Archive for August, 2009

A “Consensus of Concerned Interests”

Friday, August 28th, 2009
A local skateboard park… wait, this will make sense by the end of this blog. (Photo by Brian Evans, our IT manager and a park patron)

A local skateboard park… wait, this will make sense by the end of this blog. (Photo by Brian Evans, our IT manager and a park patron)

 

I came across this wonderful turn of phrase while doing some recent research in an American Society of Mechanical Engineers (ASME) standard.  It so precisely explains the what, how, and why of our nation’s non-governmental, consensus standardization process.  

Unfortunately, I’ve found that most people in the workplace who make reference to a consensus standard developed by, say, ASME, ASTM, or ASSE (I’m only naming a few) don’t actually understand the distinctions between these organizations’ documents and ANSI (the federation or “mother ship” of concerned interests).  There is further confusion when we try to delineate clear boundaries between an OSHA standard that has been taken in part, adopted in whole, or referenced to a national consensus standard such as ANSI or NFPA.

A little “consumer education” will help.  We all buy consumer products, many of which show “accredited manufacturer’s” stamps (e.g., ASTM for toy safety).  But, does the general public know what those stamps indicate?  Safety professionals will understand what a manufacturer’s tag means when it says “always wear eye protection that meets ANSI Z87.1 requirements.” But, again, do the majority of professionals understand the distinctions between ANSI and one of its accredited Standards Developing Organizations (SDO) such as ASSE?  (Note: The official numbering for the eye protection standard is ANSI/ASSE Z87.1).

This topic of standardization and consensus development could take up a whole college course – maybe even one that I’ll get an opportunity to teach someday.  Such a course is not improbable since ANSI and its SDO’s are promoting “standards education.”    

So, get off that social networking site and spend some time reading the educational information on the consensus standard websites.  It’s actually all very interesting!  I suggest starting with http://www.ansi.org/about_ansi/introduction/history.aspx?menuid=1.   There is a simpler version at http://www.ansi.org/consumer_affairs/history_standards.aspx?menuid=5.  Then check out the new ASTM F2334 – 09 for Above Ground Public Use Skate Park Facilities… and you will view the above photograph with deeper appreciation.  A standard such as this guides the construction, operation and safety equipment required at a public use skate park and is just one example of a national consensus standard for all “concerned interests.”

  • Delicious
  • Digg
  • Facebook
  • MySpace
  • LinkedIn
  • Ping
  • StumbleUpon
  • Twitter
  • Share/Bookmark

When To Flag – Virginia’s New Reverse Signal Rule

Thursday, August 20th, 2009
(An excellent example of a crew working safely within vehicle backing zones.  Photo: Jan Thomas)

(An excellent example of a crew working safely within vehicle backing zones. Photo: Jan Thomas)

See the ready mix truck on the left?  Thirty years ago, I did a fatality investigation of a worker on foot who was run over by such a vehicle.  Virginia averages two fatalities per year involving what has become known as “reverse operations.”   Sure, there are multiple causes to all such fatalities but it’s still accurate to say that we’ve been running over workers for decades because we have made pedestrians mainly responsible for their own safety. 

 

The OSHA standards (except for an exception in logging) have used what I call the “one solution” approach to keeping workers safe in a vehicle’s backing zone.   Up until now, it’s pretty much been about back-up alarms or maybe a flagger.  Three years ago, VOSH threw down the flag and started the public process to develop Virginia-specific Reverse Signal Operation Safety Requirements.  The new rule uses a multiple-strategy approach and requires action from drivers, ground guides as well as all workers on foot.  Emphasis is placed upon employee training!

VOSH starts enforcement on September 18, 2009, but don’t panic if you didn’t know about this.  The Virginia Department of Labor and Industry has developed and published excellent outreach and training materials and promises to use a phased-enforcement strategy.  When to use a designated observer or ground guide can be a complex and confusing issue but VOSH has already gone a long way to helping us understand when to flag and when to train.  Start here http://www.doli.virginia.gov/vosh_enforcement/reverse_signal.html .

By the way, a big Hi-Vis Fluorescent Yellow star goes to the contractor whose crew is shown above (I believe this is Jack L. Massie Contractors out of Williamsburg, Virginia).  Even their yellow hard hats give the drivers one last chance to spot the workers on foot.

  • Delicious
  • Digg
  • Facebook
  • MySpace
  • LinkedIn
  • Ping
  • StumbleUpon
  • Twitter
  • Share/Bookmark

Moving from Compliance to Excellence

Friday, August 14th, 2009

Circle Safety ScreenshotHere is a screenshot of our website logo and our company slogan.  Looking back on our 14 years of safety and health consulting, I can actually see how our own professional development, attitudes, practice, and recommendations to clients have moved across an arc – from a focus upon regulatory compliance to excellence as the motivation.

There are so many stories and examples of our successful work with clients.  See our client list for examples of those who have moved from worrying about OSHA compliance and are now  meeting their business goals while incorporating excellence in safety and health. 

But, our stories of failures are also illustrative.  Every once in a while we meet with company or agency managers who “want safety” and a proposal from us to “do some work.”   At Circle Safety, we try to accommodate all sizes of organizations, work cultures, management styles, and budgets.  We want to help but negotiations sometimes fail when management just isn’t ready to dedicate the time and resources or the leadership!  One of the early clues that we may not be able to help is reflected in the language being used – examples of which I just pointed out.

We, too, are a business; we seek new clients and we will usually work with anyone who needs help. Still, what we enjoy most is working with those who already envision moving toward Excellence.

  • Delicious
  • Digg
  • Facebook
  • MySpace
  • LinkedIn
  • Ping
  • StumbleUpon
  • Twitter
  • Share/Bookmark

Don’t Fall Into the “Where Does OSHA Say I Have To Do That?” Trap

Friday, August 7th, 2009
Photo – OSHA

Photo – OSHA

Every once in a while Circle Safety gets a follow-up question after one of our site hazard audits.  It usually goes like this – our client’s representative walks around with us and we all note minor and major issues as well as obvious disregard of company safety policies – some or all of which may be violations of OSHA standards.  Later, that rep calls or emails, saying there has been some pushback concerning one of our recommendations.   Someone is now insisting that we support our recommendation with a reference to a specific OSHA standard. 

 

It’s interesting to note that we are not being asked to give citations to all of our recommendations for improvements – just to someone’s special issue.   No problem.  We can usually dredge up some reference from OSHA to prove our stance to the doubter, even if we have to point to the General Duty Clause or to the VOSH ARM.

 

But, I always take this opportunity to remind our client that we were walking around making observations based upon common sense, common industrial practices, and their own written company practices.  OSHA standards are at the very bottom of our template for a safe worksite.  Sad but true.

 

I call this kind of pushback the “where does OSHA say I have to do that?” trap

 

The question shows both a misunderstanding of modern safety management practices as well as a self-limiting mind-set that started almost 40 years ago and is still being passed on.  I have some suspicion that the OSHA Outreach Classes maybe maintaining the “where does OSHA say I have to do that?” trap (but more on that later).

 

While we wait for OSHA to “reset” (and I have faith that will start to happen), I want to remind all safety professionals to continue to update their own organization’s policies and programs to track with the latest US and International consensus standards and to always use manufacturer’s safety guidelines.   And, be ready for The Trap Question by having a ready response.  Maybe something like “Joe, our company rules go beyond the minimum requirements of law – that’s what you need to focus on.”

  • Delicious
  • Digg
  • Facebook
  • MySpace
  • LinkedIn
  • Ping
  • StumbleUpon
  • Twitter
  • Share/Bookmark

Please Note: Analysis and opinions expressed are specific to the current discussion only. Different facts, changes in standards and codes, or other circumstances may lead to different results.