I know by the poll results and the emails/texts/calls I have received these past 2-3 weeks that this post will be met with a healthy dose of skepticism, but that has never stopped me from saying what I believe when it comes to the safety and health of those we have the privilege to protect. So, I hope to spark many more discussions with this series of articles titled “Is shorter better?“
I am 100% convinced that the idea of “if we only had shorter written programs that more people would read them” is a pipe dream that has found a strong foothold in our profession. Hell, we visit facilities where safety team members have not read all the written safety programs, so to think that those outside the safety group will sit down and read a program from cover to cover is puzzling to me.
I have always used the same format, whether a PSM/RMP or a traditional OSH written program, for my programs. This allows the reader to find the info they seek much easier – rarely having to read large sections of the program to get their answer(s).
IMPO Written Programs are not intended to be read like books by front-line workers and management. I do expect that ALL safety team members will read the program’s cover-to-cover. Hence, they get a complete understanding of the program and can provide feedback on concerns and opportunities to improve the program. The written programs are intended to be reference documents; I use them to explain WHY we do what we do to be SAFE (not compliant!). I still use the OSHA/ANSI/NFPA standards as my foundation for the material in my programs, but I NEVER regurgitate the language of the standard. Our programs need to EXPLAIN who, when, and how the facility will achieve the standard’s requirements and beyond (remembering the standard is often the minimum framework requirement).
This often means our written program could be 50-70 pages. However, it will cover every aspect and inform the reader how to perform every piece of the program to execute the program requirements.
For example, if your facility performs entries into Permit-Required Confined Spaces, I will bet the written program will say something like…
Before an employee enters the space, the internal atmosphere shall be tested, with a calibrated direct-reading instrument, for oxygen content, for flammable gases and vapors, and for potential toxic air contaminants, in that order.
That is a cut and paste from 1910.146(c)(5)(ii)(C). In this one sentence, there are two (2) safety-critical requirements that many entry supervisors can NOT explain the WHY or HOW.
1) calibrated direct reading instrument (including the meter manufacturer’s requirements for daily bump tests)
2) order of sampling the atmosphere within the space
I am sure everyone is training their entry supervisors and safety team members on the calibration frequency, how to perform the daily bump tests (per the manufacturer’s requirements), and why we first sample the atmosphere for O2. But the program is in place for those occasions where we trained them in January, and now it is August, and they will be doing their first entry. Do we think they may have questions about HOW to perform these tasks?
These days, most businesses that use direct-reading instruments for PRCS entry and HW permitting will have bump test/charging stations. But who maintains these stations and maintains the calibration and bump-test gas cylinder inventory? Does this person understand what happens if they switch from a test gas with methane vs. pentane? It is relatively common for us to find:
- EXPIRED gases are being used in these critical tasks (calibration/bumping)
- meters being used beyond their calibration dates or the facility not meeting the frequency of the manufacturer’s calibration frequency
- meters that are not being bump tested at all or bump tested using the wrong gas or not being bump tested daily
So, over the years, I have learned that “owner manuals” grow legs and walk off the plant site, but my written programs did not. So, I would cut and paste critical info from the owner’s manuals for my meters and include the info in my written programs. These were usually informative appendices to the written program, but I ensured the correct info was available to those who needed it. This was on top of my entry supervisors’ very detailed and hands-on training. We used the appendix in the training while performing the hands-on tasks to familiarize them with the written program. And during audits and OSHA inspections, they always had the written program to aid them in recalling these critical aspects of their job.
Without it, they had to rely 100% on memory recall. Even in my VPP STAR sites, where safety was at a different level than most, our entry supervisors, and even some of the EHS team members, could NOT recall 100% of the critical data WITHOUT the aid of the written program.
Another example we can use regarding atmospheric monitoring for entry into a PRCS would be the “correction-calculation” for the LEL sensor on direct-reading instruments. I can say that 99.99% of the PRCS programs will regurgitate the “10% of the LEL” as their means to define a hazardous atmosphere. Sadly, far too many safety professionals fail to grasp this fully. Nearly 100% of entry supervisors do NOT understand this, and it is because they have never been appropriately trained in the use of and the LIMITATIONS of the make/model of their direct-reading instrument(s).
In our audits, we ALWAYS fair-warn when the interview questions are trick-or-loaded questions. Still, when given the following scenario, almost all entry supervisors, including safety pros, will sign the permit and allow entry to begin.
The written program and permit both correctly state that 10% or greater of the atmosphere’s LEL is a hazardous atmosphere.
You correctly sample (another critical task) the entire space, and the meter reads 7% on the LEL.
Since 7% is less than the 10% limit, would you authorize the permit and allow entry?
When we get the puzzled look, we will add the following:
The vapors in the space that are triggering the LEL of 7% are Toluene vapors from the workers cleaning the inside of the space the day before.
Do you authorize the permit and allow entry?
Even if we TRAIN our folks on this major limitation of all direct-reading meters, but we do NOT change our written program and permit requirements to something less than 3% of the LEL, we are setting up our entry supervisors for a MAJOR failure that could have catastrophic consequences. I prefer to use 2-3% rather than 10% in my program and permit and explain WHY we use this reduced level in the written program/appendices. It is NOT because we want to be that much better than OSHA’s 10%; it is so we can ensure that we actually meet OSHA’s 10% LEL requirement. If this scenario has you puzzled, PLEASE read your owner’s manual(s) of the brands/models of your meters. Or, if you’re a SAFTENG member, you can read my many articles on this safety-critical failure.
These are just two examples of how our written PRCS entry program can grow by many pages, but I dare anyone to argue that this information should not be included in the written program and the training. This movement to shorten our programs and training on these programs, as well as the move away from face-to-face training on these safety-critical training needs, is NOT advancing the safety and health of our workforces. With the movement to CBT, our written programs must become our “safety foundation” to compensate for reduced training content and time. As a safety manager at chemical and semiconductor facilities, our Entry Supervisor training was 8 hours, of which 4 was the same training that entrants and attendants got. The additional 4 hours for those who will be an entry supervisor covered these two topics discussed here, as well as a detailed review of “permitting,” which included a review of isolating the space using the three approved energy isolation methods, ventilating the space, the rescue requirements (entry and non-entry), and means to reclassify a PRCS to a non-PRCS status for entry. Today, many businesses do NOT provide this level of training, and with a 5-page PRCS entry program that is simply a cut and paste of 1910.146, we should not be surprised when things go wrong.