No safety program is perfect for one simple reason: people aren’t perfect. No matter how many policies you put in place, no matter how much equipment you buy, no matter how much training you do, in the end you are depending on human beings to implement your safety program and human beings make mistakes. Forget those that intentionally bypass the program, all it takes is for somebody’s timing to be off, their depth perception to be less accurate than they thought, their judgement of good and bad ideas to be less than ideal, and you have a failure. And what of the physical failings of human beings? Some aren’t as strong as they think. Others, stronger. Some could experience a medical condition they didn’t know they had, that came on suddenly, or that was exacerbated by the work environment. These could also lead to program failures.
How should a company deal with the human factor? The answer might be by human-proofing as much as possible. You will never be able to do it 100%, but you can minimize your exposure to human failure in a number of ways. Here are just a few examples:
Self-Closing Gates vs Chains
The less a person has to do to return an environment to a safe state, the better. If you place a chain at the top of a ladderway or at the edge of a platform, it is possible that more often than not – whether out of laziness or forgetfulness, that chain will not be re-hooked. Sure, you can put policies into place and issue disciplinary action to your workers. You can post signs and hold training early and often. But, in the end, you are creating a lot of unnecessary work for yourself. If you had a safety gate that automatically closed behind the worker, your energy could be better expended elsewhere, in places where there might not be as easy a solution. Of course, a person could still find ways to bypass this automatic feature, by wedging the gate open for instance, but they would have to go out of their way to do that and if they couldn’t be bothered to hook a chain, odds are they’re not going to be bothered to find ways to bypass a gate. But, let’s say they do bypass it. Where they might be able to argue that hooking the chain was just something they forgot to do, bypassing of the safety gate would be a clearly intentional act, making disciplinary action a much more clear-cut matter.
Guardrails vs Lifelines
Lifelines are fantastic. They certainly help provide fall protection in many situations where it would be difficult to find any other way. Still, they lend themselves to human failure. In order to use a lifeline, the worker must be properly trained in fall protection, understand it, and use it perfectly. And that’s not even counting the human errors that could have been made during design and installation of the system. Railings, on the other hand, eliminate much of that human error. Besides the fact that they actually prevent falls rather than arrest a fall that has already occurred (making them the clear winner, where possible, regardless), pretty much everybody knows how to use a railing. Don’t walk into the rail. Don’t run into the rail. Don’t jump the rail. Don’t climb the rail. Pretty simple. With the lifeline, again – assuming it’s designed and installed properly, you have to worry about whether or not the user is wearing their harness properly. Did he clip his snaphook where he was supposed to? Did he clip his snaphook at all? Are they overloading the line? Are they taking chances they shouldn’t be taking? Are they doing any work that can be affecting the integrity of the line? Railings eliminate much of that headache.
If areas are dangerous, don’t trust your employees will understand that. Even if they understand it, don’t trust they’ll always use their best judgement. Physically restrict access to dangerous work areas where possible by locking doors and gates. Place signs. Where necessary, place a watch outside the dangerous area to ensure nobody will enter, just as you would a confined space. Why wouldn’t you use the same thought process if you’re working in an electrical room with live equipment, for example, just because the regulations don’t necessarily require you to do so? Don’t just throw up a piece of caution tape. It often gets seen as just something to move out of the way before passing through. Use red danger tape for more impact, but also, use lots of it (whether ultimately deciding on Caution or Danger). When you force people to have to think about what they’re doing and go out of their way to bypass the precautions put in place, they will think twice about it.
Lock-Out is specifically designed to take human mistakes out of the equation when it comes to people being hurt in the workplace. In fact, its very definition says so when it states that Lock-Out / Tag-Out is intended to protect workers who could be harmed by the unexpected energization or startup of machines or equipment. Why would it be unexpected? Because somebody did something they weren’t supposed to do, most likely. That could be somebody physically starting the equipment or it could be the person working on the equipment forgetting to notify people, or expecting they could accomplish something before the power came on, etc. By having a Lock-Out / Tag-Out program, assuming it is properly followed, you make it nearly impossible for an employee to be injured by unexpected startup. Sure, somebody could go grab a pair of bolt-cutters and go cut off a lock, but you’d hope that the rest of your staff would be well enough trained to understand that this is NOT something you do and that there are very severe repercussions for bypassing somebody else’s lock.
Also, notice that I said that Lock-Out is specifically designed to eliminate human error as much as possible. Tag-Out is, as well, when used in an actual Lock-Out / Tag-Out situation, but in the few instances where it is used as the only protection (for example, in a nuclear plant, there are often procedures that no equipment may be physically locked at any time), there is still a great deal of room for human error.
Until we reach that dystopian future where our world is run by robots and humans just sit around getting fat, we have to recognize that we need humans to run our businesses. And, as wonderful a resource as those people are, the possibility for human error comes with them. There is no way to completely human-proof your programs, because somebody who wants to violate it will always find a way, but you need to do everything you can to reduce the potential for human error or to reduce the severity of the impact a human error might have on your employees and production.
Roof washing is probably never on anybody’s top-5 list of ways to spend an afternoon, but it certainly can become a necessary evil. If it were just a matter of aesthetics, you could almost write it off as vanity and leave your roof to become whatever filthy mess it was destined to become, but that’s not the case. Historically, there are a number of reasons somebody might want to clean their roof. For example, preventing the buildup of food sources for birds and rodents or preventing chemical buildup that can damage the roof membrane. However, it’s become even more important in recent years with the emergence of energy-efficient buildings and construction. Build-up of dirt, soot, algae, or other residue can alter the amount of light and heat your roof absorbs or reflects. Washing it is necessary to keep it as efficient as when it was installed. However, there are some things you need to consider:
You may have local, state, or national regulations that govern the types of soaps you can use to clean the roof and what to do with the dirty water. Unfortunately, it’s not as simple as lathering it up and letting it run down a drain. Know what’s required in your area before beginning. You’ll also want to protect plants, shrubs, and other parts of your building that could be damaged by the run-off, especially if chemicals are being used.
Most likely your warranty will not cover the roof if you’re washing it for aesthetic purposes, but it could if washing it is necessary to keep it as energy efficient as designed. Know what will and what won’t negate your warranty before starting or hiring a contractor. If this is the case, the manufacturer/installer of your roof may have recommendations or requirements for you to follow which will dictate what type of brushes to use, what pressure a pressure washer can be used at and more. Any damage you cause is going to be on you, so be familiar with this. As another option, your installer can help you write your cleaning plan or may actually offer cleaning services. Weigh your options and the possible outcomes.
This is important because people not used to working on roofs may not take the precautions necessary. Fall protection is going to be a major concern. If you can do the job from a ladder and maintain three points of contact, you may not need fall protection, but I find it difficult to believe you’ll be able to apply the necessary soaps and water without letting go of the ladder. If you use an aerial lift or do the work from the roof itself, you are going to need to have fall protection. On a commercial roof, you may have the benefit of a parapet that meets the requirements for fall protection according to OSHA, but if not, you need to figure out how to protect your workers. You will not only have open edges where you or your employees will be exposed to a fall, but slippery surfaces as well. Remember, this is a concern on flat roofs as well as sloped roofs. Personal fall arrest systems may be your best bet, but you need to determine a proper anchor point, ensure your employees are wearing their harnesses and lanyards properly, and ensure they have been trained in the proper use of their fall protection equipment. If you are not capable of providing all of this, then it may be in your best interest to hire a licensed, trained contractor or to bring your installer back out for the process. Don’t take this lightly. Falls are a major cause of occupational deaths and the number one cause in construction.
Sometimes, things seem simple. If you need to wash your roof, you may think you just have to throw some soap up there and rinse it off with some water, how hard can it be? Unfortunately, if you take a moment to look further into it, you could be putting yourself and your employees at risk. The bottom line: Know what you’re doing or hire somebody that does.
OSHA regulations speak in absolutes: there is a hazard or there isn’t a hazard. In reality, though, there are varying degrees of hazards because there are varying degrees of severity and varying degrees of likelihood that an incident will occur. You will see this reflected by OSHA in their citations (De Minimis, Other than Serious, Serious, Repeat, Willful), but the regulations are written to protect against the very existence of a hazard, regardless of its likelihood or the severity of injury that could occur due to lack of compliance.
In order to determine what hazards you have and the means by which you will protect your workers, it is important to do an assessment. Let’s take fall protection situations for example. You could have multiple fall exposures in your facility, but budget, scheduling of contractors, etc. do not allow for you to immediately abate each and every one. Just determining that there is a hazard does not help you decide which hazards to focus your efforts on. However, if you assess your hazards based on frequency and severity, you start to get a better picture.
If you’re still confused, picture this scenario. You have two locations that have an exposed drop of 20 feet. One is the top of a ladder that is used all day, every day. The other is the edge of a mezzanine that is only accessed by maintenance personnel when a repair is needed. Both are indeed fall hazards. The severity of a fall from either of them is pretty much equal. The main difference here is how often your workers are exposed to the danger. With the ladder, it is multiple times daily while with the mezzanine it is infrequent at best. This points to the fact that your first priority should be to install a ladder gate near the top of the ladder. You can then, at a later date, worry about protecting the edges of the mezzanine. In the meantime, you can restrict access to the area and require any maintenance personnel needing to go on the mezzanine to utilize personal fall arrest systems.
So, what’s an easy way to do this? The following chart is a good tool to help you determine which hazards are the most in need of attention:
As you can see, these may not be precisely measurable criteria, so you’ll need to estimate your responses or, better yet, come up with your own benchmarks for each category to help you better determine the severity of the hazard or frequency of your employees’ exposure. For instance, the frequency with which your employees expose themselves to a hazard is directly proportional the certainty of injury – the more frequent the exposure, the more likely you are to have an incident occur. Therefore, you could, if you wanted, change the categories along the top to Frequency of Exposure. Then you could list them as Rarely, Annually, Monthly, Weekly, Daily (or you could just know in your head that those were the equivalent categories).
Sometimes, what we see at first glance isn’t accurate. Something can look like much more of a hazard than it is, while other things that don’t look hazardous can pose a big danger to your employees. This tool keeps you from having to guess. Without it, should something go wrong and you get asked the question, “Well, how did you assess the hazard?” or “Did you even assess the hazard?” you would have nothing to point to. This chart makes your hazards measurable, which means you are making better decisions. Better decisions mean your employees are better protected. Isn’t that our end goal?
It’s inevitable. If you are a safety-conscious worker, you will at some point in your career be faced with the task of presenting a safety concern to your employer. If you’ve been given this responsibility, or if your company is truly supportive of safety efforts, then it’s easy. However, not everybody is lucky enough to be in those situations. Some employers are dismissive of safety concerns at best, and hostile toward those who bring them up at worst. So, what’s the best way to bring safety issues to your employer’s attention?
The answer will, of course, depend on the nature of the hazard you are reporting. If it’s not an immediate danger, you have flexibility in how you approach your boss. However, if the safety issue is an immediate danger and somebody’s life or well-being is on the line, then you need to act accordingly. In that situation, the best thing to do would be to make an attempt to get the employee exposed to the hazard, out of the situation first. Deal with the consequences once they are safe, but waiting to get a supervisor if they are not immediately available could be the difference between life and death. Yes, this could initially have a negative impact on your job (we’ll discuss employer retaliation in a bit), but you need to ask yourself if you want to live with the death of a co-worker on your conscience. If your employer is not supportive of safety efforts, this situation will prove to be very complicated.
Let’s assume, though, that we’re not in an immediately life-threatening situation. In that case, you should consider these suggestions:
Follow the Chain of Command
Nothing is going to upset your boss more than you going over his or her head. Your immediate supervisor should be the very first person you address safety concerns with, even if you have a company safety director. Give them the opportunity to fix the problem. Let’s face it though, some of you have been working for your supervisors for a long time and you are fully aware of what their reaction will be. If you are in this unfortunate circumstance, or if you do approach them and their response is simply unsatisfactory, then you may need to seek help elsewhere. In a union shop, this could mean addressing the concern with your shop steward. In either union or non-union situations, it could be addressing the issue with your safety manager or director. A good safety manager will find a way to approach the situation without unnecessarily dragging your name into it. When an employee reports a safety issue to a safety manager, it is a good idea for that manager to go and do a walk-through of the area before contacting the supervisor. That way, when they contact the supervisor it is because they happened to be in the area and observed a safety violation, not because somebody went over the supervisor’s head.
Enlist an Ally
Some companies don’t have safety managers or shop stewards. In these situations, you need to ask yourself, are there people in your company with influence that are strong proponents of safety? Perhaps you can bring the issue to their attention, once you’ve unsuccessfully attempted to work with your supervisor. Find a way to discreetly let them know what the problem is and maybe they will be able to run with it from their end.
Make Sure You're Not Simply Complaining
One of my old bosses used to always say, “Don’t come to me with a problem, come to me with a solution.” He had an extremely open door policy, but he didn’t want us just walking through his door to complain. He wanted to see that we’d thought about the problem we were experiencing and had a suggestion to fix it. Sometimes, we didn’t have suggestions and we would explain that, but what he was doing was showing us how to problem-solve. It’s an important lesson that most likely helped lead to where I am today. So, the next time you want to run to a supervisor to complain, first think about what it is you’re complaining about. Are co-workers tied-off to unsuitable anchor points? Maybe you can go in suggesting what a suitable anchor point might be or that railings may be a better option. Do your co-workers seem to not understand what is required of them from a safety perspective? Maybe you can go in and request a training class that would help everybody understand better.
Don't Be Argumentative, Be Cooperative
In line with going in and presenting a solution, your whole approach should be one of cooperation. If you go in making accusations and attacking management, you can expect negative results. Let your boss know that you wouldn’t be bringing something to his or her attention if it wasn’t important and that you did put a lot of thought into it, but you are really concerned. Tell them what you believe to be wrong and give them a chance to explain. Offer any solutions you may have and let them know that you will help them in any way you can to make sure the situation is corrected as efficiently and as quickly as possible.
Do Your Research
Know what you are talking about, plain and simple. Don’t go and complain that the height of the railings are wrong when they’re not. Don’t complain that an anchor point is insufficient when it’s not. Do whatever research you need to do to back up your concern and have that backup in writing. If you find the information you need on OSHA.gov, print that page up and bring it with you. Show your boss what it says in the standard, but be careful, there can be old information out there that has possibly been superseded by new regulations or letters of interpretation. Employees who are adept at navigating the internet have a world of information at their fingertips, but if you know a safety professional in the field, perhaps you can ask them for a little assistance to ensure that your information is up-to-date. I have had many safety concerns brought to my attention in my career and, while many were valid, there were quite a few that weren’t. If you get an explanation of why something is not unsafe and why it is compliant with the law, you may need to be willing to accept that.
Know You are Protected
As an employee, you have rights, and one of those rights is the right to a workplace free of recognized hazards. Another is the right to voice concern for your safety without fear of retaliation – to your employer or to OSHA. In the worst case scenario, where you have a safety hazard that your employer refuses to address, or refuses to address in a satisfactory manner, you have the right to contact OSHA directly and file a complaint. In fact, every employer is required to post the OSHA poster that specifically tells you how to do this. The sad fact is, that not all employers are going to be willing to hear you out or be responsive to your concerns.
Old-school thinking may cause them to label you as a trouble maker or a problem employee, but you need to stand by your convictions. Simply put, your employer cannot retaliate against you in any way for bringing up safety concerns. They cannot fire you. They cannot transfer you to a less desirable position as a result. They cannot reduce your pay. They cannot change your working conditions to make you uncomfortable or unhappy. If they do, OSHA has your back. And, retaliation fines are steep. This is not a slap on the wrist. If a company is found guilty, the results are usually significant fines, full back-pay for the employee, and full reinstatement of the job. Granted, nobody wants to be out of work waiting for the system to work, but sometimes you have no choice.
Voicing safety concerns to your employer is not only a good idea, but it is imperative if you want your company to have an effective safety program. However, there are right and wrong ways to do things. In these situations, diplomacy is key. Follow the chain-of-command as long as it is effective. Do your best not to hang anybody out to dry or throw anybody under the bus. Remember that the goal is your well-being and the well-being of your co-workers. Know that what you’re asking for is right. Once you know this, be insistent, be fearless, and you might just save somebody’s life.