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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 the ‘Accident Prevention’ Category

Prevention through design – a tip to make things easier

April 1st, 2013 posted by Mike Taubitz

Mike Taubitz

The March issue of ASSE’s Professional Safety magazine was devoted to the subject of Prevention through Design (PtD), with three excellent articles that covered:

  • Integrating PtD into undergraduate curricula
  • Design methods for implementing PtD, including things like policy, standards, processes and procedures, management of change, etc.
  • Business cases supporting PtD solutions

What I rarely see is something that the writer actually put into practice.  In 1970 (some of us lived in ancient times), I was a graduate engineer responsible for purchasing millions of dollars of production equipment for Chevrolet engines.  A few months into the job, we were called into the Master Mechanic’s office (chief manufacturing engineer) and advised that the Walsh Healy act had passed and we were now responsible for OSHA compliance.  Our bosses told us not to look to safety because they had no more information than they did.

We were engineers – what the heck did we know about safety?  The answer – precious little. But our bosses made us personally responsible for noise, guarding, ventilation and engineered controls for employee safety.   One thing all engineers know is this:  If you miss something in the bid specification and place an order for a machine or process, you will pay big time to get the added features.  While in the competitive bid stage, many of those items might have been no cost.

We learned something that all PtD proponents should put into practice immediately — make sure your bid package requires vendors to detail costs for noise control, guards, etc.  In some cases, you may ask for different options because you, the buyer, will determine what is feasible for your operations.  Not only is it right for the purchaser to put responsibility on the supplier but you’ll quickly flush out those who aren’t qualified to handle the job.  Once the bid is awarded, engineering and safety can demand CAD drawings or equivalent of the safeguards just like the base machine, sub assemblies and components.

Don’t wait until the machine is nearly done to start safeguarding – demand that the vendor offer solutions in the competitive bid stage.





Safety: What to do when employees know better but don’t do better

March 21st, 2013 posted by Jim Stanley

Jim Stanley

Multi-tasking has evolved from a talent to a necessity to maintain the pace of everyday productivity.

Whether an employee is talking on a cell phone while working, or not wearing his or her personal protective equipment, many workers have placed themselves and others at needless risk to save time or be more comfortable.

The bottom line is that the majority of accidents are not due to a lack of training, skill or knowledge — they are simply related to poor decision-making.

This article will take a comprehensive look at addressing this problem along with the culture of safety, and examines the philosophy, accountability and structure needed to develop a successful safety program.

First thoughts about safety

Think back to the person who taught you the first safety rule: Possibly, it was your mother warning you about a hot stove. (“Hot, don’t touch!”) Most people are likely to rebel when pushed into a decision until they truly understand the rationale and risk behind the decision. The “it could never happen to me” attitude sends many people to emergency rooms with serious injuries, sometimes life-threatening.

Sadly, carelessness in the workplace can tend to go hand in hand with pressures to produce and, in some cases, it is rewarded. Too often, it is easier for a manager to turn away and cross his or her fingers when observing a safety rule being violated than to slow down the process with enforcement and follow-through.

Time, effort, comfort and peer pressure are the foremost reasons employees commit unsafe acts when they know better but don’t do better. Many employees don’t like being required to attend safety training sessions or, in some cases, obey safety rules. Many companies establish safety as a “No. 1 priority,” but send mixed messages when something more important bumps safety to the back burner.

Employee safety must be a value and a lifestyle, with a 24/7 approach.

Accountability for actions

Poor management techniques and/or lack of company-sponsored training efforts are ultimately responsible for sustaining a culture that “permits” unsafe behavior. If there are no consequences for violating company safety rules, no enforcement of the safety program, and no way to point to any bottom-line accountability, major changes must be made and implemented in the existing programs.

There are three main components of an effective safety program:

1. Total, unwavering safety commitment from management.

2. Active implementation of a formal site-specific safety program led by mid-management.

3. Employee involvement through example and demonstration, not directives.

It’s not enough to make safety a “No. 1” priority. Safety must become an inherent company value because priorities nearly always change at some point.  All individuals want to succeed, best echoed by the old saying, “What interests my boss, fascinates me.”

The term “accountability” typically tags along with a negative connotation of punitive or disciplinary action. In a compliance context, this word translates to everyone owning responsibility for individual safety.

How a company demonstrates its commitment

While conventional wisdom says that employees criticize their companies when they impose strong disciplinary actions in safety, the opposite is usually the case. Companies with a high regard for safety and health demonstrate a greater level of care and concern for employee well-being. When safety and health standards break down, serious injuries/illnesses or even fatalities can occur, leaving families shattered due to carelessness and irresponsibility.

What would happen if there were no highway patrolmen to monitor traffic on the roads? Obviously, that would be a recipe for disaster. The same principle holds true with safety measures. Lower costs and higher productivity correlate directly with companies that demonstrate a strong baseline safety program that includes front-line supervision and employee participation. Safety becomes part of the job and a condition of employment.

Companies need to have highly detailed safety procedures in place, ensure and account for employee training and awareness, and ultimately use a zero-tolerance policy for serious violations of the policy. Employers must create a system of accountability that includes:

  • Thorough training
  • Strong and effective safety and health policies
  • Regular and frequent inspections and documentation
  • Accountability to follow through with safety rules

To look at it another way, many companies terminate employees because of excessive tardiness or theft, while merely warning them for a serious breach of safety rules that could have caused death or serious physical harm.

Emphasizing what’s really important

Safety is about creating an environment where employees want to be safe because it’s the right thing to do.

Asked, “What are the top three most important things in life?”, employees commonly answer:

1. Family

2. Faith

3. Health

“If someone were to say that he or she would hurt a member of your family, what would you do?” Most people would do anything in their power to stop that from happening.

Safety values, whether at work or at home, have the power to protect or ruin your family, faith and health. If an unsafe action were to undermine any one of these values, would shaving off a few extra minutes by not putting on protective equipment or skipping steps through a safety procedure still seem as important in light of its possible consequence? Safety shouldn’t be a “have to,” it should be a “want to.”

Preparing an effective safety program

To establish a successful safety initiative here are my recommendations for senior leadership:

  • Safety begins first with top management; and deliver the message with visual concepts, not just words.
  • Create a program that is site-specific and makes sense to management and workers.
  • Identify where safety and health issues exist and implement a program that corrects these issues and all similar issues.
  • Fully understand the responsibility and requirement to follow safety and health rules.

And here are some recommendations to foster a culture of safety:

  • Encourage employees’ involvement and feedback and act on their suggestions.
  • Develop a safety committee with the authority to create and implement changes.

Select an employee from the workforce to function as a fulltime safety coordinator (without disciplinary authority) with the responsibility of making safety changes.

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Why Task Based Risk Assessment Is Better

March 18th, 2013 posted by Mike Taubitz

Mike Taubitz

When I work with clients, I always use Task Based Risk Assessment (TaBRA). Last August I wrote about how the methodology was instrumental in OSHA vacating a lockout citation.

But the method is helpful in many situations, including:

  • Deciding if a task that is normal, routine and repetitive to an operation and eligible for the OSHA exception to lockout is OK from a risk perspective
  • Assessing a task where you aren’t sure if variation is such that existing standard is suitable for the specific task
  • Maintenance tasks where the steps – and potential hazards – are not known

Because the method identifies all steps in a task and encourages open discussion, the method has advantages beyond safety. One client conducted a pilot to expand TaBRA concepts such that quality and operational performance issues were also identified. After the pilot, management and hourly personnel reviewed results with the CEO.

For a particular task, the company’s version of Job Safety Analysis (well done by the way – with visuals and all major hazards addressed) identified three steps. Before beginning the TaBRA, the experienced worker guessed that we would show six steps. The method captured 17 steps.

As the worker explained, “I guess we all do a couple of things at once and take for granted how many steps really exist.” We also identified a quality issue and variation in products that requires variation in the standard. The company made the decision to use TaBRA as the core method for driving continuous improvement and development of standard work developed with worker input.

What’s really great is that both the Quality Manager and Continuous Improvement Manager were enthusiastic supporters of this approach. That’s because they did it with the workers and came to their own conclusions.

Without the detail, you might ignore hazards and risks, but the detail also allows for creating better work instructions.

Picture having a family member or friend trying to do the job – and the instructions skip some steps. What are the chances that there will be errors, poor performance and safety risks? I’ll suggest that the chances for these negative outcomes are pretty high. If you want job instructions that allow a competent person to do a job flawlessly, you need to assure that your method to develop the instructions is adequate and captures necessary detail.

TaBRA isn’t a magic answer, but it is a method that works.





Keeping current on drug and alcohol testing rules

February 7th, 2013 posted by Jim Stanley

Jim Stanley

It is no secret that drug and alcohol abuse are among the biggest causes of workplace accidents.

Drug testing in turn can be one of the best ways to combat this problem. In fact, among companies that initiated drug testing, there was a 50 percent reduction in the number of organizations reporting high workers’ compensation incidence rates, according to a 2011 survey by the Society for Human Resource Management.

While drug testing programs can be very worthwhile, they are not without their challenges. One is keeping current with changes in state regulations on drug and alcohol testing procedures as well as court and industrial commission decisions.

I very rarely endorse specific products on this blog, but I would like to call your attention to FightReady, an automated service that helps companies stay in compliance in any state in which they operate. FightReady is very helpful tool in fighting drug and alcohol abuse in the workplace.





Staffing companies may not insure workers have proper safety training

November 20th, 2012 posted by Jim Stanley

Jim Stanley

Just because you hire contract workers from a staffing company doesn’t mean that your obligation to assure that they are properly trained in safety is any less.

That is an important point made by Dave Hoover in the current Forklift Training Systems newsletter.

Dave notes that “the true expertise of staffing companies is their ability to find qualified people and match them to a particular employer’s open positions.”

Employers should not assume that workers provided by those staffing companies have been adequately trained in safety, especially since “OSHA requires that forklift certification be site and equipment specific.

“Previous training at a past employer will not likely cover the responsibilities of the host employer, since their site, loads, attachment, layout, rules and trucks may be different,” Dave says.

Here are some tips for dealing with these kinds of situations:

1) Ensure you have a detailed contract outlining the responsibilities of each company in great detail.

2) Ensure operators are certified for your site and your forklift equipment and are completely competent to operate it. Don’t assume someone else is responsible for this part, be sure it gets done.

3) Supervise operators to ensure they are working safely; make sure all forklifts being used are safe to operate and enforce the rules of safe operation.

 

 

 

 

 

 





Can hard hats safely be worn backwards and other questions

November 14th, 2012 posted by Jim Stanley

Jim Stanley

Sometimes in our focus on the complexities of rules and regulations, we forget the simple, common-sense questions where clear answers can make a real difference in safety.

In this month’s OSHA Training Blog, Curtis Chambers addresses some of those issues with “Answers to top five questions about hard hats.”

Here are the questions:

1. Can I wear a ball cap beneath my hard hat?

2. Can I wear my hard hat backwards?

3. Do I have to replace my hard hat when it reaches a certain age?

4. Can I paint the shell of my hard hat?

5. Can I put stickers on my hard hat?

Curtis researched the answers by checking the websites of three leading hard hat manufacturers. As you might expect, the three mostly agree. Although, interestingly, they disagree about whether a hard hat can safely be worn backwards.

Curtis also rightly notes that the answers may change, so always check the manufacturer’s web site as well as the printed materials that come with your hard hat for their latest recommendations. And be aware that in some cases, the manufacturers’ guidance is restricted to a particular model or type of hard hat.

 





Stronger leadership on safety needed at colleges

November 12th, 2012 posted by Mike Taubitz

Mike Taubitz

A spotlight has been focused on UCLA ever since a horrific lab accident in December 2008 caused the death of a research assistant. Most recently, a chemistry professor pleaded not guilty to three counts of willful violation of an occupational safety and health standard.

But while the case is important, it is the bigger picture of safety on college campuses that truly demands action. There have been several other campus deaths in the past two years caused by accidents that in other cases would have been under the jurisdiction of OSHA.

FDRsafety handled the investigation of another college student accidental death last year.  That event caused me to dig into the bigger picture.  Recent accidental deaths of students at several universities give rise to a question of how well physical hazards and risks are identified and controlled on college campuses.

In a nutshell, the picture is this:

  • Students are not employees and are not under the jurisdiction of OSHA; hence injury and illness is not recorded
  •  The 285-page document, “The Handbook for Campus Safety and Security Reporting,” released by the Dept of Education in February of 2011 is devoid of guidance for physical safety hazards other than fire.  It focuses on personal safety related to crime.
  • There does not appear to be a central location for collecting data on student deaths related to accidents from physical hazards.
  • Many schools seem to have a strong focus on chemical, biological, nuclear and other sophisticated types of hazards and risks.
  • Some schools have a focus on sustainability, but the “social” aspect for student safety is absent at the level of top leadership.
  • Many colleges have well staffed and competent ESH staffs that seem to be responsible for safety. ESH staffs rather than the Presidents of colleges and universities draft policies and mission statements.

Let’s focus on leadership in colleges taking an active role and infusing safety as a value among all professors, staff and students.  When that happens, efforts to identify risk associated with “high severity – low probability” exposures can help reduce the numbers of tragedies that we are experiencing.

 

 





What to do when a safety standard doesn’t fit the task

October 19th, 2012 posted by Mike Taubitz

Mike Taubitz

What happens when a worker is injured and you find that a standard was not followed?

Do you point a finger at the worker or supervisor?  Maybe you take a systems view and try to improve your management system.   But, what if the standard was not suitable for the specific task being performed?

As we work with more and more clients doing Task Based Risk Assessment, we continue to document the variation in jobs and tasks.  A job with a Job Safety Analysis, Standard Operating Procedure or other instruction that prescribes the proper and safe way to do a job often does not work for a seemingly similar task because the circumstances and conditions may not be the same.  This particularly true of work for:

  • Set-up and changeover
  • Maintenance
  • Adjustments with power on
  • Diagnostic and trouble shooting

Safety has done a pretty decent job of documenting best practices and standardized work for operators.  However, the myriad tasks involved with the work listed above often does not lend itself to having a standard for every single task because you will drown in non–value added paper.  The variation in the work is something that you typically cannot change due to machine, operation or facility design.

Lockout is excellent as a standard means of protection but floor people know there is usually considerable diagnostic work to perform before the machine can be shut down and locked out.  Those are the situations where standards don’t work.

Count on trained, responsible workers

Assuming that workers have been trained and have the required skill set, we need to count on them to be responsible and accountable for their actions.  Particularly in situations where there are teams, power on, climbing, etc., it is important for employees to step back and use critical thinking to make sure they – and their colleagues – are safe while doing the necessary work.  In such cases, the simple Plan, Do, Check, Act model of continuous improvement that is the foundation of ANSI Z10 (US National Standard for Occupational H&S Management Systems) is useful as a tactical floor tool.  We should ask employees to:

Plan –Do they recognize the hazards and task requirements for all concerned in the work?

Do – “Do” is actually a pilot before the real work begins – make sure the plan will work. (If you must initiate machine motion for diagnostic purposes, do so with everyone in a safe position.)

Check – Validate the “Do” (Did the machine move as the team expected?)

Act – Act is get on with the work, “Adjust” the Plan or “Abandon” and make a new plan.

Respecting employees as thinking adults, we would be well served to arm them with critical  thinking skills rather than searching for a non-existent standard or a standard that is not suitable to the task at hand.





Safety incentive programs ineffective, but OSHA rule is off-base

October 15th, 2012 posted by Jim Stanley

Jim Stanley

Safety incentive programs generally don’t work very well, but that doesn’t mean OSHA is on the right track with a memo the agency issued to restrict them.

In an article in the current edition of EHS Today magazine , I delve into the problems with incentive programs.

Take Joe, for example. He’s finishing up his workday, hurrying to get done so he can get to his son’s Little League championship game. Is the promise of a pizza party to celebrate a safety milestone or a chance in a drawing going to cause him to stop to take proper safety precautions? Or is his desire to make it to the first pitch going to override any safety incentive? I think most of us know the answer.

A better, more fundamental approach focuses on management responsibility, compliance and creating a culture of employees who want to be safe

But for the companies that choose to use safety incentive programs, OSHA’s new approach creates problems of fairness.

OSHA’s latest memo warned employers that rewards programs unintentionally – or perhaps even intentionally – could encourage employees not to report injuries.

But the memo leaves open to interpretation the “how” and “why” of a safety incentive program. Is a party to mark a safety milestone an opportunity to reward and thank employees, something that most human resources experts tell us workers crave? Or is it a form of pressure to prevent employees from reporting injuries? In many cases, the answer is subjective — and that subjectivity conceivably could lead to fines.

OSHA’s aggressive stance may be well founded in some cases, but it is so broad and confusing that many companies acting in good faith could be found at fault.

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Identifying ‘invisible’ employees for safety training

August 27th, 2012 posted by Jim Stanley

Jim Stanley

Even at a company with a strong safety program some employees can be overlooked for training, leaving them vulnerable in case of an accident, fire or explosion.

An excellent blog post by Curtis Chambers on oshatraining.com identifies these employees. They could be employees we don’t normally associate with hazardous work, such as receptionists, accounting clerks or interns.

As Curtis rightly points out, there are OSHA regulations that require information and training for affected workers in these situations, even if they work in the office.
Here are some links to those regulations:

Emergency Action Plan Training – 1910.38(f)(1) – (3)
Portable Fire Extinguisher Training – 1910.157(g)(1)– (4)
Hazard Communication Training – 1910.1200(h)
Personal Protective Equipment Training – 1910.132(f)(1)
Lockout Tagout Training for “Other” Employees – 1910.147(c)(7)(i)(C)