In this line of work, it will not take long to hear the phrase “Is it really worth it?” We hear it when developing our Corrective Action Plans after an Audit, a PHA, or an Incident Investigation. Everyone agrees that “we need to do something”; it’s the level of that something that splits the road to success! I have used the scenario many times to demonstrate the Hierarchy of Controls and how sometimes management sees dollar signs over real safety…
We get the call to come help “evaluate” options for an exposure complaint that got called into OSHA after months of complaints from workers. All the complaints were chalked up to the workers being a “weak generation of workers”. “I worked in that room for 20 years (cough cough) and look at me, I’m as healthy as a horse.” Sound familiar? We sample half the workers only to find out that most of their samples are over PEL – meaning there is a legitimate exposure issue that needs to be resolved.
We walk management through the Hierarchy of Controls, leading to a discussion of ventilation vs. PPE. A month later, we returned to discuss the OSHA visit, and OSHA was really pushing the ventilation (as we were too). But the engineering manager got some bids to ventilate the room and about had a cow on the price tag, as well as all the maintenance and upkeep on the system. He also googled respirators (a dangerous thing to do!) and found out that he could equip each worker with their own 1/2-mask APR, burn through hundreds of cartridges a year, and still not spend the $ the ventilation system would cost to install. Of course, we had to shed some light on this thought process and explain the requirements of an RP program. But even with all the medical evals, fit testing annually, training annually, and the change-out schedule for the cartridges, the RP was a fraction of the price over a 10-year period as compared to the engineering control – ventilation.
So how does this come back to “feasibility”? Using OSHA’s own language, we provided the following in our push to engineer out these exposures, rather than rely on PPE (bottom of the hierarchy of controls)
The latest version of the Field Operations Manual (2020), CPL 02-00-164, provides the following definitions:
Feasibility: Abatement measures required to correct a citation item are feasible when they are capable of being done.
Technical Feasibility: The existence of technical know-how about materials and methods available or adaptable to specific circumstances, which can be applied to a cited violation with a reasonable possibility that employee exposure to occupational hazards will be reduced.
Economic Feasibility: This means that the employer is financially able to undertake the measures necessary to abate the citations received.
NOTE: If an employer’s level of compliance lags significantly behind that of its industry, an employer’s claim of economic infeasibility will not be accepted.
This is a billion-dollar global business, so the PPE debate fails on BOTH Technical Feasibility and Economic Feasibility. Begrungingly, the business (with the help of the Corporate Safety Team) decided that ventilation was the right thing to do.
Source: https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21