the simplicity, common sense and straightforward nature of safety regulations. The General Duty clause (http://goo.gl/oGkSb) is less than 100 words of pure logic. Read: http://safetyrich.blogspot.com/2011/05/general-duty-clause.html.

2. Make sure the employer is fully aware of the consequences of non-compliance: citations with fines and possible criminal charges. The costs of injuries can be significant. See: http://safetyrich.blogspot.com/2011/05/cost-of-injuries.html.

3. Equate the cost of a safety program and the cost of not being safe to the employer’s boss: the bottom line. Take the total cost of injuries over the last few (3 to 5) years – include direct and indirect costs (read article: http://safetyrich.blogspot.com/2011/05/cost-of-injuries.html) – then divide by the profit from a single unit of work such as a piece of product, an hour/day week, a project. Watch here for a future post on doing this step. Email me (SafetyRich@gmail.com)for details on how to do a calculation for a specific client.

Employees are a bit less obvious on how to manage behaviors, but there are two things we use to help them understand.

1. Family. Hilda Solis, the Secretary of Labor said: "With every one of these fatalities, the lives of a worker's family members were shattered and forever changed. We can't forget that fact."

SafetyRich encourages employers to conduct Safety Orientation classes for new employees. Read the two articles on Training, Part 1 here: http://safetyrich.blogspot.com/2011/06/training-part-1-of-2.html. We have designed the first 20 to 30 minutes to be an overview of the importance of working safe and the consequences of not working safe. This short session is recorded on video, then copied to a CD for the employee to show his family. We send a form with the CD for every family member (especially the kids!) to sign that they watched it. Most people act differently when they are thinking about their family. The family helps put pressure on the worker to be safe.

2. Consequences. Make it clear of how their lives can change with a serious injury. Tie a hand behind their back and have them do simple tasks: tie a shoe, put on a belt, button a shirt, tie a tie, make a peanut butter sandwich. Suggest that they drive home that evening sitting on one hand. Splint two or three fingers, discuss amputations and have them try the same tasks. Have the students read and discuss actual cases. See SafetyPhoto for pictures and case reporting.

The only way anyone changes behaviors is if they clearly see understand the consequences to themselves and others for not working safely.

See our Web site: SafetyRich

Changing Behaviors – 1 of 2.

Reality is that changing behaviors is nearly impossible. Ask any parent who has tried to get a teenager to write a book report when it is first assigned rather than the night before it is due. Ask any employer who has a worker that lives five minutes away, but gets to work ten minutes late every day. Human behaviors are very difficult to change.

Behavior based safety is big business. Most company executives are very smart people, but they spend a lot of time and effort trying to change the behavior of their employees when they, themselves are not motivated by some fairly harsh punishment to follow a few simple, common sense, logical rules.

The business of safety incentive programs is another well-intentioned concept that causes as much harm as good. Commercial trucks are required to pass certain inspections conducted by the Department of Transportation (DOT). When the DOT enforcer pulls a truck over on the highway, it is inspected for compliance. If the truck passes, a sticker is issued to display showing the truck is compliant. The sticker allows the truck to avoid being inspected again in a time period. The driver is rewarded with a $100 bonus. A friend who manages a fleet of trucks reports that, once the drivers figured out that their trucks would pass any inspection, they removed the stickers in hopes of being stopped again – and being rewarded with another bonus.

At SafetyRich, we try to change behaviors by focusing on the things that are important to the employer and the worker, then we present our case in the strongest way possible.

In Part 2 we discuss specifics on demonstrating the benefits and affecting the behavior of employers and employees.

See our Web site: SafetyRich

Incident Investigation & Reporting.

Reporting of incidents resulting in injuries is required by law. Many companies do not investigate anything or merely report the basics of what happened. See: http://safetyrich.blogspot.com/2011/07/view-from-inside-part-2-of-2.html for a brief discussion what most companies do not do, even when serious injuries or fatalities occur.

Incident reporting is far too complex of a subject to cover in detail in this forum.  Make sure that a thorough, detailed  investigation is completed to the point the root cause of the incident is identified and prevention is addressed.

It is important to pause here to note the difference between accidents and incidents. Accidents are completely unforeseen and almost impossible to prevent. A true industrial accident is rare, because seldom does a completely unforeseeable event occur. With sufficient planning, risk management and attention to safety detail, all we have left are incidents.

We have mentioned before the story of Robert. Robert was a maintenance worker at a United States Steel in Pennsylvania who completed a 35-year career to retire without a single, lost-time incident. He did not even have an injury requiring minor first-aid in an industry that has serious hazards.

When investigating an incident, gather details from any injured worker and witnesses. The report should include a timeline that includes the events leading up to and following the incident.

Your report should include an in-depth analysis of the causes of the accident. Causes include:

• Primary cause (e.g., a spill on the floor that caused a slip and fall)

• Secondary causes (e.g., employee not wearing appropriate work shoes or carrying a stack of material that blocked vision)

• Other contributing factors (e.g., burned out light bulb in the area).

You are seeking a Root Cause for the incident. In the above example, the Root Cause might be a spill that was not reported.  A spill caused by a sudden event, such as a burst pipe, would be the cause of a true accident (completely unforeseen), but only for a few minutes until the spill was observed. Unless, of course, the burst pipe was the result of poor maintenance, in which case it was fully preventable.

Finally, focus on the prevention of future occurrences of the incident: How will the company prevent this from happening again? Practice proper risk evaluation methods, conduct job hazard analyses and recommend corrective action: engineering, training, work process design, signs, PPE.

If an incident or near miss is not properly investigated, it is likely to be repeated which could result in serious OSHA violations, injuries or a fatality.

See our Web site: SafetyRich

High Visibility

Thought all high-visibility vests are the same? Look closer.  There are actually three classes of vests:

Class 1 - main identifier is that is does not have closed sides. Sides are closed with Velcro tabs, snaps, ties.

• Use where traffic does not exceed 20MPH and worker can pay full attention to oncoming traffic. Also for use on private property (sometimes called "Private Property" vests).

Class 2 - main identifier is that it is made with "closed" sides.

• Use where conditions require greater visibility and worker's attention is diverted from approaching traffic.

Class 3 - jacket style - fully closed with sleeves.

• Use where traffic exceeds 50MPH and worker must be easily identified as a person through the full range of motion.

Other high-visibility garments are available such as T-shirts and jackets (light to heavy). The primary consideration is to use a High-Visibility when the site has vehicles moving about. Many companies use vests as a “uniform” to designate First Responders, Supervisors, Safety people and others

See our Web site: SafetyRich

O&G offshore regulations.

Update 18 November 2011: According to Oil &  Gas Journal, In mid-November 2011, BSEE anounced it would begin proposed rulemaking procedures to enforce SEMS regulations on offshore Contractors in addition to Operators. Enforcement can begin when rulemaking is complete - expected in late 2012. Read the article.

On 15 November 2011, new regulations go into effect requiring safety and environmental systems for oil and gas exploration and production companies. See 30CFR250.

In September, the Bureau of Energy Management, Regulation and Enforcement (BOEMRE) splits into two entities: the Bureau of Energy Management (BOEM) and the Bureau of Safety and Environmental Enforcement (BSEE) to enforce SEMS and API RP75 standards.

We focus our services on the later - BSEE - providing:

• Compliance tracking
• Safe Work programs (SWPs)
• Job Safety Analysis (JSA, JHA HA) - development & authorizations
• Bridging documents to comply with Operator SEMS programs
• Risk Assessment and Management
• Plans: Safety, Process, Operating
• Competency Models
• Training: General and Specialized
• Confined Space
• Fall Protection
• Hazardous Communications
• Walking & Working Surfaces
• Personal Protection Equipment (PPE)

SafetyRich partners with IHRDC to provide expert consulting, e-learning and tracking services. We provide a number of subject matter experts to offer a wide variety of services to O&G companies.

Write us at SafetyRich@gmail.com for no-obligation intial consultation and answers to critical questions.

See our Web site: SafetyRich

Spotted! #5

As we described in our two-part series on Training published in June, OSHA requires training on initial assignment – before workers set out to their assignments.  If their employer had trained them and made it clear that safety rules are to be followed, it is likely this case would have not occurred.

In the picture, a couple of violations are obvious:

1. A ladder used to reach a higher level of work should extend at least three feet above the level the worker is reaching. Using the rung spacing to estimate, we can say the ladder extends above the roof by about a foot.

2. The workers are not wearing gloves (or any other PPE, for that matter). So they expose their hands to several hazards when dealing with the metal Air Conditioner units.

3. Although the picture was taken while standing at ground level, it is easy to see the debris around the feet of the worker on the roof.  This debris presents tripping and slipping hazards.

4. Since the work is taking place close to an edge more than six feet above the lower level (the ground), Fall Protection for the worker on the roof is mandatory.

Some unseen concerns.

5. The base of the ladder is too close to the wall, so the ladder is too vertical. Regulations call for a ladder to be placed at  1:4 ratio – 1 foot out for every 4’ in elevation to the support point. The wall is approximately 13’ high, so the ladder should be around 3’ out from the wall for maximum stability.

6. Training: The workers are willing to work in unsafe conditions, so it is likely their training is deficient. Had the workers been trained in the requirements of federal laws, they would understand the hazards and how to avoid them.

A gentleman told me the other day: “You know, safety rules are pretty much common sense.” He is right, they are not difficult to remember or to follow.  Workers need to know the hazards and how to prevent injuries. Employers must want to protect their workers.

See our Web site: SafetyRich