Is Hazard Abatement Really Necessary?

For over 30 years I have preached the need for hazard abatement. It is not enough to only identify the hazards they must be fixed. This is also a shortcoming of risk management that I have also spoke against. You can’t identify control measures for hazards and reduce the risk unless you do the control measures that fixed the hazards.

A recent Metrorail (subway) incident at the Washington Metropolitan Area Transit Authority (WMATA) provides an excellent example of why this is necessary. Let me start at the beginning.

In 2015, there was a failure of an insulator cables in the tunnel near L’Enfant Plaza. I worked right there and went outside to see what was going on. As you might expect all the action was going on underground in the train tunnel. There were plenty of emergency vehicles above ground. As a result of the failure, the tunnel had a lot of smoke, and several passengers were trapped in cars. There were several injuries and one fatality. One person died of a heart attack while in the train car. An inspection was done that highlighted, among other things the issue with the insulator cables (FTA, 2015). Mullins and Di Caro list the other recent incidents with the systems. “After a fire at McPherson Square last week, the fatal smoke incident at L’Enfant Plaza last January, a crash at Fort Totten in 2009 and a number of other incidents” (Mullins and Di Caro, 2015).

“WMATA officials said there have been two problems with third-rail power cables, and they’re not waiting for a third to occur. They said the cables were inspected about a year ago, and they are unsure of the equipment’s current conditions” (WBAL, 2015). The first incident was the L’Enfant Plaza tunnel fire and the second was the McPherson Square tunnel fire. Here the officials also acknowledge that inspection was done, but they are unsure of the current condition. That last point should be an eye opener.

This all led up to the D.C. Metrorail closing for 29 hours in reaction to these safety concerns to inspect hundreds of cables and make necessary repairs (GWU, 2015). Shutting down the entire Metrorail of the Nation’s Capital for safety was something dramatic. I was stunned when I heard this on the radio. What would cause such a failure of a safety program that the entire operation had to be shut down to inspect hazards? As I read more, it became apparent that these hazards occurred over time and that at least the inspections after the L’Enfant Plaza tunnel fire identified them. Somewhere along the line, no one knew if the hazards had been repaired or not.

The Metro General Manager and CEO said “This is a hazardous condition that we cannot accept. The shutdown today was necessary.” The DC Metro Board Chairman said, “We are sorry this happened, that it has come to this.” Apologies aside that one-day shutdown cost the Metrorail an estimated $2 million in revenue. Now it is logical to assume some of that loss will be made up by more riders on the Metro buses. Suffice it to say that the system lost a great deal of money not to mention the confidence of the safety of its operations.

One of the elements of any safety program is to conduct follow-up to verify hazard abatement has been completed (Fanning, 2003, 18). It might be good to go over the whole hazard abatement cycle. It starts with Hazard Recognition, goes to Hazards Assessment, goes to Hazard Abatement, goes to Verification of Hazard Abatement, and finally goes to Control Measures. Let me highlight the two steps of the cycle that I think most people don’t do.

“Hazard Abatement is a set of procedures that are implemented to reduce or eliminate the risk to prevent the accident from occurring or to control the severity. This includes Engineering repairs, Wear of personal protective clothing and equipment, and administrative controls that consist of training, employee reassignment, and standard operating procedures” (Fanning, 2003).

“Without verifying that a hazard has been corrected [Verification of Hazards Abatement] it can be left uncorrected and may cause an accident in the future.  Verifying that hazards are corrected also builds confidence in the safety program because it helps demonstrate that the safety program can get things done and is not just a paperwork program that only documents hazards” (Fanning,2003).

The most important question in this cycle is: After hazards are identified are abatement plans with dates developed? Everywhere I have worked I have used a formal hazards abatement plan. This is a one-page document that provides all essential information. There is the usual administrative data like plan number, date prepared, date revised, activity or organization, hazard location, and risk assessment category. Then I document the actual safety standard being violated followed by a description of the proposed corrective action or remedial measures. I identify the estimated cost as well as estimated operating and maintenance costs, if any.  I list the interim hazard control measures in effect and other relevant information. I identify a completion date. The form is usually signed by a safety professional and approved by the safety manager. A copy of this form is then posted at the location of the hazard. There is one safety specialist in the office that tracks the completion dates.

Over the years, I have found this plan to be very useful in resolving hazards. Since the completion date was identified follow-up can be done to ensure the work was done. If not, the safety manager can meet with the director to discuss why the hazard has not been abated. I have recommended that operations be shut down when repairs to hazards have not been done and I used the abatement plan to support my argument that operations should stop until the hazard is corrected. So what do you think? Is Hazard Abatement Really Necessary?

References

FTA Safety Management Inspection Action Plan, Board Action/Information Summary (July 23, 2015). Retrieved from https://www.wmata.com/about_metro/board_of_directors/board_docs/072315_3BFTASMIResponsePlan.pdf

Mullins, Luke and Martin Di Caro. 2015. 40 Years of Metro: Was D.C.’s Transit System Always Like This? Retrieved from

https://thekojonnamdishow.org/shows/2016-03-21/was-metro-always-like-this

WBAL Television Channel 11. Entire DC Metro shuts down for day of safety checks. Retrieved from http://www.wbaltv.com/news/report-dc-metro-to-shut-down-wednesday/38528200

GWU George Washington University Hatchet Newspaper (March 23, 2015). Metro shutdown results in $2 million loss for WMATA. Retrieve from http://blogs.gwhatchet.com/newsroom/tag/wmata/

 

About Fred Fanning Author

Fred Fanning spent over 20 years in the safety profession. His final safety position was as the Director of Occupational Safety and Health for the U.S. Department of Commerce. He began writing in 1994, published his first book in 1998, and began writing professionally in 2015. He has authored and coauthored articles, written books, and chapters for technical books and stories for anthologies.
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