Permit Required Confined Spaces, Part 1 – Is it Confined?

Ok, I admit it, I’m one of those EHS people that likes analyzing regulations. I can’t help it. Prior to changing my major to Environmental Health and Safety Management, I was Pre-Law. The structure of the regulations, along with the ability to interpret their meaning holds a strange draw for me that I have never been able to understand.

So, with that being said, I thought it might be interesting to focus on some of the more interpreted OSHA regulations and try to bring my own interpretive reasoning to the stage for those who might be interested. Since I am a self-labeled Confined Space Geek, I thought I might start with 1910.146.

Since I DO tend to ramble on, especially on subjects I enjoy, this will definitely be a multi-parter…

Kick it…

1910.146(c) – General Requirements

I know, I skipped the definitions – I figure, we’re going to be referencing the definitions enough throughout this whole thing that I can get away with it.

1910.146(c)(1) The employer shall evaluate the workplace to determine if any spaces are permit-required confined spaces.

Seems simple enough, right? In my experience though, there is a lot of discussion around this single, simple-seeming statement. I have heard numerous times that the regulation “only requires me to look for Permit Required spaces”, and this is, technically, true.

However, in taking a step-by-step approach to managing confined spaces in your workplace, there is another, implied, requirement that some people miss. You have to identify ALL confined spaces first.

After all, how do you know if you have any Permit spaces, if you don’t identify them as confined spaces first? (Interpretation – bullet 1)

Although the regulation does not require a listing of all spaces, some form of identification system that includes all spaces should be utilized. For example, a space at the Main Street facility, in the LL building, on the basement level, in the South wing; could potentially be identified as Space # MS-LL-B-S-01. This will allow you to reference a specific space location should a regulatory agent, or employee, have a question about the space.

Is It Confined?

So, you’ve identified a potential confined space – how do you know if it is or not? In order to determine if your space meets the definition of a confined space, you need to look at 3 things. A space must meet all 3 of these criteria to be considered a confined space.

Is large enough and so configured that an employee can bodily enter and perform assigned work

Again, seems simple. Again, a lot of discussion goes into this statement.

In order to determine if this requirement applies to your space, you must have a good understanding of what the statement is asking. Bodily enter, means that the space must be large enough for an employee to fit his entire body into the space. (Interpretation). If the employee cannot fit their entire body into the space, or through the opening, then this requirement is not met and the space is not a confined space.

Now, I will tell you that what I can fit my entire body into (5’10” 290lbs) is a lot different from what my maintenance guy can fit into (5’8” 170lbs) or the female parts person (5’2” 100lbs) – so who do you use as your barometer as to whether someone can bodily enter?

This is one of those questions that OSHA is not really very good at interpreting, therefore, it is left up to facilities to make their own judgment calls. The closest I ever saw to an actual answer to this question was from a training class given by the Michigan Training Division for their State OSHA program. They stated that it had to be big enough for an AVERAGE person to bodily enter.

By the strictest letter of the law, however, the definition implies that you are required to look at all of your employees and if one of them could get into the space, then it is large enough and meets the definition.

Once you’ve made the decision on whether your space is “large enough to bodily enter”, you then move on to -

Has limited or restricted means for entry or exit

Another fun one. What exactly does this mean?

Typically, the answer to this question is that the configuration of the space is such that an employee would have to contort (stoop, bend, wriggle, etc.), use specialized equipment (lowering devices, ladders, etc.)(Interpretation – bullet 1) or would require outside help to enter or exit the space. The ability to self-rescue in the event of an emergency is also a criteria in some interpretations.(Interpretation – Question 1).

However, in certain circumstances, such as the Chest Freezer Interpretation (Interpretation), low walls or depth of the space may not constitute a restricted entry/exit point, depending on the height/depth. The interpretation above references 30-inches as not being restricted, while the following (Interpretation – Question 3) states that 48-inches (4-foot) IS considered restricted.

Since other OSHA standards regulating walking and working surfaces, require a standard guard rail to be 42-inches tall, (presumably so that you cannot overbalance and fall, thereby “restricting” you to an area), I have typically used this as a discussion point to draw the line of restriction at 36-inches.

Other design factors which may determine restriction may be, airlocks, doors locked from inside, no handles on inside of hatches, tall sills at the bottom of entryways, changes in elevation within the space, etc.

Once you’ve figured out if the space has “limited or restricted means for entry or exit”, you’re now ready for the final criteria, which is –

Is not designed for continuous employee occupancy

This one actually IS pretty simple. Is the space designed for employees to occupy it, during normal operation (Interpretation) of the space, on a continuous basis? Would you want to set your desk and computer up in there? Does it have lights? Fire protection? Stairs in and out rather than ladders?

Look at the space while it is operating and ask if employees can be in it on a continuing basis with no risk to life or limb. If the answer is “yes” then it does not meet the definition. If the answer is “no” than it meets this criteria for being a confined space.

Congratulations!

It’s a Confined Space! – or not. It all depends on how you answered the 3 criteria above for the space in question. Remember, a space has to meet ALL 3 CRITERIA in order to be considered a confined space.

Whether you determine that the space is a confined space or not, documentation of these determinations should be done and held on to. Although not expressly required in the standard, documentation and identification of even the non-confined spaces, will serve as proof that, not only was the space evaluated for these requirements, but also the rationale used for identifying why the space is, or is not, a confined space.

Also important, just because a space is a confined space, does not necessarily mean that there are any special requirements for entering that space. Conversely, just because a space is not a confined space, doesn’t necessarily mean that there is nothing in there to harm your employees.

As we all know, or should - If it’s not documented, it didn’t happen (at least in the eyes of the Regulator).

Next time, we’ll talk about what makes a Confined Space Permit Required.

Be Safe My Fellows

1910.146 Permit Required Confined Spaces

OSHA Confined Space Interpretation Page

Zealots, Minions or Converts?

Zealot – A member of a fanatical, militant sect. A fanatical partisan.

Minion – A servile dependant, follower or underling. A subordinate or petty official.

Convert – One who is brought over from one belief, view or party to another

(Source – www.mirriam-webster.com)

How many of us have heard the Environmental Health and Safety field referred to as almost “a religion” or “a cult”? Maybe you haven’t heard those exact phrases, but I would bet that you’ve heard similar enough language from employees, supervisors and managers to get the point – that’s how we sound to some people.

So, I started thinking, (dangerous for one of my ilk), if you compare EHS to a religion or a cult, what is the best type of follower to develop in your facility? Which type will allow your EHS programs to be the most effective?

Note: I know, this whole post may seem heretical to some, but go along with me here.

Every EHS Professional knows that your programs won’t work if you don’t have – and I’m not fond of this term, but – Engagement, from all levels of the organization. You need support, accountability and - for those of us who are the only EHS person – you just need help getting stuff done.

Like it or not, our profession is also about perception and politics. How you look, act and interact with all levels of an organization allow employees within that organization to form opinions about your credibility. On top of that, employees also look at the people who are representing your agenda in order to form those opinions.

So what kind of representative should you be striving to develop? Do YOU fall into one of these categories as well?

The Zealot

A Zealot is fanatical about what they believe in. They go the extra mile, they do what needs to be done and they do it in the most direct way possible.

This may sound great, except zealots are also militant, meaning they do what needs to be done, but they do it without understanding or empathy for surrounding circumstances. A zealot will latch on to a rule and attempt to enforce it mercilessly, without allowing for argument or discussion, simply because it is THE RULE.

Typically, a zealot will choose a rule that does not require thought in its everyday application – PPE, for example. In the eyes of the zealot, if you are not wearing your safety glasses, you are an offender and need to be whipped into submission. Zealots are, basically, bullies and tend to be the type of employee who, when given a taste of power, hold that perceived power over the heads of their peers.

Zealots also tend to piss people off. Now, I have said to people on many occasions, sometimes jokingly, that my job is to make people angry and if I don’t make at least one person angry a day then I’m not doing my job.

However, there is no surer way to get people to ignore your overall message, than to piss them off over something they think is petty. Safety glasses should be a “hot button” issue while someone is operating a lathe, but if they take them off to wipe the sweat off their face once the immediate hazard has passed, it shouldn’t incur the wrath of the storm.

Now, having said all of that, zealots DO have their place in some programs, particularly program areas that require unwavering compliance at all times to the strictest letter of THE RULE. However, usually they do more harm in “promoting” your agenda than good.

The Minion

These folks are very political and empathetic - to a fault. Minions tend to be seen as “sneaky” and disingenuous when handling most situations. Minions attempt to communicate and enforce EHS procedures without any real belief in the process itself – and it shows.

A minion will perform a task well enough to make sure that they get noticed. If people don’t notice, then they talk about their part in the process to as many people as necessary to get that recognition. Minions will complain right along with an employee about a rule, throwing their hands in the air and using the phrase “I’m just doing what I’m told”.

Minions also tend to have a self-serving, “yes man” attitude when it comes to authority figures, because it reinforces the perception that they are invaluable, while still allowing them to pursue an agenda of their own, politically.

Minions are one of the most dangerous people to have on “your side” as an EHS professional because of their ability to undermine the program through disbelief. Once a minion has been labeled such by the general population, they lose credibility and effectiveness – and so do your programs.

The Convert

A true convert to the “EHS Cult” can be a powerful ally in the fight to change culture and thinking within an organization. Converts usually fall into 2 groups – those that come to understand the importance of EHS processes through training, knowledge and practical application to their direct position, and those that come to the same understanding through witnessing, or being involved in, a serious incident.

A “Knowledge” convert has a general, thorough understanding of, not only what is required, but also why it is important to the company. Typically, these will be supervisors, managers, safety committee members, etc. They bring to the table a subdued passion about EHS that draws from seeing it work, but also an intellectual aspect to explain the “whys” to those who are skeptical of the benefits.

An “Incident” convert is usually very passionate about specific processes, typically those that were related to the incident that caused the conversion. These converts can speak with personal conviction to all levels of an organization about the importance of processes designed to prevent similar incidents from occurring again. Incident converts, maybe unfortunately, can come from any level of an organization, but are the most powerful when speaking to employees at their level on the organizational pyramid.

In the Mix

All of these types of “followers” also have the potential to fall into 2 , or even all 3, categories in different situations and with different audiences. As an EHS professional, one of the most important things that you can do with these employees, is to understand what type(s) they fit into and in what situations they work best. Once you have determined that, you can place them where they will do the most good for your EHS program.

So – which type of employees do you need in your daily work? Which category do YOU fall into?

As to Environmental Health and Safety being a Cult or Religion – Well, I’ll let you look up the definitions, you draw your own conclusions…

Be Safe My Fellows

The Lowest Common Denominator

Facepalm

 

No, this isn’t a math lesson (I suck at math).

This is a lesson in frustration, jaded cynicism and catching myself doing something I always said I wouldn’t do in my profession.

It happened about a year and a half ago. I was just starting a new position with a fairly well known, international company. I was rediscovering my passion for safety in a way that only someone new to an operation can. The process was new (to me anyway) and exciting. The political atmosphere was new, the players were new – and yet familiar in a good way. It was refreshing to be back in a “stable” manufacturing environment after so many years in Research and Development.

Some of the challenges, however, were not new. “That will slow us down…”, “That’s been broken for years…” and “It’s common sense!” – are all, to anyone who’s been in the EHS world (for more than a week anyway), common phrases and discussions heard from employees. I have heard these everywhere I’ve worked. I’ve heard these comments from my relatives and my high school buddies about their places of employment. We all develop our little canned statements and platitudes to deflect or explain these. Life – and safety – goes on…

So, like any grizzled EHS Professional with years of “experience” under his belt, I was fully prepared to rebuke any attempt at argument from the maintenance supervisor during our machine guarding inspection.

It was like a well-rehearsed sparring exhibition – comment and counter-comment, a discussion I had all but memorized:

               Me: “There is an access hole on that machine that needs to be covered.”

               Him: “That’s crazy, it’s a 2-inch hole for lubricating the gears.”

               Me: “…and 2-inches is big enough for someone to put their finger in it and get bit.”

Him: “You would have to work really hard to get at it where it’s at and you can see that it has moving gears in it! You’d have to be an idiot to put your finger in there!”

…and then I heard myself say something that that left his, and my, jaws hanging open:

“You’re right, but somebody will find a way to do it. Safety is about managing the lowest common denominator…”

Soul Searching

 

Uttering that phrase was what started a long, scrutinizing look at where my attitude had drifted over the last several years in regard to my chosen career path.

I have always thought of myself as a “think and choose” EHS professional, as opposed to a “cause I said so” type. Meaning, I would rather spend an hour, or 2 hours, talking to someone about an issue and explaining it until they completely understand the “Why?” behind the “What?” of what I’m asking them to do. My motto for the first several years was - “Train ‘em ‘til they PUKE!” – which was my abrasive, uncouth way of saying “Keep explaining it until you see the light of understanding go on in their eyes.”

Very rarely have I taken the attitude of “because I said so” and NEVER have I taken the attitude that my job exists because people are stupid.

But there it was – a comment that revealed where my brain was at. After 8+ years of passionately attempting to educate employees on the reasons behind what I do, I had just equated my entire career to putting the whole school in diapers because one kid peed his pants in class.

When did this cynicism creep into my way of thinking? When did my passion for doing the right thing give way to the pragmatism of doing what was easy?

While soul-searching for these answers to my personal dilemma, I began rereading old policies, procedures and training material that I had written, (I keep everything on a hard drive for reference). While spooling through these old presentations and procedures, I marveled at the difference between what I presented and wrote in my early years vs. projects later in my career. I had definitely grown in knowledge, experience and technical writing skills over the years – some of my old stuff out of college was almost cartoony.

I also noticed a definite growing jaded side to my material as it progressed. Presentations became less about keeping people interested and more about reciting rules and worst-cast scenarios. Policies and procedures went from general statements of intent to pages of detailed documents that would make a lawyer cringe as I attempted to close every possible loophole and account for every possible situation. Once I noticed the pattern, I began matching old email conversations to the time frames of the material and made a shocking discovery…

As my cynicism got worse, I had more difficulty getting what I wanted done in my facility. What a cycle to be stuck in!

Realization

 

I never did find a definitive starting point, but the whole situation did get me thinking about how we, as Safety Professionals, manage our processes. I and many others, I’m sure, get caught in the trap of issuing blanket statements and rules without regard to how those rules are being perceived by the people whom they are affecting. Procedures intended to prevent injuries, metamorphose into procedures that punish everyone in order to make managing the process easier.

And don’t kid yourself – employees DO look at it as a punishment…

Think about your facility – hearing conservation, for example – do you require everyone on the shop floor to wear earplugs at all times? Are all of those employees exposed to a 90dB TWA, or do you make everyone wear them to make it easier to enforce?

Do your policies make sense? I know, regulations sometimes require procedures that don’t seem to make sense to your operation, but are you tailoring those ones that are performance standards to meet the regulation without placing an undue burden on your employees?

I was talking to an employee of another company a few years back who had just been issued a hard hat and told it was mandatory to wear it in the shop. He told me that the Corporate policy was, if there was ever a recordable head injury at the location, hard hats would become mandatory in the shop (apparently the company had not done risk assessments to see if they were needed before they had an injury). A few months later, a recordable head injury requiring stitches happened, prompting implementation of the mandatory policy in the shop (wait for it).

The injury occurred in the office when an administrative assistant pulled a box of paper off a high shelf and it struck and lacerated her forehead. Guess who wasn’t affected by the new mandatory hard hat policy…?

Take a Look at YOU

We as professionals need to take a good, hard look at how we are managing our processes. Are we managing individual risk or are we taking the easy way out.

Do some soul-searching along the way too and ask yourself if your cynicism is interfering with your career and your passion for your chosen life-path. If you’re frustrated with lack of participation and support, constant second-guessing of your decisions, people falling asleep during training, badgering by your management team, questioning by your employees over feasibility of safety processes or just generally feel like you are protecting people in spite of themselves – remember, the one common element in all of these problems, the lowest common denominator, might be you.

Be Safe my Fellows.

Culture Shock!

My Cultural Awakening

When I walked into my first heavy industrial facility with my old man at age 14, (yeah, I know – who the hell let’s a 14 year old into an industrial facility?), I really had no idea what to expect. Clipboard in-hand, camera in my pocket and safety glasses on my face, I remember being told, “Don’t touch anything, don’t talk to anyone. Follow behind me and take notes and pictures that I tell you to take.”

Probably pretty good advice if you’re a consultant walking an adolescent through a foundry operation, or a stamping plant.

I remember following my dad through a gray iron foundry and being amazed – and frightened – and overwhelmed. It was dirty, hot, smelled funny, the air was almost too thick to breath – AND IT WAS LOUD! I was thinking, “Why would ANYONE choose to work here?”

Then I saw what my dad did for a living – he asked questions. He asked why operations were set up the way they were. He asked about how they made the sand cores, what materials they used and how much. 

He asked how old equipment was, what was the maintenance schedule and who controlled the building ventilation system.

The thing that confused me, at the time, was that he did not ask these questions of the Management and Supervisors of the operations. He asked the employees who were working on the line. He told these folks that they “were the experts” and that they knew their operations better than anyone.

I remember the looks of disbelief on the soot-smudged faces of the employees, seemingly dumbfounded that someone would ask their opinion on what conditions were like at the operation they worked at, let alone, ask them how they thought it needed to be fixed.

In my mind, this was my first glimpse into how a business culture can affect the safety culture. Why were those employees so confused when someone showed interest in their opinions? Why did these people, most of whom had been performing these operations, in these conditions, for 20+ years feel as though it didn’t matter what they had to say?

The business culture, at that time, was what I call “Compliance Only”. That old-style, Safety guy does it all, “… it doesn’t matter what you think, this is the way it is…” attitude. It was compliance for the sake of compliance with no explanation to the people it affected as to why it was important to comply. “Do it because I said so.” 

 

The Now

Jump forward 10-years to my professional career. The prevalence of “Culture Initiatives” has expanded exponentially. Companies are asking for input, trying to make their employees happy to be there, working toward lofty goals such as “Vision Zero”, “Target Zero” and “Zero Harm”. All of these initiatives have one thing in common – responsibility for keeping yourself, and your coworkers, safe at work.

However, somewhere along the line, “compliance” became a dirty word. Mention compliance to today’s “Leader”, even in the EHS field, and you are likely to get a look that would wilt lettuce.

There is a perception in today’s businesses that, somewhere along the line, culture and continuous improvement initiatives became better than compliance. That compliance was achieved sometime in the past and a forward thinking company must look to “Human Performance” to achieve “Zero Harm” to their employees. Large companies as a whole have flipped from one end of the spectrum to the other extreme.

To clarify – I also believe that culture and accountability, along with training (or better yet, teaching) employees, including Management, the “why” behind the “what” are a critical part of any EHS program in order for it to be sustainable in the long run. Employee input on processes, integrated with roles and responsibilities of those employees, and an accountability system that drives improved performance within those processes – is the menu for a happy and healthy workplace. This is true of safety, production, quality, engineering – or any other facet of a business.

Unfortunately, you can have the most beautiful menu in the world, the most talented chef, the most helpful waitstaff – but you will still fail if your meat and potatoes are rotten.

That’s how I view compliance – meat and potatoes. The framework. The foundation - the skeleton of laws that the musculature of culture, the circulatory system of training and the skin of accountability are attached to.

We now have, in business, a polar opposite of what was happening in the 80’s and 90’s. The old “Management” culture of “Do as I say”, which led to employee disenchantment, fear of the rules, lack of understanding and sub-par results; has now been replaced with the “Leadership” culture which has led to employee entitlement, no fear of consequences, an over-abundance of information to every last detail on pretty colored boards – and sub-par results.

As is typical of our society, we have gone to an extreme, to the almost complete exclusion of the other side. Many companies over the last several years have seen decreased injury rates within their company and then leveled off and stopped at a certain rate. The argument can, and has, been made, for any number of reasons why the rates have declined. Everything from under-reporting due to incentive programs to ISO-type management systems to automation of processes.

All I can speak to is companies I have personally been involved in – and I will tell you that, in my mind, very few times has the reduction had anything to do with reduction of actual risk within the facility…or changes in safety culture in the general population of the employees.

The business culture, on the surface at least, HAS changed. Managers tout from on-high that they are concerned for their employee’s well-being, companies add Safety and Environmental metrics and accomplishments to annual business reports and public relations documents. Management repeats the mantras of stopping production and “Safety First” and refusing to work unsafely to the masses. All of this while continuing to cut maintenance of equipment and facilities, expenditures of time and money for training and replacement of outdated and obsolete equipment.

Like anything else, all the slogans in the world won’t overshadow actually fixing physical concerns that employees have while performing their jobs. A little good will and cash will go a long way to winning the hearts and minds of the general population.

Pressure still exists, at least in the mind of these employees, for production above all else, especially in hard economic times. Employees still feel that, in order to keep their jobs or in order to keep their facility open, they must do whatever it takes to keep the line moving, even if it means using a broken forktruck, or climbing into a machine to clear a jam without locking it out.

In order to achieve an environment free from hazards, companies must take a step back and bring compliance and common sense back into the equation.

Write Procedures That Make Sense

When writing procedures, don’t just copy and paste the OSHA reg and think that is going to do the trick for compliance. OSHA regulations are meant to be the framework for larger procedural documentation SPECIFIC to your operation. Too many times, I have walked into a facility that has re-written the regulation and replaced “…the employer shall…” with “XXX Company will…”, then called it a day.

Explain HOW you are going to do it, what special equipment and training are YOUR employees going to need. Specifically WHO is going to be responsible and accountable, and WHEN are you going to do it. These details will allow you to answer the tough questions like – “Why do I hafta’?” and “Who’s job is it?”

These procedures also have to make sense to the general population of employees. If the procedure doesn’t align with what your people are doing every day, than it will quickly get lost in the day-to-day operations of the plant. That’s why it’s also important to…

Ask the Experts and Communicate the “Whys” 

Get your employees involved in writing procedures and changing processes. Although I advocate bringing some “Management” back to the world of business, it must be tempered by empathy for the personnel actually performing the job.

Imagine things from the employee’s point of view. Imagine working in your office the same way, in the same place for 5 years or more. One day you come in to work and someone has moved all of your furniture, or replaced your chair and desk with a standing work station.

Imagine if they took your stapler away because you might staple your finger and they’ve guarded the blade on your tape dispenser so you don’t cut your hand. You would probably think it was over-the-top, and ridiculous, especially if you had never injured yourself on the tape dispenser and no one talked to you about why the changes were made.

Employees who have worked at a task every day, even for a few months, have adapted to that task and have a way of doing it that fits their need. Asking them what they need, offering options to make it better and explaining why changes need to be made will go a long way toward improving the reception those changes get when they are implemented.

Don’t sugar-coat the explanations. Explain the reasons in well thought out, sincere answers that are direct and to the point. Nobody wants a dissertation on why they can’t have food next to their dip-tank, they just want to know why.

Allow Employees to Champion the Cause 

This is a great way to improve safety culture within your facility, but it must be done correctly. It only makes sense, if you have an employee who is doing crane inspections for your entire facility, to make them an integral part of your crane program, but they need to have the will to do it.

An employee who only comes in to do his job and go home, may balk at any extra responsibility given, but if you approach that same employee and offer additional training, ability to oversee repairs, contact with crane vendors, input into the policies and procedures and identity as a Subject Matter Expert, they may jump at the opportunity to “own” something at work.

The important piece of the equation is to talk to the supervisor of the employee and then approach the employee directly with the opportunity. Never, (if you can help it), assign these duties to an employee before getting their input, or you will end up with a lame duck champion.

It is also vitally important to choose employees who have some “skin in the game” for these positions. An accounting person, for example, is not going to have much stake in ladder inspections. However, that same accounting person may be very passionate about emergency egress, tornado shelters or office ergonomics.

Be Approachable, Ask for Feedback and Solve the Problems 

One of the first people I look for in a new facility is the person on the floor everyone tells me to stay away from. The “Whiner”, the “Screamer”, that person who always has a complaint about safety and is ignored out of habit because of the roughness of their vocal antics.

9 out of 10 times, this person has legitimate concerns for the safety of himself and/or his co-workers, but has had difficulty getting these items addressed for one reason or another. Since they are legitimate concerns, this employee continues to push and is relegated to the position of “complainer”.

Management should be on the shop floor on a regular basis, there should be no “Carpet Dwellers” in your facility. I’m not speaking to just the Supervisors and Production Managers – I mean all the way up to the highest level of your organizational chart and everyone in-between. This should include all levels and disciplines within the organization, including EHS, Human Resources, Accounting, Purchasing, Engineering – even IT.

These visits to the floor should not be “audits”, although they can encompass some of those duties. The visits should be with the express goal of speaking with the employees on the floor to determine if they have concerns and get the “Face Time”.

They don’t have to just be about EHS concerns either. You would be amazed how many cost savings ideas my last Purchasing manager came up with on his first visit to the floor and how many IT concerns were eliminated by my IT manager asking people how they were doing once a month.

Equally, if not more important, is to ensure that these concerns are addressed – quickly. Even a communication back to the employee with a detailed explanation as to why something cannot be done will garner a TON of respect, imagine what a positive change to the process will do! 

Add Your Own Spin

The few steps I have listed are, by no means, the “silver bullet” for complete employee safety, but I have used them to my advantage every place I have worked. All of these have several advantages for the employees (who receive a feeling of participating in their work life instead of being enslaved to it), the company (who receives better numbers in safety, quality, production and profits) and the Safety Professional (who is able to focus less on the tactical items and more on the strategic aspects of the program).

Above all, be sincere, open and respond appropriately to the situation, while still ensuring that you are in compliance.

Doesn’t sound like much – right? Welcome to the wonderful world of Environmental Health and Safety Management.

By the way, keep your 14-year old out of the foundry too.

Be Safe my Fellows.