A movement within the safety community, primarily online banter, somehow finds fault with a WRITTEN safety management system (SMS). There are even books published on the topic that are being pushed, decrying written programs as a bureaucratic waste of time, too controlling, no value added, etc. I find this very sad, but they do have a point. Most written safety programs are written as COMPLIANCE (check-the-box because OSHA says I have to have a written program) style programs that do NOT add value to our safety efforts. However, a well-written safety management program that explains the WHYs and HOWs of controlling the recognized hazard the program is written for is foundational to any mature SMS. The problem is not that the program is written; the written programs are most often a simple regurgitation of the OSHA standard, and this does little to nothing for the safety of employees. A few weeks ago, I wrote a post about the difference between a “compliance program” and using the SMS approach for our written programs. For these programs to add value and be a useful resource to the non-safety professionals within the organization, we MUST explain the WHYs and HOWs of controlling the recognized hazard.
When a client reacts to my 70+ page Lockout or Confined Space programs viscerally, I immediately recognize their maturity level in safety. They fear this type of program and decry that no one will ever read a 70-page safety program. My response is how many are reading your 1-2 page programs? It is not the LENGTH of the program that measures its effectiveness; it is the CONTENT of the program. How many LOTO or PRCS programs can even be compliant and be less than ten pages is a mystery to me; however, if we merely cut and paste 1910.146 into a WORD document, we can achieve this. But take 1910.146(c)(1) as an example…
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1910.146(c)(1) The employer shall evaluate the workplace to determine if any spaces are permit-required confined spaces. Note: Proper application of the decision flow chart in appendix A to § 1910.146 would facilitate compliance with this requirement. |
It is one thing to state this requirement, but it takes several pages to explain HOW this workplace evaluation must be done in order for it to be done PROPERLY. And this is STEP 1 in our efforts to CONTROL a recognized hazard – if we mess up this step, the entire program/effort to control PRCS hazards fails at some level. And with this type of hazard, we can not afford to have this type of failure.
So if the facility’s written PRCS simply regurgitates this compliance requirement and does NOT specify
- WHO can do this assessment,
- HOW the assessment is to be carried out, and
- HOW the assessment is documented
we are already taking on more risks than most businesses want.
And yes, OSHA (in its wisdom) has stated that this evaluation need not be documented [for compliance with the standard]. But if we want our written programs to aid in the management of safety, they need to be more than compliance (minimum expectations). Without documenting this assessment and clearly spelling out what the space is a CS and listing the hazards that make the CS a PRCS, we leave open the debate that almost always arises when it comes time to enter the space. This becomes CRITICALLY important when the facility wants to enter the space using the reclassification-entry method (.146(c)(7)). This entry method states when it can be used and that all the physical hazards that made the space a PRCS must be “eliminated” using one of the three accepted isolation methods.
Now how many entry supervisors fully understand WHEN (c)(7) can be used (it has severe limitations in its use) and HOW to properly use it. If the written program EXPLAINS WHEN and HOW we are a step closer to controlling lethal hazards. If the written program simply cuts and paste (c)(7) or 1926.1203(g) then the non-safety professional reading it will be at a loss.
This is evident by the massive misuse of (c)(7) or 1926.1203(g) found during our audits and investigations. Most front-line supervisors, usually the entry supervisors in most workplaces, have no idea when or how to use these entry methods safely. But suppose they had a CS hazard assessment form that clearly stated the hazards that made that CS become a PRCS and that these hazards MUST be ELIMINATED and how this must be done. In that case, we now have a CONTROL SCHEME for that manager/supervisor to follow to ELIMINATE those hazards. But if our written program is simply a check-the-box compliance program written to satisfy OSHA, none of this will be available for our managers/supervisors.
Now imagine having NO written program for the manager(s)/supervisor(s) to refer to/follow. Imagine the level of variability of how something so critical as entry into a PRCS would be managed. So this nonsense that written programs are a bureaucratic waste of time is fool’s talk! Suppose we use the written programs to SUPPORT the SMS and to be a FOUNDATIONAL RESOURCE for non-safety professionals at the facility. In that case, we have a wonderful CONTROL tool for our recognized hazards. Getting the workers who are at risk involved in the writing of these programs will ONLY strengthen the written programs and the likelihood they will be used as such.
