Call me a simple man educated in Western TN and KY, but to me, safety is VERY SIMPLE and I like to keep it that way. I have been around for 25 years in the Emergency Response field and safety profession and I have had the opportunity to work for some truly world-class companies and even more extraordinary plant managers. The one thing that all three (3) of my world class plant managers had in common in safety was “KISS” – Keep it simple Stupid. Not one of these plant managers lived by “compliance or die” theory; meaning they saw OSHA standards as the “Lowest Safety Denominator” and not our ultimate safety goal. We did safety because they wanted no injuries to the workers they felt responsible for and I was their tool to aid them in achieving that goal. Granted, I worked for these three men for the vast majority of my career in the petrochemical industry so it was almost a Utopian environment for me to grow up in, but I see safety professionals today making some of the most basic errors in how they manage their programs. Here is how we kept it simple…
1) OSHA Compliance is the FIRST STEP to safety. OSHA is not our problem – in fact OSHA is a blessing when we are instituting a safety program/process. I am a fan of OSHA standards, not all are what I wish they could be, but they provide us MUCH NEEDED STRUCTURE in framing up our overall safety process/program. Unfortunately too many businesses, who usually speak bad of OSHA, have grown to see OSHA as “safety”. Achieving the “Lowest Safety Denominator” is NOT “safe” by any stretch. Ask any CSHO or A.D. if they believe 100% compliance with all OSHA standards will result in an injury free workplace; I will bet you that 100% will tell you “hell no”. First, if there is an OSHA standard that covers an activity at a facility, that standard was written to be the “Lowest Safety Denominator”; but most importantly, OSHA standards most likely ONLY COVER a small portion of all our workplace risks and hazards! We can not expect OSHA to spoon feed us a standard for every lithe hazard/risks that is present in our working environment! That is why we now have college safety degrees, advanced safety training, etc. in order to have personnel who can IDENTIFY the hazards/risks AND develop an EXPOSURE CONTROL PLAN to manage these hazards/risks. Hell we can not even count on OSHA in having the ability to update the standards they have now, so asking for new ones is just crazy! But we should view those OSHA standards that are applicable to our business as the BUILDING BLOCKS of our safety process/program and we should strive for 100% compliance in these standards BEFORE we move on to more fancy and costly safety activities.
2) There is NO SILVER BULLET in safety. We see way too many behavior based safety programs in place that are generating horrible data that is lulling management to merely fall asleep at the wheel and dream about safety! I am a huge proponent of behavior based safety processes (BBSP) BUT ONLY when a facility is ready for such a massive undertaking. There is SO MUCH work to be done before we spend the time, energy and MONEY on a BBSP; however, more often than not we find these programs at facilities that struggle to meet the “Lowest Safety Denominator” in the most basic of safety programs. And do you know the excuse we get from the safety professionals as to why the “Lowest Safety Denominators” are failing… “I just don’t have the time to do XXX”. Now let me be frank here and this may be painful to a lot of you reading this, but doing an observation on a worker who is wearing a respirator, yet that worker was never medically clear, has not been fit tested in four years, is not clean shaven, and has missed their annual training for the past four years – yet the observer states on their observation card the employee was 100% safe merely because the job called for a respirator and the worker had one on is just CRAZY!!!! We need to have systems in place that will ensure we are meeting the “Lowest Safety Denominator” of our respiratory protection program BEFORE we begin to lay claim that merely wearing any type of respirator when a procedure calls for it is a SAFE BEHAVIOR! Again we are merely lulling management AND OURSELVES to merely fall asleep at the wheel and dream about safety when we actually believe our BBSP data without any type of validation of our “Lowest Safety Denominators”! Bottom line, we are NOT ready for a BBSP until we have reached the “Lowest Safety Denominator” – OSHA Compliance!
3) If you are looking for your next STEP after achieving the “the “Lowest Safety Denominator”, look no further as it is in the OSHA standards. How do we validate our efforts to have reached the the “Lowest Safety Denominator”? Well I like to call it the Six Sigma Safety Process and the methodology I subscribe is the Design, Measure, Analyze, Improve, and Control (DMAIC). This methodology fits nearly perfect into a safety process at a high risk facility where EVERY aspect of compliance plays a major role in achieving our the “Lowest Safety Denominator”. Lets look at the respiratory protection program again for a working example. There are several CRITICAL PATHS in this program that can be EASILY measured and those measurements fed back to management for ACCOUNTABILITY. They are:
- Medical Clearance
- Annual Training
- Annual Fit Testing
- Inspections
All of these activities are AGAIN part of achieving the the “Lowest Safety Denominator” (e.g. OSHA compliance), but merely achieving 100% with these four measurable will NOT ensure we have ZERO exposure events; however, coupling 100% compliance with these four measurables AND then layering on a BBSP observation process to vaildate the behavors match our requirements will get us closer to our goal of ZERO exposure events. These measurables are VERY EASY to set up, track and report. We MUST know who is in the respirator program (e.g. total number of participants). This then gives us our goals for medical clearance, training, and fit testing. I really think these measurements should be done by “department” or “area” so that key management personnel can look at the data and see the failings and SUCCESSES of our safety process. I use nothing but an excel spreadsheet that a friend at GE showed me how to set up (MANY THANKS Keith!) to track and report progress. Here is how it worked:
- Each participant in the respirator program was listed by their department (NOTE: there may be people on site who in the course of their normal duties are not in the program, but do fall into the program because of their participation on the emergency response team(s). I prefer to have these folks reside in their normal work groups, but I have created an ERT work group because the failings were so vast in the departments that I wanted to be 100% certain that if I were making the call to send that responder into an IDLH atmosphere I had NO DOUBT they were ready with regards to their respiratory protection).
- Each member was assigned a medical clearance “due by date”. Now here is where it gets tricky… the “Lowest Safety Denominator” does NOT require an Annual Medical Evaluation, but I have never worked for a company that did not require one. I will remind you that if you have an ERT that those members MUST receive an annual physical that is MORE than a respirator physical so these folks WILL HAVE to get an annual physical. (SAFTENG Members can CLICK HERE to read by ERT Physicals article). So back to the medical clearance due date measurement… it is quite simple – the employees complete their medical eval by their due date the achieved their “Lowest Safety Denominator” on that measurement. We do this for ALL those in each Department/Area and our goal is 100%; when the data is reported to management and we fell short on achieving just this simple “Lowest Safety Denominator” one has to wonder “what else are we failing at”.
- Annual training is an ABSOLUTE MUST. Never fool yourself that just because a worker wears a respirator on a daily basis that he/she somehow does not need the annual training. If nothing else, the annual training is to get them back on track and away from some bad habits that may have formed over the past 12 months. Now if I have a true “process” in place and I have audit data that includes field observations that workers are doing all their training requires of them, then maybe I may shorten the training a tad bit; but in all my years of being a respiratory protection program administrator I never once found my workers at 100%. Just watch their donning practices and you most likely will see the absence of “field fit checks” (of course we STOP them and correct this BEFORE they enter the hazard zone) but when your audit data tells you that workers are not doing this CRITICAL ACTIVITY then we need to RETRAIN them so that it becomes as simple as BREATHING! Remember what Dr. Geller says about “Training” and “Education”… Training is DOING the task and Education is hearing about or watching the task. There is a big difference between Sex Education and Sex Training! So what I am trying to say is that Respiratory Protection TRAINING should NOT be done via “computer based” or watching a video. It needs to be provided by a highly competent person with hands on demonstrations. Remember, a respiratory is our last line of defense in an IDLH atmosphere – so there is NO ROOM for error! Track who made the training and report the data for those who did not make the training. I prefer to call out those who fail to meet the “Lowest Safety Denominator” by name and title; just like I like to call out those who MEET and EXCEED the “Lowest Safety Denominator” by name and title!
- Annual Fit Testing. Again there is some wiggle room in how we define the “Lowest Safety Denominator”. OSHA gives us two options for this tasks: Qualitative and Quantitative, so we can achieve the “Lowest Safety Denominator” by using either method; however this is an area that I learned a long time ago can be played with! So I have not done qualitative fit testing since 1999 and we do not offer this type testing as a service at SAFTENG. We ONLY offer QUANTITATIVE fit testing (lessens my liability as the tester and improves your reliability in the tests). But as for measuring this, it is quite simple – assign dates (and times) for participants to sign up for so they can achieve their “Lowest Safety Denominator”. We can actually see AHEAD of time who has not signed up and apply pressure to them and their manager/supervisor before the dates in order to ensure they are at least signed up. We track who made it and who did not.
- Inspections. I break this down into two types of “inspections”: 1) personal respirators and 2) Emergency Respirators. My focus early on in the program is on my emergency respirators. These include escape packs used in the units, SCBA’s used by responders on both the mobile equipment and fixed locations throughout the facility. But again, I know how many emergency respirators there are and that they must be inspected MONTHLY during those months we did not use them in an emergency (NOTE in the event of their use during an emergency they are inspected before DONNING and again when they are RETURNED to their storage location). I do take on the responsibility for managing the emergency respirators on site, but utilize ERT personnel from the site to actually conduct these inspections. So I am at the mercy of the unit managers to allow the time for their personnel to conduct these inspections; keeps the safety leader from becoming too much of an _ss!
So there you have a snap shot of what achieving the “Lowest Safety Denominator” begins to look like in regards to JUST ONE of the applicable OSHA standards. I can do this for dozens more standards and if I can not have a measurable process on the actual standard then I implement a “audit process” on those standards. For example, 1910.23 is not a standard that lends itself to a management system; however, it is one that can be EASILY audited. Falls are a SERIOUS risk to all personnel and having FIXED FALL PROTECTION that is DESIGNED, INSTALLED and MAINTAINED properly on workplatforms over 4′ is critical. 1910.23(c), (d), and (e) are very DESCRIPTIVE, such that I can take these descriptive requirements and put them in a checklist. I can then train a group of personnel on these requirements and how to do their audits and then set an audit schedule and measure their progress by department.
Once we have this measurement process in place and OUR DATA has been VALIDATED showing us we have achieved the “Lowest Safety Denominator”, we are now ready to move on to our next phase AND IT DOES NOT involve BBSP yet either! It is what I like to call my Improve and (Quality) Control phase of DMAIC.
So the next time a safety professional is struggling with the “Lowest Safety Denominator” and yet he/she is burdened with questionable observation data, and those “flavor of the month” programs, make a suggestion that they take a step back and lay the foundation of which we can build upon… OSHA Compliance!
More to come soon… And by the way, these three (3) plant managers have about 5-6 VPP Stars to their name, OSHA rates below 1.0, and even those facilitiies that did not go for the STAR – I would put them up against any VPP Star site in the USA. So keeping it simple and using OSHA compliance as our foundation WORKS and it keeps it SIMPLE.