In today’s business climate, most businesses have limited resources to fight a lot of different fires, per se. I often see management teams who have their manufacturing risks defined to how much they spend on post-it pads per month! When asked if they have their hazard risks that fined tuned, I often get the answer “it is what it is”, “we have learned to live with $XXX in worker’s comp cost per year”, etc. This not only is setting the facility up for failures in safety, we are also MISSING A GRAND OPPORTUNITY to determine our Risk Profile. Let me explain what a Risk Profile is in terms that most of us can follow (maybe not agree, but follow).
Recently I have participated in a group discussion on LinkedIn regarding a private school needing a HAZCOM program if an employee brought Clorox Bleach to campus for the sole purpose of sanitizing multi use dishes. I of course tell the poster, it depends on HOW MUCH and HOW IS IT USED. OSHA has exempted products like “Clorox Bleach” when it is used in quantities, frequencies, and purposes like what you and I would use it at home. At my last check and after 39 comments, I was the only one who took this position, and I actually received some less than favorable e-mails from colleagues for providing that line of advice. I have been told “as a safety professional we need to do what is right when someone from outside our profession ask for advice and not do something solely because OSHA does not require it.” In my defense, the person did ask…is a HAZCOM program required? Of course the school would be better off if they had a HAZCOM program! The question we safety professionals often forget to ask ourselves is where in the scheme of things does HAZCOM fall when we look at a schools Risk Profile? I answered the post strictly from an OSHA compliance standpoint and was called out (privately) that I should not have answered her that way. My response to these fellow safety professionals is the following:
She should be commended for bringing this to her leadership’s attention and I applaud her for taking the bull by the horns and getting a HAZCOM program in place. BUT, and it is a BIG but (I see you smiling and don’t even go there), in the scheme of things, where does exposure to Clorox Bleach rank in the risks of the workforce at this school? I had the pleasure of doing a series of safety and health audits for a school district about three years ago and I was BLOWN AWAY at the lack of controls for some LIFE THREATENING RISKS. I for one had no idea about schools and their “working environments”, but came back home and offered a FREE safety audit to the school that my kids attend! Take a few minutes one day and ask to see the custodian’s closet, storage area, boiler room, HVAC room, etc. Ask to see the training records for the maintenance/custodian(s) who work at the school. Four schools, ten maintenance/custodian workers and NOT one training course on Electrical Safety, LOTO, Fall Protection, Chemical Safety, PPE, etc. We found these workers were doing LIVE ELECTRICAL WORK and some could not even explain the fundamentals of electricity. They had no voltage meters, no PPE, no electrical safe work procedures, etc. and they did electrical work on a weekly basis, if not on a daily basis in the oldest school in the district. All of them accessed the roof on a regular basis to work on HVAC units and with ZERO fall protection. Chemical safety was totally out of control, as we found gas cylinders for the school cookout grills stored in the boiler rooms, office supply cabinets used as flammable and acid cabinets, also in the boiler rooms. Nothing ever got locked out, as workers had no idea the lockout concept existed. And we are going to spend our time/resources getting MSDS’s for squirt bottles of clorox bleach? We could debate the deficiency of the OSH Act all day long and agree that OSHA should cover all sectors of employees, but again, I was blasted for providing advice based on OSHA regulations, so lets just focus on “risks” and not whether OSHA regulates the risk or not.
This is ALL ABOUT a Risk Profile? Management teams MUST understand what their Risk Profile is BEFORE a plan can be developed and implemented to lessen the risks for the facility. I would even make the argument that management needs to understand the businesses Risk Profile even before they hire a safety professional! If your business does not want to hire someone like me to develop your profile, a great resource is your property insurance company. I can guarantee they have a Risk Profile for your business. It may not be very detailed, but in their insuring your business, they will develop a risk profile in order to determine your premiums. They will not get down to a level of personal tasks and the risk these tasks pose to workers, but they will do a good job of looking at the higher level type business risks.
Let’s look at how risk is defined. Risk is defined in the following manner:
Risk = Frequency (or probability) X Severity.
In other words we can place “risks” into four categories:
- High Frequency and High Severity
- High Frequency and Low Severity
- Low Frequency and High Severity
- Low Frequency and Low Severity
Sounds simple right…long ways from simple, as this equation holds true in every situation, but the decision making process as to how we define “high” and “low” “frequency” and “severity” is what causes issues. For example, if I asked 100 safety professionals to “Risk Rank” the four categories stated above, how many of you would say that the 3rd listed level is more “risky” than the second? How do you equate a fatality, even though it occurred in a task done every ten years? Do you personally put more weight on the frequency or on the severity?
I need to digress here and share a learning that has stuck with me since 1997. I learned a very neat thing when becoming a Six Sigma Green Belt and that was an exercise called “Gauge R&R”. This is a method of validating your data from a measurement system to ensure your data is accurate. The plant I was working at had a Behavior-Based Safety Observation Process in place and it had been in place for about a year, when we decided to test our data. Like most BBS processes, we reported Safe v.s. Unsafe observations and like most facilities we had a high percentage of safe and low percentage of unsafe observations. Yet the safety team was seeing something entirely different in our official and “unofficial” observations around the plant. So we had an EHS Six Sigma Black Belt help us determine if our data accurately reflected reality. Keep in mind, most management teams would frown on doing this Gauge R&R as they like the “97% Safe – 3% Unsafe” data, as it paints a very favorable picture of the facility for outsiders. I was lucky, the vast majority of my management team at this facility, was in favor of it as they too felt they were personally seeing too many unsafe acts for the official numbers to be accurate. To do this test we staged some “common” unsafe acts and conditions and video taped the acts and took pictures of the conditions. We then brought in the site safety council and for an hour showed them the video footage and photos and had them complete an observation card for each staged scenario. All trained observers (in fact some were observation trainers themselves), same observation cards, same scenarios! You would think the cards would be nearly identical… the results were, well lets just say, they were UGULY! But they did validate the safety teams concerns!!!! If the safety council, an all voluntary group of people excited about safety, trained in the same manner, and shown the same acts/conditions could have such varying definitions of what safe and unsafe are, how would we ever get 700 workers to agree? Often times, the SAFTENG team will debate “risk levels” within audit results and often times it can get heated as we are all passionate about accidents we have experienced in our careers that have shaped us as safety professionals. Even safety professionals can gravitate to lesser risks based on their personal experiences, leaving higher risks activities unattended usually through their own personal ignorance of the subject matter. What I am trying to say is that safety professionals are NOT experts in every single risk/hazard that can be present in a workplace. I for one do NOT do risk profiles for construction companies, as I am not well versed in the type of hazards present on a construction site, much less the methods to control these construction hazards. On the other hand, having a 20+ year construction safety professional do a risk profile on a chemical plant may not be the best choice either. More on this later and how a Risk Profile plays into this scenario.
So defining high and low frequency and severity is a bit tricky, but none the less, it can be done qualitatively much easier than doing a quantitative analysis. By this I mean that we can get agreement on the vast majority of tasks as to whether they are done daily, weekly, monthly, quarterly, annually, and so on. We can get agreement on the severity of an injury in doing these task as to whether the injury would be a first-aid case, a recordable, a restricted duty, a lost time, or a fatality.
So how do we generate our Risk Profile? The way we, Safety Engineering Network, do it is to get the most experienced workers in each exposure group (e.g. operators, maintenance, engineers, contractors, etc.) so that we can generate a list of “Activities” that these exposure groups do at the facility. Activities would be things like “Electrical Work”, “Hotwork (e.g. welding/cutting)”, “Confined Space Entry”, “Chemical Handling”, etc. (note handling bleach is MUCH different than handling elemental chlorine and thus a business may need to break down chemical handling by class of chemicals or maybe even each individual chemical) Once we have our activities identified for our exposure groups, keeping in mind there will most often be hundreds, not dozens, of activities for each group, we then begin the task of assigning a frequency to them. Once a frequency has been applied, we then assign a severity potential to each one. I like to work “vertically” when doing this. In other words, I have found it to be more accurate when we go through all the activities per group and assign ONLY the frequency to each one. Then we go back to the start of the list and assign a severity to each one. By keeping the frequency and severity exercises separate, we often get an “awareness boost” from the exercise when we finally bring together the frequency and the severity. By this, I mean workers tend to get their eyes opened as to what tasks are HIGH risk, based on their own analysis. Complacency can be blinding and just because we have done a tasks day in and day out without a negative consequence, does NOT make the task “safe”!!! Workers participating in the exercise begin to see “their risks” becoming personalized and in many cases they become better stewards of safety with their co-workers. Now that we have a frequency and severity for each activity within each exposure group, we can begin to see our Risk Profile. You are going to want to risk rank each activity within each exposure group so that we can clearly connect which exposure groups are at the highest risks and what activities put them at this level of risk. But this is where most businesses make their biggest mistake… they think they are done! At this point we have ONLY looked at risks associated with worker activity. How about “manufacturing process” risks? This is the argument on personal safety v.s. process safety. If all we look at is worker activities, we will loose sight of the biggest risk on site and that can be the risks posed by the manufacturing process(es). Remember the Baker Report on the BP Texas City explosion? There was concern that BP had placed so much emphasis on “personal safety” that “process safety” did not receive the same level of attention and this played a contributing factor in the accident. We need to rank our manufacturing processes by risks as well. Once we have BOTH the process(es) and tasks based risk ranked, we can then begin to analyze our Risk Profile. We can now examine these risks much more closely and determine if we have ample safeguards in place to reduce the risks to an acceptable level for the business.
We have completed many Risk Profiles for clients who were shocked at their results. Lately, the biggest shock has been combustible dusts issues (a “manufacturing process” risk). One specific facility in the food industry had seen news accounts of plants blowing up, many saw them in my weekly Incident Alerts, but never once thought it could happen to them. Therefore, without knowledge of this risk or it’s magnitude, they were not addressing these significant risks. And when the risk magnitude is such that it could permanently close the business, on top of fatalities and Lost-Time injuries (and burns are VERY EXPENSIVE worker-comp injuries) management then begins to understand their Risk Profile!
So…does your facility have a Risk Profile? Think about the young lady who so bravely went to management and said “we need a hazcom program”. Was she wrong? Absolutely not, but in the scheme of things, where does this hazcom program lie within the Risk Profile for her school? Assuming the school is similar to the ones we have worked for, I can tell you it is LOW, way down on the lists of risky tasks. And lastly don’t be fooled by the term “manufacturing process”. A “manufacturing process” can be making “wooden widgets” and I can assure you there are process hazards and risks. Your process does not have to be covered by OSHA’s Process Safety Management standard to be a “risk”. If your process uses steam in any capacity you will have a boiler and a boiler MUST BE considered a HIGH risk process. How about electricity? Natural gas feeds? Compressed Air systems? These “processes” usually run 24/7 (e.g. high frequency) and if there is an accident involving them, the severity of injuries would be considered HIGH; thus these are usually considered HIGH RISK processes. Without a Risk Profile management just does not understand where they need to apply their limited resources and even yet, what type of resources are needed for their type and magnitude of risk. The client mentioned above realized they needed a more qualified safety professional in house to deal with the combustible dust risks, electrical workers risks, their chemical process safety risks regarding flammable liquids. So they hired a safety professional with a long list of certifications and credentials, but they knew absolutely nothing about combustible dusts, electrical safe work practices, and process safety management or non-conductive flammable liquids – three of the facility’s biggest risks. You would have thought the management team would have taken the top 5 risks in their profile and had the job candidates explain how they would go about bringing these risk under control. Just another way for a business to use their Risk Profile. So, as a safety professional, do we know our top 10 risks? Do we spend adequate time and resources on these risks? If we struggle answering these questions, maybe we should consider developing a risk profile for our facility.
Bryan
