How well does management know the "barriers/controls/safeguards"?
When meeting with executive teams, I like to conduct an exercise to gauge the leadership team's level of knowledge and direct involvement in the safety and health of their employees. Before getting deep into the organization's specific barriers/controls/safeguards regarding their top 3 risks (which the team picks), I ask the team to take 10 minutes and identify the barriers/controls/safeguards in today's vehicles and to place them into the three (3) Layers of Safety. They do this as a single team. It is a fun exercise for any group of employees, and it brings to light the stark difference in the role of a barrier/control/safeguard. Some are intended to PREVENT the accident; some are designed to PROTECT the occupants from the consequences of the accident; and some (not necessarily on the vehicle, so this is a trick question) are intended to MITIGATE the event's severity. Membership Content
Who is the idiot?
We see these silly stickers occasionally in our work with clients. Although they are not official company positions, I am curious as to why they aren't removed from company machinery and equipment. Could this be because management/supervisors believe this to be an accurate statement/belief? But let's talk about the message these silly stickers really convey and to do so, I ask the question: Who is the idiot? The worker asked to operate the piece of machinery/equipment or the Management that hired them to operate the piece of machinery/equipment?
The seven C's
The seven C's of being all we can be as safety professionals.
Compassionate
Confident
Collaborative
Contemplative
Civil
Curious, and
Courageous
Let us remember WHY we became safety professionals AND, more importantly, putting those we have the privilege to protect # 1 in our efforts.
Source: 7 C's of Compassionate Leaders (Forbes)
Does staffing impact the culture of safety?
I have grown up in safety and emergency response and found that the tools used in both aspects can cross over to the other. For example, I use the National Incident Management System (NIMS) Incident Command on accident investigations to bring structure to the team. In that IC we have a "span of control" of no more than seven (7) people reporting to any one person. This lets people properly manage their team members in a high-stress working environment. And it works. So when we visit a facility/business and see front-line supervision-to-employee ratios of 30:1, we can almost predict what we will find in terms of culture. And this has a dire impact on safety performance and the culture of safety. Looking back to some of the more extreme cases we have encountered, we also remember the "over-the-top" effort by management with their safety banners, safety parties, etc., to overcome their cultural problems. Let's be transparent (and honest): RELATIONSHIPS are a huge part of safety. I have been talking about TRUST and CREDIBILITY in the safety effort as a crucial part of turning around both safety performance numbers and the culture around safety. Both of these are highly dependent on RELATIONSHIPS. Now, I am not talking about supervisors becoming everyone's best friend - it is a tough job, but being fair, honest, and approachable are traits a supervisor MUST have. However, even a great supervisor with these traits can not properly manage 20-30 people AND allow them to build relationships with their team. In a recent project, we interviewed 12 department supervisors, each with over 20 years of experience as a supervisor at the facility. A very stable and dedicated group of professionals. The company had invested in the folks; several had gone on to get degrees in business (paid for by the company), and all had undergone some excellent "supervisor" training throughout their careers. But when asked to name their employees, they could only name 25-30%, and you can probably guess which 25-30% they could name: the great ones and the problem ones. This was also, across the board, the most significant frustration they had. EPA issues RMP citations @ cheese manufacturing plant (NH3, Line Break Accident, & $38K)
This is an unusual case in that it involved a 20-pound release of NH3 during a "line break" on a refrigeration system. There was only a single citation and it came at a price of $38,500. The employee was injured. I have been unable to locate an OSHA investigation regarding this incident, which occurred in TX. This case is also interesting in that the company agreed to implement:
Respondent is the owner and operator of a cheese manufacturing plant. On March 16, 2023, there was an incident at the Facility that resulted in the accidental release of 22 pounds of anhydrous ammonia and the injury of one (1) employee (the “Incident”). On January 11, 2024, the EPA requested documentation and information concerning the Incident and Respondent’s compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68 (the “Investigation”). The process includes fluid milk unloading, cheese manufacturing, cheese packaging and storage, liquid whey processing, whey powder packaging, storage, and shipping. Processing aid substances handled and stored onsite consist of ammonia and sanitation chemicals. The Respondent’s processes meet the definition of “process” and “covered process”, as defined by 40 C.F.R. § 68.3. The Respondent’s RMP Program Level 3 covered process stores or otherwise uses a regulated substance in an amount exceeding the applicable threshold. Anhydrous ammonia is a “regulated substance” pursuant to Section 112(r)(2)(B) of the CAA, and the regulation at 40 C.F.R. § 68.3. The threshold quantity for anhydrous ammonia is 10,000 pounds, as listed in 40 C.F.R. § 68.130. Respondent has greater than a threshold quantity of anhydrous ammonia in a process at the Facility, meeting the definition of “covered process” defined by 40 C.F.R. § 68.3. EPA Findings of Violation A DECON practice challenge
I have been involved with emergency response for over 30 years. During those years, I trained thousands of municipal and private responders, specializing in traditional Hazardous Materials Responses. During all those years, when I received continuing training from the likes of Texas A&M, LSU, NFA, and SERTC, these advanced courses only validated my first HAZWOPER course at Murray State University in 1991. Today, I got my first question, which I could not answer! So, I am turning to the ER and Safety community to see who can provide the "source" of this DECON practice... Inerting a flammable atm is more of a science than art
Not all "simple asphyxiants" are created equal; thus, not all make for good purging or blanketing. Would you believe me if I told you that one very common simple asphyxiant gas should NEVER be used for purging or blanketing flammable atmospheres? Many folks view Nitrogen (N2) and Carbon Dioxide (CO2) as very similar. This is based on how we, as humans, respond to both of these gases. CO2 has been getting a lot of attention lately due to its increasing use in the food and beverage retail industry and industrial refrigeration. It has some great qualities for its intended uses, but it comes with a significantly increased risk to workers who normally do not work around hazardous chemicals. Does OSHA have any specific requirements regarding dimensions of gaps between the moving parts (belt or shaft) and the guards? (LOI)
Yes. OSHA's standards at 29 CFR § 1910.212 and 29 CFR § 1910.219 apply to the safeguarding of machines and mechanical power-transmission equipment and require guarding to protect the operator and other employees in the area from hazards such as those created by ingoing nip points, rotating parts, flying chips, and sparks. In regard to the gap dimension between belts and their respective guards, § 1910.219 (e)(1)(i) states:
Please note that the requirements for guarding belts contained in 29 CFR § 1910.219 do NOT apply to the following types of belts when they are operating at two hundred and fifty (250) feet per minute or less: Something to think about when preparing to issue discipline to those closest to the risk
I am a proponent of accountability in safety; however, I also believe that accountability is necessary at all levels of the organization. We tend to be very quick in identifying the ACTIVE failures by those who made the error, mistake, or violation, and a negative consequence was the result (vs. all those times, the outcome was positive). Heck, in today's world, we may even have caught it all on camera for everyone to see. And if that ACTIVE failure was an EXCEPTIONAL violation (vs. a routine or situational violation), then we can consider holding those who performed that act accountable. But why are we so slow to hold managers accountable for their violations of Management System expectations? Examples include failure to certify SOPs, utilizing the MOC tool on changes, "pencil whipping" permits and safety checklists, failure to manage corrective action plans, etc. These failures are called LATENT ORGANIZATIONAL failures, and although they may be farther away from the ACTIVE FAILURES we see in the videos of accidents, they "set the stage" for many of the ACTIVE FAILURES we may eventually see in future videos of accidents. This discrepancy in who we hold accountable for safety can drive a massive wedge between the men and women doing the dirty and dangerous work closest to the risks and management who sets the tone and expectations of how the business (and, more specifically, the daily tasks) will operate. Remember, disciplining workers closest to the risks will never change a culture (or their behaviors), but a culture may never change without proper discipline. This applies to ALL LEVELS of the organization: those closest to the risks and those removed from the risks. EVERYONE plays a role, and therefore, "accountability" needs to be applied at ALL levels that influence the ACTIVE FAILURES. What are the final changes in the Safer Communities by Chemical Accident Prevention (SCCAP) Rule?
Some of the more eye-opening revisions:
Here is a summary of all the new requirements: 2024 DOT ERG is coming!
DOT/PHMSA have compiled the most important changes from ERG2020 to ERG2024, organized by the color of the corresponding section in the guidebook
In addition to the changes listed below, all sections have undergone minor editorial changes for accuracy and consistency. In this edition, DOT/PHMSA has added QR codes to the back cover of the hard copy version of ERG2024, offering quick access to critical incident reporting information for users on the scene of an emergency. If you have already downloaded ERG for iOS or ERG2020 for Android, published by the Pipeline and Hazardous Materials Safety Administration (PHMSA), no action needed! Your app will update automatically to ERG2024. |
Partner Organizations
I am proud to announce that The Chlorine Institute and SAFTENG have extended our"Partners in Safety" agreement for another year (2024) CI Members, send me an e-mail to request your FREE SAFTENG membership
Member Associations
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