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068: Fundamentals of NIOSH Total Worker Health Safety
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Fundamentals of Total Worker Health
Keeping workers safe is the foundation upon which a TWH approach is built. Total Worker Health integrates health protection efforts with a broad spectrum of interventions to improve worker health and well-being.
The Fundamentals of Total Worker Health Approaches is the practical starting point for employers, workers, labor representatives, and other professionals interested in implementing workplace safety and health programs aligned with the Total Worker Health (TWH) approach. There are five Defining Elements of TWH:
Element 1: Demonstrate leadership commitment to worker safety and health at all levels of the organization.
Element 2: Design work to eliminate or reduce safety and health hazards and promote worker well-being.
Element 3: Promote and support worker engagement throughout program design and implementation.
Element 4: Ensure the confidentiality and privacy of workers.
Element 5: Integrate relevant systems to advance worker well-being.
Create a team of people who know about different policies, programs, and practices in your workplace that impact worker safety, health, and well-being. Draw team members from all levels of the workforce, and consider including the following:
Defining Element 1: Demonstrate leadership commitment to worker safety and health at all levels of the organization
Organizational leaders should acknowledge and communicate the value of workforce safety and health as a core function, and they should prioritize worker safety and health on the same level as the quality of services and products.
ProTip: Middle management is the direct link between workers and upper management and plays a critical role in program success or failure. For example, supervisors often serve as gatekeepers to employee participation in programs, and when program involvement competes with productivity demands, they may discourage employee participation
Effective programs thrive in organizations that promote respect throughout the organization and encourage active worker participation, input, and involvement. Leaders at all levels of the organization can help set this tone, but everyone (from managers down to front-line workers) plays an essential role in contributing to this shared commitment to safety and health. Beyond written policies, stated practices, and implemented programs that endorse safety and health in your workplace, consider the extent to which your organization’s spoken and unspoken beliefs and values either support or deter worker well-being [CPWR and NIOSH 2013].
Encourage top leaders to:
Encourage mid-level management to:
Defining Element 2: Design work to eliminate or reduce safety and health hazards and promote worker well-being
A Total Worker Health approach prioritizes a hazard-free work environment for all workers. It applies a prevention approach that is consistent with traditional occupational safety and health prevention principles of the Hierarchy of Controls.
Eliminating or reducing recognized hazards in the workplace first, including those related to the organization of work itself, is the most effective means of prevention and thus is foundational to all Total Worker Health principles. Although some hazards can be eliminated from the work environment, others (such as shift work) are more difficult to change. These must be managed through various engineering, administrative, or (as the very last resort) individual-level changes. Workplace programs that adopt a TWH approach emphasize elimination or control of workplace hazards and other contributors to inadequate safety, health, and well-being. This emphasis on addressing environmental determinants of health is a crucial concept for TWH programs.
The Hierarchy of Controls Applied to NIOSH Total Worker Health® provides a conceptual model for prioritizing efforts to advance worker safety, health, and well-being. This applied model is based on the traditional Hierarchy of Controls well-known to occupational safety and health professionals.
As in the traditional Hierarchy of Controls, controls, and strategies are presented in descending order of anticipated effectiveness and protectiveness, as suggested by the cascading arrows. The Hierarchy of Controls Applied to NIOSH Total Worker Health expands the traditional hierarchy from occupational safety and health to include controls and strategies that more broadly advance worker well-being.
The Hierarchy of Controls Applied to NIOSH Total Worker Health is not meant to replace the traditional Hierarchy of Controls, but rather is a companion to this important occupational safety and health model. It serves to illustrate how TWH approaches emphasize organizational-level interventions to protect workers’ safety, health, and well-being. To apply this model:
Using the Hierarchy of Controls Applied to NIOSH Total Worker Health, a program targeting reductions in musculoskeletal disorders could consist of the following:
Similarly, a TWH program reducing work-related stress might consider the following:
Defining Element 3: Promote and support worker engagement throughout program design and implementation
Ensure that workers involved in daily operations, as well as supervisory staff, are engaged in identifying safety and health issues, contributing to program design, and participating in all aspects of program implementation and evaluation. Again, letting workers be involved in workplace safety, health, and well-being, instead of being just recipients of services, nurtures a shared commitment to Total Worker Health. Some ways to do this include:
ProTip: Design programs with a long-term outlook to ensure sustainability. Short-term approaches have short-term value. Programs aligned with the core values of the organization will likely last. These should be flexible enough to be responsive to changes in workforce and market conditions, workplace hazards and exposures, and the needs of individual workers. A participatory approach can help in this regard, but keep sustainability in mind for the bigger picture.
To help encourage worker engagement, communicate strategically; everyone with a stake in worker safety and health (workers, their families, supervisors, etc.) must know what you are doing and why. Tailor your messages and how they are delivered, and make sure they consistently reflect the values and direction of the initiative.
Whether workers are willing to engage in workplace safety and health initiatives, however, may depend on their perceptions of whether the work environment truly supports safety and health. For example, one study found that blue-collar workers who smoke are more likely to quit and stay quit after a worksite tobacco cessation program if workplace dust, fumes, and vapors are controlled and workplace smoking policies are in place
Defining Element 4: Ensure the confidentiality and privacy of workers
Designing and enforcing appropriate privacy protections goes beyond ensuring that only authorized personnel has access to sensitive safety and health information. Observe all relevant local, state, and national laws regarding the privacy of personally identifiable data and health-related information by taking appropriate steps. So doing things like masking personally identifiable information on reports, and using a digital management system that is encrypted and protected by user passwords are some best practices.
Data sources that require confidentiality considerations and/or protections:
Defining Element 5: Integrate relevant systems to advance worker well-being.
Total Worker Health emphasizes the role that organizations have in shaping worker safety and health outcomes, recognizing that a multilevel perspective that includes policy, environmental, organizational, and social concerns may be best for tackling complex challenges to worker safety, health, and well-being. Integrating data systems across programs and among vendors, for instance, can simplify monitoring and evaluation while also enabling both tracking of results and continual program improvement.
Consider ways to integrate relevant systems within your organization:
Questions to Consider Asking Yourself or Your Team
Understanding the connections between various systems and levels of an individual worker’s experience may help design creative, well-rounded approaches to safety and health challenges.
By working together and discovering what each professional in the organization is already working on you will often find related goals and objectives - the benefits administrator struggling to get workers to participate in an exercise class and the safety professional struggling to get a warm-up/stretching program started will be able to work together. So to put a pin in this topic, I will say this: If you want to have a successful wellness program, you must first have a strong culture of workplace safety. Then you can build on that credibility and ask folks to move toward participating in safety or health-related activities off-the-job. Make sure you are first building a workplace safety culture.
Let me know what you think about this episode. Send emails to firstname.lastname@example.org and share with me your thoughts.
You can find me on LinkedIn! Post an update, letting me know what you think of the podcast. Be sure to @ mention Blaine J. Hoffmann or The SafetyPro Podcast LinkedIn page. You can also find the podcast on Facebook, Instagram, and Twitter
|Jul 19, 2019|
067: Profiles in Risk Podcast Interview
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In this episode, I interviewed by Mr. Nick Lamparelli, the host of Profiles in Risk Podcast. We talk about general liability and risk management - something we don't touch on enough on the SafetyPro Podcast. We discuss my work with iReportSource and managed workflows for incident investigations.
I want to dedicate this episode to the incredible development team over at iReportSource for all the hard work that goes into building an incredible service that safety pros can use to help keep workers safe:
The intern team:
Let me know what you think about this episode. Send emails to email@example.com and share with me your thoughts.
You can find me on LinkedIn! Post an update, letting me know what you think of the podcast. Be sure to @ mention Blaine J. Hoffmann or The SafetyPro Podcast LinkedIn page. You can also find the podcast on Facebook, Instagram, and Twitter
|Jun 29, 2019|
065: Establishing an Effective Fatigue Risk Management System
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Fatigue and its safety implications is an important topic that likely impacts every single industry. According to the National Safety Council, when people don’t get the sleep they need, they aren’t able to physically or mentally function at optimal levels - routine tasks feel more demanding. Reaction times slow. People become more forgetful, make poor decisions, and don’t communicate or coordinate well with their co-workers.
Many studies have found a connection between fatigue and increased safety risks on the job in a wide range of work settings. Long work hours, working at night, and rotating shifts are some factors that can lead to increased risks of errors, incidents, accidents, and injuries.
Absenteeism represents a significant cost to organizations, and sleep loss is one of its leading causes. Presenteeism, being at work but not working effectively, also leads to substantial reductions in productivity. With reduced physical and mental functioning due to lost sleep, productivity goes down.
Increased risk of errors
People with sleep deficits are not as productive as they could be, and they are also more prone to making mistakes and errors. An estimated 274,000 insomnia-related workplace accidents and errors occur yearly and cost U.S. employers more than $31 billion, which is more than any other chronic health-related condition.
Incidents and crashes
A 2014 study estimated that up to 21% of all fatal vehicle crashes might involve a drowsy driver. Factors that contribute to such events include working multiple jobs, working nights or other unusual schedules, getting less sleep than needed and getting poor-quality sleep. Long commutes add to longer waking days and cut into the time available for sleep, putting many workers at increased risk for driving while drowsy.
ProTip: According to the NTSB: 20% of accidents are related to fatigue, with 40% of highway crashes involving fatigued drivers. Share this information as much as possible.
Fatigue culture is difficult to overcome
A workplace culture that rewards or tolerates fatigue can also be a factor. In some high-performance cultures, employees may view fatigue as a sign of weakness or laziness. They may be committed to getting the work done despite long hours, even coming to believe fatigue doesn’t affect them.
Employers may incentivize long hours with financial incentives or promotions, increasing risk and promoting a culture of burnout instead of managing fatigue as a potential safety hazard.
Fatigue management as part of safety management systems
We address workplace fatigue through the same types of safety management mechanisms that an organization uses to for overall safety. Such an approach ideally applies multiple elements, recognizing that fatigue is a complex issue that can be minimized but not eliminated.
Getting started with a fatigue risk management system
Fatigue management is a way to further enhance the current safety management system and can rely on many existing mechanisms. As a first step, organizations should make an effort to understand what fatigue risks exist.
Incremental components or comprehensive plan
While a comprehensive fatigue management program may be the best approach, especially for larger organizations, test individual elements at first. A first part, perhaps smaller in scope, can be implemented and evaluated. Lessons learned can then be applied as the component is expanded upon and when considering other activities.
Form a fatigue committee
Designating an individual, or individuals, to head up fatigue management activities is critical for success. For larger organizations, a small committee can oversee activities, gather and evaluate feedback, and determine areas to focus efforts. Having representatives from across the organization such as safety, operations, and health/wellness will ensure that you include different perspectives.
It is essential that the fatigue management process be transparent and that appropriate information is shared throughout the effort to obtain buy-in from all levels of the organization. Providing open forums that allow employees to share how fatigue affects them is one way to get engagement from the outset.
Identifying fatigue risks
In addition to employee input, an audit or survey of supervisors and managers can help determine where fatigue risks exist and provide an indication of the magnitude. Such information can help prioritize what countermeasures or mitigation actions to take and where to focus efforts.
For the initial activities, it is imperative to present some action in the near term, so contributors will feel their input was and is incorporated. As a result, they are more likely to be engaged in the ongoing process and actions.
Critical components of a fatigue risk management system (FRMS)
Education and training
Sleep health education is a vital element of any fatigue management effort. Different delivery mechanisms can be considered and may be used over time as the program matures as a way to help keep information fresh. Depending on available resources, external expertise can be beneficial. In a public safety setting, expert-led sleep health training resulted in knowledge acquisition and subsequent actions to address sleep issues. Consider sleep health education as part of annual, recurrent or new-hire training.
While individuals are generally unreliable at recognizing the effects of fatigue in themselves, developing a "personal signs and symptoms" checklist can provide a structured mechanism for self-assessment. People should include ways in which fatigue affects them, such as yawning or being forgetful and then track the number of hours of sleep in the past 24 hours, hours awake and time of day. If multiple fatigue factors are present, then the individual should seek out countermeasures to boost alertness.Policies and practices
Clarify roles and expectations - A recognized internal point of contact with responsibility for fatigue management efforts is a necessary first step towards practical implementation. This individual should be responsible for managing communications about the program and coordinating all program activities. This “fatigue champion” recognizes both the benefit to the organization and employees’ lives. The champion can provide an extra level of motivation and inspiration that can lead to an exceptional fatigue management program.
Policies and practices for work periods - Effective policies and practices for hours of work and rest should be science-based and recognize the physiological need for sleep and circadian rhythms. They should also take into consideration the type of work that needs to be done and understand the characteristics of the workforce. There is no “one size fits all” number for daily or weekly work hours.
Daily and weekly limits - Daily fatigue risks increase with more hours on duty, or with more time on task (hours of work without a break). Daily work limits should also address the impact of hours awake, and how factors such as commute times and shift start times will affect the time workers are awake before the start of their work period.
Sleep loss throughout a workweek impairs performance. Setting weekly limits on total work hours and including a provision for a weekly off-duty “reset” period are common ways that organizations seek to manage the cumulative effects of sleep loss over time. The intent of the “reset” day or days off is to allow workers to obtain recovery sleep and be rested and ready for their next period of workdays.
Time-of-day fatigue (circadian rhythm misalignment) - Working at night and corresponding daytime sleep are both misaligned with the normal circadian rhythms. Fatigue risks increase during night shifts, and sleeping during the day is less than optimal due to the circadian clock. For those working a night shift, consider minimizing monotonous or monitoring tasks that can unmask underlying sleepiness, and safety-sensitive duties should be scheduled earlier in the work shift when possible.
ProTip: Early morning shifts require employees to adjust their sleep schedules, which might lead to chronic sleep loss. They also need employees to be alert when their bodies are still in sleep mode. Discuss this with your employees to raise awareness.
Limits on night shifts - With increased fatigue risks associated with working at night, employers should consider implementing shorter night shifts, which provides a way to minimize the interaction of risks related to hours awake and the increased likelihood of fatigue during the low point in circadian rhythms.
Fatigue risks have also been found to increase over consecutive night shifts, so minimizing multiple nights in a row and providing regular breaks should be considered.
Limits on early morning shifts - Early-morning shift starts can also infringe on individuals’ regular sleep periods. With long commutes, wake times necessary for early shift starts may feel more like the middle of the night than morning.
Difficulty in getting to bed earlier than our circadian clock’s programming is a challenge in getting adequate sleep.
Limits on work hours - While flexibility is necessary in many situations, additional restrictions should be considered for those working irregular schedules, for example limiting the number of on-call periods per week.
Shift workers are vulnerable to fatigue because of non-traditional work schedules that might require long shifts, non-daytime working hours, and changing shifts. As a result, shift workers are at a higher risk of drowsy driving.
One shift-working population that is at particular risk is medical workers, who can log more than 100 hours in a workweek with very little sleep. After an extended shift, medical interns were five times more likely to have a near-miss incident on their commute home, and twice as likely to have a motor vehicle crash.
Fit for Duty - An employee arriving fit for duty is the responsibility of both the employer and the employee.
A workplace with positive environmental controls promotes better overall working conditions and should be less physically stressful in ways that contribute to fatigue on the job. Factors such as high temperatures, noise, and vibration are leading drivers of occupational fatigue.
Environmental factors can play a role in employees’ accumulation of fatigue. Things that help promote alertness include:
Also, designated break areas that are separate from the work areas can be an essential tool in managing fatigue. Break time in well-lit, moderate temperatures with adequate ventilation (fresh air) can provide an opportunity to reset for those working in physically stressful settings.
ProTip: Caffeine can provide a short-term boost to alertness when appropriately used. Rather than relying on caffeine throughout a shift, it is best to use it just before a critical work task or before the mid-afternoon period when sleepiness occurs. A cup of regular coffee with 100–200 mg of caffeine can boost alertness up to four hours, with about 15–30 minutes needed to take effect. Be cautious with sugar in coffee or caffeinated beverages, as it can reduce alertness when coming down from the “sugar high.”
Data-driven programs and continuous improvement
A fatigue management program provides the most value when it is data-driven and strives for constant improvement.
Ask employees for their input - Employees can be a wealth of information. You need to ask and listen.
Low reporting levels? Maybe something isn’t working. Don’t assume that low reporting levels mean there are no issues. Are reporting and monitoring systems effective? Usable? Are employees discouraged from reporting by the use of layered paperwork processes?
Monitoring and reporting mechanisms allow the program champion and other safety managers to assess the levels of fatigue risk in the organization over time, identify trends, and understand the issues that are being reported and need addressing. Incorporate reporting processes into current procedures within an existing safety management system. Keep in mind that when implementing a program, low levels of reporting may indicate a lack of awareness of the program rather than a lack of fatigue-related issues in the workplace.
Incident and accident investigation reporting
Established incident and accident investigation processes should be expanded to include an evaluation of the potential role of fatigue. Generally, a combination of factors present at the time of an incident/ accident would indicate that fatigue played a role. Include the following:
Review and learn from data
Incident and accident reports can be a valuable tool for the fatigue program manager. Look for trends in the types and sources of reported fatigue factors. Investigations can provide valuable “lessons learned” to incorporate into ongoing education and training activities.
Continuous improvement: collecting data and applying lessons learned
As with any organizational safety-related effort, it is essential to seek ways to continue improving operations. Monitoring and reporting information, along with incident or accident investigation and reporting, provides valuable information to the program manager.
Employers should consider a regular internal audit, or use of an external evaluator to address the above questions and determine ways for further improvements and expand the program.
Fatigue Management Tools
Scheduling software - Some industries, such as aviation, use programs that evaluate work schedules for potential fatigue risks as part of their fatigue management efforts. Such programs use science-based algorithms related to factors such as sleep need, circadian disruption, hours awake and time of day. Safety managers then evaluate work schedules for potential issues and implement strategies that will attempt to address the problems and minimize risks.
Risk assessment tool - Factors include the length and timing of work periods, time-on-task, workload, consecutive days or nights of work, variations in work schedule, and timing and duration of rest periods.
Other factors to consider include worksite environmental conditions, commute times and other potential stressors such as critical deadlines. Safety managers can similarly evaluate potential risks with this approach and determine interventions to minimize those risks.
ProTip: You can do all of this by using a tool like iReportSource by the way. So as I often ask folks; if you aren't already using a digital EHS solution, why?
Wrapping it all Up
The National Safety Council is leading the conversation on workplace fatigue in the U.S. Follow the various links in this post to learn more.
NIOSH offers tips to help reduce the effects of fatigue in the workplace:
Cost of a Tired Workforce
NSC in collaboration with the Brigham and Women’s Hospital Sleep Matters Initiative developed an online fatigue cost calculator that estimates the cost of sleep deficiency for businesses. Entering four data points into the calculator – workforce size, industry, location, and shift scheduling practice – generates an estimated dollar cost that helps the organization quantify the cost of fatigue and justify the implementation of a fatigue risk management system (FRMS).
The cost calculator and the methodology used to create it are in Calculating the Cost of Poor Sleep: Methodology at www.nsc.org/tiredatwork.
Find more information about the effects of fatigue on physical and mental functioning in the NSC report Tired at Work: How Fatigue Affects Our Bodies.
You have a lot on your plate…But iReportSource helps you own safety and become the master of your culture:
|May 07, 2019|
065: Join Me at the VPPPA National Symposium in August
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ANNOUNCEMENT: Visit VPPPA to register for the National Symposium and join me as I podcast on location! Listen to this episode for some details.
Let me know what you think. Send an email to firstname.lastname@example.org and share with me your thoughts about VPP or the VPPPA.
Please leave a ranking and review on Apple Podcast, it helps others find the podcast and assists me in making improvements.
If you are not on Apple Podcast you can find me on LinkedIn! Post a LinkedIn update letting me know what you think of the podcast. Be sure to @ mention Blaine J. Hoffmann or The SafetyPro Podcast LinkedIn page. You can also find the podcast on Facebook, Instagram, and Twitter!
|Apr 10, 2019|
065: Podcast Announcement - New Look, New Sound, Same Mission
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In this announcement, I reveal a new strategic partnership that strengthens the high quality, actionable safety info you have come to expect from this podcast! I am excited to make this announcement.
Blaine J. Hoffmann, MS OSHM
VP, iReportSource - Simplifying Safety
|Apr 10, 2019|
064: Is Your Safety Management System ISO 45001 Ready?
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Every day, thousands of lives are lost due to work accidents or fatal diseases linked to work activities. These are deaths that could and should have been prevented and must be in the future.
Whether you are an employee, a manager or a business owner, you share a common goal – you don’t want anyone to get hurt on the job. Improved productivity stems from ensuring people operate in workplaces that provide transparency and build trust throughout their operation and supply chain. In addition, responsible practices are becoming increasingly important to brands and reputations.
ISO 45001 is the world’s first International Standard dealing with health and safety at work. Quite simply, it offers a single, clear framework for all organizations wishing to improve their OH&S performance. Directed at the top management of an organization, it hopes to provide a safe and healthy workplace for employees and visitors. In order to achieve this goal, it is important to control all factors that might result in illness, injury, and in even fatalities, by mitigating the impacts hazards have on the physical, mental and cognitive condition of workers – and ISO 45001 covers all of those aspects.
While ISO 45001 does draw on OHSAS 18001 – the previous benchmark for workplace safety – it is a completely new and distinct standard, not simply a dusted off version or revision or a simple update. Organizations will, therefore, need to revise their current thinking and work practices in order to maintain organizational compliance.
What are the major differences between OHSAS 18001 and ISO 45001?
There are many differences, but the main change is that ISO 45001 focuses on the interaction between an organization and its total business environment while OHSAS 18001 was focused on managing hazards and other internal-only issues. But the standards also differ in other ways:
These points represent a huge shift in the way health and safety management and even viewed in business today. Safety can no longer be treated as a “stand-alone” department or silo. Instead, key safety roles need to be embedded within the company - partnering with the various departments in order to run a sustainable organization.
Let's see what ISO.org has to say:
My company already follows OHSAS 18001. How do I start to switch over to ISO 45001?
When moving over from OHSAS 18001, there are some steps you have to take in order to lay the groundwork for ISO 45001. Here are a few steps ISO.org says you will need to take to get started:
Once you have adapted all the data to the tools of OHSAS 18001, you can reuse most of what you already have in your new management system. So, while the approach is quite different, the basic tools are the same.
What do I need to know if I am new to ISO 45001?
The answer depends on how much you know about ISO management systems. ISO 45001 adopts Annex SL, thus sharing a high-level structure (HLS), identical core text and terms and definitions with other recently revised ISO management system standards such as ISO 9001:2015 (quality management) and ISO 14001:2015 (environmental management). If you are already acquainted with the common framework, then much of ISO 45001 will seem familiar to you and you will just need to fill the “gaps” in your system.
If this is not the case, things could be a little more tricky. The standard is not easy to apprehend when you read it as a normal book. You have to realize all the interconnections between the specific clauses. The best advice would be to find a good training course to help you unlock the standard’s full potential. You may also want to consider employing consultancy services to assist you in the process.
See the entire ISO.org article here: https://www.iso.org/news/ref2271.html
How can I compare my safety management system against ISO 45001?
The best thing to do is to use the checklist that you can download HERE
Let me know what you think. Send an email to email@example.com and share with me your thoughts about ISO 45001.
You can find me on LinkedIn! Post a LinkedIn update letting me know what you think of the podcast. Be sure to @ mention Blaine J. Hoffmann or The SafetyPro Podcast LinkedIn page. You can also find the podcast on Facebook, Instagram, and Twitter!
|Mar 13, 2019|
063: New Tool to Check for Mold in Your Buildings
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“Implementing regular visual inspections for dampness can help to identify trouble areas before they become major problems and help to prioritize maintenance and repair,” said David Weissman, M.D., director of NIOSH’s Respiratory Health Division. “The Dampness and Mold Assessment Tools provide an inexpensive mechanism to investigate, record, and compare conditions over time.”
Office buildings, schools, and other nonindustrial buildings may develop moisture and dampness problems from roof and window leaks, high indoor humidity, and flooding events, among other things. Damp building conditions promote the growth of mold, bacteria, fungi, and insects. Occupants in damp buildings can be exposed to pollutants in the air from biological contaminants and the breakdown of building materials.
Research has shown that a number of health problems are associated with exposure to building dampness and mold including:
The Dampness and Mold Assessment Tools guide users through assessing all rooms, whether in a school or a general building, for areas of dampness and mold and identifying the source(s) of the dampness and mold. The tools provide an easy-to-use checklist and instructions for assessing and recording any damage that is found and for tracking conditions through time
NIOSH previously published an Alert, Preventing Occupational Respiratory Disease from Exposures Caused by Dampness in Office Buildings, Schools, and Other Nonindustrial BuildingsCdc-pdf that provides further information on respiratory disease related to indoor dampness and recommendations for preventing and remediating damp buildings.
When workers suspect their health problems are caused by exposure to building-related dampness or mold, workers should report new, persistent, or worsening symptoms, particularly those with a work-related pattern, to their personal physician and, as instructed by their employer, to a designated individual at their workplace.
You can find more information about dampness and mold in buildings, including action steps for management and building owners and workers, on the NIOSH website.
NIOSH is the federal institute that conducts research and makes recommendations for preventing work-related injuries and illnesses. More information about NIOSH can be found at www.cdc.gov/niosh/.
Let me know what you think. Send an email to firstname.lastname@example.org and share with me your thoughts about indoor air quality.
Please leave a rank and review on Apple Podcast, it helps others find the podcast and assists me in making improvements.
If you are not on Apple Podcast you can find me on LinkedIn! Post a LinkedIn update letting me know what you think of the podcast. Be sure to @ mention Blaine J. Hoffmann or The SafetyPro Podcast LinkedIn page. You can also find the podcast on Facebook, Instagram and Twitter!
|Mar 04, 2019|
060: 4 Ways to Use Data to Improve Your Safety Culture
Mentioned in this episode:
Every safety leader wakes up each morning looking to avoid any accidents. And, each day, you want to take steps to improve your culture of safety.
That’s no easy task, which is part of why an analytics dashboard is so helpful in giving you the information you need to do just that.
Listen to this episode to get a quick introduction into 4 ways you can use data to improve your safety culture.
Use data to drive shared accountability
A great scorecard tells a story of what’s happened, what’s currently happening, and what needs to be done next. Part of that picture is also about improving accountability to make sure what needs to happen does happen.
iReport’s dashboard is one example of a tool that supports accountability and improvement: it shares accountability documents created, proactive reports, critical actions needed, the number of days without incidents, the number of incidents, the type of incidents, and more.
In doing so, it helps to make the connection between what’s been done and what needs to be done, and why. As simple as it sounds, knowing just what to do and being held clearly responsible for it is invaluable in supporting a safer culture.
Use data to show costs avoided
It’s clear that there are costs to any incident or accident. Direct costs include property damage, theft, workers’ comp, fatalities, lawsuits related to injuries (or worse!), and legal fees in general, just to name a few.
But if an incident happens, there’s also harm done to your company’s brand and goodwill, your reputation, and it affects employees’ trust and morale. It can negatively affect productivity and it can affect the kind of talent you’re able to recruit and hire in the future.
What’s more: there is also a long list of indirect costs: downtime per day, distraction, and your insurance premium increase.
The point is this: effective data will allow you to show at least some of these indirect costs. That’s a powerful tool when it comes to showing ROI and in giving a strong rationale for future safety investments.
Use data to take the guesswork out of corrective actions
One of the best ways to see if your data is working for you: whether or not your data has the ability to prevent future occurrences of a similar or same type of incident. If your data (or dashboard) isn’t informing you of ways to make changes, you have a major opportunity for improvement.
For example, iReportSource’s dashboard generates a real-time view of near miss by type, top causes for corrective action, and Total Case Incident Rate (TCIR). It also gives you a snapshot of other key incident and inspection metrics. Based on what’s most meaningful to your company, it captures behavior-based steps/actions that have occurred so you can know exactly what’s going on and where.
Use data to keep everyone in-the-know
Whatever dashboard you use, be sure that anyone—from upper management to HR to safety—has quick access to your report. When everyone does have that access, there’s no more waiting on the safety leader (or another person) to send the report.
That means your data is more real-time and more actionable than ever. Finally, you can easily show exactly how safety is improving each month and why. Plus, if someone leaves your company, you’re not stuck trying to figure out what he or she had completed in terms of data collection.
Let me know what you think. Send an email to email@example.com and share with me the tools you use! Also, leave a rank and review on Apple Podcast, it helps others find the show and assists me in making improvements.
If you think of it, find me on LinkedIn! Post a LinkedIn update letting me know what you think of the podcast. Be sure to @ mention Blaine J. Hoffmann or The SafetyPro Podcast LinkedIn page. You can also find the podcast on Facebook, Instagram and Twitter!
|Feb 17, 2019|
059: 8 Critical Tips for Effective Safety Coaching
Mentioned in this episode:
Does your company help develop employees through coaching?
Not to be confused with training, or even consulting, coaching is a much more collaborative process that helps to bring out someone’s best work. In fact, two-thirds of employees cite that coaching improved their performance within their company and also improved their satisfaction (1).
Coaching sessions can include open-ended questions and discussion on personal and professional goals and objectives. If coaching happens consistently, it can strengthen relationships between managers/employees and between peers. It can reinforce the right kind of behaviors you want to see in your business to promote safety and health. Last, it also helps workers have more support as they work through challenges or problems, both personally and professionally (2, 3, 4).
Here are top tips you can utilize for effective safety coaching:
1. Don’t assume leaders know how to coach
Make sure leaders are equipped to start coaching before you ask them to do so. For example, a common misconception is that coaching is where specific performance feedback can be given. While coaching can influence an employee’s performance, a coaching session is not the same as a review session, even if your current reviews are informal.
First, help leaders recognize that coaching is an open-ended conversation that is aimed at helping someone improve…and that is in all areas of their life. On the other hand, an evaluation is going to give specific feedback to someone regarding their performance. If coaching is what you’re after, make sure your leaders know that difference (2).
Second, teach leaders how to use open-ended questions during their coaching sessions. Instead of asking a question that can be answered with a simply “yes” or a “no,” open ended inquiries can be used to help lead someone into potential solutions. It also helps them to better reflect and to become more self-aware. These kind of questions can also give the coach more context about a challenge someone is facing. Last, they also keep the focus on the person who is receiving the coaching.
For example, if someone is having uncertainty with how to resolve a safety-related issue on their team, avoid immediately giving them potential solutions. Instead, ask them questions by using words such as “what and “how.”
That could sound like: “How do you envision this process changing?” or, “What have you considered doing to change the way things are done?”
By giving them the opportunity to reflect and talk out the solution, leaders can remain focused on listening. After hearing more from the person, then a coach can help the individual learn how to come up with solutions. This will build confidence, empower the individual and help them break out of three vicious circles that author Michael Bungay Stonier describes in the book “The Coaching Habit: Say Less, Ask More & Change the Way You Lead Forever”:
Getting good at coaching takes practice, but at least try to teach your people some of the subtle shifts in their behavior that can help the dialogue be productive and authentic (1, 5). This is the difference between consulting and coaching! Consulting is telling someone what to do - coaching is about helping others develop the ability to sense something needs to be changed, problem-solve, draw upon the needed resources the organization has to affect change and make good decisions.
2. Make sure it’s a two-way conversation
Since a coach is often going to be in a position where they are helping to drive some kind of change, make sure you are having a two-way conversation that allows for that to happen. Avoid the temptation to make it all about yourself. The key is to actually talk less and listen more (6).
In addition, if you are the one doing the coaching, avoid the tendency to share all your stories that are similar to the person being coached; after all, the focus is on them, not you. Again, this is where leading or empowering questions can be a very effective tool to use. Remember, telling someone what they should do is consulting. It also creates dependency. It can be tricky to get into here, but go grab The Coaching Habit book I mentioned and start some of the habits the author described.
The bottom line is that things need to be addressed, but you as a coach need to develop other leaders’ ability to coach as well. Each problem they bring to you is an opportunity to further develop their ability to coach others as well. So open up the lines of communications and ask good questions and listen!
3. Provide ‘just enough’ structure
Coaching—even if it’s peer to peer coaching—won’t necessarily happen on its own. Like anything with your culture, be as intentional as possible about how your coaching sessions are going to be implemented. Companies with effective safety coaching take the time to develop strategies and internal processes that support a culture of coaching (4, 5).
Especially when a company is first introducing coaching, structure is going to help. Give guidance on responsibilities related to coaching, coaching duration, the type of coaching you are looking for, and any desired outcomes or measurement of feedback that you want captured (4, 5).
4. Avoid punishment
Coaching should be focused on empowering people to succeed. This means you want to avoid the perception that there will be negative consequences from anything discussed in your session. We want to see this activity as a way to learn and grow, not discover deficiencies and hold someone accountable for them.
Look to avoid any kind of punishment or discipline when coaching. That doesn’t mean there can’t be any accountability, but these interactions are not a place where there should be any kind of fear.
5. Capture the progress
Companies that are successful at safety coaching are able to capture and celebrate all the progress someone has made. Depending on the level of formality your coaching has, at the very least, celebrate small wins and successes. Then, when you can, be sure to capture contributions and share that with your team, when appropriate.
6. Encourage peer-to-peer coaching
Many of us think of a manager coaching a direct report, and in many cases, that’s going to be the kind of coaching relationship that is most effective. But also know that peer to peer coaching is extremely valuable and can also help to deepen relationships and improve morale in your company.
7. Customize your coaching to the learning curve of the employee being coached
Safety training typically requires everyone to meet minimum standards at a certain point in time. In contrast, your coaching sessions are going to have their own pace that is going to be different for everyone.
Embrace how these interactions are going to be mostly based on the learning curve of the employee who is being coached (4). In other words, with much less structure than a training session, coaching sessions are going to follow an employee’s progress—and that progress is going to ebb and flow at times (2, 3, 4).
8. Always come from a place of compassion
Coaching interactions are all about improving an employee and helping them develop in specific areas they care about. For that to happen, there has to be a deep sense of caring and mutual trust in any session. As a coach, you can help that happen by always coming from a place of compassion as you hear about someone’s personal challenges, issues, and perceptions.
That is what makes safety a great place to start in any organization that wants to develop a coaching culture. Safety starts with the basic assumption that all workers just want to do a good job and be able to return again. Even the most average worker punching the clock - that’s what they want to keep doing, their job. Preventing injuries and illnesses that ultimately prevent that is compassionate. That’s what I love about this industry; we may have discussions about how to get there, but not getting hurt is something that almost all of us can agree.
Improve Safety & Health In Your Company
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|Feb 12, 2019|
057: 5 Common OSHA Recordkeeping Errors to Avoid
Mentioned in this episode:
What are some of the top mistakes employers make when it comes to OSHA recordkeeping? (article link HERE)
Even with good intentions, here are some of the top mistakes that can happen, resulting in major headaches and even citations:
Let’s take a closer look at some of these common errors, and what steps you can take to avoid making the same missteps.
1. Not understanding what an OSHA-recordable work restriction is
Don’t make the mistake of believing an injury is not recordable as a work restriction if your injured employee is still doing useful work, even if that work is within their job description.
Just because you’ve worked at another employer that made this mistake, don’t make this same error, even if it’s a misunderstanding of the regulation up until now (2, 6). Recognize how OSHA states how much it comes down to the routine functions of the worker:
Restricted work occurs when, as the result of a work-related injury or illness: You keep the employee from performing one or more of the routine functions of his or her job, or from working the full workday that he or she would otherwise have been scheduled to work; or A physician or other licensed health care professional recommends that the employee not perform one or more of the routine functions of his or her job, or not work the full workday that he or she would otherwise have been scheduled to work [emphasis added] (2, 6).
2. Not using enough detail in records
Be sure you accurately report and record all injuries—each and every time. That means including as many specific details as possible in case you need to defend a certain incident or issue.
For example, that may include factors such as:
With iReportSource, you have a guided process that was designed to help make sure all information is collected and recorded in an accurate and detailed way…no matter what worker is collecting that information for future use.
A major part of this is making sure you have a way for all workers to record and/or report work-related injuries, illnesses, and incidents. If there’s no simple and accessible way to do so, it’s going to be much harder to make sure that information is consistently gathered in a detailed, comprehensive manner.
3. Not using a system to track employees’ days away from work and other events
Do you have detailed information on what’s happening with all your incidents and/or claims? And are you able to easily see the ongoing status of any injured worker, no matter how long they’ve been away from work? (2)
One of the biggest errors employers can make is forgetting to track the days away from work once an employee has stopped reporting to work. You also don’t want to be in the dark when it comes to updates to an employees’ health that come from their physician (2).
To fix this potential error, make sure you have a system that can track and monitor these types of subsequent events. With that kind of visibility, recordkeepers can consistently track them—and you can put that knowledge to use, too, so you can mitigate risks that have been causing those accidents in the first place.
4. Not keeping OSHA 300 logs up to date during the required 5-year storage period
If requested by OSHA, would you be able to present your five-year history of logs with 4 hours? Many organizations, for a number of reasons, fail to maintain their OSHA 300 Log during the five-year storage period.
That updating and maintenance includes newly discovered recordable injuries or illnesses.
It also includes documenting changes that have occurred in the classification of previously recorded injuries and illnesses. If the description or outcome of a case changes, you must remove or line out the original entry and enter the new information (1, 3).
The bottom line: make sure they are maintained, and make sure they are easily accessible so you can always provide those up-to-date copies to OSHA.
5. Lack of alignment between workers’ comp recordkeeping and OSHA recordkeeping
Yes, these are separate records, but information on workers’ comp records and OSHA records should at least coordinate and the information should be able to line up accordingly. That also means if OSHA were to ask to see your workers’ comp records, the information provided should be able to align with your OSHA log—or else, you should be ready to explain why it doesn’t (5).
Avoid Any OSHA Recordkeeping Errors
One significant obstacle with detailed, accurate and organized recordkeeping: not having a consistent, reliable way for workers to do it. iReportSource changes that, making it possible to track and manage workflow and accountability in real time.
With everything from reporting employee injuries and auto accidents to performing job safety audits and inspections, iReport is your all-in-one safety solution. Request a demo to learn more today.
What are your thoughts? Send emails bout how you use technology to keep workers safe to firstname.lastname@example.org
|Feb 04, 2019|
056: Safety Hazards in the Healthcare Industry
Mentioned in this episode:
Findings from a survey conducted by the National Institute for Occupational Safety and Health (NIOSH) show that precautionary measures to minimize worker exposure to high-level disinfectants (HLDs) are not always used. The study results were recently published in the journal Infection Control and Hospital Epidemiology.
The recent release is one of a series of reports detailing results from the 2011 Health and Safety Practices Survey of Healthcare Workers, the largest federally-sponsored survey of healthcare workers in the U.S. Respondents included those who chemically disinfect medical or dental devices using one or more of the following HLDs during the past week:
Information on various exposure controls and impediments to using personal protective equipment (PPE) was assessed.
Findings suggest that recommended practices are not always used by healthcare workers. The following describes examples of practices that may increase exposure risk:
When precautionary practices are not followed, workers handling HLDs are at risk of exposure. Ensuring proper precautionary measures are utilized requires diligence on the part of both employers and healthcare workers. Employers who provide a safety culture that demonstrates a strong commitment to health and safety of their workers ensure that adequate resources and safety equipment are available.
Yes, workers should seek out training, understand and follow safety procedures, and feel free to report any safety concerns. In order to do this, leadership must set that expectation and provide the support needed to develop this culture of safety excellence.
What are your thoughts? Send emails bout how you use technology to keep workers safe to email@example.com
|Jan 27, 2019|
055: Using Drones for Safety
Mentioned in this episode:
How would you like an OSHA inspector to launch a drone over top your jobsite or building, looking for hazards and violations. Perhaps workers on the roof, forklift operators in the yard, cell tower workers on a mountain - an OSHA inspector could see it all without even stepping foot on your property.
It's not as far-fetched as it may sound.
OSHA has authorized the use of drones by certain inspectors to collect evidence during inspections in certain workplace settings.
But before you freak out, currently, OSHA inspectors are only allowed to use drones for enforcement purposes in areas that are inaccessible or pose a safety risk to inspection personnel.
The other issue worth noting; OSHA must obtain express consent from the employer prior to using a drone on an inspection. In addition, personnel on site must be notified of the aerial inspection prior to the drone's launching.
So, for now, most employers don't have top worry. But, it is something that employers should keep in mind, in case OSHA decides to expand their use of drones. Obviously, any secret usage over an employer's worksite could bring up constitutional issues, but as technology advances, and drones become more commonplace, employers may want to incorporate the issue into their OSHA inspection procedures.
Listen to the full podcast episode to hear about ways you can use this technology to your advantage!
Send emails bout how you use technology to keep workers safe to firstname.lastname@example.org
|Jan 12, 2019|
054: Integrating Safety with Existing Processes
Mentioned in this episode:
Have you ever struggled to make your safety processes mesh with other existing business processes, like quality or maintenance? By using lean principles and tools it can be easy to do just that. Stop trying to convert workers and take the work to them, in terms/tools they are comfortable using.
This can be as simple as using a layered audit approach - piggyback off another inspection that is done frequently. Or leveraging existing operator checks, sprinkling safety-related checks in there. If there are chemical checks needed for quality then add checks for labels, SDS, spill kits, PPE, etc. to the list.
Using lean manufacturing is all about first asking what else are we doing that has worker's attention? Can we leverage those efforts? I read a pretty decent article touching on this and you can find it here: https://www.industryweek.com/safety/think-lean-make-safety-simpler
But for a deeper look and some real-world examples listen to this podcast episode. Be sure to share your tips on how you have been able to integrate safety with existing business processes. Send emails to email@example.com
|Dec 23, 2018|
053: How to Handle OSHA Safety Inspections
Mentioned in this episode:
In this episode I will talk about preparing for an OSHA inspection and how to best handle the event should one occur. Here, my focus will be what to do up front, and should a compliance safety and health officer (CSHO) arrive at your facility, what to expect and what you should have ready to make it go smoother.
I will also talk briefly about how to handle any alleged violation and potential citations that come your way.
Let’s first get some definitions out of the way:
I already mentioned the CSHO (Compliance Safety and Health Officer): This is the federal OSHA employee who conducts inspections for the agency — a.k.a. “OSHA Inspector.”
General Duty Clause (GDC): A section of the OSH Act — Section 5(a)(1) — that requires employers to protect employees from recognized, serious hazards, regardless of whether there is a specific standard addressing that hazard. OSHA often uses the GDC to cite employers for not protecting workers from ergonomic-type hazards, workplace violence, and heat stress.
OSHA: The Occupational Safety and Health Administration — the federal agency that sets and enforces worker safety and health laws.
OSH Act: The Occupational Safety and Health Act of 1970, which is the enabling legislation for OSHA.
Repeat violation: A hazardous/violative condition that is the same or similar to a previously cited condition in the past five years at either the same establishment or another establishment of the same company under federal OSHA jurisdiction.
Serious violation: A violation where there is a substantial probability that death or serious physical harm could result, and the employer knew or should have known of the hazard.
Willful violation: A violation that the employer intentionally and knowingly commits.
Understand that OSHA has the right to inspect places of work. A question I get more often than I am comfortable with is whether or not you can require OSHA to come back with a warrant. Yes, employers may exercise their Constitutional rights to request a warrant; however, there is a fairly low threshold for OSHA to obtain such approval - so this is not advised in many cases and will not show your willingness to cooperate. Instead, use your right to an opening conference upon their arrival.
Pro Tip: When the compliance officer arrives, avoid showing a negative attitude. Creating a bad first impression could set up your facility for failure so practice having a positive attitude towards the compliance officer. Being polite can put the inspector at ease and create a positive environment—you might even enjoy the inspection.
Know the reasons that prompt most inspections. Inspections can be triggered in a variety of ways, such as reports of serious injuries, complaints, targeting/emphasis programs, and plain-view hazards. They are seldom at random.
Note that some smaller workplaces in low-hazard industries may be exempt from certain types of inspections. See: CPL 02-00-051-Enforcement exemptions and limitations under the Appropriations Act.
Know the phases of an OSHA inspection. Inspections will consist of an opening conference, records review, walkthrough inspection, and closing conference. Citations will not be issued during the inspection; those come later from the Area Office director.
Verify CSHO’s credentials. Always ask to see the CSHO credentials upon arrival. You can also contact the area office to verify their identity if needed.
Get a clear understanding of the proposed scope of an inspection. CSHO’s should generally stick to that scope. This means, what do they want to see? A specific process, part of the facility, program review, etc. This tells you exactly how to narrow the visit - where to take them and where NOT to take them!
Have documents ready. The OSHA Compliance Officer will look for documentation including but not limited to injury and illness records, written safety plans, past inspections, training, exposures, and other safety-related documents. You should maintain, review, and keep documents in a place where you or an assigned supervisor can easily find and present them to the officer. Remember that OSHA could show up at any time. They'll usually arrive during business hours, but an inspection prompted by a serious workplace injury during third shift could mean a knock at the door in the middle of the night.
Pro Tip: A note about self-audits or inspections; OSHA has never officially stated that they will not use self-audits. However, in a final policy published in the Federal Register (65:46498-46503), OSHA stated that the Agency will not “routinely” request to see self-audit reports at the initiation of an inspection, and the Agency will not use self-audit reports as a means of identifying hazards upon which to focus during an inspection.
OSHA has also stated that where a voluntary self-audit identifies a hazardous condition, and the employer has corrected the condition prior to the inspection and taken appropriate steps to prevent recurrence, the Agency will refrain from issuing a citation, even if the violative condition existed within the six months limitations period during which OSHA is authorized to issue citations.
Keep in mind, OSHA has the right to take photographs during inspections. It is a good idea for employers to duplicate this effort. Employers must also remember that OSHA does have the right to photograph in confidential areas; in instances where there are trade secrets, OSHA has special privacy procedures to follow with regard to maintaining the case file documentation.
As for videos, the same rules apply here as well. I remember during one fatality I was investigating; the CHSO informed me of his intent to video tape and he showed me the camera, how he would turn it on, the light indicating it was on, etc. He even told me that he would NOT record me or ask me any questions during the recording. It was simply to capture the worksite and equipment that was involved in the fatality. He really made it a point to ensure I was comfortable - he even dispelled the myth that CHSOs would pretend they turned the camera off but kept secretly recording to gain evidence. That is NOT how they operate. I was there alone without an attorney, walking through a site where a 20-year employee of the company was killed - a very sensitive and emotional time. CHSOs are highly trained and more importantly, they are also human; they have empathy like anyone else. I was so impressed by this CHSO I have stayed in touch with him since then and we have collaborated on Q&A from time to time.
Always correct hazards. Although you might not undergo an inspection, correcting daily hazards can prepare you for an unexpected visit. I have said it for years, your number one strategy for dealing with an OSHA inspection is 3 words: BE. IN. COMPLIANCE.
You'll have less reason to fear an OSHA inspection if you conduct self-inspections, looking for missing machine guards, blocked fire exits, unkept working areas, and fall hazards. Preparing your workplace for a compliance officer will depend on your ability to consistently identify and correct known hazards.
For each alleged violation found during the inspection, the compliance officer has discussed or will discuss the following with you:
Do not interfere with employee interviews. Under the OSH Act, OSHA has the right to question employees privately. Supervisors however, do have the right to legal counsel. Be careful that you do not appear to be coaching or intimidating the CHSO.
I always held a brief meeting with all employees with the CHSO present to introduce them and explain that the only expectation the company has is that the employees, should they be interviewed, are to be cooperative and professional and that their conversation is kept private and confidential.
OSHA has 6 months from learning of a hazard to issue citations. Only the Area Director can issue citations. Once you get it, it will be certified mail and the clock starts ticking at that point. I will explain.
Post OSHA citations for 3 days or until the violation is corrected, whichever is longer. The citation must remain posted in a place where employees can see it, for three working days or until the violation is corrected, whichever is longer. (Saturdays, Sundays, and Federal holidays are not counted as working days.)
Pro Tip: Post it as close to the violation location as possible - in some cases, a public location will be acceptable. Like a bulletin board or inside a job trailer.
Exercise your right to an informal conference to discuss proposed citations. Employers may also contest citations before an independent review commission. This has to be requested ASAP! I always tell employers, even if you are going to agree with the citations, always ask for the informal conference.
It is a great opportunity to show to OSHA that your are committed to improving workplace safety and can even negotiate an informal settlement agreement - which will always have some training requirements attached, so be prepared to invest in time and resources and not just expect to smile and get a good neighbor discount.
Pro Tip: The Area Director is authorized to reduce proposed penalties by up to 50% with an informal settlement agreement. I have negotiated many of these and even had some proposed citations vacated during these conferences after bringing evidence and arguing an interpretation of the standard - risky but we were right so it made sense to do it at the time.
Remember there’s only 15-working days to file a proper notice of contest. This must be in writing. Which is why it is critical to get the informal conference going right away!
Do not retaliate against any worker for exercising their rights under the law. This is key - and if employee violations of company rules are at play, always ask OSHA about the retaliation rules if in doubt. But this may be needed as a result of any investigations.
A pro Tip: Simulate inspections…
The best way to train is to simulate an inspection. Prior to an OSHA Compliance Officer visit, practice the procedures that will be taken when the officer arrives. insurance underwriters can offer some assistance here - think about it, they will often inspect workplaces as a part of their coverage policy, so why not communicate to staff/employees that this is also a mock audit?
Ask the insurance rep for their agenda and add some activities that the CHSO may conduct. This might include, but not be limited to:
Chances are, an inspection will go smoothly if you prepare your facility by having documents ready, correcting hazards before the visit, and simulating the inspection.
Taking these precautions won't eliminate the possibility of a citation, but the compliance officer might view your effort as "good faith," making it easier to manage any hiccups during the inspection, so put your fears to rest and prepare, prepare, prepare!
Be sure to send emails to firstname.lastname@example.org
|Dec 05, 2018|
052: Safety Incentives that Work
Mentioned in this episode:
OSHA has changed course in its view of employers' post-incident drug testing programs and injury rate-based incentive programs. In a Memorandum to Regional Administrators and State Designees published October 11, the Agency now says most of these types of programs do not run afoul of the anti-retaliation provisions of the injury and illness recordkeeping regulation at §1904.35(b)(1)(iv).
This is a huge shift in policy guidance from that published when the Agency issued the final rule in May 2016 requiring employers to electronically submit injury and illness records. As part of that rulemaking, OSHA added a provision that employers not have any barriers for employees to report injuries or illnesses. The rule also said that employers could not discriminate or punish employees for being injured.
While the rule itself didn't address drug testing or incentive programs, policy guidance published along with it indicated that most post-incident drug testing programs would be in violation. The same thing was said about incentive programs that were tied to injury rates.
But now, OSHA says that many employers who implement safety incentive programs and/or conduct post-incident drug testing do so to promote workplace safety and health. In addition, the Agency says evidence that the employer consistently enforces legitimate work rules (whether or not an injury or illness is reported) would demonstrate that the employer is serious about creating a culture of safety, not just the appearance of reducing rates. Thus, action taken under a safety incentive program or post-incident drug testing policy would only violate §1904.35(b)(1)(iv) if the employer took the action to penalize an employee for reporting a work-related injury or illness rather than for the legitimate purpose of promoting workplace safety and health.
In the new policy, OSHA says that incentive programs can be an important tool to promote workplace safety and health. One type of incentive program rewards workers for reporting near-misses or hazards, and encourages involvement in a safety and health management system. "Positive action taken under this type of program," the Agency says, "is always permissible under §1904.35(b)(1)(iv)."
OSHA describes another type of incentive program that is rate-based and focuses on reducing the number of reported injuries and illnesses. These programs typically reward employees with a prize or bonus at the end of an injury-free month or evaluate managers based on their work unit's lack of injuries. The Agency says these rate-based incentive programs are also permissible under §1904.35(b)(1)(iv) "as long as they are not implemented in a manner that discourages reporting."
So, if an employer takes a negative action against an employee under a rate-based incentive program, such as withholding a prize or bonus because of a reported injury, OSHA would not cite the employer under §1904.35(b)(1)(iv) as long as the employer has implemented adequate precautions to ensure that employees feel free to report an injury or illness.
What would be an “adequate precaution”?
OSHA says that a statement that employees are encouraged to report and will not face retaliation for reporting may not, by itself, be adequate to ensure that employees actually feel free to report, particularly when the consequence for reporting will be a lost opportunity to receive a substantial reward. However, an employer could avoid any inadvertent deterrent effects of a rate-based incentive program by taking positive steps to create a workplace culture that emphasizes safety, not just rates. For example, the Agency says that any inadvertent deterrent effect of a rate-based incentive program on employee reporting would likely be counterbalanced if the employer also implements elements such as:
In addition, OSHA says that most instances of workplace drug testing are permissible under §1904.35(b)(1)(iv). Examples of permissible drug testing include:
Listen to this episode for more information on how to set up your incentive program properly.
Be sure to send emails to email@example.com
|Nov 20, 2018|
051: How to Write an Effective Accident Report
Mentioned in this episode:
With proper safety training and an air-tight safety program in your workplace, you won’t have to write too many incident reports. However, sometimes things slip through the cracks and it results in an incident or near-miss. When this happens, it’s not only mandated by OSHA to report it, but it can be imperative in future prevention of like incidents.
The best way to go about reporting an incident is to fill out an incident report. The following steps will help you to write an effective incident report that covers all of the necessary elements needed for further action.
1. Respond in a timely manner
You should begin to gather the details almost immediately after receiving news and becoming aware of the incident. This will help you gather details that are fresh in the minds of those involved, and will help you be able to piece together the factors involved in the incident’s occurrence.
2. Gather all of the details and facts
Having all the facts is important in being able to decipher what caused the incident and how it can be prevented in the future. It’s also necessary for business insurance purposes and to help make decisions in the final stages of analysis. Critical facts of the incident to include are:
Another resource that is beneficial for documenting events is to take pictures of where the incident took place. Note the conditions of the area and the scene(s) of the incident. If available, CCTV footage is another avenue of reviewing the chain of events that led to the incident.
3. Piece together the sequence of events
Piecing together the sequence of events will help determine which factors were involved and how they were involved at the time the incident occurred.
The details gathered above should be specific enough so that anyone reading the report can seamlessly create a story in their mind, and can, therefore, view the incident as a whole. It often helps to create a diagram to start to visually analyze the incident.
4. Analyze your findings of the incident
You can now begin to create an in-depth analysis of what caused the events, the factors involved, and ultimately answer the “why” of the incident. With the details you gathered, you should be able to speculate the following items:
5. Formulate a preventative action plan
An incident report is useless without a plan to correct actions for future prevention. Every incident is a hard lesson that has yet to be learned or has been overlooked. The following items are examples of areas that may need correcting based on the facts surrounding the incident:
A good incident report identifies the problem using in-depth analysis and research and offers a viable solution to that problem. A thorough, well-prepared report will accurately pinpoint what corrective action is necessary so that you may prevent future incidents and keep your team safe!
Reprinted with permission from Atlantic Training
Be sure to send emails to firstname.lastname@example.org
|Nov 15, 2018|
050: Electrical Safety-Related Work Practices
Mentioned in this episode:
OSHA's Safety-Related Work Practices standards for general industry are performance-oriented requirements that complement the existing electrical installation standards.
These work-practice standard include requirements for work performed on or near exposed energized and deenergized parts of electric equipment; use of electrical protective equipment; and the safe use of electric equipment.
These rules are intended to protect employees from the electrical hazards that they may be exposed to even though equipment may be in compliance with the installation requirements in, 1910 Subpart S (electrical). When employees are working with electric equipment, they must use safe work practices. Such safety-related work practices include keeping a prescribed distance from exposed energized lines, avoiding the use of electric equipment when the employee or the equipment is wet, and locking-out and tagging equipment which is deenergized for maintenance.
The training requirements apply to employees who face a risk of electric shock that is not reduced to a safe level by the electric installation requirements of §1910.303 - §1910.308. Employees in the following occupations would typically face these risks and are required to be trained:
With the exception of electricians and welders, workers in these groups do not need to be trained if their work or the work of those they supervise does not bring them or the employees they supervise close enough to exposed parts of electric circuits operating at 50 volts or more to ground for a hazard to exist.
Other employees who also may reasonably be expected to face a comparable risk of injury due to electric shock or other electrical hazards must also be trained.
These standards cover electrical safety-related work practices for both qualified persons (those who have training in avoiding the electrical hazards of working on or near exposed energized parts) and unqualified persons (those with little or no such training) working on, near, or with the following installation:
Other Covered Work By Unqualified Persons
The provisions of these standards also cover work performed by unqualified persons on, near, or with the following installations:
IMPORTANT: Excluded Work by Qualified Persons
If a qualified person is performing work near one of the four types of installations listed above, and the work is not actually being done on or directly associated with the installation, then that work is covered under the Safety-Related Work Practices.
Definitions you should know...
Barrier: A physical obstruction that is intended to prevent contact with equipment or live parts or to prevent unauthorized access to a work area.
Deenergized: Free from any electrical connection to a source of potential difference and from electrical charge; not having a potential different from that of the earth.
Disconnecting means: A device, or group of devices, or other means by which the conductors of a circuit can be disconnected from their source of supply.
Energized: Electrically connected to a source of potential difference.
Exposed: (As applied to live parts.) Capable of being inadvertently touched or approached nearer than a safe distance by a person. It is applied to parts not suitably guarded, isolated, or insulated.
Live parts: Energized conductive components.
Qualified person: One who has received training in and has demonstrated skills and knowledge in the construction and operation of electric equipment and installations and the hazards involved.
In general, the standard requires covered employers to:
So there you have it; a quick run-down on electrical safety-related work practices. Let me know what you think; send emails to email@example.com
|Oct 10, 2018|
049: 8 Tips for Selecting Key Safety Performance Indicators
Mentioned in this episode:
How do you measure safety in your workplace to enhance performance and reduce employee downtime? There are several tested methods that Environmental, Health, and Safety (EHS) leaders use to reduce employee incidents and illnesses. Among the leading methods, which the Gensuite white paper discusses, are Key Performance Indicators (KPIs)–or leading and lagging indicators.
Leading indicators are pre-incident measurements, as opposed to lagging indicators, which are measurements collected after an incident occurs. For example, a slip and fall incident from stray construction materials is a lagging indicator because the incident has already occurred, but an inspection that notes the poor quality of the surrounding area and prevents a future slip and fall from taking place is a leading indicator. A key component of leading indicators is that they measure safety events or behaviors that precede incidents and have a predictive quality.
By measuring leading indicators including conditions, events and sequences that precede and lead up to accidents, these KPIs have value in predicting the arrival of an event and can provide the opportunity to introduce control measures to stop the event from happening.
Recently, many articles have stressed the importance of looking beyond lagging indicators, but then how can your organization learn from past incidents and track results? By combining incident measurement and training management software, your company or organization can adopt a holistic approach to reducing workplace incidents and meeting Occupational Safety and Health Administration (OSHA) standards.
Both leading and lagging indicators can be relevant to workplace safety and worth measuring. They present important aspects of an overall safety management system. We have to use all the tools available to us to create an environment that drives us to a zero-incident job site.
Selecting and Using the Right Key Performance Indicators (KPIs) for Your Organization
Attempting to track complex data analytics and results, train employees and keep your team safe on your own can be dicult tasks to handle. Leading and lagging indicators can help reduce and prevent incidents. One way EHS leaders begin using KPIs is by selecting the appropriate sets for their organization.
When trying to pinpoint the indicator type essential for your organization–understand that both are essential. Leading indicators are like a car windshield, and lagging indicators are like the rearview mirror. You’ll certainly spend more time looking out the windshield to see what's coming–with leading indicators–than looking in your rearview mirror to see where you've been–with lagging indicators.
Look at your company and see how you can start moving forward–toward a culture of safety–rather than looking behind. Within the leading and lagging indicator types, there are eight important characteristics that KPIs should have. Ensure that you follow this guideline when selecting the ones important for your workplace.
1. Actionable–metrics that have measurable steps
2. Achievable–setting goals that are obtainable
3. Meaningful–obtaining information for continued tracking
4. Transparent–metrics that are clearly understandable
5. Easy–to communicate effectively
6. Valid–relevant to the organization’s objectives
7. Useful–metrics that are beneficial to the organization’s safety goals
8. Timely–distributing information that is still relevant to the organization
Once you select your set of indicators and follow the necessary characteristics, it's important to track how well they are working and be flexible if the set needs to be revised for consistent improvement.
Why Leading and Lagging Indicators Are Important: Rising OSHA Regulations & Safety Trends
Each year brings about new regulations and carries over existing regulations that companies must abide by. Thus, it’s important to stay on top of ever-evolving regulatory trends so you don’t risk non-compliance. Use the leading and lagging indicator system to help with the following key OSHA regulations and safety trends.
Overview of the Occupational Exposure to Crystalline Silica Rule
OSHA’s final rule aims to reduce the risk of lung cancer, silicosis, chronic obstructive pulmonary disease and kidney disease in America’s workers by limiting their exposure to respirable crystalline silica. The rule is comprised of two standards, one for Construction and one for General Industry and Maritime. Responsible employers have been protecting employees from the harmful substance for years, but now it’s becoming mandatory. Here are some of the rule requirements:
Overview of OSHA Improve Tracking of Workplace Injuries and Illnesses Rule
The Bureau of Labor Statistics reports more than three million workers suffer from a workplace injury or illness every year. Currently, little or no information about worker injuries and illnesses is made public or available to OSHA. With this new rule, employers are required to submit a record of the injuries and illnesses to OSHA to help them with identifying hazards and fixing problems.
Here are the rule requirements:
Trend #1: Dealing with Workplace Stress
The National Institute of Occupational Safety And Health emphasizes that work-related stress disorders are expected to rise as the economy continues to undergo various shifts and impacts.
Therefore, companies should take steps to ensure that any current programs are robust enough to reduce the concerns associated with stress in the workplace, as well as implement any new programs that show an increased effectiveness at reducing the generation of stress.
Trend #2: Leveraging Risk Management
2017 saw a continued trend in developing internal risk management programs and systems, and 2018 into 2019 looks to be the year where many of these programs are leveraged for results across the company spectrum. In other words, sucient time has occurred for the internal development of risk management data and effectiveness that this can now be translated directly into specific areas of the business to further reduce inherent risk development within the company.
Trend #3: Increased Reliance on Predictive Analytics
A new trend becoming prominent in 2018 is an increased reliance on predictive analytics. Many companies have been developing risk management and mitigation data and using analytics to help derive sense from this mountain of information. 2019 looks to be the year where many of these are put into practice company-wide. In addition, the trend of emphasizing the use of these predictive analytics is expected to rise as much of this information is refined even further.
This should begin to show positive returns for companies that have been implementing this predictive technology as part of a risk management profile. However, there is still time to take advantage of these systems for those companies that have not implemented these types of analytics.
Trend #4: More Regulatory Changes
There are few that doubt that more regulatory and legislative changes are expected in 2018.
While many differences continue to grow between national policy and those enacted on the state and local level, few can predict what the specific changes will actually be. However, what is an almost certainty is that for companies, flexibility will be necessary in order to adapt to the new policies to come.
Models and Methods for Using Leading and Lagging Indicators: A Contextual and Visual Guide
Various proven, yet antiquated and manual, methods have been used for measuring KPIs, such as those discussed in the report, A Method for Modeling of KPIs Enabling Validation of Their Properties. The authors cover two techniques workplaces use to track KPIs.
The first model integrates the following attributes for tracking performance: indicator name, type, scale, source, owner and threshold. Though, it is not easy to find all of this information so EHS experts often rely on documentation, expert knowledge and previous conceptual models.
The second model used for KPI formalization is known as performance indicator expression. It is “a mathematical statement over a performance indicator evaluated to a numerical, qualitative”.
In other words, a given value for a time point, for the organization, unit or agent. The authors suggest specifying the required values of performance indicators as constraints coming from goals. The relations between performance indicators are modeled using predicates.
The third model used by EHS professionals and safety teams is known as the Heinrich Pyramid–a traditional way of tracking occupational illnesses and injuries.
The Heinrich Pyramid (also known as the Safety Triangle) quantifies the number of reported workplace incidents into four main categories: major injuries, severe accidents, first aid cases and near misses. Employee concern reports, safety observations and at-risk observations can also be added to the base of the triangle to incorporate leading indicators into the analysis.
This is a 1-10-30-600 model. For every 1 incident reported in the major injury category, severe accidents are 10 times as likely to happen. Also, for every 1 major injury, approximately 30 first aid cases, and 600 near misses.
When companies plug their own incidents into this model or pyramid, they can see if they have the corresponding model ratio, as described above, and if they have a significant amount of major and severe incidents. The premise for this model is that the more companies focus on reducing the numbers at the bottom of the pyramid, the more likely they are to reduce major safety incidents at the top.
The pyramid is inclusive of many types of injuries and incidents, but it doesn’t assist EHS professionals with narrowing down the data to the critical cases/accidents, root causes and solutions. For example, a site could have a series of cases that stem from ergonomic-related issues and spend significant amounts of time on root cause and trend analysis instead of the cases/accident that have a high potential to result in an employee fatality or significant property damage.
Critics of the Heinrich Pyramid also claim that “adhering to it can lead to an over-emphasis on worker behavior and not enough attention on health and safety management software systems.” No matter the flaws, there is always a solution to the system.
These methods are used to benefit companies’ safety success rates and business performance objectives. The methods can be adapted to any enterprise modeling approach. Companies can apply these measures of thinking into a conventional and modernized process by integrating EHS management software into their workplace as discovered in the following section.
A Gensuite Solution: Implementing Key Performance Indicators (KPIs) Into Your Workplace
To simplify and digitize the three models and methods discussed above, companies turn to compliance and management software systems such as Gensuite. Such systems enhance workplace safety performance by simplifying the tracking of leading and lagging indicators.
Utilize Gensuite EHS software tailored to measure KPIs and manage training compliance. Just a few of Gensuite’s specialized features of these tools include:
What makes this important right now? Why should your business invest? Other than avoiding everyday safety violations and reoccurring workplace injuries, investing will help you meet current and upcoming OSHA regulations. Here’s a look at customizable Gensuite applications.
Incidents & Measurements
The Gensuite Incidents & Measurements application can help you address the new regulation by enabling one-click generation of a site/business OSHA 300, 300A, and 301 forms. In addition, Gensuite joins ongoing discussions with subscribers and industry groups to meet with OSHA to talk through options for direct system integrations, thus removing the need for sites to manually generate logs and input them into OSHA’s website.
Other benefits of the Gensuite Incidents & Measurements application:
The Gensuite Training Compliance suite can help you address both new OSHA regulations by keeping your employees up-to-date with OSHA’s mandatory training requirements. In addition, training employees prevent new and future injuries from occurring, so you don’t have to evaluate progress based on how many employees have been severely injured and how that number has improved. Prevent them from happening in the first place.
Other benefits of the Gensuite Training Compliance application:
Look to Key Performance Indicators so your business can avoid safety violations and injuries.
Let me know what you think; send emails to firstname.lastname@example.org
|Sep 30, 2018|
048: Wearable Tech for Safety
Mentioned in this episode:
In this takeover podcast episode I visited the offices of Gensuite to talk about wearable tech and the impact it has on safety. Hit the links in these show notes for more info on the cloud-based EHS software solutions Gensuite can provide for your business. Join the over 600,000 users that trust Gensuite with their compliance and EHS software needs.
Let me know what you think; send emails to email@example.com
|Sep 08, 2018|
046: What Are Industry Consensus Standards?
Mentioned in this episode:
Throughout OSHA regulations, you will find references to industry consensus standards such as those in Subpart I - Personal Protective Equipment. These PPE regulations refer to ANSI standards as the safety criteria manufacturers must meet when producing eye, face, head, and foot protective equipment. OSHA requires employers to purchase personal protective equipment that bears the ANSI mark to ensure that the equipment provides the maximum protection for the wearers.
OSHA does not include industry consensus standards in the regulations; rather, it refers employers to various consensus standards as the safety procedures and specifications that must be met in the workplace. This referral procedure is called "incorporation by reference."
Incorporation by reference was established by statute and allows federal agencies to meet the requirement to publish regulations in the Federal Register by referring to materials already published elsewhere. The legal effect is that the material is treated as if it were published in full in the Federal Register and, like any other properly issued regulation, has the force of law.
In some cases, OSHA may not incorporate by reference a particular industry standard, but it may hold employers to that industry standard under the General Duty Clause of the OSH Act, recognizing that the industry standard contains best practices the employer should use. For instance, ANSI/ISEA Z308.1, Minimum Requirements for Workplace First Aid Kits an Supplies, has not been adopted by OSHA. However, ANSI/ISEA Z308.1 provides detailed information regarding the contents and types of various first aid kits; OSHA has often referred employers to ANSI/ISEA Z308.1 as a source of guidance for the minimum requirements for first aid kits.
Where an OSHA standard incorporates an old consensus standard, what is the significance of an updated industry consensus standard?
Under OSHA's de minimis policy, where OSHA has adopted an earlier consensus standard, employers who are in compliance with the updated version will not be cited for a violation of the old version as long as the new one is at least equally protective.
Remember, though, that where an OSHA standard incorporates an earlier consensus standard, the only way the OSHA standard can be changed to adopt the new version is through rulemaking. For example, OSHA’s aerial lift standard references ANSI A92.2-1969. Even though ANSI A92.2 has been revised, the OSHA aerial lift standard continues to require only compliance with the 1969 standard. There is no automatic adoption of the more current industry consensus standard.
Industry consensus standards are just that, a voluntary standardization system for private industry. They set conformity and uniformity criteria for the development and manufacture of a great volume of products. This criteria is developed by committees of qualified representatives from industry, labor, and government agencies. In many instances, U.S. consensus standards are adopted in whole or in part as international standards.
Some organizations that publish consensus standards include:
Copies of the consensus standards may be purchased from the organization that issues them. OSHA’s Docket Office and each regional office also maintain copies of the standards referenced in the regulations. These standards are available for public review at those offices.
What is NIOSH?
NIOSH, the National Institute for Occupational Safety and Health, is an agency separate from OSHA. NIOSH is part of the U. S. Department of Health and Human Services. NIOSH, also established by the OSH Act, is the research agency for occupational safety and health.
What is ANSI?
According to their website; As the voice of the U.S. standards and conformity assessment system, the American National Standards Institute (ANSI) empowers its members and constituents to strengthen the U.S. marketplace position in the global economy while helping to assure the safety and health of consumers and the protection of the environment.
The Institute oversees the creation, promulgation and use of thousands of norms and guidelines that directly impact businesses in nearly every sector: from acoustical devices to construction equipment, from dairy and livestock production to energy distribution, and many more. ANSI is also actively engaged in accreditation - assessing the competence of organizations determining conformance to standards.
And there you have it; a quick run-down on national consensus standards. Let me know what you think; send emails to firstname.lastname@example.org
|Jul 21, 2018|
047: Machine Guarding Safety in 5 Easy Steps
Mentioned in the episode:
In almost all industries, we may work with or around machinery. Moving machine parts have the potential to cause severe workplace injuries, such as crushed fingers or hands, amputations, burns, or blindness. Safeguards are essential for protecting workers from these preventable injuries. Any machine part, function, or process that may cause injury must be safeguarded. When the operation of a machine or accidental contact could injure the operator or others in the vicinity, the hazards must be eliminated or controlled.
OSHA’s machine guarding standards apply to employers having employees exposed to dangerous moving parts.
29 CFR 1910.212 — General requirements for all machinery. This is OSHA’s general requirement for all machinery. It is a catch-all standard (like the General Duty Clause) requiring employers to protect employees from dangerous moving parts and to guard points of operation. OSHA also has some machine-specific standards, which you may need to know:
29 CFR 1910.213 — Woodworking machinery
29 CFR 1910.215 — Abrasive wheel machinery
29 CFR 1910.216 — Mills and calendars in the rubber and plastics industries
29 CFR 1910.217 — Mechanical power presses
29 CFR 1910.218 — Forging machinery
29 CFR 1910.219 — Mechanical power transmission apparatus
Definitions you should know...
In general, you can use the following 5 steps to ensure safe machine operation in your workplace:
These basic steps will cover almost all of your machine guarding needs. Let me know what you think, send emails to email@example.com.
Until the next safetyPro podcast episode, be safe!
|Jul 14, 2018|
045: 10 Steps to Improve Driver Safety
Mentioned in this episode:
Safety and Security starts with knowing who's on location - WhosOnLocation.com
The official floor marking/floor sign company of the SafetyPro Podcast; MightyLine Floor Tape
Preliminary estimates from the National Safety Council indicate motor vehicle deaths dipped slightly – 1% – in 2017, claiming 40,100 lives versus the 2016 total of 40,327. The small decline is not necessarily an indication of progress, as much as a leveling off of the steepest two-year increase in more than 50 years.
The 2017 assessment is 6% higher than the number of deaths in 2015. If the estimate holds, it will be the second consecutive year that motor vehicle deaths topped 40,000.
About 4.57 million people were injured seriously enough to require medical attention in motor vehicle crashes in 2017, and costs to society totaled $413.8 billion. Both figures are about 1% lower than 2016 calculations.
So what can we do about all of this? A driver safety program should keep the driver safe, as well as others who share the road. If necessary, the program must work to change driver attitudes, improve behavior, and increase skills to build a “be safe” culture. By instructing your employees in basic safe driving practices and then rewarding safety-conscious behavior, you can help your employees and their families avoid tragedy.
Do current prevention efforts really address the problem?
• Nearly all legislation focuses on banning only handheld phones or only texting while driving.
• All state laws and many employer policies allow hands-free cell phone use.
• Public opinion polls show people recognize the risks of talking on handheld phones and texting more than they recognize the risks of hands-free phones.
• Many drivers mistakenly believe talking on a hands-free cell phone is safer than handheld.
A hands-free device most often is a headset that communicates via wire or wireless with a phone, or a factory-installed or aftermarket feature built into vehicles that often includes voice recognition. Many hands-free devices allow voice-activated dialing and operation.
Hands-free devices often are seen as a solution to the risks of driver distraction because they help eliminate two obvious risks – visual, looking away from the road and manual, removing your hands off of the steering wheel. However, a third type of distraction can occur when using cell phones while driving – cognitive, taking your mind off the road.
Hands-free devices do not eliminate cognitive distraction.
The amount of exposure to each risk is key. Crashes are a function of the severity of each risk and how often the risk occurs. Most people can recognize when they are visually or mechanically distracted and seek to disengage from these activities as quickly as possible. However, people typically do not realize when they are cognitively distracted, such as taking part in a phone conversation; therefore, the risk lasts much, much longer. This likely explains why researchers have not been able to find a safety benefit to hands-free phone conversations.
The National Safety Council has compiled more than 30 research studies and reports by scientists around the world that used a variety of research methods, to compare driver performance with handheld and hands-free phones. All of these studies show hands-free phones offer no safety benefit when driving.
Conversation occurs on both handheld and hands-free phones. The cognitive distraction from paying attention to conversation – from listening and responding to a disembodied voice – contributes to numerous driving impairments. Specific driving risks are discussed in detail later in this paper. First, let us look at why hands-free and handheld cell phone conversations can impair your driving ability.
Multitasking is a myth. Human brains do not perform two tasks at the same time. Instead, the brain handles tasks sequentially, switching between one task and another. Brains can juggle tasks very rapidly, which leads us to erroneously believe we are doing two tasks at the same time. In reality, the brain is switching attention between tasks – performing only one task at a time.
The brain not only juggles tasks, it also juggles focus and attention. When people attempt to perform two cognitively complex tasks such as driving and talking on a phone, the brain shifts its focus (people develop “inattention blindness”). Important information falls out of view and is not processed by the brain. For example, drivers may not see a red light. Because this is a process people are not aware of, it’s virtually impossible for people to realize they are mentally taking on too much.
Brain researchers have identified “reaction-time switching costs,” which is a measurable time when the brain is switching its attention and focus from one task to another. Research studying the impact of talking on cell phones while driving has identified slowed reaction time to potential hazards are tangible, measurable and risky. Longer reaction time is an outcome of the brain switching focus. This impacts driving performance.
The cost of switching could be a few tenths of a second per switch. When the brain switches repeatedly between tasks, these costs add up.
Even small amounts of time spent switching can lead to significant risks from delayed reaction and braking time. For example, if a vehicle is traveling 40 mph, it goes 120 feet before stopping. This equals eight car lengths (an average car length is 15 feet). A fraction-of-a-second delay would make the car travel several additional car lengths. When a driver needs to react immediately, there is no margin for error.
Brains may face a “bottleneck” in which different regions of the brain must pull from a shared and limited resource for seemingly unrelated tasks, constraining the mental resources available for the tasks.
Research has identified that even when different cognitive tasks draw on two different regions of the brain, we still can have performance problems when trying to do dual tasks at the same time. This may help explain why talking on cell phones could affect what a driver sees: two usually unrelated activities become interrelated when a person is behind the wheel. These tasks compete for our brain’s information processing resources. There are limits to our mental workload.
The workload of information processing can bring risks when unexpected driving hazards arise.31 Under most driving conditions, drivers are performing well-practiced, automatic driving tasks.
For example, without thinking about it much, drivers slow down when they see yellow or red lights, and activate turn signals when intending to make a turn or lane change. These are automatic tasks for experienced drivers. Staying within a lane, noting the speed limit and navigation signs, and checking rear- and side-view mirrors also are automatic tasks for most experienced drivers. People can do these driving tasks safely with an average cognitive workload.
During the vast majority of road trips, nothing bad happens, as it should be. But that also can lead people to feel a false sense of security or competency when driving. Drivers may believe they can safely multitask; however, a driver always must be prepared to respond to the unexpected.
The industrial ergonomics field has been able to identify physical workload limits and, in the same way, the workload limits of our brains now are being identified. The challenge to the general public is the bottlenecks and limits of the brain are more difficult to feel and literally see than physical limits.
Multitasking Impairs Performance
We can safely walk while chewing gum in a city crowded with motor vehicles and other hazards. That is because one of those tasks – chewing gum – is not a cognitively demanding task.
When chewing gum and talking, people still are able to visually scan the environment for potential hazards.
People do not perform as well when trying to perform two attention-demanding tasks at the same time.32 Research shows even pedestrians don’t effectively monitor their environment for safety while talking on cell phones. 33-35 The challenge is managing two tasks demanding our cognitive attention.
Certainly most would agree that driving a vehicle involves a more complex set of tasks than walking.
What are primary and secondary tasks? What happens when people switch attention between them?
When people perform two tasks at the same time, one is a primary task and the other a secondary task. One task gets full focus (primary) and the other moves to a back burner (secondary). People can move back and forth between primary and secondary tasks.
The American National Standards Institute publication ANSI Z15.1, Safe Practices for Motor Vehicle Operations, offers guidelines and best practices for motor vehicle safety programs. In addition, the Network of Employers for Traffic Safety (NETS) assisted in developing a 10-step program.
NETS 10-step program to minimize crash risk
The Program provides guidelines for what an employer can do to improve traffic safety performance and minimize the risk of motor vehicle crashes. Following these steps helps to ensure that you hire capable drivers, only allow eligible drivers to drive on company business, and maintain company vehicles properly. Adherence to these 10 steps can also help to keep your motor vehicle insurance costs as low as possible. These steps are from the NETS Traffic Safety Primer: A Guidebook for Employers.
Step 1: Senior management commitment and employee involvement
Senior management can provide leadership, set policies, and allocate resources (staff and budget) to create a safety culture. Actively encouraging employee participation and involvement at all levels of the organization is a good practice and will help the effort to succeed. Workers and their representatives must be involved in the initial planning phase.
Step 2: Written policies and procedures
A written statement emphasizing the commitment to reducing traffic-related deaths and injuries is essential to a successful program. Create a clear, comprehensive and enforceable set of traffic safety policies and communicate them to all employees. Post them throughout the workplace, distribute copies periodically, and discuss the policies at company meetings. Offer incentives for sticking to the rules, and point out the consequences of disregarding them.
Step 3: Driver agreements
Establish a contract with all employees who drive for work purposes, whether they drive assigned company vehicles or personal vehicles. By signing an agreement, the driver acknowledges awareness and understanding of the organization’s traffic safety policies, procedures, and expectations regarding driver performance, vehicle maintenance, and reporting of moving violations.
Step 4: Motor vehicle record (MVR) checks
Check the driving records of all employees who drive for work purposes. Screen out drivers who have poor driving records since they are most likely to cause problems in the future. Periodically review the MVR to ensure that the driver maintains a good driving record. Clearly define the number of violations an employee/driver can have before losing the privilege of driving for work, and provide training where indicated.
Step 5: Crash reporting and investigation
Establish and enforce a crash reporting and investigation process. All crashes, regardless of severity, should be reported to the employee’s supervisor as soon as feasible after the incident. Company policies and procedures should clearly guide drivers through their responsibilities in a crash situation. Review all crashes to determine their cause and whether or not the incidents were preventable. Understanding the root causes of crashes and why they are happening, regardless of fault, forms the basis for eliminating them in the future.
Step 6: Vehicle selection, maintenance and inspection
Properly maintaining and routinely inspecting company vehicles is an important part of preventing crashes and related losses. Review the safety features of all vehicles to be considered for use. Choose vehicles that demonstrate “best in class” status for crashworthiness and overall safety.
Regular maintenance preventive maintenance should be done at specific mileage intervals consistent with the manufacturer’s recommendations. A mechanic should do a thorough inspection of each vehicle at least annually with documented results placed in the vehicle’s file.
Personal vehicles used for company business are not necessarily subject to the same criteria and are generally the responsibility of the owner. However, personal vehicles used on company business should be maintained in a manner that provides the employee with maximum safety and reflects positively on the company.
Step 7: Disciplinary action system
Develop a strategy to determine the course of action after a moving violation and/or “preventable” crash. The system should provide for progressive discipline if a driver begins to develop a pattern of repeated traffic violations and/or preventable crashes. The system should describe what specific action(s) will be taken if a driver accumulates a certain number of violations or preventable crashes in any pre-defined period.
Step 8: Reward/incentive program
Develop and implement a driver reward/incentive program to make safe driving an integral part of your business culture. Safe driving behaviors contribute directly to the bottom line and should be recognized as such. Incorporate driving performance into the overall evaluation of job performance. Reward and incentive programs typically involve recognition, monetary rewards, special privileges, or other incentives to motivate positive behaviors.
Step 9: Driver training/communication
Provide continuous driver safety training and communication. Even experienced drivers benefit from periodic training and reminders of safe driving practices and skills. It is easy to become complacent and not think about the consequences of poor driving habits.
Step 10: Regulatory compliance
Ensure adherence to highway safety regulations. It is important to clearly establish which, if any, local, state, and/or Federal Regulations govern your vehicles and/or drivers. These regulations may involve, but may not necessarily be limited to the:
Promote safe driving practices
The safety issues described below should be addressed in an employee awareness and training program.
Secure materials for transport: Tools or equipment should be secured while being transported to prevent unsafe movement. During a crash or when making sudden maneuvers, loose objects can slide around or become airborne, injuring the driver or passengers. Objects that could become a hazard should be secured or stored outside the passenger compartment.
Seat belt use: Seat belts are the single most effective means of reducing deaths and serious injuries in traffic crashes.
Alcohol and drug impaired driving: It is estimated that three in every 10 Americans will be involved in an impaired driving-related crash some time in their life. Alcohol, certain prescription drugs, over-the-counter medications, and illegal drugs can all affect a person’s ability to drive safely due to decreased alertness, concentration, coordination, and reaction time.
Fatigued driving: Fatigued or drowsy driving may be involved in more than 100,000 crashes each year, resulting in 40,000 injuries and 1,550 deaths. Employees should be well rested, alert, and sober on the road so they are in a position to defend themselves from drivers who do not make the same choice. Train employees to make smart decisions when they’re behind the wheel, on and off the job.
Aggressive driving: Employees commuting to and from work or traveling for work often get caught up in bottlenecks and traffic delays, wasting their time and reducing their productivity. These situations create frustration that can spark aggressive driving behavior. Aggressive driving acts include excessive speed, tailgating, failure to signal a lane change, running a red light, and passing on the right. The best advice is to avoid engaging in conflict with other drivers and to allow others to merge.
Young drivers: Under Federal law, 16-year-old workers are prohibited from driving as part of their job, and 17-year-olds may drive for work only under strictly limited circumstances. Some state laws may be more restrictive than Federal laws. For more information on child labor laws visit, www.youthrules.dol.gov or www.cdc.gov/niosh/topics/youth/.
Be sure to check out the National Safety Council and get their FREE online Safe Driving Kit HERE.
Let me know what you think; send emails to firstname.lastname@example.org
|Jul 03, 2018|
044: Safety, Security and Workplace Violence - What's your policy?
Mentioned in this episode:
Because workplace violence is a growing problem at workplaces across America, it is good for a company to develop its own company specific worksite violence policy and procedures manual.
There is evidence that suggests worksite violence is largely preventable through the development and implementation of a specific policy and procedures. To be effective, company policy and procedures must discourage all types of worksite violence. They must also encourage employees to come forward in the event they are victims of, or witnesses to, any prohibited behavior. Additionally, whatever disciplinary action is deemed appropriate for policy violations, it must be handed out impartially and consistently. This will send a clear message that threats and other violent acts will not be tolerated by your company.
When developing your company’s policy and procedures, it is important to remember that employees are not likely to adhere to something they don’t understand. To prevent this from happening, refrain from using legal jargon, or referencing other documents that employees may not be familiar with. Also resist the urge to adopt any model or sample policy and procedures without first modifying them to address the specific needs of your company. Once you have a draft document prepared, you may find it helpful to solicit employee feedback regarding its clarity and completeness.
A final point to keep in mind is that policies and procedures should not be forgotten once they have been published. Make plans to review them on a regular basis, and to update them to reflect changing roles and conditions. Also encourage employees to provide suggestions for ways they can be improved.
At a minimum, your company’s workplace violence policy and procedures should include:
To be effective, policies and procedures must be:
|Jun 07, 2018|
043: Workplace Safety Postings
Mentioned in this episode:
NERD ALERT! This episode covers all those little posters and postings that have to be displayed in the workplace. Most public and private employers fall under at least some posting requirements under federal, state, and/or local government laws, regulations, and/or executive orders. These workplace posters (also known as labor law posters or notices) are generally meant to make employees aware of their rights under certain laws or executive orders, or otherwise impart information about the employer and/or the law or executive order.
Employers need to be aware of the posting requirements that apply to them, as not having the appropriate information posted for employees may result in citations and fines. Some of these posting requirements have penalties associated with them for noncompliance. Failure to post federal employment law posters can potentially result in fines of over $32,000.
In addition, it is important to be in compliance with posting regulations because the posters can help an employer prove that it has made employees aware of their rights under the law. Courts have ruled that failing to display a poster can extend the amount of time an employee has to sue for damages.
The posters that a private or public employer needs to display will depend on its location, the number of employees who work for the employer, the industry type, and/or the contracts under which it performs work. The scope and applicability is specified in the posting law, regulation, or executive order.
The federal government enforces workplace posters under the following regulations and executive orders (I only cover a few in the episode):
8 CFR 214 — Nonimmigrant classes
9 CFR 381 — Poultry products inspection regulations
20 CFR 655 — Temporary employment of foreign workers in the United States
20 CFR 658 — Administrative provisions governing the job service system
20 CFR 1002 — Regulations under the uniformed services employment and reemployment rights act of 1994
23 CFR 635 — Construction and maintenance
29 CFR 4 — Labor standards for federal service contracts
29 CFR 5 — Labor standards provisions applicable to contracts covering federally financed and assisted construction (also Labor standards provisions applicable to nonconstruction contracts subject to the contract work hours and safety standards act)
29 CFR 10 — Establishing a minimum wage for contractors
29 CFR 13 — Establishing paid sick leave for federal contractors
29 CFR 24 — Procedures for the handling of retaliation complaints under the employee protection provisions of six environmental statutes and section 211 of the energy reorganization act of 1974, as amended
29 CFR 471 — Obligations of federal contractors and subcontractors; Notification of employee rights under federal labor laws
29 CFR 500 — Migrant and seasonal agricultural worker protection
29 CFR 501 — Enforcement of contractual obligations for temporary alien agricultural workers admitted under section 218 of the immigration and nationality act
29 CFR 516 — Records to be kept by employees
29 CFR 525 — Employment of workers with disabilities under special certificates
29 CFR 801 — Application of the employee polygraph protection act of 1988
29 CFR 825 — The family and medical leave act of 1993
29 CFR 1601 — Procedural regulations
29 CFR 1627 — Records to be made or kept relating to age notices to be posted
29 CFR 1635 — Genetic information nondiscrimination act of 2008
29 CFR 1903 — Inspections, citations and proposed penalties
29 CFR 1904 — Recording and reporting occupational injuries and illnesses
29 CFR 1960 — Basic program elements for federal employee occupational safety and health programs and related matters
41 CFR 60-1 — Obligations of contractors and subcontractors
Executive Order 13495 — Nondisplacement of qualified workers under service contracts
|May 20, 2018|
042: 7 Ways to Prevent Ergonomics Injuries
Mentioned in this episode:
What is an ergonomic injury?
Opinions vary on how to define an ergonomics injury, and the definition of the term may depend on the context. However, ergonomic injuries are often described by the term “musculoskeletal disorders” or “MSDs.” This is the term that refers collectively to a group of injuries and illnesses that affect the musculoskeletal system.
Musculoskeletal disorders (MSDs) include a group of conditions that involve the nerves, tendons, muscles, and supporting structures (such as intervertebral discs). They represent a wide range of disorders, which can differ in severity from mild periodic conditions to those which are severe, chronic and debilitating. Some musculoskeletal disorders have specific diagnostic criteria and clear pathological mechanisms (like hand/arm vibration syndrome). Others are defined primarily by the location of pain and have a more variable or less clearly defined pathophysiology (like back disorders). Musculoskeletal disorders of the upper extremities include carpal tunnel syndrome, wrist tendonitis, epicondylitis and rotator cuff tendonitis. Both non-occupational and occupational factors contribute to the development and exacerbation of these disorders.
There is no single diagnosis for MSDs.
As OSHA continues to develop ergonomics-related guidance material for specific industries, the agency may narrow the definition as appropriate to address the specific workplace hazards covered. OSHA says it will work closely with stakeholders to develop definitions for MSDs as part of its overall effort to develop guidance materials.
Lower back disorders
1. lifting and forceful movements,
Disorders of the neck and shoulders
Disorders of the hand, wrist and elbow
There are several conditions to consider within the hand and wrist region. Combined work factors of forceful and repetitive use of the hands and wrists are associated with carpal tunnel syndrome. Vibration from hand tools like chainsaws (those that do not have vibration controlling mechanisms) also contributes to carpal tunnel syndrome.
Vibrating tool use has also been strongly linked to hand and arm vibration syndrome, a separate condition of the hand and wrist that affects the nerve and blood vessels.
Carpal tunnel syndrome
Carpal tunnel syndrome (CTS) is a cumulative trauma disorder (CTD) affecting the hands and wrists. CTS is the compression and entrapment of the median nerve where it passes through the wrist into the hand in the carpal tunnel.
The median nerve is the main nerve that extends down the arm to the hand and provides the sense of touch in the thumb, index finger, middle finger, and half of the fourth, or ring, finger.
When irritated, tendons housed inside the narrow carpal tunnel swell and press against the nearby median nerve. The pressure causes tingling, numbness, or severe pain in the wrist and hand. The pain is often experienced at night. The pressure also results in a lack of strength in the hand and an inability to make a fist, hold objects, or perform other manual tasks. If the pressure continues, it can damage the nerve, causing permanent loss of sensation and even partial paralysis.
CTS develops in the hands and wrists when repetitive or forceful manual tasks are performed over a period of time. For example, the meatpacking industry is considered one of the most hazardous industries in the United States because workers can make as many as 10,000 repetitive motions per day in assembly line processes, such as deboning meats, with no variation in motion Consequently, stress and strain placed on the wrists and hands often results in CTS.
Today, more than half of all U.S. workers are susceptible to developing CTS. Anyone whose job demands a lot of repetitive wrist, hand, and arm motion, which need not always be forceful or strenuous, might be a potential victim of CTS. CTS is common among meat and poultry workers, letter sorters, carpenters, garment workers, upholstery workers, shoe and boot makers, electronic and other assemblers, packers, product inspectors, machine operators, computer/keyboard operators, and cashiers.
Since the early 1980s, CTS has been reported widely among many service-sector employees, including office workers and newspaper and news service employees who use video display terminals (VDTs). CTS, among other health effects, is becoming a growing problem among VDT users because of the numerous repetitive motions of keystroking data into the computer over long periods.
Compounding problems is the fact that employees are often unaware of the causes of CTS and what to do about them. Initially the person may have fatigue and pain that develops during the workday and disappears overnight with no physical symptoms. After a length of time, fatigue and pain develop earlier in the day, some physical symptoms such as clumsiness may occur, which affect work performance, and there may be no overnight recovery. When the case becomes full-blown, there is constant fatigue and pain with no overnight recovery, and disturbed sleep results.
At this point, work performance is inhibited to the extent of requiring off-duty time or light/restricted duty. Often victims do not associate their pain with their work because symptoms may only occur during evening or off-duty hours. When workers finally seek medical help, they may be given the wrong diagnosis and find the road to recovery takes more time and money than had been anticipated.
Length and intensity of exposure
The research indicates that the greater the level of exposure to a single risk factor or combination of factors, the greater the risk of having a work-related musculoskeletal disorder. An additional important factor is the time between each episode of exposure. With adequate time to recover or adapt, and particularly when lower forces are involved, there may be less harm to the body from repeated exposures. The intensity as well as the extended length of the exposure to forceful, repetitive work plays a substantial role in the risk of work-related musculoskeletal disorder in many traditional occupational settings.
What factors may contribute to symptoms of MSDs?
What’s a good plan for preventing work-related musculoskeletal disorders?
Send emails to email@example.com. Be safe!
|Apr 29, 2018|
041: 7 Elements to an Emergency Action Plan
Mentioned in this episode:
Download the Elements to an Emergency Action Plan HERE
How would you escape from your workplace in an emergency? Do you know where all the exits are located? What about a 2nd way out? A safety plan is needed, let' talk about that in this episode.
Send emails to firstname.lastname@example.org
|Apr 26, 2018|
040: Trenching and Excavation Safety
Mentioned in this episode:
Welcome, in this episode I want to talk about trenching and excavation safety. I know here locally we just had another trench collapse that trapped 2 workers. And I am sure you may have heard about incidents near you or reading about them on a national level. Managing safety for these operations is quite simple once you know the requirements and understand some of the nuances that go along with the different soils and protective systems we have.
Cave-ins pose the greatest risk with these activities and are much more likely than other excavation-related accidents to result in worker fatalities. Other potential hazards include falls, falling loads, hazardous atmospheres, and incidents involving mobile equipment. One cubic foot of soil can weigh 100 pounds. One cubic yard of soil can weigh as much as a car, and the kinetic energy of soil falling 3, 4, 10 feet, and you can see the danger here. It has been said that an unprotected trench is an early grave. So let me start by stating the obvious: do not enter an unprotected trench.
So at what point do we need to protect a trench? According to OSHA, trenches 5 feet (1.5 meters) deep or greater require a protective system unless the excavation is made entirely in stable rock. Oh, and forget about stable rock, I will explain that later. If less than 5 feet deep, a competent person may determine that a protective system is not required.
OSHA standards require that employers inspect trenches daily and as conditions change by a competent person before worker entry to ensure elimination of excavation hazards. A competent person is an individual who is capable of identify- ing existing and predictable hazards or working conditions that are hazardous, unsanitary, or dangerous to workers, soil types and protective systems required, and who is authorized to take prompt corrective measures to eliminate these hazards and conditions.
OSHA standards require safe access and egress to all excavations, including ladders, steps, ramps, or other safe means of exit for employees working in trench excavations 4 feet (1.22 meters) or deeper. These devices must be located within 25 feet (7.6 meters) of all workers. Here are some other requirements to follow:
Keep heavy equipment away from trench edges. In the fire department, we tried to keep all heavy rigs at least 25 feet away. But this was to prevent vibrations to already unstable trenches during rescue operations. But heavy equipment that could pose a hazard of falling into the trench or even knocking materials into the trench have to be located back at a safe distance.
The standard requires that you keep excavated soil (spoils) and other materials (like sand and gravel used for back fill or pipes being installed) at least 2 feet (0.6 meters) from trench edges. Ongoing inspections are needed to ensure this requirement is being met.
Know where underground utilities are located before digging. This is a requirement in the OSHA standards, but it requires you to follow State laws that actually govern locating and marking PUBLIC utilities. Private utilities still need to be located and marked as well. So familiarize yourself with the 811 call before you dig system.
Test for atmospheric hazards such as low oxygen, hazardous fumes and toxic gases when > 4 feet deep. This is when you suspect there could be a hazardous atmosphere or one could reasonably be expected to exist, such as in excavations in landfill areas or excavations in areas where hazardous substances are stored nearby.
The COMPETENT PERSON must inspect trenches AND the adjacent areas at the start of each shift and as needed throughout the shift, as well as following a rainstorm or other water intrusion event.
Do not work under suspended or raised loads and materials. This means workers down in the trench and the track hoe bucket swinging over their head to drop gravel, sand or pulling material out.
Also, Walkways have to be provided where workers or equipment are required or permitted to cross over excavations. Guardrails which comply with §1926.502(b) shall be provided where walkways are 6 feet (1.8 m) or more above lower levels. Again, only when workers are to CROSS OVER the open trench of 6 feet deep or more.
Ensure that personnel wear high visibility or other suitable clothing when exposed to vehicular traffic. This is a requirement and you have to reference the Manual on Uniform Traffic Control Devices for minimum requirements for highways as well as flaggers being used. This tells you the ANSI rating needed for certain reflective apparel needed for day and night work.
Also, prepare for an emergency, especially if in an unfamiliar area, a rural area and/or working with a hazardous atmosphere by contacting the local emergency response service and determining whether or not they are equipped and prepared for a potential rescue. This may also drive the need to have someone trained in 1st aid/CPR at the site as well. Also, know where the nearest emergency medical center is located. For job sites, this should ALWAYS be a part of a site-specific safety plan anyway.
Now, let’s get into soil classification. You need to understand what OSHA deems to be stable or unstable soil and how the class of soil drives the protective system you choose. So let’s get into some definitions you need to know and the different types of soil classifications as well as HOW to test soils. Remember, these terms are important to understand as we move forward:
"Cemented soil" means a soil in which the particles are held together by a chemical agent, such as calcium carbonate, such that a hand-size sample cannot be crushed into powder or individual soil particles by finger
"Cohesive soil" means clay (fine grained soil), or soil with a high clay content, which has cohesive strength. Cohesive soil does not crumble, can be excavated with vertical side-slopes, and is plastic when moist. Cohesive soil is hard to break up when dry, and exhibits significant cohesion when submerged. Cohesive soils include clayey silt, sandy clay,
"Dry soil" means soil that does not exhibit visible signs of moisture content.
"Fissured" means a soil material that has a tendency to break along definite planes of fracture with little resistance, or a material that exhibits open cracks, such as tension cracks, in an exposed surface. So anywhere in the Standard where you see reference to whether or not the slope or bench of a trench is “fissured”, that is what it means.
"Granular soil" means gravel, sand, or silt (coarse grained soil) with little or no clay content. Granular soil has no cohesive strength. Some moist granular soils exhibit apparent cohesion. Granular soil cannot be molded when moist and crumbles easily when dry.
"Layered system" means two or more distinctly different soil or rock types arranged in layers. Micaceous seams or weakened planes in rock or shale are considered layered.
"Moist soil" means a condition in which a soil looks and feels damp. Moist cohesive soil can easily be shaped into a ball and rolled into small diameter threads before crumbling. Moist granular soil that contains some cohesive material will exhibit signs of cohesion between particles.
"Saturated soil" means a soil in which the voids are filled with water. Saturation does not require flow. Saturation, or near saturation, is necessary for the proper use of instruments such as a pocket penetrometer or sheer vane. Which I will get into shortly.
"Stable rock" means natural solid mineral matter that can be excavated with vertical sides and remain intact while exposed.
"Submerged soil" means soil which is underwater or is free seeping.
"Unconfined compressive strength" means the load per unit area at which a soil will fail in compression. It can be determined by laboratory testing, or estimated in the field using a pocket penetrometer, by thumb penetration tests, and other methods.
So let’s dig into classifying soil. “Soil classification system" means, for the purpose of this subpart, a method of categorizing soil and rock deposits in a hierarchy of Stable Rock, Type A, Type B, and Type C, in decreasing order of stability. The categories are determined based on an analysis of the properties and performance characteristics of the deposits and the characteristics of the deposits and the environmental conditions of exposure.
"Type A" means cohesive soils with an unconfined, compressive strength of 1.5 ton per square foot (tsf) (144 kPa) or greater. Examples of cohesive soils are: clay, silty clay, sandy clay, clay loam and, in some cases, silty clay loam and sandy clay loam. Cemented soils such as caliche and hardpan are also considered Type A.
However, no soil is Type A if:
"Type B" means:
"Type C" means:
In order to properly classify the soil, OSHA requires at least on visual analysis and one manual test be performed on the soil.
A visual analysis is conducted to determine qualitative information about the excavation site in general, the soil adjacent to the excavation, the soil forming the sides of the open excavation, and the soil taken as samples from excavated material. Here are the steps:
1. Observe samples of soil that are pulled out of the ground as well as the soil in the sides of the excavation. You need to estimate the range of particle sizes and the relative amounts of the particle sizes. Soil that is primarily composed of fine-grained material (like a putty) is cohesive material. Soil composed primarily of coarse-grained sand or gravel is to be considered granular material.
2. Watch the soil as it is excavated. If it remains in clumps when excavated and dropped out of the bucket or shovel it is considered cohesive. If it breaks up easily, falls apart and does NOT stay in clumps you would consider it to be granular.
3. Look at the sides of the opened excavation and the surface area next to it. Crack-like openings, like tension cracks, could mean that you are dealing with fissured material. If chunks of soil spalls off a vertical face of the excavation, this is another sign the soil could be fissured. Small spalls are evidence of moving ground and are indications of potentially hazardous situations. So be sure to look for this.
4. Watch the area next to the excavation and the excavation itself for evidence of existing utilities and other underground structures, and to identify previously disturbed soil. An obvious sing would be indicated via utility markings made prior to digging or conduit, pipe, etc. being exposed as you dig. A less obvious sign of this would be a small patch of gravel or sand that you may have cut through or running along side the trench. This may indicate backfill material and thus previously excavated soil.
5. Also, watch the opened side of the excavation for a possible layered system. Examine layered systems to identify if the layers slope toward the excavation. Estimate the degree of slope of the layers. This will also drive the slope angle allowed or if you can even bench the sidewalls.
6. Look for evidence of surface water, water seeping from the sides of the excavation, or the location of the level of the water table. Both in the excavation as well as at the surface.
7. Check the area for sources of vibration that may affect the stability of the excavation face. If you are running a front end loader up and down the length of an open trench carrying loads or straddling part of the end of the trench with the track hoe then you might be subjecting the excavation to vibrations that could lead to unstable sections.
OSHA also requires at least 1 manual test be performed in order to determine quantitative as well as qualitative properties of soil. This provides more information in order to classify soil properly so as to get us to the next step; selecting appropriate protective measures. Let’s run down the options for manual testing:
2. Dry strength test. If the soil is dry and crumbles on its own or with moderate pressure breaks into individual grains or even a fine powder, it is granular - so, any combination of gravel, sand, or silt. If the soil is dry and falls into clumps which break up into smaller clumps, but the smaller clumps can only be broken up with difficulty, it may be clay in any combination with gravel, sand or silt. If the dry soil breaks into clumps which do not break up into small clumps and which can only be broken with difficulty, and there is no visual indication the soil is fissured, the soil may be considered un-fissured.
3. Thumb penetration test. The thumb penetration test can be used to estimate the unconfined compressive strength of cohesive soils. (This test is based on the thumb penetration test described in American Society for Testing and Materials (ASTM) Standard designation D2488 - "Standard Recommended Practice for Description of Soils (Visual - Manual Procedure).") Type A soils with an unconfined compressive strength of 1.5 tsf can be readily indented by the thumb; however, they can be penetrated by the thumb only with very great effort. Type C soils with an unconfined compressive strength of 0.5 tsf can be easily penetrated several inches by the thumb, and can be molded by light finger pressure. This test should be conducted on an undisturbed soil sample, such as a large clump of spoil, as soon as possible after excavation to keep to a minimum the effects of exposure to drying. If the excavation is later exposed to rain, flooding, etc. the classification of the soil must be changed as well.
4. Other strength tests. Estimates of unconfined compressive strength of soils can also be obtained by use of a pocket penetrometer or by using a hand-operated shearvane. These are instruments used to penetrate a sample with a rod containing a resistance spring and a measured cylinder to read unconfined compressive strength. The shear vane is a tool with a numbered dial and needle and requires a soil sample with a flat surface where you impress a disc with vanes and twist it until it shears off a section of the soil sample thus giving you a reading. These instruments come with instructions and also have some environmental limitations (springs acting differently in cold vs hot weather) and could be subject to wear over prolonged use.
5. Drying test. The basic purpose of the drying test is to differentiate between cohesive material with fissures, un-fissured cohesive material, and granular material. The procedure for the drying test involves drying a sample of soil that is approximately one inch thick (2.54 cm) and six inches (15.24 cm) in diameter until it is thoroughly dry:
Some of these tests are more for soils engineering and designing complex protective systems. Your average worker involved in excavation activities is probably going to use the visual analysis along with the plasticity test or thumb penetration test. Just getting your hands on a sample and trying to mold it, feel it, see how it behaves is really a good way to determine what you are dealing with.
Now having said all that; I will give you my take:
Forget solid rock; it can have any fractures/fissures, if you are scraping, blasting, hydraulic fracturing, pile-driving, drilling, then you are creating this condition. Which means pieces of varying size could potentially come loose and fall into the trench. Therefore you move to the next level: Type A soil. Well, if it is fissured or subject to vibration, etc. then it cannot be considered type A. And let’s face it, most excavations will be subject to varying degrees of activities that meet this criteria.
So, we are left with Type B soil and C. Cohesive or non-cohesive? (ok, there is a gray area known as non-cohesive type B, but honestly, just call it non-cohesive and get to work!). So is it Clay or Sand? It really is that simple. Once you know the soil type, you can determine what protective system to use.
Here your options are sloping, benching or shoring of some kind. The maximum allowable slope are as follows:
Stable rock - vertical (90)
Notice I said MAXIMUM allowable slope! This means you may need to make it “flatter” if it is needed. Sloped means the angle at which it will lie and NO LONGER MOVE! So keep that in mind. If you have Type B soil based on the visual and manual test and slope it to a 45 degree angle and you get sloughing then you need to dress that slope back more.
Benching is the same; the angle of the bench as measured from the TOE of the trench (nearest bottom side). So you can tell how many steps will be needed to achieve the 45 degree angle. You are only allowed a 4 foot maximum face for the first bench step you make, then a 5 foot maximum face thereafter.
You can also use a single bench; make a 4’ maximum face, cut it back then go to the slope needed for the sol type. Or an unsupported vertically sided lower portion; you can come straight up no more than 3 1/2 feet then hit your slope. But keep in mind, Type C soil according to OSHA CANNOT be benched! Only sloped or shored.
And, these are ONLY allowed for trenches up to 20 feet deep. Trenches 20 feet (6.1 meters) deep or greater require that the protective system be designed by a registered professional engineer or be based on tabulated data prepared and/or approved by a registered professional engineer.
As for shoring; like trench boxes and speed shoring - you have to make sure you have what is called the tabulated data sheet for that system ONSITE. This tells you the depth limits based on soil type as well as width limitations, whether you can stack 2 or more trench boxes on top of one another, things like that. This gets tricky as there are all sorts of systems so I won’t get into specifics here. Just keep in mind, if your box or shield is below grade at any point, you must slope or bench as allowed per the soil type for any soil above the top of the device and you need at least an 18” lip to catch any rolling materials from going into the trench.
Same for the bottom; you can only raise the box or shield off the bottom of the trench up to 18” if conditions allow. So there are some little rules that go along with these systems; but again, you need to know the system requirements BEFORE beginning work and have that data onsite while work is taking place.
I hope you got some good info from this episode. Please follow up and seek more formal training for yourself and your co-workers on this topic. If you are overseeing work at your facility that involves this type of activity then I hope I gave you some good tips so that you can begin to go out and look at this work and assess whether or not things are complaint. Please let me know what you think, share your thoughts by emailing me at email@example.com or visit www.thesafetypropodcast.com
Until the next SafetyPro Podcast episode, please be safe.
|Apr 11, 2018|
039: Vacation Message - Off the Job Safety
Final vacation week! Thanks for being loyal listeners. I wanted to remind everyone in this quick episode about taking safety with when you leave work.
I may put together an episode about this topic soon. Share your off-the-job safety tips by sending me an email to firstname.lastname@example.org.
Don't forget to visit our incredible partners in safety:
Be safe out there!
|Apr 03, 2018|
038: 6 Steps to an Effective HAZCOM Safety Program
Mentioned in this episode:
I am on vacation! But, I still managed to get a quick episode out for all my awesome listeners. 6 Steps to an Effective Hazard Communication Program for Employers That Use Hazardous Chemicals!
It's a good one! Get the document mentioned in this episode: Hazard Communication: Steps to an Effective Hazard Communication Program for Employers That Use Hazardous Chemicals Fact Sheet
Email comments or questions to email@example.com
|Mar 19, 2018|
037: Safety for Tree Trimmers
Mentioned in this episode:
Get the freebies mentioned in this episode HERE
As I get ready to head to the beach for Spring Break (I will already be there when this episode drops!) I was thinking about some of the seasonal work we need done at our homes as well as at our businesses. And that got me thinking about tree trimmers. And it hit me, when it comes to workplace safety, it is easy to overlook the folks that do some of this work, either at our homes or when we hire these companies to help us maintain our facilities.
Each year thousands of trees are uprooted by powerful winds from a hurricanes, thunderstorms, etc. And usually taking power lines and transformers with them. I wanted to get a quick topic out about the safety needed for workers that come out and take care of these trees and help us improve our personal property as well as our businesses.
Tree trimming is serious business. There are numerous SERIOUS safety hazards involved. Everything from falls to electrical hazards, these workers must be well-trained, well-equipped and focused to do this job safely.
One of the more common hazards deals with power lines. Either downed lines from a storm or tree that fell or just trimming tress near power lines. The safest approach is ALWAYS ASSUME THAT POWER LINES ARE ENERGIZED!
If clearing trees, contact the utility company to discuss de-energizing and grounding or shielding of power lines. This takes time, yes, but just search online for stories involving tree trimmers being shock or electrocuted on the job! Oh, and it often involves ground workers; yep, this can happen when a ladder or the boom of cherry picker unknowingly comes into contact with an energized lines and the operator is insulated in the basket, doesn’t realize it and a ground worker walks up and grabs the metal door of the truck, reaches for a tool or something like that and becomes part of that circuit. It happens more than you think! These can all be avoided.
One way to avoid disaster is to always perform a hazard assessment of the job in general as well as the work area prior to start of work. So for electrical hazards, ask will you get closer than, say, 10 feet to your average power line? What about the stability of the ground for outriggers on the cherry picker? Is there traffic nearby or will you need to be in the roadway? What about clearance for your work, especially when removing or cutting down a tree?
Let me say, to “fell a tree” means more than just cutting it down. Felling means to cut the tree in such a way that it falls in the desired direction and results in the least damage to the tree. To safely fell a tree, you must eliminate or minimize exposure to potential hazards found at the tree and in the surrounding area. This means BEFORE YOU BEGIN WORKING!
Part of being prepared for your work means having the right equipment. Always use proper personal protective equipment as recommended by the manufacturer’s operating manual, including eye, face, head, hand, and foot protection for tools and machinery. Chippers, shredders, chainsaws, etc. all have very specific safety requirements. And don’t forget TRAINING!
Your employees NEED to be trained on all the tools they will be using. Don’t rely the old “I have been using chainsaws for years” certification. Just look online for any number of manufacturer videos or literature on chainsaw safety. Or any other power tool. The Power Tool Institute has some good videos a well, so search for them too. By the way, I have an OSHA publication that covers the hazards of wood shippers as well. So be sure to hit that link!
Broken or hanging branches, attached vines, or a dead tree that is leaning can be of concern. All of these hazards can cause injuries. So making sure employees are trained to spot these overhead hazards and stage work accordingly should also be covered. I have an OSHA publication that covers falls and falling objects hazards for tree care workers. Just hit the link in these show notes or go to thesafetypropodcast.com/podcast and look for this podcast topic, get the links there as well.
What about working outdoors in general? There is extreme cold and heat concerns. This should all be a part of your employee training. How to spot poisonous plants, what about insect bites and stings? How about encounters with snakes or other wild animals? Basically, if it is a realistic hazard of the job, have a plan to educate workers on the hazards and to manage them! If you are not sure what to cover in any training. Just break the job down into stages:
These accidents CAN be avoided! So when getting ready for the spring season and all the storms it brings, downed trees and power lines; remember safety starts well before the work begins! I hope I gave you some things to look for, some topics to research and begin training your workers on as well as started you all thinking about this work in general. If you hire these workers to help you maintain your facilities, be sure to ask for certifications for aerial lift training, if that applies, ask for a pre-job plan to include where they will stage their equipment, provide them a list of PPE they will need to wear while at your site. This can really start a conversation about safety and give you an idea on how proactive that contractor is and whether they are ready for this type of work.
If you are a tree trimmer, either worker or company owner, this is a good time to start looking at safety as both an employee benefit as well as customer service. It is the right thing to do, it is good for business, it just makes sense.
|Mar 12, 2018|
036: Confined Space Entry Safety Part 3: Rescue Teams
Mentioned in this episode:
In the last couple of episodes I dance around the rescue team parts of the standard. I want to get into that section here. Let’s start with an outside rescue option, since a lot of folks go this route. If you recall, whenever you use outside resources you must evaluate a prospective rescuer's ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified.
So you have to have done a hazard assessment first, so that you can have a meaningful conversation with the outside agency. Also, don’t forget, bring them in to do a walk-thru, look at the spaces involved, the internal configurations, chemicals used onsite, etc.
You also have to develop and implement procedures for summoning rescue and emergency services to your location. Ask about whether the local authorities use a regional dispatcher, this may delay response time a little, does your site use a different number to dial out to emergency services, instead of 911? All of this goes into your program and training.
Once you determine the rescue team that will be used, you have to develop a procedure for rescuing entrants from permit spaces and be able to provide necessary emergency services to those workers. The primary requirement in the first aid standards is that an employer must ensure prompt first aid treatment for injured employees, either by providing for the availability of a trained first aid provider at the worksite, or by ensuring that emergency treatment services are within reasonable proximity of the worksite.
You have to take appropriate steps prior to any accident (like making arrangements with the service provider) to determine if emergency medical assistance will be promptly available when an injury occurs. While the standards do not prescribe a number of minutes, OSHA has long interpreted the term "near proximity" to mean that emergency care must be available within no more than 3-4 minutes from the workplace, an interpretation that has been upheld by the Occupational Safety and Health Review Commission and by federal courts.
One option these standards provide employers is to ensure that a member of the workforce has been trained in first aid. This option is, for most employers, a feasible and low-cost way to protect employees, as well putting the employer clearly in compliance with the standards. OSHA recommends, but does not require, that every workplace include one or more employees who are trained and certified in first aid, including CPR.
The first aid training standards at 29 CFR 1910.151 and 1926.50(c) generally apply throughout the industries that they cover. Other standards which apply to certain specific hazards or industries make employee first aid training mandatory, and reliance on outside emergency responders is not an allowable alternative. For example, see 29 CFR 1910. 266(i)(7) (mandatory first aid training for logging employees), and 29 CFR 1910.269(b) (requiring persons trained in first aid at work locations in the electric power industry).
So seriously look at getting a team of volunteers to be trained, on all shifts. More support for this is that medical literature establishes that, for serious injuries such as those involving stopped breathing, cardiac arrest, or uncontrolled bleeding, first aid treatment must be provided within the first few minutes to avoid permanent medical impairment or death.
Also, in workplaces where serious accidents such as those involving falls, suffocation, electrocution, or amputation are possible, emergency medical services must be available within 3-4 minutes, if there is NO EMPLOYEE on the site who is trained to render first aid. So this can buy a victim more time if folks are trained and equipped onsite already.
OSHA exercises discretion in enforcing the first aid requirements in particular cases. OSHA recognizes that a somewhat longer response time of up to 15 minutes may be reasonable in workplaces, such as offices, where the possibility of such serious work-related injuries is more remote.
Now, I will restate what the standard says: In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first aid supplies shall be readily available. This is a way to meet that standard!
And, for an in-house rescue team, at least one member of the rescue team or service holding a current certification in first aid and CPR is available. Trust me, ALL of them should have it. What if the only member trained in 1st aid goes down? So spread the love folks!
So what does this tell us? Well, it tells us we need to careful examine and consider the actual hazards likely to be present as well as the injuries and illnesses likely to occur. This has to be included in the training in order for us to claim our in-house first aid team is “adequate”.
Let, me illustrate this for you; A lot of the first aid training programs I have reviewed are really good at preparing you (as best as possible) for an emergency. They cover what to do, how to react, things like that. A lot of effort goes into keeping the responder safe; blood borne pathogens, PPE, checking the scene; which is great. Then there are sections that get into how to perform a patient survey, for both an unconscious and conscience patient. And then there are sections of training covering how to stop bleeding and immobilize a limb maybe.
Here is where you need to be sure to include covering injuries likely to occur at your facility. Work with the instructor ahead of time to include how to treat a chemical burn, and be specific - like hydrochloric acid, or chlorine gas for example. This site-specific or even chemical or hazard-specific training is what will deem your personnel “QUALIFIED” to render first aid at your facility. The basic community first aid training, just won’t be enough.
Okay, let’s move on to an in-house rescue team. First, they have to be equipped for and proficient in performing the needed rescue services. Do you have underground tanks? Do they have rectangular, square or round entry points, or a combination? This tells me what types of hoists I will need to have available for rescue. What about horizontal spaces? Are some of them above grade, requiring staging from an elevated platform? This tells me aerial lifts, personnel hoists, stair chairs, stokes baskets, etc may be needed as well. What about SCBA, air line respirators, things like that for rescue teams?
So equipped means just that; equipment needed to facilitate a rescue from any and all possible spaces to be entered. Standardization really helps but some older facilities that have been upgraded and modified over the years do not have this luxury. But think about this moving forward; standardize openings (their shape and size) whenever possible, and their location (at grade vs. elevated openings, things like that.). This ALL has to be set up and gone over each time you have training for this team. Every piece, all the PPE that may be needed, all of the monitoring instruments, everything!
Ensure that rescue and other affected employees (like potential victims) practice making permit space rescues at least once every 12 months. This has to be by way of a simulated rescue in which you remove dummies, manikins, or actual persons from the actual permit spaces or from representative permit spaces. Representative permit spaces shall, with respect to opening size, configuration, and accessibility, simulate the types of permit spaces from which rescue is to be performed. I have seen a few facilities that have old tanks that have been cleaned and the sides cut open but they keep them onsite as a training aid for this purpose. Of course, you may not have the room for this, but that was a representative space from them.
Of course non-entry rescue is where it’s at whenever possible. If your rescue personnel never have to enter this is best. To facilitate non-entry rescue, retrieval systems or methods have to be used whenever an authorized entrant enters a permit space, unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant.
So practicing at LEAST every 12-months is the OSHA standard. I recommend quarterly just so that you can reinforce these procedures and familiarize rescue teams with this equipment better. Also, hold a monthly first responder meeting instead of just the annual refresher for first aid and every two years for CPR recertification. This is a “use it or lose it” skill, its perishable, so keeping it fresh is going to help save lives. Give your responders a chance to talk about scenarios, practice first aid techniques in the meetings, dry runs, even debrief past responses since the last meeting to see what went right, what could be better, things like that. It will really add value and enhance the bare minimum OSHA sets for this stuff.
Look at your training program; what is it missing? What don’t you cover that we just ran through? How can you enhance your existing training? Make it stick? This is the challenge I have for you: do a full review of your written confined space entry program, the written permit, the rescue plan, your chosen method of rescue (non-entry, in-house or outside rescue team) and try to poke holes in the plans. That way you can improve it.
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|Mar 06, 2018|
035: Confined Spaces Pt 2 - Safety with Entry Permits
Mentioned in this episode:
This is part 2 in a series about confined space entry, the requirements including training and entry procedures and we will wrap the series up with some tips, interpretations and examples written programs. If you remember from the last episode I covered the basic definition of a confined space:
* Is large enough and so configured that an employee can bodily enter and perform assigned work
* Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.
AND (yes, it has to have all of these)
* It is not designed for continuous employee occupancy. And we talked about what that means as well.
And a ”Permit-required confined space (permit space)" means a confined space that has one OR more of the following characteristics:
1. Contains or has a potential to contain a hazardous atmosphere
Okay, we touched on just some of the training requirements as well. Not too much detail there, but I will go into rescue teams including in-house rescue and the training requirements in the next episode, so be listening for Part 3. For now let’s move into the actual permit and entry procedures.
Let’s begin with the space itself. Any time you remove covers to openings, especially at ground level, it has to be guarded immediately by a railing, temporary cover, or other temporary barrier that will prevent an accidental fall through the opening.
You always want to address safety outside the space, before beginning work - addressing the space itself. This means identifying any potential hazards that may impact ground workers outside, but also those that may create hazards inside the space. For example, any generators or other combustion engines (like from service trucks) that may be running nearby and could create a carbon monoxide hazard entering the space.
And of course, before any employee can enter the space, the internal atmosphere has to be tested. You do this with a calibrated direct-reading instrument, for oxygen content, for flammable gases and vapors, and for potential toxic air contaminants, in that order. Most multi-gas meters will test for all of these simultaneously. So no need to worry about the order in that case.
Keep in mind, any employee who enters the space has to be provided an opportunity to observe the pre-entry testing directly. This avoids the whole “hey I checked, it’s fine in there” type of scenario.
A note on this one; anyone that witnesses the monitoring needs to be trained on monitoring as well. This means how to operate and read the results. This way they know what they are looking at. Plus, if continuous monitoring goes on, they know what the alarm sounds like and of course if they take one in with them, they know how to operate it as well.
If you plan to use forced air ventilation, be sure to set it up the right way. Notice I said “forced air”. You cannot use negative pressure. That is, a fan pulling air OUT of the space. Some folks may think pulling “bad air” out is a better idea. It is not. Forcing fresh air in is required.
Well, it is all part of the permit system. According to OSHA, the employer must verify the space is safe for entry by way of a written certification that contains the date, the location of the space, and the signature of the person providing the certification.
The certification must be made before entry and be made available to each employee entering the space. This is accomplished by using an entry permit. Let’s get into what the permit looks like.
Let’s talk about the permit itself for a bit. The actual permit has to contain the following information:
1. The permit space to be entered: This can be a site name such as vault 2B, or autoclave oven # 4, something like that.
2. The purpose of the entry: This can say PM check of tank welds, changing O-rings, stuff like that.
3. The date and the authorized duration of the entry permit: If there are issues with extreme heat or cold, you may have placed a 15 minute time-limit on the entry. Or if using breathing air, like SCBA, you could place a time limit for the entrants. These are examples of authorized durations, as I get asked about this one frequently. Essentially, the duration of the permit cannot exceed the time required to complete the assigned task or job identified on the permit.
4. The authorized entrants: This can be done by listing their names or by using a roster or accountability log - For example, entrants check in and out moving names on and off the log. The goal is that attendants can know who is inside at any given time.
5. The name of the attendant(s): This is needed especially if you will be rotating attendants, you can see who is authorized to do so.
6. The name of the entry supervisor: Remember, this is just the person supervising the entry process, not necessary a work supervisor. The permit also has to have a space for the entry supervisor’s signature. This authorizes the entry.
7. The permit has to also list the hazards of the space: These should be spelled out. I am not a fan of the check list, that is, a list of typical hazards and a box next to it for you to check. I just adds to the length and visual clutter of the permit itself. I prefer to list the hazards that are present or likely to be present so those involved fully understand what they are protecting themselves from and what to look out fo. This helps when communicating with entrants, looking for signs and symptoms of exposure. This requires that all involved be trained on such symptoms of different hazards as well.
8. This gets us to listing the measures taken to eliminate or control those hazards. Like blanking, purging, LOTO, etc. It also give all involved something to check during the entire process. If you indicated a forced air blower, that is plugged into a generator the you know that you have to check the fuel level periodically, or you may have indicated CO as a potential hazard. Again, all this stuff is useful when you think about how you can use it to protect yourself and your co-workers.
9. You have to list acceptable entry procedures as well. This is key, because you then have to continuously check conditions against this list. If there are any differences that is a red flag. You may determine a condition improved, not worsened. But you still have to flag it and determine whether or not to evacuate the space and cancel the entry permit.
10. This also means you need a section for the initial and periodic test results. This helps us document ongoing monitoring activities.
11. A section for the rescue and emergency services that can be called and you have to detail HOW they will be called; such as the equipment to use and the numbers to call.
12. The communication procedures that are to be used by authorized entrants and attendants to maintain contact during the entry. Constant audible or vial contact must be maintained during the entire entry process. If at any time a specified communication device goes down, you have to pull entrants out until you establish another acceptable, and agreed upon way of communicating, note this change on the permit, retest, and proceed again.
13. You also have to list all the equipment to be used, such as PPE, testing equipment, (again, communications equipment), alarm systems, and rescue equipment as well. This also tells us what types of pre-entry inspections are needed, based on what will be used.
14. Any additional info that would be pertinent especially additional permits like hot work, that you will rely on for the entry.
I have a permit template available here as well as a written program template in case you want to compare it to the one you have, or if your are looking to create one altogether. Some points to consider in your program:
The entry supervisor must terminate the entry (in writing on the permit) once operations have been completed and all personnel, materials, tools, etc have been accounted for and are out of the space.
They also have to terminate the entry when a condition that is not allowed under the entry permit arises in or near the permit space. Again, not just the entry supervisor, but the attendant and any entrant can terminate the entry for this reason. But only the entry supervisor of record should sign and terminate the entry permit itself.
OSHA requires that you keep each entry permit for at least 1 year to facilitate the review of the permit-required confined space program. So at least annually, go overall the entries that were made, look for issues discovered, reasons entries were terminated prematurely, hazards encountered that were not noted on the permit originally, etc. This is so you can improve the written permit required confined space entry program, improve training, and so on.
Not just for confined space entry, but all of your written safety programs; conduct an annual review to verify they are still adequate and do not need updating. This is a requirement! It is also a great way to use a safety committee; have the group go through a program and talk about how it applies, what needs to be added, what needs to be removed, and so on.
This is a perfect place to stop and tease the next episode; we will get into training specifics and rescue teams; both in-house and external services. Then wrap it all up with some best practices and a template you can use to get started writing your own program.
Thanks for listening to the podcast; keep your emails coming (firstname.lastname@example.org). I love hearing from all of you so please, if you think I won’t get the email, or read it or reply, I WILL…and have! Each one. So please do NOT hesitate to reach out with suggestions, comments, even questions about safety management.
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|Feb 25, 2018|
034: Confined Space Entry Safety Pt 1
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I want to get into confined spaces and permit-required confined spaces. I need to break this topic up into a couple of different episodes, beginning with a general introduction to terms, definitions, emergency response and some training requirements before getting into specifics around the actual entry permits and entry procedures like monitoring in the next episode.
Ok, so let’s first define the terms for our discussion:
According to 29 CFR 1910.146, a confined space is ANY space that:
* Is large enough and so configured that an employee can bodily enter and perform assigned work
Let’s talk about that last part for a moment; OSHA defines continuous human occupancy vaguely, but use the following as a benchmark:
Can the worker safely remain inside the space during operation? Of course we are talking about not being exposed to a recognized hazard while inside; moving/rotating parts, live electrical components, gases, fumes, or other hazardous atmosphere, things like that.
I have heard all sorts of crazy excuses why a space is NOT a confined space:
- It has a door
You need to assess and evaluate ALL aspects of the space to determine whether or not it is considered a confined space according to OSHA.
So, confined spaces can include underground vaults, tanks, storage bins, manholes, pits, silos, underground utility vaults and pipelines, etc. It really depends on you being able to assess the space in question.
Now, OSHA states that the employer shall evaluate the workplace to determine if any spaces are PERMIT-required confined spaces.
Well, a ”Permit-required confined space (permit space)" means a confined space that we already defined, has one or more of the following characteristics:
1. Contains or has a potential to contain a hazardous atmosphere
2. Contains a material that has the potential for engulfing an entrant
3. Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section OR
4. Contains any other recognized serious safety or health hazard
If the workplace contains any permit spaces, you have to inform exposed employees, by posting danger signs or by any other equally effective means, of the existence and location of and the danger posed by the PERMIT spaces.
I always recommend controlling access further by adding physical locks when possible. Especially if your policy is that no employees are permitted to enter these spaces. This adds another level of security to the postings.
Ok, for me, starting with managing the spaces themselves as well as the activities in and around these spaces is the key to ensuring worker safety. And it all starts with making sure you are PREPARED to respond to ANY emergency in the workplace.
Emergency services (whether you have confined spaces or not) is critical for any workplace. First and foremost, you need to determine whether or not emergency crews are able to reach your facility in what OSHA calls a “reasonable amount of time” for life-threatening situations.
So, according to OSHA, in workplaces where serious accidents such as those involving falls, suffocation, electrocution, or amputation are possible, emergency medical services must be available within 3-4 minutes, if there is no employee on the site who is trained to render first aid.
OSHA recognizes that a somewhat longer response time of up to 15 minutes may be reasonable in workplaces, such as offices, where the possibility of such serious work-related injuries is more remote.
Also, OSHA has interpreted the standard to require a separate (either in-house or outside) rescue and emergency service when permit space entry operations are performed in an immediately dangerous to life and health (IDLH) atmosphere.
This means any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individual's ability to escape unaided from a permit space. An example would be during inerting activities.
Even in permit space entry operations involving non-IDLH atmospheres, more than one rescuer may be required in permit space entry operations depending on the hazards present and the number of authorized entrants that may require rescue.
The minimum number of people required to perform work that is covered by OSHA standards for permit-required confined space entry standards and respiratory protection standards will be driven by facts such as the hazards or potential hazards, the number of entrants who may require rescue and the configuration and size of the space. So planning is critical!
When using outside services that are able to meet the responsible time, consider the following:
* Have local response crews been out to see your facility?
These are just a few examples of best practices you can follow to ensure a higher level of safety.
Also, keeping track of who is entering these spaces at any given time is key. Whether they are contractors or your own employees; knowing when entries are taking place and tracking entrants is a major part of the OSHA requirements.
This gets us into the permit entry system. This is your written procedure for preparing and issuing permits for entry and for returning the permit space to service following the termination of entry.
This is important; for a PERMIT required confined space, NO entry is allowed unless a written entry permit is completed, you have identified the trained attendant, entrants and entry supervisor (we will go through all that in the next episode) and have documented each hazard of the space and how each hazard is mitigated.
Now, since deaths in confined spaces often occur because the atmosphere is oxygen deficient or toxic, confined spaces needs to be tested prior to entry and continually monitored. More than 60% of confined space fatalities occur among would-be rescuers; therefore, a well-designed and properly executed rescue plan is a must.
If spaces spaces are properly evaluated prior to entry and continuously monitored while the work is being performed and have appropriate rescue procedures in effect, fewer incidents would occur. OSHA considers entry to have been made into a space whenever ANY part of the entrant’s body breaks the plane of the space opening.
So just because OSHA says you have to break the plane to have made entry, don’t forget about the general environmental controls standard that applies just outside the space.
Let’s stop there with entry procedures and save that specific topic for the next episode. I wanted to give you an overview of what is involved and what to expect moving forward.
Employees need to be trained BEFORE they are assigned any duties related to confined space work. Let me break these into some categories for you:
1. General safety
For general safety training, all employees, regardless of their role, need to understand the common hazards present or that may be present in any of the spaces that they might work. Especially hazards they may be introducing themselves. Are they cutting or welding? Are they using chemicals? Are they using electrical equipment?
Training also has to include signs and symptoms of exposure to certain hazards. All workers need to know how to identify whether or not an entrant is being affected by any of the hazards that may be present. They also need to understand how hazards are to be controlled, the monitoring equipment used in spaces, etc.
According to the Standard; you have to develop and implement procedures for summoning rescue and emergency services, for rescuing entrants from permit spaces, for providing necessary emergency services to rescued employees, and for preventing unauthorized personnel from attempting a rescue.
Also, if there is any fall protection or retrieval equipment being used, they have to be properly trained on its set up and use. Especially if non-entry rescue is being utilized. This is crucial. You can see that knowing the confined spaces standard is not enough. You will need to know general safety requirements, PPE standards, Fall Protection, Respiratory Protection, Emergency Services and First Aid, and more!
Attendants need to know all of the general training requirements as well as the need to remain at the space at all times. They cannot perform ANY other duties that interfere with being an attendant. The entrant can’t yell out to the attendant that they need a wrench or something and the attendant runs to the tool box real quick and grabs it. They can’t be chatting up another site worker about the game last night, nothing like that!
The permit itself we will go into detail on in the next episode. How to fill it out, terminating the space entry, how long you need to keep these on file, all that stuff. I will have permit templates available, checklists for you so you can get started. But this episode, I wanted to introduce the topic, talk about some of the definitions and training requirements to get us started.
So keep an ear out for the next episode as we go deeper into this topic. Let me know what your thoughts are on confine spaces. I would like to cover some FAQs as well and talk about some common letters of interpretation in the next episode that will help you improve your confined space entry program. Drop me an email - email@example.com
|Feb 19, 2018|
033: Lean Safety
In this episode I want to talk about Lean manufacturing principles and how it can help you transform safety in your organization.
If you listen to this podcast regularly (and I hope you do!) you probably have heard me tell you to go look at what tools the lean or quality folks are using in your organization. And there is a good reason for that. They CAN help you improve safety processes.
I am going to reference 2 good books I studies and will draw upon their lessons in this episode. One is called Lean Safety: Transforming your safety program with lean management by Robert B. Hafey and the other is called Safety Performance in a Lean Environment: A guide to building safety into a process by Paul F. English.
Basically, Lean is a manufacturing philosophy that reduces the total cycle time between taking a customer order and the shipment by eliminating waste.
What is great about lean principles are they apply to all business processes and especially safety. Also, lean can be applied to all types of businesses.
Edward Demming is widely considered the father of lean and what became the Toyota Production System (TPS). He went to Japan after WWII to teach Japanese business leaders how to improve quality. His work went unnoticed in the US until the early 1980’s.
Of course that period of time is important; it’s when Japanese auto makers overtook US companies in quality and productivity. Ford first brought Demming in to help improve their quality.
This is when Demming determined Ford’s quality systems were not at fault, but rather their management practices were. A major cultural change would be needed.
So Demming developed 14 points of management. Let’s go through them and see how they relate to safety:
1. Create constancy of purpose for improving products and services.
It is clear to see how universal these can be. Another useful tool we can take from lean (and trust me, there are many, as I have covered in past episodes) is DMAIC: Define, Measure, Analysis, Improve and Control.
Let’s go through what this might look like for safety.
Define: Who is the customer? What is the voice of the customer? What is critical to safety? What is the cost of poor safety?
Measure: Cause & Effect fishbone. Is the safety process state and in control? What is the current safety process performance (or capability)? What actions are being taken to protect the employee/company (containment)?
Analysis: Which issues are effecting health & safety the most? how many samples do you need to draw conclusions?
Improve: What is the ideal solution? What is the proof the solution will work? How many trials are needed? what is the work plan to implement and validate the solution?
Control: Can you demonstrate the improvement is sustainable over time? Is the process in control? How do we keep it that way?
Again, here is just one example of how lean principles and tools can be applied to safety. Furthermore, this can empower everyone in an organization to champion safety. So safety leadership doesn’t require a business leader or manager. Shop floor workers can get lean training and begin identifying ways to improve the systems they have to interface with everyday; including safety.
We see this in accident investigations as well. One of my favorite lines to use is to focus on the process not the person. In his book, Lean Safety, Robert Hafey tells a story about accidents at a manufacturer he once toured. There they uncovered a trend involving forklift accidents.
Some managers looked into force monitors; these shut down the forklift in the event of an impact requiring operators to seek out a manager to turn it back on. You see, most of the incidents were hit and runs, no witnesses.
His approach was different. Because they had no idea who caused the damage, since it was usually reported by someone other than the driver, they needed an approach that removed that aspect from the equation. The approach was to invite a forklift driver (any driver) in that area and help investigate.
They were told that they would not be spending time looking for WHO was responsible, but rather to determine the root cause and come up with corrective processes in place to prevent recurrence.
What they discovered was the majority of the incidents were a result of poorly placed racks, improper clearances, etc. So they went about fixing those things, and wouldn’t you know, soon enough the drivers that had an incident began self-reporting.
The reason is TRUST! The approach to many accident investigations completely destroys trust. If focuses on “what did you do wrong?” instead of “how can this be improved?”
I remember at a client site years ago and operator got a laceration from removing a glove to grab a sample piece of metal off the line for a quality check. Management wanted to issue discipline, for removing PPE.
The problem was that everyone was issued the same gloves - heavy leather gloves because of the sharp metal edges on their product. But they were also required to cut a sample piece for a quality check. They all knew you could not pick up this thin 4” wide sample with those gloves on. So everyone, every worker removed their glove to do so. And management knew this. But the others had not gotten a laceration…yet.
So issuing discipline would destroy trust, and drive reporting underground. Also, it did NOTHING to address the root cause; the conditions remained the same, therefore they were doomed to repeat this cycle.
By focusing on the process, we were able to determine the form, fit and function of those gloves (on that line anyway) needed to change and samples were brought in for operators to try and then score based on cut resistance level needed and dexterity. That operator, he became a part of the solution, not just another victim of a hazard of the job.
I could go on with hundreds of stories like this I have seen in my work as a consultant for over a decade. But let’s save those for future episodes!
The main takeaway I want you to get here is to look toward Lean principles to help you improve safety. Mainly build the trust needed to build a collaborative environment where you turn workers into champions for change and improvement across all areas of the business.
And until the next safetypro podcast episode, be safe.
|Feb 12, 2018|
032: Is Online Safety Training Effective?
Online safety training has come a LONG way from what it was even 5 years ago. Technology like mobile devices and apps has made digesting information easier and more interactive.
So in this episode I want to focus on what works best as far as online safety training goes, and what to avoid.
Years ago, a model for training emerged called Adaptive Learning. I won’t bore you with the higher education definition of the term. Not because I don’t think any of you would understand it; of course you would! But because when we use the term in the context of online safety training, the definition takes on a whole new meaning.
Adaptive learning for this discussion simply means the learner can drive the direction of the training based on their interactions. This goes well beyond the old “CORRECT/INCORRECT” feedback responses they typically get.
So let’s get into what to look for in online safety training and what to avoid.
So for online safety training, adaptive learning is simply the lesson presenting an activity whether it is a questions, matching, photo to select what is wrong, even a short clip of a work scenario and some question after, and then, based on the learners answer, they are presented with more information.
A simple example is if the lesson presents a question like, True or False: “safety glasses are only to be worn when you are performing a task with a power tool.” and the learners selects true, the lesson presents information explaining that “many times employees are around someone or will pass by someone using power tools that may present a hazard, given this information what should you do?”
The learner would then select an answer, again, either answer results in more information other than a simple CORRECT/INCORRECT. You see, the lesson seems to adapt to the learner’s responses. So how does this work?
The answer is quite simple. Using software one can easily create different “slides” with this information. Then using buttons for answer options, link each option to a slide with the relevant info. You could even do this with PowerPoint - create branching slides based on responses.
The question is, how deep do you want to go with it? Ideally you want to go as far it takes to make a point. If someone doesn’t get a simple concept by the third slide or so, it would be best to present a policy statement and ask several different ways if they understand; requiring a “yes, I understand” selection. If not, their training is paused until an actual person can coach them.
But back to the training concept, it is that simple. It is more engaging and informative to ask if PPE needs to be worn in a specific scenario (either described or shown in pictures or video). And if they choose the wrong answer, present a slide or video or picture with text with the rationale for the right answer, then ask it again in a different way to verify they understand the concept. Make sense?
So imagine an online training lesson that adapts this way? It is far better than the old “Pump and Dump” approach that is still used today. This adaptive learning model is great as it allows you (if you are the creator) to really dive deep on concepts and ideas for the learner. Even the correct answers can introduce another level of depth into a concept.
This graduated approach makes complex issues like CSE or Fall Protection easier as it allows you to introduce and validate foundational elements before getting into more complex ones. The learner tells the system when he/she is ready for the next level.
Another way to approach ANY online safety training is to use a blended approach. This can be live or broken up over time. Meaning, combining online training with instructor-led training. This can really enhance learning.
Imagine taking basic definition of terms on concepts of fall protection in an online adaptive learning course, then jumping into the classroom for hands-on demos and activities to reinforce what you were introduced to online? That is really powerful. I have seen this work well.
This brings up a distinction worth noting; the difference between training and education. I have a simple way (maybe too simple) of looking at the two terms:
Education is transferring knowledge of a particular subject.
Training is the practical application or use of that knowledge.
So to me, taking an online course about fall protection simply educates one on the requirements of the subject; definitions, procedures, policies, etc.
Training is the hands-on demonstration where learners have to inspect harnesses with hidden flaws, practice donning/doffing, using snap hooks, practice using a beam strap on a simulated beam, etc.
You need BOTH in many safety and health topics. So to me, you need to be involved in the training and education process for all employees. You cannot simply pass this off to an online option with no input whatsoever.
That said, online safety training is extremely effective and user friendly, accessible, and affordable. Many topics that simply require knowledge (education) about requirements can be taken online. A lot of us safety professionals need to keep up on regs, permit requirements, etc. and much of this is at the education level I just talked about. Maybe one could add an activity to fill out a permit or shipping manifest or something like that as a training aide.
But by and large, much of what we professionals need is definitely in the realm of education vs training. There are so many options out there for this. Personally, I have an affiliate relationship with Atlantic Training. Their courses are affordable, and give you what you need to get started; knowledge of the topic. I have a link in the show notes if you want to check them out. Again, they are not a sponsor or anything like that.
Other options are the National Safety Council. They have industry recognized training and education courses that I have recommended for years now to clients and even listeners that have contacted me about how to brush up on their safety management skills.
So look around, ask peers what they did and how they liked it - that is still the best way to get feedback before you buy. Also, many offer free lesson previews as well. So be sure to look at those to see if the look, feel and style of the online training is best for you. I have taken some where the voice was digitized, monotone and just unbearable! I would not have chosen that course if I had a preview first.
So look for that. Also, look for anything that provides downloads or supporting materials like manuals, handouts, even job aides to use with others at work, like tool-box talks, safety huddles, etc.
The internet is seemingly endless with options these days. So I hope I have given you some options to look for. Let me know what you think - have you taken some really bad lessons? How about your recommendations?
Please share your thoughts by sending an email to firstname.lastname@example.org
Mentioned in this episode:
|Feb 05, 2018|
031: A Process to Change Workplace Safety Culture
So in this episode I want to talk about changing workplace culture. I have had a couple of episodes on Safety Culture already. And all of that still applies. Again, for the discussion let’s define the term:
Culture is the character and personality of your organization. It's what makes your organization unique and is the sum of its values, traditions, beliefs, interactions, behaviors, and attitudes.
This is key: the values, traditions, beliefs, interactions, behaviors, and attitudes. These are what drive behavior, specifically, what help workers make CHOICES that we then see in actions, or behaviors.
The reason I bring this up is that for the last year or so I have been talking to colleagues, reading and chatting in online groups and I keep reading about a common theme out there by so-called “thought leaders’ and ‘guru’s’ in organizational development and safety culture development. As many of you know I had been in consulting for a decade specializing in these areas; culture development. And yes, I have an opinion on this as you may have guessed.
So let me use a specific example of what I am talking about; I have seen a number of LinkedIn posts and articles about NOT talking too much about regulations or starting a conversation with “OSHA says…”. or similar discussions. While we can all agree that not having to drag in the references to regulations is good; we often have to go to those minimum standards. The reason? It is a sign of a “bad” safety culture.
Workplace culture often drives HOW we communicate about safety. The mistake most folks make is they manage by aspirational cultural values or from a future state. Here is what I mean; I see a lot of professionals pick up a book about culture this and culture that or read The Toyota Way and then look at their work culture and think, “yeah, we need to be like this!”
Problem; You are NOT like that. You need a roadmap to get there, yes. But do NOT approach your work culture as if they already are, based on what you wish were true about your work culture. These aspirations are commendable, but sets you up for failure.
You manage from where you ARE, not where you wish to be. So I have some examples of what I mean. If you think you should not have to talk about minimum regulations because you feel your culture is so much beyond this yet you continually get challenged by leaders and coaches to “show me where I have to do this” or “where does it say I have to do that?” then you are not there yet!
You can try and avoid stating regulations or reciting the unfortunate phrase “according to OSHA…” but at some point, you will have to simply because your culture is still at that place. I have heard time and time again and have had key maintenance and leadership personnel flat out ask, “What is the policy or regulation on this or that?” And if they are seeking validation, give it to them. These are folks that just need to be consulted. Give them the info because this is what they are saying they need as a basis for their work. OR justification for how they work. You may eventually get past this point but if this is where you are now…manage from there.
Another sign of where you are is when key personnel ask what the minimum amount of effort needed is to get by? Or, when you attempt to go above and beyond but the workforce pushes back with “we never had to do this before…”
These are clear signs of YOU needing to understand where your work culture is right NOW, not wishing where you would like them to be. Again, those aspirations should motivate us to discover where we are (or current state) and determine the difference between that and the ideal (or future) state. This is the gap we need to work to close. That way we can devise a change plan that is realistic and addresses the areas that need developed and not focus on things we will never be able to improve.
So, if you are tired of having to say, “According to the Standard…” then ask WHY you are still having to say it. If you try to improve something beyond minimum compliance and get pushback, ask WHAT it is folks are resisting. It may just be the change, and not the specific safety rule. So you may want to shift focus to change management in general. Go ask the quality folks or the lean folks if they have issues implementing even small changes to tasks or the work environment. Chances are they do.
So don’t get wrapped around the axle that your SAFETY culture is broken, when it may just be a PEOPLE thing. Strive to work with the other teams to find common obstacles and barriers. Safety needs to STOP operating in a vacuum and collaborate with other areas of the business to strategically align efforts to improve workplace culture.
If you are reading a book about workplace safety culture, fine. I recommend several on my resources page. But again, don’t get so wrapped up in your silo and think that this is unique to YOUR department. Most likely it is not. And if you have something figured out, like an aspect of the culture that you can improve, then you need to reach out and share this with others. Look into some management of change approaches. Helping workers deal with change.
You have a change plan, laid out timelines for training on this initiative you want to implement, how long before everyone gets the new equipment, etc. You know, a project management process. But do you have a process for change? One example is the ADKAR Model (again, just ONE example). This is a framework for understanding change at an individual level. It has 5 elements, or building blocks, that bus be in place for real change:
ADKAR stand for:
Awareness: this represents a person’s awareness of the nature of the change, why it is being made and the risk of NOT changing.
Desire: This represents the willingness to support and engage in the change.
Knowledge: This represents the information, training and education needed to know HOW to change.
Ability: This represents the realization or the execution of the change. It addresses turning the knowledge into action.
Reinforcement: This represents those internal and external factors that sustain change.
The elements of the ADKAR model fall into the natural order of how one person experiences change. Desire cannot come before awareness because it is the awareness of the need for change that stimulates our desire or triggers our resistance to that change.
Knowledge cannot come before desire because we do not seek to know how to do something we do not want to do.
Ability cannot come before knowledge because we cannot implement what we do not know.
Reinforcement cannot come before ability because we can only recognize and appreciate what has been achieved.
The lifecycle for ADKAR begins after a change has been identified. From this starting point, the model provides a framework and sequence for managing the people side of change.
In the workplace, ADKAR provides a solid foundation for change management activities, including readiness assessments, sponsorship, communications, coaching, training, recognition and resistance management.
Look, there are other models. This is but one that I have used and have seen success with in the past. But I want to point you in the right direction to get started addressing what I stated earlier, that is identifying the change that is needed is one thing, having a process to facilitate the change, ensuring its success is another.
This is a tool that can help. Stop managing from where you wish you were. Identify where you are today and get started laying out a plan to achieve successful, lasting change.
|Jan 30, 2018|
030: Determining Work-relatedness for Safety Injuries and Illnesses
As we know, the language of the OSH Act limits the recording requirements to injuries or illnesses that are "work-related." The Act uses, but does not define, this term.
OSHA has interpreted the Act to mean that injuries and illnesses are work-related if events or exposures at work either caused or contributed to the problem. Work-related injuries or illnesses may (1) occur at the employer's premises, or (2) occur off the employer's premises when the employee was engaged in a work activity or was present as a condition of employment.
What most people would read under paragraph 1904.5(b)(1), is the "work environment" means "the establishment and other locations where one or more employees are working or are present as a condition of their employment. The work environment includes not only physical locations, but also equipment or materials used by the employee during the course of his or her work."
Work-relatedness is presumed for injuries and illnesses resulting from events or exposures occurring in the work environment. Essentially, there must be a causal connection between the employment and the injury or illness before the case is recordable. There are some exceptions. These exceptions help us to better understand what WOULD be recordable. So let’s go thru the exceptions:
Injuries or illnesses will not be considered work-related if they involve symptoms that surface at work but result solely from a non-work-related event or exposure that occurs outside the work environment. OSHA's recordkeeping system is intended only to capture cases that are caused by conditions or exposures arising in the work environment. It is not designed to capture cases that have no relationship with the work environment.
For this exception to apply, the work environment cannot have caused, contributed to, or significantly aggravated the injury or illness.
An example of this type of injury would be a diabetic incident that occurs while an employee is working. Because no event or exposure at work contributed in any way to the diabetic incident, the case is not recordable. This exception allows the employer to exclude cases where an employee's non-work activities are the sole cause of the injury or illness. The exception was included in the proposal, and OSHA received no comments opposing its adoption.
Injuries and illnesses will not be considered work-related if they result solely from voluntary participation in a wellness program or in a medical, fitness, or recreational activity such as blood donation, physical, flu shot, exercise classes, racquetball, or baseball. This exception allows the employer to exclude certain injury or illness cases that are related to personal medical care, physical fitness activities and voluntary blood donations. The key words here are "solely" and "voluntary."
The work environment cannot have contributed to the injury or illness in any way for this exception to apply, and participation in the wellness, fitness or recreational activities must be voluntary and not a condition of employment.
This exception allows the employer to exclude cases that are related to personal matters of exercise, recreation, medical examinations or participation in blood donation programs when they are voluntary and are not being undertaken as a condition of work.
For example, if a clerical worker was injured while performing aerobics in the company gymnasium during his or her lunch hour, the case would not be work-related. On the other hand, if an employee who was assigned to manage the gymnasium was injured while teaching an aerobics class, the injury would be work-related because the employee was working at the time of the injury and the activity was not voluntary.
Similarly, if an employee suffered a severe reaction to a flu shot that was administered as part of a voluntary inoculation program, the case would not be considered work-related; however, if an employee suffered a reaction to medications administered to enable the employee to travel overseas on business, or the employee had an illness reaction to a medication administered to treat a work-related injury, the case would be considered work-related.
Injuries and illnesses will not be considered work-related if they are solely the result of an employee eating, drinking, or preparing food or drink for personal consumption (whether bought on the premises or brought in). OSHA has gotten many letters asking for interpretations on this very topic. So they addressed it in this exception.
An example of the application of this exception would be a case where the employee injured himself or herself by choking on a sandwich brought from home but eaten in the employer's establishment; such a case would not be considered work-related under this exception.
On the other hand, if the employee was injured by a trip or fall hazard present in the employer's lunchroom, the case would be considered work-related.
In addition, a note to the exception makes clear that if an employee becomes ill as a result of ingesting food contaminated by workplace contaminants such as lead, or contracts food poisoning from food items provided by the employer, the case would be considered work-related.
Another wrinkle here worth noting is if an employee contracts food poisoning from a sandwich brought from home or purchased in the company cafeteria and must take time off to recover, the case is not considered work related.
On the other hand, if an employee contracts food poisoning from a meal provided by the employer at a business meeting or company function and takes time off to recover, the case would be considered work related. Food provided or supplied by the employer does not include food purchased by the employee from the company cafeteria, but does include food purchased by the employer from the company cafeteria for business meetings or other company functions.
So the test is whether the employer is providing food for a work-event or not.
Injuries and illnesses will not be considered work-related if they are solely the result of employees doing personal tasks (unrelated to their employment) at the establishment outside of their assigned working hours. This exception, which responds to letters OSHA received over the years, allows employers limited flexibility to exclude from the recordkeeping system situations where the employee is using the employer's establishment for purely personal reasons during his or her off-shift time.
For example, if an employee were using a meeting room at the employer's establishment outside of his or her assigned working hours to hold a meeting for a civic group to which he or she belonged, and slipped and fell in the hallway, the injury would not be considered work-related.
On the other hand, if the employee were at the employer's establishment outside his or her assigned working hours to attend a company business meeting or a company training session, such a slip or fall would be work-related.
Injuries and illnesses will not be considered work-related if they are solely the result of personal grooming, self-medication for a non-work-related condition, or are intentionally self-inflicted. This exception allows the employer to exclude from the Log cases related to personal hygiene, self-administered medications and intentional self-inflicted injuries, such as attempted suicide.
For example, a burn injury from a hair dryer used at work to dry the employee's hair would not be work-related. Similarly, a negative reaction to a medication brought from home to treat a non-work condition would not be considered a work-related illness, even though it first manifested at work.
Injuries will not be considered work-related if they are caused by motor vehicle accidents occurring in company parking lots or on company access roads while employees are commuting to or from work. This exception allows the employer to exclude cases where an employee is injured in a motor vehicle accident while commuting from work to home or from home to work or while on a personal errand.
For example, if an employee was injured in a car accident while arriving at work or while leaving the company's property at the end of the day, or while driving on his or her lunch hour to run an errand, the case would not be considered work-related.
On the other hand, if an employee was injured in a car accident while leaving the property to purchase supplies for the employer, the case would be work-related. This exception represents a change from the position taken under the older record keeping rule, which was that no injury or illness occurring in a company parking lot was considered work-related.
So, OSHA has concluded that some injuries and illnesses that occur in company parking lots are clearly caused by work conditions or activities -- e.g., being struck by a car while painting parking space indicators on the pavement of the lot, slipping on ice permitted to accumulate in the lot by the employer -- and by their nature point to conditions that could be corrected to improve workplace safety and health.
Common colds and flu will not be considered work-related.
OSHA allows the employer to exclude cases of common cold or flu, even if contracted while the employee was at work.
However, in the case of other infectious diseases such as tuberculosis, brucellosis, and hepatitis C, employers must evaluate reports of such illnesses for work relationship, just as they would any other type of injury or illness.
Please listen to the full episode as I explain some more OSHA Q & A's on this topic. Please leave your comments or questions!
|Jan 23, 2018|
029: Safety Meetings that Succeed
Regular meetings can be beneficial to your business (if done right). In this episode I want to talk about meetings. Yes, the dreaded business meeting. But don’t worry, I have some great tips for you to follow so you can make sure your business meetings don’t put folks to sleep, turn employees off to being engaged, or make you look like a knucklehead!
No matter why you are having the meeting, some simple rules apply; the meeting should be specific, you should only invite those absolutely needed, and you must understand what makes a meeting BAD! So you can avoid it.
In his book, Death by Meeting: A Leadership Fable About Solving the Most Painful Problem in Business, Patrick Lencioni talks about four types of meetings:
Here I want to talk about the first 3. Specifically the third one - the monthly strategic meeting. Ask yourself what information is important enough to pull employees together once a week, or once a month and sit down to review? This can be difficult. Fear not! I break it all down in this episode.
Get the book mentioned in this episode by clicking HERE
|Jan 16, 2018|
028: Bloodborne Pathogens Safety Program
Visit www.thesafetypropodcast.com for more great workplace safety information.
Bloodborne pathogens are infectious microorganisms in human blood that can cause disease in humans. OSHA requires employers to protect employees who are occupationally exposed to blood or Other Potentially Infectious Materials (OPIM).
While most would associate exposure to bloodborne pathogens with healthcare workers, there are many other occupations, including first-aid team members, housekeeping personnel in some industries, and various other workers who may be at risk of occupational exposure to bloodborne pathogens
OSHA’s bloodborne pathogen standard applies to all occupational exposures in General Industry. Let's break dow some definitions of terms, training requirements as well as program requirements in this episode.
|Jan 06, 2018|
027: Engaging Workers In Safety
If you want to increase safety engagement between leadership (direct supervisors) and workers try asking what coaching leaders are already getting. Chances are HR is coaching front line supervisors on how to engage workers to increase morale, retention and productivity. Instead of reinventing the wheel, piggyback on what they are already doing.
I have used the Gallup Survey information many times with many clients. It just works! Listen to this episode for details but you can get the one-pager of the 12 questions by clicking HERE. If you are SERIOUS about learning more about this approach, you NEED the book! Click HERE FOR THE BOOK.
And of course, head over to my RESOURCE page for ALL the essential tools you should have! This topic is a good one and I will definitely expand on it in a later episode. Send your thought to email@example.com
Be safe, enjoy the Holidays with your friends and family:)
|Dec 26, 2017|
026: Corrosives Safety
Our exposure to corrosive chemicals in the workplace is more common than folks realize. Just think about the chemicals we use around the home! Safety, on and off the job, is key to managing the hazards associated with these chemicals.
Listen to this episode to find out the most common safety hazards, types of corrosive chemicals and how to better prepare your employees for working with them.
I also cover ANSI requirements for emergency eyewash stations and emergency showers, workplace safety best practices, OSHA requirements and I share some simple workplace safety tips to help you keep workers safe around these workplace chemicals.
Leave your feedback, including topic requests, via email: firstname.lastname@example.org
Don't forget to visit the official floor marking and floor sign company of The SafetyPro Podcast, Mighty Line Floor Tape - go to www.mightylinetape.com/podcast for a free sample today!
|Dec 18, 2017|
025: Multi-Employer and Contractor Safety
More episode info at www.thesafetypropodcast.com
Increasingly, companies are using contract or temporary workers to perform work. This work ranges from maintenance and construction to security and even production-related tasks. It’s easy to pass off responsibility for contractor safety to someone else — particularly the contractor.
Under the OSHA multi-employer worksite policy, citations may be issued to employers using temporary employees.
OSHA’s multi-employer worksite citation policy states that on multi-employer worksites (in all industry sectors), more than one employer may be citable for a hazardous condition that violates an OSHA standard. A two-step process must be followed in determining whether more than one employer is to be cited. Listen to learn all about it and better protect your company and your contractors.
Send emails to email@example.com. Be sure to visit the OFFICIAL floor marking and floor sign company of the Safetypro Podcast, Mighty Line Tape. Go to www.mightylinetape.com/podcast for a free sample of the most durable floor tape on the market.
|Dec 11, 2017|
024: Aerial Lifts, Powered Platforms and Scissor Lifts
In this episode, aerial lifts, powered platforms and scissor lifts - they all have slightly different requirements.
Be sure to share your thoughts by sending a message to firstname.lastname@example.org
Please visit our sponsors www.vppsimplified.com and the official floor marking and floor sign company of the podcast, www.mightylinetape.com/podcast
|Dec 04, 2017|
023: OSHA Outreach Training Issues
Outreach training was never supposed to replace required safety training under specific OSHA regulations. So what about contractors that we hire that simply produce the 10 or 30-hour OSHA Outreach training card? What questions do we ask? How do we verify they have had actual safety training beyond the OSHA Outreach Training Program? Listen as I tackle this topic.
Be sure to drop me your thoughts by sending a message to email@example.com
Please visit our sponsors www.vppsimplified.com and the official floor marking and floor sign company of the podcast, www.mightylinetape.com/podcast
|Nov 23, 2017|
022: Learning From Safety Mistakes of Others
I often have folks share safety news stories or OSHA citations they hear about. Most of the time it's an odd curiosity and serves no other purpose than to shake our heads and say, "idiots!".
What if we take this information and bring into our organizations and try to place ourselves in those situations? I do this all the time. It is a great way to learn from the mistakes of others.
Everything from accidents, injuries and news about OSHA citations for alleged violation of workplace safety standards; I try to use this info to challenge teams to go out in their facilities and find those or similar situations, conditions or practices.
We can use this info to engage operators/workers, look at policies, processes and facilities/equipment. Listen to this episode to learn how you can do this in your company.
Be sure to subscribe and drop an email if you have comments or a request for a topic. firstname.lastname@example.org
Also, Mighty Line Floor Tape is now the official floor tape and floor marking company for the SafetyPro Podcast. All of your industrial floor marking needs are in one place. Visit www.mightylinetape.com/podcast to learn more.
|Nov 17, 2017|
021: Charting Your Safety Culture
Special announcement! Mighty Line Floor Tape is now the official floor tape and floor marking company for the SafetyPro Podcast! All of your industrial floor marking needs in one place. Visit www.mightylinetape.com/podcast to learn more.
Where are you on the culture maturity curve? How do you chart this? Click HERE to download the free graph and listen as I talk about the different levels of safety culture and how you can tell where your company is right now. Click HERE to join the email list!
Send feedback and topic requests to email@example.com
|Nov 10, 2017|
020: Let's Start Talking About Safety Culture
|Nov 02, 2017|
019: Creating 13-Week Roadmap for Safety Projects
Get the 13-Week Roadmap journal I use: http://bit.ly/2sQ7NVm
Staying focused can be hard. Listen as I describe the journal that helps me create a 13-week roadmap for projects, stay focused on what matters and track my progress along the way. The Self Journal can help you as a safety professional, check it out today here http://bit.ly/2sQ7NVm
Dont' forget to HIT THE SUBSCRIBE button to get every episode. Send emails to firstname.lastname@example.org
|Oct 27, 2017|
018: Fishbone Diagram for Safety Incident Reviews
Get your FREE Fishbone Diagram Template HERE
One way to capture different ideas and stimulate the team’s brainstorming on root causes is the cause and effect diagram, commonly called a fishbone. The fishbone will help to visually display the many potential causes for a specific problem or effect.
Listen as I explain how it is used. Download the FREE template to follow along!
Send email comments and topic requests to email@example.com
|Oct 12, 2017|
017: 5-Why Problem Solving Tool for Safety
Visit our show sponsor here: www.vppsimplified.com
**To get the free 5-Why template mentioned in this episode click HERE.
Using 5-why for safety problem-solving will really help those looking for an easy yet effective tool to get to the root causes of issues.
Be sure to subscribe and leave a rank/review so others can find us and so we can improve the podcast. firstname.lastname@example.org
|Oct 07, 2017|
016: Intro to HAZCOM
Visit our sponsor www.vppsimplified.com to simplify your VPP journey!
HAZCOM is still a frequently cited OSHA violation. Listen to this intro to the topic so you can keep your employees safe.
Be sure to SUBSCRIBE via Apple Podcasts and please leave a rank and review so I can improve!
Send your email questions or topic request to email@example.com
|Sep 27, 2017|
015: Chemical Safety Labels
Visit our sponsor www.vppsimplified.com to simplify your VPP journey!
Labels still create problems for many employers. Learn what is needed and listen to some examples of what to do and not do when it comes to labels in the workplace.
Be sure to SUBSCRIBE via Apple Podcasts and please leave a rank and review so I can improve!
Be sure to send email questions or topics for future episodes to firstname.lastname@example.org
|Sep 25, 2017|
014: VPP Element 4 - Safety & Health Training
The fourth element in the OSHA VPP is safety & health training. Let's dive into this one and simplify it. Remember, the VPP Simplified Tool will explain all the elements of the VPP, the sub-elements, and track you progress along the way. Be sure to subscribe to the podcast and visit the website to learn more about the VPP Simplified Tool.
Send email questions to email@example.com. I may answer you question on the podcast!
|Sep 05, 2017|
013: VPP Element 3 - Safety Hazard Prevention & Controls
The third element in the OSHA VPP is hazard prevention & controls. Let's dive into this one and simplify it. Remember, the VPP Simplified Tool will explain all the elements of the VPP, the sub-elements, and track you progress along the way. Be sure to subscribe to the podcast and visit the website to learn more about the VPP Simplified Tool.
Send email questions to firstname.lastname@example.org. I may answer your question on the podcast!
|Aug 31, 2017|
012: VPP Element 2 - Worksite Safety Analysis
The second element in the OSHA VPP is worksite analysis. Let's dive into this one and simplify it. Remember, the VPP Simplified Tool will explain all the elements of the VPP, the sub-elements, and track you progress along the way. Be sure to subscribe to the podcast and visit the website to learn more about safety and the VPP Simplified Tool.
Send email questions to email@example.com. I may answer your question on the podcast!
|Aug 26, 2017|
011: VPP Element 1 - Leadership Commitment & Employee Involvement
ANNOUNCEMENT: We are now offering the #1 safety and health management system review tool used to prepare companies for the partnership with OSHA. Now you can use the same tool I have used for years.
But don't worry, staying true to my values and goals for this podcast, I explain it all in the next 4 episodes covering the VPP elements and sub-elements in detail.
Take notes! A lot of info is packed into the 4-episode series on VPP! email me at firstname.lastname@example.org
|Aug 25, 2017|
010: BONUS - SMART Goals Part 2
I got a lot of responses from the last episode, and noticed an odd trend each time I release a new one as well. I talk about those here in this bonus episode.
Keep the emails coming! And hey, if you enjoy the info in the podcast please be sure to leave a ranking and review on Apple Podcasts or drop me a personal message using the email address above.
|Aug 19, 2017|
010: Workplace Safety & Health Goals and Objectives
How to set S.M.A.R.T. workplace safety and health goals and objectives and avoid vague lofty goals you will never realize!
Subscribe to the podcast and leave a ranking and review so others can find us and to help make this podcast even better :)
|Aug 02, 2017|
009: Safety & Health Management System
Have you ever wondered what should be in your safety program? Where do you begin? In this episode I give you a quick rundown on how to get started and the elements of your written program. Don't forget to subscribe and rank/review the podcast so that I can improve it for you!
Email your safety question or comment to email@example.com
|Aug 01, 2017|
008: OSHA Aisles and Walkways Safety Update
|Jul 24, 2017|
007: OSHA Safety Recordkeeping Listener Questions Pt 2
|Jun 25, 2017|
006: OSHA Safety Recordkeeping Questions from Listeners
In this Q&A episode I tackle some of the most common OSHA recordkeeping questions that past clients have asked me!
Subscribe today and leave me a rank/review to help me improve and help others find this podcast!
|May 28, 2015|
005: Safety Questions from Listeners
Also mentioned in this episode is my 5 tips to navigate the OSHA website without losing your mind! You really want this cheat sheet if you find yourself looking up info on their website. Click HERE to get it now!
Be sure to subscribe and leave a ranking/review to help me improve the podcast and assist others in finding me. Or just drop a note firstname.lastname@example.org
|May 01, 2015|
004: Meaningful Employee Involvement in Safety
In this episode I discuss the importance of meaningful employee involvement in the safety and health management system.
Some barriers to employee involvement in the safety and health management system:
-Disregarding the fact that all injuries and illnesses result from exposure to hazards.
-Perception by employees that management is primarily interested in disciplining “un-safe” acts without adequately addressing hazards and root causes.
-Personnel actions, such as promotions, compensation, demotions, disciplines, and re-assignments that are administered in such a way as to reduce or undermine the commitment to safety.
-Treating worker behavior as though it is a root or underlying cause rather than identifying hazards or system related causes.
-Administering a post-accident program, such as drug testing, in a way that discourages injury reporting
-Not implementing hazard recognition and control measures and/or ignoring the hierarchy of controls.
-Blaming employees with undue emphasis on discipline instead of implementing system changes.
-Uneven accountability – focusing only on the line/hourly worker and not addressing “behavior” of supervisors, senior management and corporate leadership.
-Employee perception that production takes precedent over their personal safety and health.
Be sure to subscribe, rank and review this podcast so I may improve and to aid others in finding me!
|Mar 05, 2015|
003: What Does Leadership Support For Safety Mean?
Have you ever heard the recommendation to conduct periodic reviews of the safety and health management system? Ever wonder what was meant by the term 'system'?
I want to take some time and talk about what is involved in a comprehensive Safety and Health Management System review. You may have heard this phrase and wondered what exactly does it mean? So let's break it down. Basically, the safety and health management system starts (at least initially) with a review of all facilities, machines, chemicals, tasks, etc. to determine hazards.
If you listened to my previous episode, I talked about how to go about conducting such an assessment in preparation for writing a safety manual, which will become a part of this management system. So that assessment kicks off a cycle.
|Feb 04, 2015|
000: Intro to The SafetyPro Podcast
This is the SafetyPro Podcast with Blaine J. Hoffmann, MS OSHM. Think of me as your personal safety professional!
In this quick intro I talk about my professional experience, background and what to expect from this podcast moving forward.
I will cover real-world workplace safety and health management issues and how to implement safety and health program elements in your workplace. I will also tackle training issues, audits, safety trends, interview experts, and more!
I will also provide bonus materials (downloadable tools) for you to use on the job! Things like safety talks, charts, inspections, surveys, and more.
For access to the bonus materials and tools, you will need to download our exclusive SafetyPro Podcast App available for Windows, Windows Phone, iOS, and Android. Again, our exclusive App is the ONLY way you can get access to all the downloads we will provide for each episode.
Otherwise, subscribe to the podcast so you won't miss a single episode. Learn about workplace safety and health management one informative episode at a time! If you like what you hear, please leave us a rating and review to help others find our program!
Learn more about safety services at www.consulthoffmann.com.
|Dec 19, 2014|