This week during my ASSE PSM Training course I had conversations at lunch and after the course around the use of the “fitness bands” that seem to be so popular in “wellness programs” that so many companies are doing. These wellness plans have a lot of financial incentives to encourage employees to participate. Both of these organizations had such programs and the “plant nurse” took issue when the “safety department” banned these devices from being used in the Hazardous Locations (HAZLOCs) within the PSM Battery Limits. So the question posed to me by both groups was…”Can you tell me a standard I can point to that makes these unsafe for our HAZLOCs?” My answer took them by surprise…
First, I said NO WAY – draw the line in the sand and do not allow them. This is NOT my “Haywood Rule”, rather this is basic OSHA HAZLOC compliance! I will not wear mine when I am working in any type of HAZLOC because simply put… it is NOT rated for those areas.
But this scenario is one that safety professionals need to understand a basic requirement… There are situations where it is not our job to disapprove the actions – it is the job of the person wanting to take the action to demonstrate it is safe to do so! Follow me on this, in this scenario the rule/law/standard is pretty darn clear:
1910.307(c)(3) Safe for the hazardous (classified) location. Equipment that is safe for the location shall be of a type and design that the employer demonstrates will provide protection from the hazards arising from the combustibility and flammability of vapors, liquids, gasses, dust, or fibers involved.
This “demonstration” is via an OSHA accredited third-party certifier (NRTL) for the specific hazardous (classified) location – NOT by a member of management, the plant nurse or a safety professional! So it is NOT our responsibility to establish what can or can not be used in an HAZLOC, it is UL’s or FM’s job (which by the way are the two most recognized Nationally Recognized Testing Laboratory for equipment to be used in an HAZLOC). We just educate and help manage the requirement that ALL devices used in our HAZLOCs are safe for those specific areas.
In other words, I have yet to find a “fitness band” that is rated for an HAZLOC. So our response to management and the plant nurse should be… “Show me where this fitness band is approved for use in our HAZLOC”. If they can not demonstrate, via an OSHA accredited third-party certifier (NRTL) for the specific hazardous (classified) location then the bands must be banned (pun intended) from use in these locations.
I was asked, “what is the real risk of these devices being used in these areas?”
That would depend on the Class, Division, and Group in which we wanted to assess. Then we would need data from the manufacturer telling us what the level of energy available within their device(s). Then, maybe, we could quantify the actual risk. But remember, OSHA 1910.307 is a BASELINE we must all follow, so unless the manufacturer wants to get their device(s) certified for HAZLOC(s) then our risk assessment MEANS NOTHING, as we would still NOT be permitted to use these devices inside our HAZLOC.
And this folk is why being a safety leader is not a popularity contest. Yes – this elimination of these bands may very well impact some employees participation in the fitness program and this may even impact them financially and yes, the health and well-being of the employees are important – BUT not at the risk of a flash fire or explosion. This discussion should also INCLUDE ALL personal devices used in our HAZLOCs. One of the Engineering Managers I worked with many years ago was “old old school” and he was so strict, employees were not allowed to have their “key fobs” in their pockets while working and folks this was back when the “fobs” were the latest and greatest thing for your new car! He also did NOT allow battery-operated wall clocks in our HAZLOCs because some of our HAZLOC areas were Group B (Hydrogen) areas and he just drew the line in the sand and said “no battery clocks in any HAZLOC”. He knew from his experience that if he allowed one HAZLOC to use these clocks, someone would think that the clocks were OK for any HAZLOC and we would eventually find these clocks in HAZLOCs we did not want them. He had the war stories to back it up and no one argued with him. As soon as we just crack open the door and allow certain non-rated devices to be used, which do NOT have the 3rd party accreditation, we will find all sorts of equipment being used in our HAZLOCs. This is one area where we need to be strict – not because a “fitness band” can be an ignition source, but because the fitness band will lead to i-pods, personal stereo’s, cell phones, computers, printers, desk lights, etc. finding their way into our HAZLOCs. I will leave it up to everyone to draw their own line in the sand on what devices are allowed and which ones are not, but just remember – any device allowed should be labeled/APPROVED for the HAZLOC.