Wait, that doesn’t apply only to working. It applies throughout life. Ask yourself how many times you drove over the speed limit, used a cell phone while driving in heavy traffic, didn’t take time to put on hearing protection while using a power tool at home – and the list goes on. We are all human and whether for sake of comfort or saving time, it’s easy to take shortcuts.

I’m as guilty as anyone but I’ve found that new thinking is helping me be more conscious of safety on a 24-7 basis. My discussions with Fred Rine and exposure to the FDRsafety training session on safety awareness has caused me to be much more thoughtful about what would happen to my family if I were seriously or fatally injured. I already know my major risks. They are driving and slips, trips and falls.

I’m one of these folks blessed with great health throughout my 64-plus years. No broken bones, no surgeries and I missed 4 hours of work in a 43-year career. But in the last few months, I took two tumbles – both from really stupid situations that were avoidable and I will not discuss. Both had to do with a “time” issue. I have done my self-assessment and made a commitment (to myself) to be more diligent.

Thinking from the heart

What’s important and the focus of this post is not what but why. I “want to be safer” because of my family. It’s thinking about safety from the heart – not the head. I know what to do from my head but the “want to” comes from the heart.

That takes me to thinking about my years in safety and what I read in all the professional journals and articles. We are simply missing the boat. The drive to reduce OSHA recordable cases is necessary but far from sufficient. 96% of accidental deaths are away from work. The offset of the natural inclination to take shortcuts – on and off the job – is to get folks to think about their families and make safety a 24-7 priority. That will also help improve safety in the homes and community if we do this right.

If we value someone’s safety and desire to have them “want to” be safe, we need to deal with the heart as well as the mind. Let’s expand our focus and start dealing with the real issues that are being ignored.

The past

The past four decades were a period focused mainly on OSHA compliance, with efforts geared to identifying hazards, implementing safeguards and lots of training. Most of the effort was program related, often confusing management and supervision as well as employees.

Lockout, slips, trips, falls, material handling, confined space, PPE, HazCom, and literally dozens of other regulations or safety programs were typically implemented as functional silos – all with their own terms. Along the way, we adopted OSHA recordkeeping as the primary means of tracking performance. The quest to continuously improve OSHA recordable cases for that elusive goal of “zero injuries” was a mantra often heard in the safety community. The question I would pose is, “Gee, what if I get to the top of the ladder and find out I’m on the wrong wall?”

The present

Unfortunately, we still have a strong OSHA focus. We bemoan that OSHA recordables are lagging indicators but do very little to develop new metrics for a more proactive look at things. Enlightened safety pros have moved to a systems approach that integrates the various programs into a cohesive system focused on continuous improvement.

Such systems demand leadership and employee participation and have proven to be successful when properly implemented. Concurrent with systems thinking has been the active use of risk assessment to complement traditional hazards assessment. Tools like task-based risk assessment recognize the realities of the workplace and do not skirt the issues where power must be on, work performed at elevation, etc. Through the application of the hierarchy of controls, risks can be mitigated allowing the work to be performed with acceptable risk. Those using the latest state of the art tools and thinking are making real headway — but still missing the real issue.

The future

The ghost of the future would probably ask, “Why do you folks insist on working on 4% of the problem? Is the “ghost of OSHA past” so strong that you cannot expand your focus and address the 96% of accidental deaths occurring off the job?” This is the real future of safety – tackling the bigger issue without abandoning the occupational focus.

In fact, you’ll find that making safety a 24-7 family driven value can do much to help your in-plant efforts. That is the opportunity. The challenge will come from the strategic initiatives of sustainability and corporate social responsibility that demand a broader focus of efforts geared to the family and society. If safety is not at the forefront, we will be pushed further to the back burner and CEOs will find other means and methods to address these strategic challenges.

Take stock of how you see and practice our profession. Are you in the past, the present or the future? When you climb the ladder of successfully reducing risk, make sure you are climbing the right wall – the wall of safety 24-7.

The significance of that statement is that lockout must be applied to set up (because it is classified as servicing or maintenance) regardless of whether that is the best way to protect the worker involved. And, as in many other areas, OSHA has been ramping up enforcement.

You’ve got to be kidding me. That’s like saying a mechanic must lockout the ignition switch when tuning up my car engine because it’s service and maintenance. By the way, it is service and maintenance of my vehicle, but does OSHA understand that you must have the engine running to set the timing? This is not a safety “shortcut.” It is a requirement of the task — just like the utility worker who must climb a pole in all kinds of bad weather and has potential exposure to very high voltage. Hello OSHA — welcome to the real world of work and risk.

If OSHA maintains its 40-year focus on hazards without moving to risk assessment, we’re all in for a lot of continued anxiety. Forget the impact on Santa Claus (see Jim Stanley’s Dec 23 post on how “OSHA nearly killed Christmas”), employers will have to sprinkle pixie dust to stay in business.

Power often needed for tooling changes

Employees often need power on to make tooling changes on machines like plastic injection molding machines.

Just like tuning an auto engine, this is not a shortcut but a requirement of the task. Small molding machines typically pose very low risk because employees stand on the side of the machine and are protected by passive controls (i.e. control reliable safeguards).

Hello OSHA, have you ever heard of passive controls, the holy grail of good safety design? A passive control is something like an airbag. It works without human interaction. In the case of machines, it might be an interlocked barrier that prevents hazardous motion but still allows necessary power to perform the tool change.

Oh yeah, I forgot, OSHA calls most tool changes “setup.” And because they consider setup to be service and maintenance, it automatically requires lockout. Good grief. This could be a Charlie Brown movie or the ultimate catch Catch-22.

Other safe ways to change tools

On some machines the task of changing tools might be safely performed using engineering controls and a similar task on another machine might require full lockout of the primary energy source.

By the way, with the exception of worrying about compliance, I don’t care if you call it setup or tool change as the term does not define the risk. In many cases, locking out would actually increase risk.

If OSHA’s thinking prevails, we won’t need standards that provide requirements for control reliable safeguards because the answer will always be “lock it out.” The problem, of course, will be trying to enforce what is a ridiculous rule.

Workers are smart people, and they know when management has imposed a rule that won’t let them do the task. That’s when they don’t lock out – and the machine may not have the safeguards that make the task inherently safe. Remember, these are not shortcuts but the situations where you need power to do something and risk assessment shows the work to be safe.

In the aforementioned CPL, page 10 states, “Tagout devices may be used on energy-isolating devices that are capable of being locked out if the employer develops and implements the tagout in a way that provides employees with a level of protection equal to that achieved through a lockout system.”

Time for a change by OSHA

OSHA’s exemption is inconsistent with its strident demand for locks in certain industries, and the exemption recognizes only part of the problem. The protection offered by lockout or tagout deals only with someone restarting the operation that could result in hazardous motion. It’s time for OSHA to provide an exemption for tasks requiring power where the work is performed safely using control reliable safeguards.

No wonder workers often think safety people are goofy. Oh, did I mention that many companies would simply go out of business, or at a minimum discontinue certain manufacturing processes (away go those jobs). Come on OSHA – get with it.

Task-based risk assessment as defined in the ANSI B11, family of general industry safety standards, will give you the answers you need to define acceptable risk – and allow the work to be performed safely. Unfortunately, OSHA’s outdated hazards-based approach falls miserably short. Please contact FDR Safety if you have questions.

That is the premise of “Getting to Zero Accidents,” a new e-book by FDRsafety CEO Fred Rine that is available for free download.

“You cannot force a change in attitude, but you can get people to want to be safe – and to be accountable for their actions,” writes Rine. “You can help people conclude that they should change – all by selling the benefits of their own safety.”

The e-book is based on the thinking behind a safety awareness program designed by Rine that has been presented to more than 400,000 employees and managers at companies nationwide. This program complements other elements of an overall safety system and The program is credited by many organizations with reducing helping reduce their OSHA recordable rates.

In that program, Rine – who previously ran the well-regarded safety program at FedEx — has attendees talk about what is important to them. Invariably, one of the highest priorities workers cite is coming home each day in one piece to family and loved ones. Rine helps workers understand that working safely is a way for workers to achieve one of their personal top priorities.

The book also addresses the importance of safety off-the-job, which is where 96 percent of all fatal accidents occur.

To learn more about how to change workers attitudes, click here.

How OSHA Nearly Killed Christmas!

Every December, my wife and kids beg me to put Christmas lights on our house, like all the neighbors do. But I cannot for the life of me figure out how to do it in a way that is both safe and affordable, or that does not violate at least 23 OSHA regulations. After all, I’m a safety professional, and I’ve gotta set a good example. So I gave them a made-up story about how our home owner’s insurance policy has a “special rider” that disallows Christmas lights because they’re considered a fire hazard, and that got me off the hook for one more year. But this year, I also began to wonder; how would Santa Claus comply with OSHA regulations? So I did a little research.

Now everyone probably realizes that Santa’s workshop is exempt from OSHA regulations, because it is not located in the United States or one of its territories; it sits on the North Pole at the top of the Arctic, out of OSHA’s jurisdiction. This is made further evident if you watch the animated Christmas special, “Rudolf the Red Nosed Reindeer.” Did you ever notice that the machinery in Santa’s workshop that has no guards installed? All the nip points on the belts and pulleys are exposed to contact, in violation of 1910.219(d). Also, not one single elf is wearing safety glasses or ear plugs as required by 1910.133(a) and 1910.95(b)(1), respectively, in spite of all the sawing, drilling and hammering that is going on! But once Santa gets into the good ol’ USA, things are different; because here, he must comply with OSHA regulations.

It wasn’t until recently that Santa Claus decided that he needed to do a much better job of following OSHA safety regulations, because his workers comp insurance rates were going through the roof. Also, he wanted to avoid the bad press associated with one of those news releases that OSHA started issuing to embarrass “bad actors” with multiple violations. So Santa decided to bring four elves along on his annual Christmas Eve trip to assist him with complying with the OSHA rules.

When Santa landed his reindeer-powered sleigh atop the first roof in the US (somewhere in northern Maine, I believe), he jumped out of the sleigh and started heading over to the chimney when one of the elves shouted for him to “STOP”! It was Sammy, Santa’s first-ever Safety Coordinator elf. “Claus, you have no fall protection”, explained Sammy, “So we’ll have to perform a JSA to figure out the safest way to get you over to the chimney without you falling off the roof”.

Ol’ Saint Nick had only read enough of the OSHA fall protection standards to be considered dangerous, so when he said “Let’s designate one of the elves to be our safety monitor, per 1926.502(h)”, all the elves started snickering. “No can do, Claus”, cried Sammy. “This work is not covered by the construction regs, it falls under general industry. So we’ll have to build a set of guardrails from the sleigh over to the chimney, with 42 inch top-rails, mid-rails and 4 inch toe-boards per 1910.23(c).” “Wait,” declared another elf, “all the hammering will wake the kids inside the house; we’ll have to figure out something else.” So they convened a meeting of the Safety Committee to figure out what to do.

They decided Sammy should use his smart phone to access the OSHA website to look for an alternative. He eventually found an OSHA letter of interpretation that allowed them to use an alternate means of fall protection, such as a properly engineered fall protection system, in lieu of guardrails, as long as the alternate system offered equal or better protection than the guard rails. So Sammy called on Johnny, one of the other elves sitting in the sleigh, to help; Johnny is a RPE (that’s registered professional engineer, not registered professional elf). Johnny designed a fall prevention system for Santa to use, complete with safety harness, lifelines, retractable lanyard, and designated points of attachment that can support at least 5,000 pounds per man attached.

Then Santa slipped on his safety harness (probably one of those special body harnesses designed for “husky” workers), attached his lanyard to the horizontal lifeline, and slowly crept across the roof over to the chimney. But when he started to climb up the chimney, Sammy again shouted for Santa to stop. Seems there was an overhead electrical line running overhead near the chimney, and Santa was about to encroach into the danger zone, a direct violation of 1910.333(c)(3). Because Santa had not been trained as a “qualified person” per the OSHA electrical standards, Sammy called for another elf, Ernie the Qualified Electrician, to install insulators on the overhead electrical line, per the requirements specified in 1910.269, the Electric Power Generation, Transmission, and Distribution standard.

Once that hazardous situation was rectified, Santa attached his double-legged lanyard to a vertical lifeline, climbed to the top of the chimney, and was ready began his decent down into the house. But first, Sammy had to use his gas detector to check for a hazardous atmosphere inside the chimney (confined space). “Too much CO” asked Santa? “Nah, only 15 ppm, so we can set up the blower and then enter under the alternate procedures specified in 1910.146(c)(5)”, said Sammy. Once the blower was in place, Santa started sliding down the chimney.

Halfway down, Santa mumbled something about it being a little warm inside the chimney. “Getting hot” asked Sammy? “Better stop right there, Claus.” Then Sammy pulled out his smart phone again and downloaded OSHA’s new app designed to protect workers from heat-related illnesses. Sammy entered all the necessary data into the program to get guidance on proper procedures to follow; however the app crashed three times before he could finally get it to work. But after several minutes, Sammy finally got the life-saving instructions he needed, and shouted down to Santa; “Claus, OSHA says you need to take a drink of water.”

But Santa never carried a canteen of water on him; he was accustomed to drinking all that free milk that families leave on the mantle with the cookies. So the elves improvised; they put some snow in an old McDonald’s cup they found under the sleigh seat and used their body heat to melt it into drinking water for Santa (an unintentional violation of 1910.141(b), potable water). Of course, that took several minutes, as the elves had difficulty finding snow that was not yellow (it seems that reindeer have small bladders). “Next year”, declared Sammy, “we need to bring a cooler full of drinking water for Claus”. “I prefer Sqwincher”, shouted back Santa. “But not the lemon-lime kind, I like the fruit punch flavor”!

Once Santa and his safety coordinator elf finally made it to the bottom of the chimney, they noticed there were some glowing embers beneath the ash in the fireplace. So Sammy declared that the operation was now considered “hot work”. Santa had to stop work while Sammy filled out a hot-work permit, then he called down the fourth elf, Fred, to act as the designated fire watch. Of course, Sammy had to first make sure that the portable fire extinguisher was fully charged and had its annual inspection tag attached, per 1910.157(e)(3). Then Sammy conducted a quick training session for Fred on the use of the extinguisher, since he was due for his annual refresher training per paragraph (g)(2). And Santa really had to bite his tongue when Sammy reminded him that they would have to wait 30 more minutes after they completed the “hot work”, because OSHA required the fire watch to stick around that long to make sure there were no stray sparks smoldering that could start a fire.

After confirming that all the elements of a fire prevention program were in place, per 1910.39, Sammy pronounced that Santa could proceed with distributing the gifts, just as soon as Ernie finished replacing the electrical plug on the extension cord for the tree lights; it seems the home-owner broke off the grounding pole (1910.304(g)(5)). And finally, after much ado, all the gifts were placed under the Christmas tree. Sammy announced they completed their tasks with no OSHA-recordable injuries or illnesses to enter on the OSHA Form 300, per 1904. So Santa and the elves gave each other high-fives, had a “safety luncheon”, and then everyone headed back onto the roof to load up in the sleigh so they could head to the next stop.

As soon as they were airborne, Santa decided to send a text to Mrs. Clause to let her know he would be running later than normal this year, due to the extra time it took them to comply with all the safety rules. But when Sammy saw what Santa was doing, he quickly snatched the phone out of Santa’s hand and chastised him for texting while driving.

“Claus, didn’t you read the new OSHA Alert about the dangers of texting while driving?” asked Sammy. “You need not worry”, replied Santa, “I’ll be careful. Besides, there’s not even an actual OSHA regulation that says I can’t text while driving.” “True”, said Sammy, “but you do have a General Duty, Claus, to provide us with a place of employment free from recognized hazards!”

(Note: if you did not get that last joke, refer to paragraph (5)(a)(1) of the OSHA Act of 1970).

Under the pilot program, OSHA inspected about 350 workplaces suspected of providing inaccurate reports of workers’ injuries and illnesses. The program was a relaunch of an earlier version that was halted because inspectors failed to find the underreported injuries and illnesses they were expecting.

After all the confusion surrounding the original pilot and its failure to find recordkeeping violations, I have substantial doubt that a new look at targeted companies could really find legitimate accidents and illnesses that were never reported. On the other hand, given the complexities of OSHA’s current recordkeeping requirements, it is possible that some of the injuries and illnesses were recorded improperly.

In my opinion, this pilot program is evidence that OSHA has misplaced its priorities. The agency has limited resources, as do businesses. Instead of splitting hairs about inaccurate recordkeeping, time and attention needs to go towards identifying hazards in the workplace and their correction before injuries or illnesses occur. Everyone agrees that this will produce safer workplaces.

At the Trucking Associations meeting, I was most intrigued by a survey it conducted a few months back that identified the top challenges its members are facing. Not surprisingly, one of the top five issues was the impact the US DOT’s new enforcement program, CSA, will have on carrier operations.

I have written many times before that CSA would become a “game changer” and, in fact, for the trucking industry it has become so. As freight demand is increasing, companies are anxious for more customers. However, companies with poor scores are being told that until they improve, customers will be giving their business to companies that perform better on safety.

At the conference, it was clear that a cottage industry of consultants and businesses has sprung up to help companies identify their safety weaknesses and improve their CSA performance. This help comes in the form of technologies capable of managing hours of service compliance to individual consultants skilled in improving safety culture and a company’s overall safety management program.

The demands of running a trucking operation can be overwhelming but the compliance requirements are the same whether a company has three power units or 30,000. The point is that solutions are available and many are affordable and within the reach of the small operator. To remain competitive, companies need to be mindful of their CSA performance and set a course to make improvements by either focusing time and attention on remedies or hiring someone who can help get them into a better safety position.

Home, community accidents on rise

Unintentional injury prevention is the main mission of the National Safety Council. It focuses on helping business and the public recognize the impact injuries/deaths have on business profitability and the wellbeing of families.

Surprisingly, the fastest rate of increase in preventable injury and death comes from abuse of prescription drugs, aka unintentional poisoning. We have all heard stories of people doctor-shopping, receiving highly intoxicating drugs and mixing drugs that unintentionally and tragically result in death.

In recent decades, workplace and motor vehicle deaths have been declining but home and community categories of death and injury have been on the rise. Other danger sources in the home include slips and falls. The challenge is how to create a better recognition of risk and then promote a sense of personal responsibility for oneself and one’s family that recognizes these risks and sets out to curb them.

Ladder safety, handrails in bathtubs, etc., are examples of measures that enhance safety. Adopting a mindset that says “this event can happen to me so I’m going to improve the odds by making the safe choice” is something we don’t often do. Always wearing a seat belt even when we drive the 10 minutes to the grocery store is a practice we all need to adopt.

These meetings provided me a sense of renewal and commitment to my safety journey and reminded me that there is still a great deal of work to be done to help us all be safer — whether it’s on the road, at our workplaces or in our homes. While we all can’t be at every conference that affirms our vocation, we can commit to making better choices and caring more about our personal and family’s well being.

One such emerging issue is the safety and health needs of a workforce that is growing older. Issues like an aging workforce are not tidal waves because you don’t see the wave. With a tsunami, when you see the wave it is too late.

An aging workforce is more than a socially responsible issue for many companies. The theme I heard in recent presentations from both CNA Insurance and NIOSH is – believe it or not – that many companies will be facing a major labor shortage in the next few years. I place a lot of value on actuarial tables used by insurance companies and other experts studying demographics. The data suggest that many companies will be faced with employing aging workers to stay in business or grow their business – it’s not a question of doing something nice for older workers – it’s about survival in the workplace utilizing the talents and skills of an older workforce.

I know it’s hard to believe with the current economy, but I hear employers complaining that they can’t find workers with necessary skills. Many older workers meet their requirements – - with this caveat — older workers pose new health, safety and ergonomic challenges.

A 1/8-inch difference in the floor may not be a problem for young workers but could become a trip hazard for an older worker. Lighting and visual acuity is another challenge. Workers who could handle lifting and bending in their younger years may not be able to handle similar stresses in their old age.

When/if your company hires aging workers or keeps older workers on the payroll, will you have the necessary hazard prevention processes in place to keep them healthy and well?

Is the incessant focus on OSHA recordable injury rates keeping us from planning on strategic issues that will impact our organizations? It’s all about long-term sustainable growth folks. Let’s make sure that we adding real value and deal with emerging issues like an aging workforce.

All of the attendees were immersed in using “lean” to improve operational performance in their organizations. Many healthcare organizations are beset with challenges to reduce errors, cut costs and provide faster services. Do those sound familiar to the management challenges laid out in your own organization?

“Lean” is the term used to describe Toyota’s production system in the 1991 book, “The Machine that Changed the World.” Lean thinking and tools focus on the identification and elimination of waste, allowing any business process or system to be faster, better and cheaper. Over the years, many companies and industries like healthcare have learned that “lean” works in offices and any kind/size of business.

History buffs may know that Toyota created tools and problem solving processes to follow the teaching of W. Edwards Deming. Deming, often credited with being one of the key figures for the modern quality movement, did not preach lean. His 14 Points or principles simply laid out the foundation for leadership that allowed every member of the organization to be involved with organizational transformation.

Leadership with engaged employees – sounds a lot like what we in safety are always striving for.

You cannot be lean without being safe

My message was “You cannot be lean without being safe.” It is a given that healthcare professionals are focused on patient safety. Healthcare organizations that are several years into their “lean journey” for organizational transformation have impressive case studies demonstrating improvement in operational excellence. Yet, only a few of these organizations have included employee safety in their processes to improve work.

How can this be? Needle sticks, blood borne pathogens and a myriad of ergonomic issues are just some of the hazards that confront nurses and other healthcare workers. For the lean folks, is it someone else’s responsibility to handle employee safety?

Is this the same thinking that safety folks use when we say, “Lean or production is someone else’s responsibility.” Do our paradigms about roles and responsibilities constrain taking advantage of opportunities that would make things run faster, better, cheaper – - and safer?

Whether your company uses “lean” or some other form of continuous improvement, we in safety have a golden opportunity to help our leaders understand that injury and illness is waste. If we value our employees, then we need to make safety 24-7. When we do this, we have made the first step onto the path where lean and safety are carried out as an integrated process.

As most readers know, OSHA requires lockout/tagout to control potentially hazardous energy or unexpected startup during service and maintenance work. OSHA has also said that “Setting up is not considered utilization of a machine or equipment and is classified as servicing and/or maintenance, rather than normal production operations.”

For purposes of this blog, we’ll only discuss lockout. Lockout procedures must assure the primary energy source is disabled and locked. The use of control circuitry is not allowed for tasks where lockout is required. However, minor tool changes and adjustments, and other minor servicing operations, which take place during normal production operations, are not covered by the standard if they are routine, repetitive, and integral to the use of machines or equipment for production, and if work is performed using alternative protective measures which provide effective employee protection. Lockout/tagout is not required when each of these elements exists and employees may perform servicing and maintenance activities with the machine or equipment energized.

But how do you know whether your tasks meet these criteria?

A process to follow

The good news is that there is a process a company can follow to answer the question. In a 1999 letter to the UAW and General Motors, OSHA said that the company and union had used a Task Based Risk Assessment methodology through which a Monitored Power System (MPS) was incorporated into specific equipment. (A Monitored Power System is circuitry using control reliable safeguarding.)

In the letter OSHA stated:

“…an MPS, which meets the above referenced ANSI (B11) consensus standards on control reliability and control component failure protection, would provide alternative safeguarding measures, which constitute effective employee protection. Thus, such an MPS may be used to protect employees who are performing minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations, provided that each element of the §1910.147(a)(2)(ii) exception is met. In other words, the MPS system may be used in cases in which minor tool changes and adjustments, and other minor servicing activities, are performed during normal production operations, and are routine, repetitive, and integral to the use of the equipment for production…”

FDRsafety Senior Advisor Mike Taubitz is a a long-time member of the B11 Accredited Standards Committee. He also assists companies in conducting a task based risk assessment to determine if lockout/tagout or alternative safeguarding is needed for effective employee protection.