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Occupational Safety Blog

By Fred Rine, CEO of FDRsafety and former long-time Managing Director of Safety and Health at FedEx, Jim Stanley, President of FDRsafety and former No. 2 at OSHA headquarters and Mike Taubitz, Senior Advisor to FDRsafety and former Global Safety Director for General Motors.


Archive for May, 2010

A recipe for shaking up the safety status quo

May 24th, 2010 posted by Mike Taubitz

Mike Taubitz

Many organizations claim that safety is the responsibility of everyone. However, if Manufacturing calls the Safety Department when there is an obvious hazard and corresponding correction, the words don’t matter.

Your organizational culture is probably “Safety is responsible for safety.” That is not healthy for any number of reasons, including the fact that you cannot be successful if operations management and supervisors call the Safety Department when guards are off, oil is on the floor, someone didn’t lock out, etc. Floor personnel should be responsible and accountable for safety.

If you are a safety professional and your organizational culture needs to change, here a few steps to consider:

  • Talk to the CEO or highest level person at your location. Get his / her concurrence that they are responsible for leading safety.
  • Clarify that you are there to support them – don’t ask for support.
  • Ask the top executive what they would like done that is not being done now.
  • You will probably note many gaps as you listen.
  • Tell them that you will get back to them with a plan.

The plan will include your analysis of non-value added work to be eliminated and a proposal to redistribute necessary safety functions, allowing time for the new initiatives. In your plan:

  • Carefully analyze whether time spent on floor audits and being a “safety cop”, creating reports or other administrative tasks really add value for the prevention of injury and illness.
  • Identify the non-value added things that should be eliminated.
  • Lay out a matrix for all the necessary inspections and audits that must be performed (e.g. PPE audits, fork trucks, chains and hoists).
  • Consider if others in operations, maintenance, or other staffs are capable of performing the work.
  • Develop a matrix of how the load could be redistributed.
  • Identify how much time you could free up and how you would use the time for planning and implementation of the executive’s initiatives.
  • Present your plan and make adjustments based on their critique.

Your scenario may play out differently but the goal is the same – serve top management and make others directly and personally responsible for safety. When communicating changes to the management team, ask the CEO to voice these words of wisdom to the rest of the organization:

  • “If you are not sure if you have a hazard, call safety.”
  • “If you have a hazard and are not sure what to do, call safety.”
  • “If you have a hazard and know what to do, fix it – don’t call safety.”

    Remember, the CEO or top operations person at your location is your primary internal customer. Make sure you are giving them the support they deserve.

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Posted in Accident Prevention | 1 Comment »





Make off-the-job safety a priority, too

May 19th, 2010 posted by Fred Rine

Fred Rine

A recent AAA Living Article entitled “Losing the Drinking Game” had some interesting statistics:

  • Every 45 minutes, someone in the US dies because of alcohol-impaired driving.
  • 2.5 million parents drive under the influence of alcohol yearly
  • About ½ of children killed in alcohol-related crashes are in the car with the impaired driver
  • $51 billion is the estimated annual cost of drunk-driving crashes

Lest you think that this blog is about drunk driving, it isn’t. The human tragedy and DUI numbers speak for themselves.

What perplexes me is why industry and the safety profession spends most or all of its energy on safety in the workplace. The workplace accounts for only 4% of fatalities. Last year, 39,000 people died on our highways, many from alcohol but others for a host of other causes. Another 76,000-plus accidental deaths occurred in the home and public.

These tragedies do not show up in OSHA recordable rates, another reason why more proactive and meaningful safety metrics are needed. I know the old adage “What gets measured, gets done” so perhaps we need to add some process metrics that will encourage management to deal with situations where 96% of all fatalities occur.

Why would we not begin to address these off-the job-issues in some manner? Not only are industries losing the services of valued employees, but, in many cases, the company ends up paying for healthcare one way or another. I am not suggesting that managers become responsible or accountable for employee health and well-being when not at work. I am suggesting that we begin to devote some small percentage of time and resources to address off-the-job safety.

FDRsafety has trained hundreds of thousands employees in safety awareness. I can assure you that making safety a 24-7 value and getting employees to think about the consequences that their unsafe actions could have on their family resonates with the most cynical of employees. This is not behavior-based safety, nor is it preaching or telling them what they “have to” do. Respect for people and talking to them in an honest and forthright manner helps them come to understand that “wanting to” be safe for the sake of their families can do much for on and off the job safety.

It is high time the safety profession started to infuse “safety is a 24-7 value” into their safety awareness training.

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Posted in Uncategorized | No Comments »





More evidence of OSHA’s recordkeeping crackdown: Lowe’s cited

May 11th, 2010 posted by Jim Stanley

Jim Stanley

Companies continue to be uncertain what OSHA’s new focus on recordkeeping may mean for them. A large national retailer just found out.

OSHA tagged Lowe’s Home Centers Inc. in Cincinnati and Dayton, Ohio, with $110,000 in proposed penalties for continually failing to document and report employee injuries and illnesses.

Here’s what OSHA said about it:

“As a result of an October 2009 inspection in Cincinnati, OSHA issued Lowe’s four willful citations with a proposed penalty of $40,000. Based on a November 2009 inspection, OSHA issued the Dayton store seven willful citations with a proposed penalty of $70,000. A willful violation is one committed with intentional, knowing or voluntary disregard for the law’s requirement, or plain indifference to employee safety and health.”

OSHA requires employers to record and maintain occupational injuries and illnesses on the OSHA 300 log.

If you have a question about how to handle recordkeeping in your business, ask us.

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Posted in Enforcement, OSHA, Recordkeeping | No Comments »





Deming, a pioneer in the world of safe and lean

May 7th, 2010 posted by Mike Taubitz

Mike Taubitz

I just finished reading an excellent book….

“Out of another @#&*% Crisis – Motivation through Humiliation” (available at ASQ and Amazon) grades US business on how well they stack up against Dr. W. Edwards Deming’s principles. Deming’s 1982 book, ‘Out of the Crisis’ put forth 14 principles for leaders and organizations desiring to improve quality and service. For those not familiar with Deming, I encourage you to do an internet search and find out more about the man and his contribution to quality and a philosophy of management that is perfectly suited to safety.

Deming, a statistician, is credited with starting post-WWII Japan on the path of producing quality in its products. He is regarded as having had more impact upon Japanese manufacturing and business than any other individual not of Japanese heritage. Despite being considered something of a hero in Japan, he was only just beginning to win widespread recognition in the U.S. at the time of his death in 1993.

Deming is also recognized for the concept of PDCA (Plan-Do-Check-Act) for continuous improvement. Many of you will recognize this concept as the foundation of today’s management systems. If you read ANSI / AIHA Z10 – 2005, Occupational Health and Safety Management System, you will find PDCA prominent throughout the entire document. What is less well understood is that Deming’s work in Japan also led to development of the many tools, practices and thinking associated with lean production.

More importantly, Deming’s 14 points hammer home the concepts of leadership and respect for people. With safety as a foundation for respecting people and using lean tools like 5S, value stream mapping, just-in-time, workflow, knowledge folders and a dozen other tools, the organizations practicing lean and safe are doing so because of Deming’s wisdom.

So, you ask, how does US business stack up with Deming. According to Mike Micklewright, author of ”Out of another @#&*% Crisis – Motivation through Humiliation,” US industry has earned mostly “Fs” and “Ds.’” He provides data and observations to support his personal characterization of industry’s performance. Like Micklewright, I too, am a huge fan of Deming. I spent many a Wednesday night in the late ‘80s as part of a Deming workgroup working with UAW colleagues to better understand how we might incorporate Deming’s teachings into health and safety. One of the most notable things we did was to apply statistical process control to the fatality data in General Motors to better understand our constancy of purpose.

At that time, fatality data for large global companies was typically a metric of number fatals million hours worked or 100,000 employees. You could compare performance to other companies or past years but learned little of root cause due to limited sample size. We engaged a statistical expert and gave him 30 years of fatality history.

Cranking the data, we learned something that would drive dramatic improvement in GM and much of industry. Traditionally, GM and the UAW focused on lockout because of the number of machines and injuries related to hazardous motion. What we had overlooked was that 19% of the fatals in a 30-year period came from falls from elevation. Just two common cause issues (lockout and falls) accounted for nearly 50% of the fatalities over 30 years.

Armed with the data, we went to management, and undertook a massive effort related to design, and providing proper fall protection when the hazards could not be designed out. Within a couple of years, we saw significant improvement in reducing fatalities. GM has continued the journey and boasts the best injury/illness record in the automotive industry. The knowledge for the beginnings of that journey came from Dr. Deming.

Apart from the tools of lean and safe, what Deming did best was underscore the value of the human mind. I can’t think of a better mentor to underscore safety as a 24-7 value than Dr. Deming. Companies that follow his principles will truly be on the path to sustainable growth.

Please join us for more discussion about safety and sustainability at the LinkedIn group, SHE, Sustainability and Lean.

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Posted in Accident Prevention, Safety and sustainability | 1 Comment »





Here we go again – OSHA on wrong path with injury prevention proposal

May 6th, 2010 posted by Jim Stanley

Jim Stanley

OSHA has come out with more details about its proposed Injury and Illness Prevention Program and it’s now clear to me that what could have been a good idea is headed down the wrong path.

I agree that OSHA should require every company within its jurisdiction to have a safety and health program. But I think that the guidelines should be broad and that the programs should be judged based on the companies’ safety performance. These programs should require total management commitment and employee involvement, and should hold both workers and managers accountable for following safe work procedures.

What the federal government should not do is lay down detailed specifications for how safety and health programs should be constructed. And that is exactly what OSHA is proposing to do.

Businesses vary so much in their operations that it is unrealistic to think that federal specifications will serve the cause of health and safety. Companies need the flexibility to build programs that match their own circumstances.

Here is an excerpt from what OSHA says it has in mind for a proposed Injury and Illness Prevention Program, which it is calling I2P2 for short:

“Based on OSHA’s experience, the agency believes that an I2P2 rule would include the following elements:

“1. Management duties (including items such as establishing a policy, setting goals, planning and allocating resources, and assigning and communicating roles and responsibilities);

“2. Employee participation (including items such as involving employees in establishing, maintaining and evaluating the program, employee access to safety and health information, and employee role in incident investigations);

“3. Hazard identification and assessment (including items such as what hazards must be identified, information gathering, workplace inspections, incident investigations, hazards associated with changes in the workplace, emergency hazards, hazard assessment and
prioritization, and hazard identification tools);

“4. Hazard prevention and control (including items such as what hazards must be controlled, hazard control priorities, and the effectiveness of the controls);

“5. Education and training (including items such as content of training, relationship to other OSHA training requirements, and periodic training); and

“6. Program evaluation and improvement (including items such as monitoring performance, correcting program deficiencies, and improving program performance).”

Your comments are most welcome.

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Posted in Accident Prevention, Enforcement, OSHA | 8 Comments »





OSHA’s Michaels: Egregious violations in Q1 double all of previous year

May 4th, 2010 posted by Jim Stanley

Jim Stanley

If employers needed any further proof that OSHA is following through on its promise to greatly increase enforcement, they need only look at initiatives the agency announced last week and a speech by OSHA’s chief that was reported in a newsletter article by a leading law firm.

In that speech, David Michaels said that OSHA cited almost twice as many employers for egregious violations in the first quarter of 2010 than it had in all of the previous fiscal year, according to a newsletter article by Robert A. Dimling and Andrew R. Kaake of Frost Brown Todd. Egregious violations are those considered so serious that OSHA assesses a separate penalty for each occurrence or each worker exposed. This can result in so-called “mega-fines.”

Last week, we reported in this blog on an internal memo from Michaels that presented details of a plan to increase penalties for OSHA citations. Michaels estimated that the plan would triple or quadruple the size of the average penalty.

In a webcast last week, Michaels also said that enforcement on ergonomics issues would be stepped up under the general duty clause. And he announced a proposal to require companies to put in place accident and illness prevention programs.

Earlier in April, details emerged on a Severe Violator Enforcement Program

This follows earlier announcements of a crackdown on recordkeeping.

Companies concerned about whether they are meeting all OSHA standards can conduct a mock OSHA audit and a recordkeeping review. If you would like outside assistance in doing so, FDRsafety would be happy to help. Contact me at jstanley@fdrsafety.com or (513) 317-5644.

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Posted in Enforcement, OSHA | 1 Comment »