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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

A safety question sparked by the Japanese tragedy: Are you prepared?

March 16th, 2011 posted by Mike Taubitz

Mike Taubitz

The unfolding tragedy in Japan is a disaster of unprecedented magnitude and our hearts go out to the Japanese people as they struggle with survival. It is also a lesson in emergency preparedness for all of us.

Are you prepared for an emergency?

Whether it is a hurricane, tornado, flood, fire or blinding snowstorm, most parts of the United States have the potential for some form of natural disaster. The Red Cross suggests that you do three things:

  1. Get a kit
  2. Make a plan
  3. Be informed

Get a kit

The kit should include water, food, flashlight, battery powered or hand-crank radio, extra batteries, first aid kit, sanitation and personal hygiene items, copies of critical personal documents (e.g. medical information, passport, deed to home, etc.) cell phone and chargers, contact information, extra cash, blankets and maps of the area. Depending upon your circumstances and location, it may be advisable to supplement your kit with other items.

Make a plan

1. Meet with family/household members.

2. Discuss preparation and response to possible emergencies.

3. Identify responsibilities for each member of the household. If one member is in the military, what will you do if they are deployed.

4. Choose where to meet in case of sudden emergency such as a fire. Someplace close to home or your neighborhood.

5. Decide on an out-of-area emergency contact person whom you can contact if local phone service is out. Make sure everyone has emergency contact information programmed into their phone.

6. Determine how and where you would go in case you have to evacuate.

Be informed

1. Determine what disasters or emergencies could occur in your area.

2. Identify how authorities will notify citizens in the event of a disaster.

3. Know the difference between weather watches and warnings.

4. Tailor your plans to what could occur.

5. Consider how to handle someone who may be injured or in need of medical assistance if emergency response is delayed.

6. Share your thoughts and ideas with family, friends and neighbors.

Lastly, a free emergency contact card is available at the American Red Cross website.

This is the perfect time to demonstrate your love and concern for the health and well-being of your family, demonstrating that safety is truly a 24-7 value. Be prepared.

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I2P2 may be next big battle in struggle over OSHA enforcement push

March 7th, 2011 posted by Jim Stanley

Jim Stanley

While OSHA readies itself for a fight over its Fiscal 2012 budget, another big battle is looming over a proposal that OSHA administrator David Michaels views as the centerpiece of his campaign to exert more enforcement pressure on industry.

That proposal is the Injury and Illness Prevention Program, which has become known as I2P2.

On the surface it sounds like a good idea – require all companies in OSHA’s jurisdiction to have a safety program. If that was as far as it went, I would be all for it. But OSHA is going several steps further, by laying down specific requirements that businesses would have to meet in these I2P2 programs. That is a bad idea, simply because business environments vary so much.

U.S. Chamber concerned about I2P2

Business organizations like the U.S. Chamber of Commerce and the National Association of Manufacturers are concerned about the impact of I2P2.

“This would be the most sweeping regulation that OSHA has ever put out,” Marc Freedman, the Chamber’s executive director of labor law policy, said in an article in The Hill newspaper.

Freedman believes the rule could require employers to identify all hazards in the workplace, even ones not already specifically covered by OSHA.

“There is one school of thought that they would not have to issue another regulation ever again,” Freedman said.

Freedman believes OSHA will use the I2P2 program as a backdoor way to put an ergonomics standard into effect. A proposed ergonomics standard was rejected 10 years ago under the Congressional Review Act and as a result, OSHA cannot reissue a regulation similar to the voided standard.

“Not only is this similar to the ergo rule, this will be how this OSHA does ergonomics,” Freedman said. “This is their ergo rule in style and substance.”

OSHA’s Michaels sees it differently

However, in the same article in The Hill, OSHA’s Michaels said that no new health and safety standards would be developed under I2P2.

“It is intended to help employers develop a systematic plan to find and fix workplace hazards that are currently covered under OSHA standards or that are currently covered under the General Duty Clause,” Michaels said.

Michaels said I2P2 is needed because OSHA does not have the manpower to inspect every workplace.

“It would take over 100 years for OSHA to visit every workplace under its jurisdiction,” Michaels said. “OSHA believes that workers will be better protected if each employer has a proactive plan to find and fix hazards in their workplaces so that workers don’t get hurt.”

The lobbying effort 10 years ago over the ergonomics standard was huge, and if that is any indicator you may be hearing a lot more about I2P2 from Washington in coming months.

To keep up with the latest news about increased OSHA enforcement, subscribe to this blog and have it sent automatically to your Reader or email box.

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Following the safety path to zero incidents

February 24th, 2011 posted by Mike Taubitz

Mike Taubitz

Let’s assume that you are the head of safety in your organization. The good news is that your OSHA recordable and lost work-day rates are extremely low and a point of pride for the organization. The bad news is that you seem to have hit a plateau and management keeps looking for ideas to achieve the elusive goal of zero incidents.

We’ll also assume that your manufacturing operations are well guarded, employees are trained, leading indicators are utilized and you have tried behavior-based safety approaches. What’s next?

The answer lies not in the latest program or a “silver bullet.” The solution is a long-term process of continuous improvement that engages the workforce to continually making things better. In an ideal situation, employees will take personal responsibility for their safety and look out for their colleagues. There is a foundation step before you embark on this journey:

• Employees “wanting to” be safe rather than “having to” be safe is the cornerstone of workers being responsible for their actions.

• Safety viewed as a 24-7 family-driven value is the motivator for employees “wanting to” be safe.

Ingredients of continuous improvement

Think of a continuous improvement process as a completed home that is always improved. If you only build the foundation, it won’t be a very pleasant home. Building the remaining structure requires things such as:

• Processes that communicate problems on the factory floor
• Engaging workers in identifying and mitigating hazards
• Supervisors treating employees with respect
• On-going training and hazard abatement processes
• Management communicating a personal “I care” message
• Risk assessment and other simple tools allowing employees to identify and mitigate risk without having to call the safety department

Organizations that choose this approach will reap the benefits of improved safety, quality and productivity. Remember that safety is a value – not a priority competing with the priorities of other functions. Improving safety not only improves the health and well-being of workers but also improves overall organizational performance.

If we want employees to commit to us, we need to commit to them on a personal level. That commitment can only be demonstrated with a process of continuous improvement.

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National Steel City’s commitment to safety brings better accident numbers and savings

February 24th, 2011 posted by Jim Stanley

Jim Stanley

If you want an example of what a company can do to turn in a great safety performance, you need look no further than National Steel City, a construction company specializing in steel and power industry equipment installation.

National Steel City’s recordable incident rate dropped from 1.18 in 2009 to 0.71 in 2010. Its experience modification rate dropped from 0.78 to 0.61. Both are outstanding results.

One of the key elements of a good safety program at any company is a total commitment to its success by senior management. That certainly is the case at National Steel City, which is a client of FDRsafety. Bob Dunn, CEO of the Plymouth, MI, company is a big believer in a strong safety program and shows it with his personal involvement.

“NSC safety managers on all projects report to me directly and I continue to take a personal role in reviewing daily safety reports,” Dunn says.

Not only does the strong safety record mean that employees get to go home to their families injury-free each day, it also results in lower workers compensation premiums that benefit both the company and its customers.

“A safer working environment contributes to a better motivated, more productive workforce that ultimately benefits companies doing business with National Steel City,” Dunn says.

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Preventing machine hazards just got easier

February 8th, 2011 posted by Mike Taubitz

Mike Taubitz

If your organization is intent on the control or elimination of hazards before new/rebuilt machines come into your work place, you will want to better acquaint yourself with a new voluntary standard that was recently finalized.

The “A” level standard, ANSI B11.0 -2010, “Safety of Machinery: General Requirements and Risk Assessment,” is designed to eliminate injuries by establishing requirements for the design, construction, reconstruction, modification, installation, set–up, operation and maintenance of machines. It applies to a wide range of machines in many industry sectors.

Prior to publication of B11.0 in December 2010, there were 24 individual “B” and “C” level standards, but it was hard to understand how they all fit together. The “A” level is the overarching standard that pulls it all together with general safety requirements.

This risk-based approach will answer sticky issues related to “I know we have a hazard, but how much risk is there?” The process of B11.0 can marry the reality of the factory floor with design and engineering. Risk assessment is also a valuable tool to help drive continuous improvement by helping management focus on the areas of highest risk.

In addition to being a tool for safety pros, B 11.0 is a tool that can be used by engineering and purchasing personnel as part of their procurement process. It is organized in a manner that complements the typical life cycle of a machine:

• concept / design
• build / purchase
• commission
• production / maintenance
• decommission

For those working on Prevention through Design (PtD is an initiative led by NIOSH), ANSI B11.0 is a must.

Standards are available from B 11 Standards, Inc. Send an email to dfelinski@b11standards.org.

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As OSHA withdraws ergonomics proposal, here’s what else it should rethink

January 26th, 2011 posted by Jim Stanley

Jim Stanley

In its second course reversal in a week, OSHA has withdrawn a proposal to step up recordkeeping requirements for ergonomic injuries, naturally raising questions about what else the agency might be rethinking. My suggestion is to look next at the proposed Injury and Illness Prevention Program, known as I2P2.

The ergonomics proposal would have required employers to enter musculoskeletal injuries and illnesses in a separate column on their OHSA logs. The agency said in a news release that small business had raised concerns about the plan and that it was being temporarily withdrawn to gather more input.

The ergonomics proposal and a proposed noise control initiative withdrawn last week were in the forefront of OSHA’s massive enforcement push over the last two years. While it is unclear what is behind the two withdrawals, the timing is interesting — coming just after President Obama announced a plan to revise federal regulations deemed excessive and harmful to economic growth.

There is no indication whether OSHA plans to backtrack elsewhere and doing so would be much more difficult in many cases since it would mean pulling back on initiatives that have already been put in place, such as the Severe Violators Enforcement Program and the substantial increases in average penalties across the board.

However, there is another proposal not yet implemented that OSHA would be well-advised to rethink – the Injury and Illness Prevention Program. Under that plan, announced last spring, all employers under OSHA’s jurisdiction would be required to have a safety program following specific federal guidelines.

While I agree with the idea of requiring all employers to have a safety program, it is impractical to have very specific federal requirements for those programs, since there are so many differences among businesses. I2P2 is another case of OSHA overstepping and it ought to be rethought.

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Keep alert to off-shift, contractor risks you may not see

January 17th, 2011 posted by Mike Taubitz

Mike Taubitz

Job Safety Analysis (JSA) is a long-standing foundation of the safety profession. Many jobs have low to moderate risk which is controlled by standardized work methods or instructions that could include procedures, training, awareness, PPE, etc.

Such jobs may only require standardized work instructions without a detailed JSA.

We all have limited time and resources. Prioritizing JSA’s for jobs that pose the highest risk makes sense. Remember, tasks that you do not see may pose the highest risk of fatal or serious injury. Do you know what the off-shift maintenance or contract workers are doing? Has anyone ever identified all elements of their tasks and the associated hazards?

Many breakdown tasks require power during troubleshooting. If employees are actuating solenoids or other machine devices to determine what is wrong with the operation, unidentified hazards could be present. Similarly, off-shift material handling may pose significant risk. Safety and supervision may never observe these things because they are not present when the work is being performed.

Talk with employees to get their input on the things that pose the risk of serious and fatal injury. Then prioritize your JSA efforts and devote time and energy to potentially high-risk jobs.

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OSHA’s fix on fall protection for residential construction leaves serious issues unresolved

December 9th, 2010 posted by Jim Stanley

Jim Stanley

OSHA has for sometime been trying to clear up the confusion it created about fall protection standards for residential construction, but the proposed fix may still leave many issues unresolved.

Last month, OSHA chief David Michaels said in a speech in Washington State that OSHA plans to rescind the blanket exemption in the fall protection standard for residential construction. His remarks, reported by Inside OSHA (registration required to view story) came about two years after an agency construction advisory committee proposed the change, which also has been sought by the National Association of Home Builders and the association of state OSH plans.

Under the changed policy – which is a return to the original standard — employers who want to use alternative fall protection measures would have to show that conventional fall protection techniques such as guard rails, personal fall protection systems and/or nets are infeasible or could create a greater hazard.

The current policy (which is still in effect) allows alternative plans by residential fall protection contractors to be used to protect workers at heights of six feet and above. The plans need not be in writing or be job site-specific. The OSHA directive has been criticized as endangering workers (I vehemently disagree) and OSHA has allegedly been trying to withdraw its directive for years. It is crystal clear that the agency has had difficulty determining what to do.

How will OSHA decide?

If the current directive is withdrawn and residential contractors are again required to make the determination on feasibility or greater hazard, it is not clear how OSHA will determine whether it agrees. As a matter of fact, there is no procedure for OSHA to agree or disagree other than an inspection.

The Occupational Safety and Health State Plan Association has advocated rescinding the interim fall protection guidelines. In 2008 it told then-OSHA chief Edwin Foulke that its membership felt the guidelines were unnecessary because residential construction activities performed at heights of six feet or more above floor or ground level can be performed in a safe manner using common building practices and conventional fall protection techniques. “OSHA’s [directive] has led to confusion in the regulated construction industry and potentially places employees and employers nationwide at unnecessary risk,” the group wrote to Foulke.

Again I disagree with the OSH state plan association. I have been on numerous residential construction sites where it has indeed been a much greater hazard to install conventional fall protection as opposed to implementing a fall protection plan which includes a controlled access zone and safety monitors. In addition on many sites it actually has been infeasible in many areas to construct guard rails, install nets or provide personal fall protection systems.

The National Association of Home Builders, while supporting the rollback of the current policy, has expressed concern that the standard does not define the term “residential construction” and wants to find a way to make fall protection plans consistent across job sites when builders are constructing similar houses.

To keep up with the latest news about increased OSHA enforcement, subscribe to this blog and have it sent automatically to your Reader or email box.

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Hidden in the stats: The dangers of maintenance work

December 8th, 2010 posted by Mike Taubitz

Mike Taubitz

Thorough recordkeeping is essential to a strong safety program, but even companies that keep good records may be missing something in their numbers: the high risk presented by maintenance activities.

About 6 percent of workers are involved in maintenance activities on a daily basis, where they are exposed to a wide variety of hazards. Figures from EUROSTAT indicate that around 10 to 15 percent of all fatal accidents are related to maintenance.

So a one-day conference called “Maintenance: Do It Safely,” sponsored by EU-OSHA and the Belgian EU Presidency last month was particularly valuable. The goal was to show how safe maintenance could save lives. This coincided with the release of EU-OSHA’s report, “Safe maintenance in practice: outlining key strategies businesses should adopt to prevent maintenance risks.”

The conference noted that maintenance is not only necessary to ensure the reliability of physical structures and productivity, but also is important to safer and healthier working conditions. “While maintenance is essential to keep equipment, machines and the work environment safe and reliable and prevent harm, the maintenance work itself is a high-risk activity,” the conference said.

The report details how safety and health risks associated with maintenance can be successfully managed. Good occupational safety and health management practices are at the heart of reliable and safe maintenance. Worthy of note is the recognition and inclusion of Prevention through Design, a NIOSH initiative.

Normal safeguards not always available

Awareness, skills, training, procedures and PPE become more important during maintenance work, because normal safeguards no longer provide protection. Unplanned/unscheduled breakdowns require maintenance to get back into production. Such situations are inherently higher risk when normal safeguards must be bypassed, for example:

• Guards must be removed
• Two hand controls do not provide protection
• Power may be required for diagnostic work and trouble shooting

These hazards and hazardous situations cannot be identified by analyzing lost time or recordable injury cases resulting from different exposures. If your company is primarily “focused on the numbers,” you may be overlooking some of the highest risk situations facing your workers – maintenance work. Two other factors inhibit efforts to deal with maintenance related injuries and fatalities:

• Research has shown that these high-severity incidents have low probability. Unless you have a database of near miss incidents for maintenance work, you will not have past history to analyze. Again, the exposures in maintenance work are different from those in your traditional injury illness database.

• There may be hundreds (even thousands) of unplanned maintenance tasks performed each year in small and medium enterprises. Unplanned maintenance typically involves many more tasks than planned maintenance and may pose greater risk because the risks have not been analyzed.

These issues could explain why good companies have an employee fatality when their injury statistics have been trending downwards for years. CEOs and others ask themselves, “What did we miss?” Maintenance cases are typically infrequent but often high severity. The maintenance recordable cases will be different exposures than those that result in a death. Near miss reporting could provide a history – but few have it.

Elements of a prevention initiative

Make sure that your injury prevention initiatives include:

• A process for proactively identifying high-risk maintenance work:

    –Talk to the workers and engage them in identifying the highest risk jobs.
    –Use task-based risk assessment to assure that proper protection is provided.
    –Observation

• Strong supervision
• Procedures
• Responsibility and accountability

If you have any questions, FDRsafety can help or feel free to contact me at mtaubitz@fdrsafety.com.

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Employers likely to face expense to meet OSHA requirements for controlling noise

November 2nd, 2010 posted by Mike Taubitz

Mike Taubitz

Employers in construction and general industry are likely to have a whole new category of expenses – and potential OSHA citations — to worry about if the agency’s “proposed interpretation” on noise regulations goes into effect.

Since 1983, OSHA in most cases has not cited employers who used personal protective equipment and a hearing conservation program to address noise rather than engineering and administrative controls. The exceptions were for noise so loud that it borders on 100 dBA when the most effective hearing protection is used or in cases where the controls cost less than an effective hearing conservation program. In practice, controls are almost always more expensive, so citations for failure to use them have been rare. However, that could change

That’s because OSHA now proposes to interpret 29 CFR 1910.95(b)(1) and 1926.52(b) as written.

These sections of the two noise standards are almost identical. They say, “When employees are subjected to sound exceeding those listed [in tables within the standard], feasible administrative or engineering controls shall be utilized. If such controls fail to reduce sound levels within the levels of the tables, personal protective equipment . . . shall be provided and used to reduce sound levels within the levels of the table.”

The agency said administrative or engineering controls would be considered economically feasible “if they will not threaten the employer’s ability to remain in business or if the threat to viability results from the employer’s having failed to keep up with industry safety and health standards.”

I started my career in 1970 as a process engineer in General Motors. One of my duties was assisting other engineers in eliminating and reducing noise with feasible controls on new machinery and equipment. Anyone who has ever had a similar job knows the challenge of reducing sound levels.

The challenge is compounded many times when trying to use engineering controls on existing equipment. Typically, enclosures are the last resort. However, employees must often go inside the enclosure for maintenance or tool change work and ventilation of air contaminants is often necessary. So when employers are calculating the cost of compliance, they need to be careful to include the cost of floor space, operational impacts and maintenance of the engineered control, among other things. These can all impact the assessment of whether the changes truly will affect the employer’s ability to remain in business.

If you haven’t reviewed this latest OSHA development, I encourage you to do so. For those who wish to comment, you may do so at www.regulations.gov, Docket No. OSHA-2010-0032) by December 20.

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