What do you do after inspecting?

What do you do after inspecting? Here is what I usually do.

Take the draft log you wrote while conducting the inspection and now identify the types the seriousness of the hazards that exist. This log should also include the location of hazard, a risk assessment code and any recommendation shows the correct hazard.

After the draft log is completed, you must also collate all the specific deficiencies to see if any systemic problems are involved. “For example, you may have found a fire extinguisher here and there that was discharged. Singularly, this may not seem like a big problem” (Fanning, 2003). However, when you add them together, you may find out that the contractor who was hired to service these extinguishers is doing a poor job. “If you report them separately, it is possible that no one will notice there is a problem. They will normally call the contractor to fix the problem” (Fanning, 2003).

There is a big payoff to fixing systemic problems. “For example, it may be cheaper for a person or contractor to repair several light switches at one time than it is to come out and fix each one as you find them. Systemic repairs also keep the system in check to make sure it is working” (Fanning, 2003).

A cover letter should accompany the log. This letter should give a general description of the inspection and identify systemic causes written so employees can understand and work with the report (Inspection Techniques and Hazard Recognition, 1985). The log must list corrective measures that should be taken to correct the systemic problem.

Workplace notices should be placed at the sites of any high hazards that are found and not immediately corrected. These notices should identify the hazard and explain that it is a high risk. The notice should also identify control measures to reduce the risk until it can be fixed. Furthermore, the notice should identify the person responsible for correcting the hazard and the deadline for correcting it. This will ensure the workforce knows about the hazard and will take steps to ensure it doesn’t cause an accident.

A follow-up inspection should be conducted within 90 days to keep the focus on correcting the hazards and to see if there is some assistance you can provide to help them succeed. This does not have to be a complete inspection. It is just a follow-up and should focus on the problems you identified in the first inspection. However, if you do not conduct the follow-up to correct the systemic problems within the organization, you will simply be doing the same work repeatedly. Perhaps, more importantly, management will be telling the task force that it is too busy with other issues to implement a permanent solution to the root cause of the hazards so they will continue to fix individual hazards as they come up. Once the workforce catches onto such an attitude, it will learn to work with the hazards around them. They will not focus on safety because the management has not demonstrated that safety is important.

Bibliography

Fanning, Fred. Basic Safety Administration: A Handbook for the New Safety Specialist. American Society of Safety Engineers, 2nd edition, Des Plaines, USA, Jun 2003.

Posted in Hazard Control | Tagged | Leave a comment

How do you inspect?

“Primarily, inspections that are well planned and thoroughly executed are used to identify hazardous conditions before they result in an accident (Blake 92).” You should look for conditions, procedures, and practices that if left uncorrected can lead to an accident. “But, by identifying the systemic causes of the hazards, you may eliminate the reasons the hazard occurred” (Fanning, 2003).

Secondly, you want to sell the safety program by demonstrating that the program cares about the workers. This is done by speaking with employees and listening to their concerns. “If your approach is helpful rather than harmful, you will establish credibility for yourself and the safety program” (Fanning, 2003).

Make sure you show up with the proper personal protective equipment for the workplace. “You must lead by example and wear this personal protective equipment when you are in a hazardous area. Along with this protective equipment, you will want to get the infamous clipboard, pencils, erasers, a 12′ tape measure, and a few pieces of test equipment. The kinds and types of test equipment will depend on your training and experience.  At the very least, you can get a testing device that will check the wiring and a device that will tell you when electricity is present” (Fanning, 2003).

“The in‑briefing is just an informal briefing to give you an opportunity to let management know what you are going to do and how you are going to do it. Now, no matter who leads you around the area, you have gotten the person in charge involved. Start out with the most obvious; cleanliness” (Fanning, 2003). Getting the place clean and orderly will clear up several “small” deficiencies. You will see cleanliness referred to as housekeeping in most standards.

“Getting the workplace in order can do two things for you: first, the supervisor will see some affirmative action taken right away, and everyone will benefit from the visible improvements in the workplace. This first impression will be important later when you want to try to tackle harder issues and problems. Secondly, a clean, orderly workplace promotes efficiency and enhances pride among those that work there. All of which can lead to a reduction in the number of accidents experienced in this job area” (Fanning, 2003).

As you do the inspection, try to make it a learning experience for the person leading you around “by pointing out what you are looking for, and when you find a hazard, discuss with them why it is a hazard and how they may correct it” (Fanning, 2003).

“As you find a deficiency, note it in a log that includes the building and room number along with the OSHA or another standard that was violated” (Fanning, 2003). As you finish the inspection, make sure to answer any questions the supervisor may have and give them a draft copy of the deficiency log. Remember, you are there to help them, and if they can get a few things corrected before their boss sees the report, it will help your cause, which is to reduce hazards.

If the supervisor did not go with you, go back into their office and tell him what you found both, good and bad, and leave with a promise to help him solve these problems. This is the out briefing. “Remember not to promise to solve them, only to help him solve them. You must leave the out briefing with the supervisor knowing what is wrong, where it is wrong and what they must do to correct it” (Fanning, 2003). Make sure they understand they own the hazards, not you.

Bibliography

Fanning, Fred. Basic Safety Administration: A Handbook for the New Safety Specialist. American Society of Safety Engineers, 2nd edition, Des Plaines, USA, Jun 2003.

 

Posted in Hazard Control | Tagged | Leave a comment

What do you do before inspecting?

In an earlier post, I identified several things that you will need to review before conducting an inspection. In this post, I go over the preparation that you will need to do before conducting an inspection.

A good place to go for help with any facility inspection is to get a copy of the facility list from management. This list will tell you what facilities belong to your organization. You will then need to look at the operations conducted in the facilities and determine a rank order of low, medium, or high based on hazard risk. Start out with the most obvious, hazardous material. Make a list of all the facilities that use hazardous materials in their work. Get a copy of the Safety Data Sheet (SDS) for each chemical. This is done even for workplaces that use one chemical. The SDS is a document that provides basic information about the health hazards, fire, first-aid measures, protective clothing and equipment, and transportation requirements for the hazardous substance being used. If the SDS is missing, you can contact the company that sold you the product, and they will usually fax or email you one.

If your organization has heavy machinery go on to identify those operations “that require the use of presses, cutting tools, welding, drilling, smelting, or overhead cranes” (Fanning, 2003). These all have the potential for serious personal injuries and property damage.

Next, identify those operations that have a health risk present. Health risks involve things like high levels of noise, LASER lights, use of gasses, confined spaces, and painting.

Take your list of facilities and identify all those facilities or operations that involve a high hazard. High hazards may cause a partial or permanent disability or may even lead to death. High hazards may also cause significant damage to a tool or piece of equipment or may cause the loss of the whole system. Also, high hazards may cause serious illnesses that may lead to disabilities or death. For those reasons, high hazards should be inspected monthly.

“Then make a second list of facilities or operations that involve medium hazard operations. A medium hazard will normally result in an injury that will require medical treatment, property damage of medium value, and may cause occupational illnesses” (Fanning, 2003). For those reasons, medium hazards should be inspected quarterly.

“Lastly, make a list of low hazard operations and facilities. A low hazard will normally result in a first-aid injury, minor property damage and no illnesses” (Fanning, 2003). For those reasons, low hazards should be inspected annually.

Now that you have a frequency to conduct your inspections, you will want to develop the schedule. “You should send this schedule of inspections out so everyone can have a head start on planning” (Fanning, 2003). Take your schedule and notify the supervisor or division chief at least six weeks ahead of time so they will have plenty of time to make themselves “available and locate the keys and people you need to see. You should do this by sending out a letter announcing the inspection and asking for a commitment to the date you have listed or “request a date that is better for them” (Fanning, 2003). Also, request “that you be given a few minutes of the supervisors or division chief’s time for an informal in‑briefing and out briefing” (Fanning, 2003).

A week or two before an inspection is scheduled, you will need to review those things I outlined in Chapter 1. Accident reports can tell you the hazards that caused the accident. Construction drawings can tell you about planned changes in the workplace that could introduce hazards. Employee physicals and medical reports can tell you, for example, who is cleared to wear respirators or who has sustained a back injury. Previous inspection reports can be a gold mine of information. By reviewing them, you can identify things to look for. A Job Hazard Analysis also provides details on hazards that were identified. Equipment Analysis and Purchase Reviews show you changes in hardware and material that can introduce hazards into the workplace.

Now show up on time, ready to conduct the inspection.

Bibliography

Fanning, Fred. Basic Safety Administration: A Handbook for the New Safety Specialist. American Society of Safety Engineers, 2nd edition, Des Plaines, USA, Jun 2003.

 

Posted in Hazard Control | Tagged | Leave a comment

Purpose of Inspecting

There are many purposes for a hazard inspection, all of which should be designed to enhance the effectiveness of the organization and the workers. Primarily, inspections that are well planned and executed are used to identify hazardous conditions before these result in an accident (Blake, 1963). I like to refer to inspections as “hazard inspections” because that is the real purpose, to identify hazards. You can call them what you like if you understand the purpose is to identify hazards. To be successful, the inspection must also identify not only hazards but their systemic causes as well (Inspection Techniques and Hazard Recognition, 1985).

By identifying and eliminating hazards, you only correct that hazard. This is what I call a “do loop.” You identify a hazard this month, and it is corrected. A couple of months later, the hazard is back, and you identify it again, and it is corrected again. However, through the identification of the systemic causes of hazards, you may eliminate the reason for the hazard and break this “do loop.” Unfortunately, many organizations continue to only identify and correct hazards one at a time, only to do it repeatedly.

Inspections are also used to show management’s interest in the safety program. What upper management spends time on, the workforce will see as necessary. An inspection may also be used to sell the safety program to employees and provide an opportunity for the safety personnel to contact workers and solicit their support for the safety program (Handbook of Occupational Safety and Health, 1985).

There are many types of inspections, but there are only two basic types of hazard inspections, the one-call and the continuous. The one-call inspections are usually conducted by a safety professional and normally carried out to appraise the recent safety performance of an organization (Blake, 1963). This is the full inspection. Most of us conduct yearly, but the inspections may be performed more often if the organization is involved in a high-hazard operation or if problems exist. The second type of inspection is called a continuous inspection. These inspections are conducted by shop personnel and occur on a continuing basis (Handbook of Occupational Safety and Health, 1985). Many people refer to these inspections as quality control. This is also an area where the supervisor can be very effective (Supervisor Safety Manual, 1967). The supervisor can delegate inspections to specialists who work in this field to expand their knowledge and experience. The supervisor may want to conduct some of the inspections and use this time to enforce their commitment to safety. The continuous inspection is essential because the hazards cannot simply wait for the annual inspection. Hazards must be looked for in a proactive manner and corrected as quickly as possible. In all cases, a systems inspections program can reduce the hazards while showing a continuous effort to improve the system.

Another important type of inspection is the job hazard analysis. This is a systematic and thorough review of the work process as it is being done or before it is done. By identifying individual steps within the course of the job, we can look to see if the steps are properly sequenced, if correct tools are provided, if the job requires the operator to be standing or seated, if protective equipment is needed, and if the requirements of human capabilities have been addressed, and lastly whether the process is getting the product you want. After we identified the hazards within the process, we can apply solutions to correct the hazards and improve the entire process (Accident Prevention Manual, 1997). This analysis can often be time-consuming, but it will provide benefits for the whole life of the process review (Inspection Techniques and Hazard Recognition, 1985).

If the inspections are conducted and hazards later identified by systemic causes, the correction of the systemic defect would eliminate many hazards. Unfortunately, it does not always work that way. If an organization loses sight of systemic causes, it may never fix some of the hazards. Ninety days after the original inspection you conduct a follow-up inspection regarding hazards corrected. You can also encourage management to correct the systemic deficiencies. Follow-up inspections also keep the work on track and keep the emphasis on the defects of the system.

Any safety program can benefit from a good, solid inspection program that is designed to support the organization (Weaver, 1992). Whether it is the one-call inspection, the continuous inspection, or a job hazard analysis, information gained about the condition of the program can be priceless.

Bibliography

Accident Prevention Manual for Industrial Operations, seventh edition. National Safety Council, USA, 1977.

Blake, Roland P. ed. Industrial Safety, third edition. Prentice Hall, USA, 1992.

Handbook of Occupational Safety and Health. National Safety Council, USA, 1985.

Inspection Techniques and Hazard Recognition. U.S. Army Safety Center, USA, 1985.

Supervisor Safety Manual, third edition. National Safety Council, USA, 1967.

Weaver, France. Camping Provides Real Ammunition in War on Civilian Accident Costs, Civilian Accident Prevention Program Report, Winter, 1992: 5-6.

Posted in Hazard Control | Tagged | Leave a comment

Human Error in System Approach to Hazard Inspection

When you look at a system approach to inspecting work areas, you must recognize that approximately 80% to 95% of all accidents are caused by human errors. This means that somewhere at some time a human being interacted with the system and, either by omission or commission, caused the hazard that resulted in an accident. There are human, material, and environmental factors that will be caused by one or more system inadequacies. Your inspections must look for these factors to identify the causes of hazards.

There are five system inadequacies that I use within the management approach to hazard inspections (Field Manual 100-14, 1999):

  • Support Failure – equipment, material, or supplies not provided.
  • Standard Failure – inadequate or no procedures in place.
  • Training Failure – poor or no training provided.
  • Management Failure – ineffective or no manager participation.
  • Individual Failure – an employee that does not follow procedures.

A Support Failure could be an employee assigned to work with a corrosive chemical, but was not provided gloves because none were available. The result of this failure is likely to be exposure to the chemical and damage to the skin on the employee’s hands. The immediate cause is chemical contact with the skin. The system inadequacy is a support failure because gloves were not available.

A Standards Failure could be an employee performing work in an area with respiratory hazards and failing to notice the respirator exhalation valve is missing on the respirator he wears. In this scenario, the organization had no standard operating procedure that requires training and proper respiratory maintenance. The employee was exposed to a toxic chemical, injuring his lungs and throat. The immediate cause of injury was inhalation of the chemical, but the systemic inadequacy was a standards failure because no procedure was in place.

A Training Failure could be an employee assigned to operate a forklift that received no training beforehand. The employee operates the forklift too fast while making a turn, resulting in the forklift overturning and crushing the worker. The immediate cause was the employee driving the forklift at a high rate of speed without wearing a seatbelt. The system inadequacy was a Training Failure because the employee was not trained to operate the forklift. The training would have included the requirement to wear a seatbelt.

A Management Failure could involve a supervisor of a lawn mowing crew who does not enforce standards and ignores employees who don’t follow the rules. Thus, an employee fills a lawnmower with fuel without allowing the motor to cool. The fumes from the fuel ignite, destroying the mower and burning the worker. The immediate cause was the hot engine igniting fuel; however, the systemic inadequacy was a Management Failure because the supervisor did not enforce safety standards that required the motor to be cooled before refueling.

An Individual Failure could be an employee assigned to operate a company vehicle after he received proper training. The employee partied late the evening before and got less than two hours’ sleep. This made him fall asleep while driving, allowing the vehicle to drive off the road and overturn, injuring the employee and severely damaging the vehicle. The immediate cause of the accident was that the employee fell asleep while driving. The system inadequacy is an Individual Failure because the employee came to work the next day tired because of inadequate sleep. The system should encourage employees to take the necessary steps to come to work prepared and able to work.

Bibliography

Field Manual (US Army) 100-14, Risk Management Program, Washington, USA, 1999.

Posted in Hazard Control | Tagged | 2 Comments

A Systems Approach to Hazard Inspections

A systemic approach looks at the organization as a system. A typical system has inputs a process to manipulate the inputs and outputs. All systems work the same. Figure 1 shows a simple system. In this example, materials are the input. The process manipulates those materials to make a good or service that is the output.

 

figure-1

“The whole system can be affected by just one thing or by any one individual” (Fanning, 2003). That is a hazard corrected by the inspection program can create problems and hazards in other areas of the organization. This is often referred to as unintended consequences.

From an accident perspective, this means that a hazard may have occurred days or weeks earlier in another part of the organization away from the point that it causes an accident. It is important to identify who created the hazard or allowed it to exist. This will enable you to determine the steps necessary to prevent a reoccurrence of the hazard. This is done by looking at the management system before correcting hazards. Correcting a hazard in one part of the system can create a hazard in another part of the system. Hazard abatement may only be temporary if you have not identified the other locations that same hazard may exist.

As a safety professional, your primary duties involve management of the safety program as outlined in Figure 2. “Your job is basically to identify, assess, and recommend control measures to reduce hazards. Your duties will revolve in a circular fashion” (Fanning, 2003). You should begin with hazard recognition so that you are working to correct a problem that exists.

figure-2

This book focuses on hazard recognition while conducting an inspection. This involves reviewing the following before conducting an inspection.

  • Accident reports
  • Construction drawings
  • Employee physicals and reports
  • Previous inspection report
  • Hazard surveys
  • Job hazard analysis
  • Equipment analysis
  • Purchase reviews

I have found that it is best to have a safety management information system in place. This is a single information technology solution that allows all safety information to be in a single location. There are products available that you can purchase. However, if you are like me, you do not have a management system. In this book, I can tell you how to create a rough example of one.

If you do not have one, you can put all the accidents, near misses, awards, inspection findings, reports of unsafe working conditions, and citations in a single database using building and room numbers as a reference. Then before an inspection, you can sort and print out all the information for a building to be inspected.

The safety management information system should also include a log for all the violations or hazards found during the inspection. You will also need a hazard abatement plan. This is a form that identifies those hazards that cannot be corrected on the spot and identifies a hazard control plan that will reduce the risk until the hazard can be rectified. This plan is posted next to the hazard, so workers in the area will be aware of it.

Your organization must also use Risk Assessment Codes. These codes are not a full process of risk management. Risk management is normally a five-step process that begins with identifying the hazards, assessing the hazards, identifying control measures, implementing control measures, and supervising the process. They codes are from the utilization of the first two steps of the risk management process. The result is a code that identifies the severity and probability of a hazard to result in injuries, illnesses, or damage to property or the environment (Fanning, 2015).

Your organization must also combine hazards that can be resolved by the same corrective measure whenever possible. For example, don’t fix one fire extinguisher identified as non-operational. Instead, combine all hazards concerning fire extinguishers into a contract for repair. This will get several hazards fixed at one time. Fixing one at a time is not usually a good approach because the same problem is often found later.

The last thing you need to do is identify root causes of the hazards. Let us look at the fire extinguisher example again. What caused all the fire extinguishers that were identified to get that way? Fix that cause, and you will stop the fire extinguishers from being a problem in the future.

What can you get from using a systems approach to inspections? Anyone, using a systems approach, will see a reduction in the cost of correcting hazards primarily because you should be able to fix several hazards with one solution and not fix hazards over again. You should also see an improvement in the process because correcting hazards can improve the processes. You will also look at the way management operates within the system, and by correcting the systemic defects at the management level, improve the system. In a general sense, a management systems approach to hazard inspecting can be used to enhance the system within the organization and not just correct a few hazards. Using a management systems approach leads to the use of human error to control hazards.

Posted in Hazard Control | Tagged | Leave a comment

Fixed Stairs and Ladders Case Study

With the information provided in the previous blog posts, I would like to present the case study.

This analysis was caused in response to a facility management professional found lying at the bottom of stairs with a pool of blood emerging from his head. He died from his head injury a few days later.

Let me tell you up front that it could not be determined that the condition of the stairs had any effect on his fall. However, this information can still be used to show how two buildings comply with the standards. The analysis was limited because the organization only owned two buildings.

Dr. Doug Parrish was the safety specialist in charge of this analysis. He compared requirements from:

“NFPA 101 (2012) Appendix A comment on the Section 7.2.2.2.1.1(2) “grandfather” paragraph for existing stairs further expands on topic,” (HQ DOE, 2014):

“A.7.2.2.2.1.1(2) It is the intent of 7.2.2.2.1.1(2) to permit the use of Table 7.2.2.2.1.1(b) in existing buildings, even where there is a change in occupancy per 4.6.11. Safety improvements should be made that are reasonable and feasible at minimal cost,” (City, 2016).

“Improvements include removal, repair, or replacement of step coverings, as described in A.7.2.2.3.5, particularly Figure A.7.2.2.3.5(e), and the addition of functional handrails and guardrails in place of, or in conjunction with, other rails, as described in 7.2.2.4,” (HQ DOE, 2014)

The team assessed stairs (internal and external building public stairs; mechanical room and other maintenance area stairs) in two large buildings. I will call them Bldg. 1 and Bldg. 2.

Dr. Parrish’s team looked at approximately 2,515 steps in 56 stairs in three buildings and surrounding areas at Bldg. 1 and approximately 1,800 steps in 57 stairs in four buildings and surrounding areas at Bldg. 2. The team tasks were to:

  • Measure step rise and tread run.
  • Measure handrail and stair rail heights.
  • Note stair and railing material, attachment, covering, and any deficiencies.
  • Compared any differences in height between:
  • Adjacent steps.
  • All steps in the same stair run between landings.

 

Location Public Interior Stairs Public Exterior Stairs Maintenance Access Stairs
Building No. 1 15 15 26
Building No. 2 16 17 24

Table 1 – Stair Count

Table 1 shows the number of stairs in Bldg. 1 and Bldg. 2.

The exterior stairs for Bldg. 1 were made of poured-in-place concrete, 2” metal, smooth, round continuous handrails, and non-slip metal toecaps. Some handrails were found to be noncompliant for rising/run variability on the NFPA and IBC requirements.

The internal public stairs for Bldg. 1 had hand railings that were of correct height to meet NFPA and OSHA requirements.

The exterior public stairs of Bldg. 1 were found be non-compliant with NFPA 101 requirements.

Some rails on stairs were found to be loose. The balusters did not meet the NFPA 101 minimum gap requirement.

It is noted that many stairs had 3/4” difference between the highest and lowest steps’ rise and run. Per IBC and NFPA 101 (2010), the maximum allowed difference for both rising and run should be no more than 3/8” for existing steps in a flight of stairs and 3/16” for adjacent steps.

OSHA General Industry Standard requires both rises and run in a stair to be uniform.

When they looked at fixed industrial stairs, they found that some were made from metal grate while others were made from concrete with non-slip metal toecaps. Both types met the non-skid requirement.

The team found that fixed ladders in elevator pits did not comply with OSHA fixed industrial stair requirements. IBC Section 3404.1 allows existing stairs to remain due to space constraints of space or pitch.

One flight of stairs was found to be a spiral metal staircase. These stairs did not meet the IBC Section 1009.9.

Bldg. 1 exterior stairs were also analyzed. Some met requirements while others were found to be noncompliant for step rise/run variability.

The interior stairs were made from poured concrete with non-slip coating. These stairs were provided with a 2” standard stair railings and handrails. Some were made of metal while others were made of wood. All stair railings and hand railings were compliant to NFPA and OSHA requirements.

However, as in Bldg. 1 many did not meet the NFPA 101-7.2.2.4.5.3 standard for spacing of balusters on stair rails and handrails.

The Bldg. 2 interior stairs were made from poured, non-slip plastic coverings, with removable stair railings and handrail. The stair rails and handrails were compliant per OSHA requirements. However, it was noted that the stairs were noncompliant for variability in step rise and run per NFPA 101 and IBC requirements. The balusters were also noncompliant for limited spacing per NFPA 101-7.2.2.4.5.3.

Several flights of stairs in areas used by maintenance personnel were found to be non-standard stairs that did not meet OSHA or NFPA requirements. These stairs appeared to be hand made from wood.

One flight of nonstandard stairs was made from wooden and was found noncompliant with IBC Section 1009.9 because they were too narrow, too steep, and had incorrect handrails.

Bibliography

City of Rockland Zoning Board of Appeals, Minutes of Meeting, http://www.ci.rockland.me.us/vertical/sites/%7BDE9EDD66-EFF4-4A6B-8A58-AA91254C1 (accessed December 08, 2016).

HQ DOE Stair Safety Meeting Decision Brief, May 13, 2104.

 

Posted in Hazard Control | Tagged , , | Leave a comment