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					Safety Management
    Safety Management

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                            Understanding the unique challenges
                            of nontraditional work environments
                                                             By Wendy D. Ash

                      T     THE AFTERMATH OF AN EARTHQUAKE, a tor-
                            nado, a hurricane or a flood. The large-scale emer-
                            gency response and cleanup of a city following a
                            disaster. These are examples of what can be called a
                            nontraditional work environment. In this context, this
                                                                                          •long work hours and extended work weeks
                                                                                       with few days off;
                                                                                          •presence of stinging and venomous biting
                                                                                       insects, snakes, alligators and other wildlife;
                                                                                          •security threats to workers from the general
                            term is generally defined as any work environment          public and the presence of weapons;
                            outside the parameters of standard occupational               •unspent munitions;
                            safety and health regulations, laws and statutes, in          •uncontrolled fires;
                            which it is not feasible to apply existing regulations        •presence of sharps, broken glass and needles;
                            to a mandatory operation or in which the situation is         •uneven/unstable walking and working surfaces;
                            so dynamic that it cannot be predicted or controlled.         •multiple simultaneous operations including
                               Traditionally, SH&E professionals deal with             heavy equipment and ground personnel working in
                            emergencies and cleanup operations in a structured         close proximity;
                            manner, with trained professionals performing tasks           •shortage of food, water or sanitary facilities for
                            that have been planned, practiced and mastered.            workers;
                            The scene of a disaster can be overwhelming and               •shortage of PPE (supply chains are strained on
                            chaotic, as hundreds of workers, employers, agen-          large-scale projects);
                            cies and volunteers descend on a site to perform              •foot, head and hand hazards;
                            multiple simultaneous tasks, each of which carries            •shortage of fuel or electrical power (OSHA,
                            countless risks. In an emergency, people are faced         2008a-d; NIOSH, 2004a, b; USACE, 2003).
                            with a mountainous task which preoccupies their               Traditional regulations, safety management prin-
                            focus—so much so that safe work behaviors may not          ciples and established safe work practices are often
                            be exercised.                                              inadequate for managing the magnitude and concur-
                                             Experience in nontraditional work         rent multiple hazards found in a nontraditional work
      Wendy D. Ash, CSP, is industrial environments and guidance docu-                 environment. Therefore, specially tailored safety and
     hygiene practice area leader/safety ments from various agencies indicate          health policies and programs must be developed,
      director with EE&G Management hidden and extreme hazards and chal-               which requires the SH&E professional to be adaptive
    Services LLC in Miami Lakes, FL. She lenges that may be present include:           and innovative in order to solve problems.
   was the primary CSP for the Orleans       •unknown chemical, biological, rad-
   Parish Project during the cleanup of iological and/or nuclear substances;           The Nontraditional SH&E Professional
       New Orleans. The 2-year project       •hazardous concentrations of dusts           In industries with established regulations, SH&E
          recorded more than 7 million and fibers;                                     professionals act as a “live guidance document,” able
      workhours and only two lost-time       •worksites that span large geo-           to recite subparts and paragraphs, and debate appli-
  injuries. Ash has more than 14 years’ graphical areas (e.g., 100 miles or more);     cation with employees and management. They are in
experience in occupational safety and        •multiple worksites, landfills, traffic   a comfort zone with the regulations and the company
health. She holds a B.A. from Western routes;                                          policies that mirror or elaborate on existing standards
 Illinois University and is a member of      •potential failure of traffic control     and laws. The traditional safety and health program
  ASSE’s South Florida Chapter, and of and city emergency systems;                     eventually reaches equilibrium—the policies have
   the Society’s Construction, Industrial    •utility failures (e.g., broken gas       been written, the training has been provided, and it is
Hygiene and Risk Management/Insur- lines, water lines, downed power lines);            primarily a matter of continuing and improving exist-
                ance practice specialties.   •heat or cold stress exposures;           ing processes to maintain a safe work environment.
20   PROFESSIONAL SAFETY JANUARY 2009 www.asse.org

                           The nontraditional work environment generally             •Workers must hand separate disaster debris           Abstract: Nontraditional
                       unfolds in three stages; rescue, recovery and             known to contain used hypodermic needles (OSHA,           work environments often
                       cleanup. Each stage requires a different method of        2008d).                                                   require a departure from
                       management, a different approach to hazards and a             •An abandoned car containing an active bee hive       the ideals, methodologies
                       fresh perspective on operations. New hazards and          must be moved and the services of a pest control          and regulations employed
                       challenges arise constantly and each new step in the      expert are not available (OSHA, 2008a).                   in traditional work envi-
                       operational process presents a new list of tasks—             •A task that can only be performed safely if it is    ronments. The tasks
                       each of which is operationally required to meet the       performed carefully, whereby equitable hazard con-        required in these environ-
                       goal—to be analyzed.                                      trols (“Hierarchy” sidebar, p. 22) are not enough to      ments are unusual in that
                           Traditional safety and health practices dictate the   protect personnel from harm, are not practical or         the operation or goal
                       use of Level A PPE in the face of unknown hazards,        would significantly impede performance of a neces-        cannot be abandoned
                       which are treated as immediately dangerous to life        sary operation (OSHA, 2008a).                             even when it is deemed
                       and health (IDLH) [OSHA, 29 CFR 1910.120(c)(5)(iii)].         When the operation must be performed and the          unsafe by conventional
                       In the author’s experience, such measures are not fea-    hazard cannot be removed, traditional safety practices    measures. To prevent
                       sible in the aftermath of a disaster and would signifi-   may hold that proceeding would essentially be the         injuries and illnesses,
                       cantly impede rescue and recovery operations. This is     same as condoning injury. When charged with design-       employers and SH&E pro-
                       likely the most difficult paradox in bridging the gap     ing methods to protect personnel in a nontraditional      fessionals involved with
                       between traditional safety practices and those neces-     work environment, those involved must approach            these projects must
                       sary at the scene of a disaster.                          those challenges methodically, with a good degree of      design, institute and
                           Traditional SH&E programs mandate that work           humility and the use of collaborative operational safe-   enforce specialized poli-
                       not be performed when it is inherently unsafe or          ty. Operational safety is accomplished when person-       cies to maintain the high-
                       could cause harm to the employee performing the           nel responsible for operations and those responsible      est standards of safety in
                       work or others nearby. SH&E programs traditionally        for safety and health advocate the necessity of each.     the midst of seemingly
                       strive to identify and remove each hazard or reduce           Although operational safety is not new to the tra-    insurmountable risks.
                       it to an acceptable level. In other words, both the       ditional work environment, such a symbiotic rela-
                       work environment and the operation are frequently         tionship is critical in the nontraditional work
                       controlled by the focus of safety for the workers. This   environment. Although many industries have inher-
                       is the traditional application of operational safety.     ent risks, many SH&E professionals and operational
                           In a nontraditional work environment, however,        managers are not accustomed to the extreme haz-
                       the operation, the hazard, the work and the work          ards present following a disaster. One must remem-
                       environment may not be controllable—and often the         ber that these risks affect not only the workers, but
                       operation cannot be avoided. This concept is foreign      may also present significant liability risks and poten-
                       to traditional safety and health strategies. Imagine      tial long-term legal costs for employers and agen-
                       the following nontraditional scenarios:                   cies. A strong safety and health program with a low
                                                                                                   www.asse.org JANUARY 2009 PROFESSIONAL SAFETY             21
 Hierarchy of Safety & Health Controls
 The controls in this hierarchy are presented in order of effectiveness.
     1) Elimination or substitution. Whenever possible, eliminate the hazard from the work area (e.g., repair or remove fallen
 electrical power lines before allowing other work to proceed in the area). Although desirable, elimination and substitution
 may not be options for most airborne/chemical hazards created by a natural disaster.
     2) Engineering controls. Examples include guarding pinch points associated with a machine’s moving parts; providing
 ventilation to a permit-required confined space; using heavy equipment with temperature-controlled cabs; and placing barri-
 ers around the swing radius of rotating heavy equipment.
     3) Warnings. Examples include odor in natural gas; signs and labels; backup alarms; and beepers and horns.
     4) Training and procedures; administrative controls. Use well-rested crews and daylight hours to perform higher hazard
 or unfamiliar tasks. Take frequent breaks during hot weather. Remove nonessential personnel from the area during certain
 task/operations. Decontaminate equipment and personnel after contact with contaminated floodwater or chemicals. When
 possible, use water to suppress dust and work upwind in dusty conditions. Where extensive hot work is performed in the
 form of cutting and burning, use extended-length torch handles to increase the distance from the individual’s breathing zone
 to the generation of toxic fumes.
     5) PPE. Examples include use of safety glasses, ear plugs, face shields, safety harnesses and lanyards, respirators and
 snake chaps. If other controls are not available, not feasible or do not provide sufficient protection, select and use PPE appro-
 priate for the hazard and level of exposure. OSHA provides additional assistance on PPE selection and use.
 Note. Adapted from “Hurricane eMatrix: General Recommendations—Hazard Control,” by OSHA, 2008, Washington, DC: U.S. Department of
 Labor, Author.

                      injury rate will create significant credibility and help     far as possible into the nontraditional work environ-
                      protect against future legal concerns.                       ment to protect life and health, but the unpredictable
                          In the nontraditional situation, the SH&E profes-        gaps between existing conventions and the nontra-
                      sional must act as a scientist, an analyst, a diplomat,      ditional conditions must be bridged in real time.
                      a policy maker and a regulator. This requires a depar-       Hazards must be evaluated and policies must be in
                      ture from traditional roles. In disaster recovery work,      place in a matter of hours or days, unlike traditional
                      the only clearly defined guidance may be that writ-          laws that are forged over years. The absence of
                      ten by the SH&E professionals and project leaders as         directly relevant regulations does not remove the
                      a means of protecting personnel under unusual cir-           obligation to provide a safe work environment.
                      cumstances. SH&E personnel must leave their com-                 While many issues cannot be abated by tradition-
                      fort zone and adapt to intuitive and practical               al policies, those policies are an essential resource.
                      emergency field procedures, personnel training and           Existing guidance—whether from research organi-
                      collaborative administrative management of safety            zations, laws, industry guidelines, guidance from
                      and health plans. They must also adapt on many               previous disaster response efforts, or guidance from
                      other levels, ranging from methods of hazard analy-          similar applications in other industries or countries
                      sis to methods of achieving compliance. The nontra-          —can facilitate the process of identifying potential
                      ditional work environment includes tasks, personnel          hazards and developing creative methods for avoid-
                      and policies, each also nontraditional.                      ing injuries. Ideally, the SH&E professional will be
                                                                                   familiar with safety and health requirements in most
                       Emergency Field Procedures                                  industries and organizations.
                           Existing occupational safety and health regula-             Appreciating and understanding similar safety
                       tions, guidelines and consensus standards reach as requirements in other applications is the first step in
                                                                                              designing a safety and health code for a
                                                                                              nontraditional setting. The SH&E pro-
 Figure 1
      Figure 1                                                                                fessional must understand the intent or
                                                                                              spirit of the conventional law and its
 National Incident Command System                                                             application in order to intuitively design a
                                                                                              nontraditional application of those con-
                                        Incident                                              ventions to establish hazard controls.
                                      commander                  Incident                        With the concept of operational safety
                                                              safety officer                  in mind, a policy can be created through a
                                                                                              type of reverse job hazard analysis.
                                                       Command                                Similar to proofreading a document by
                                                            staff                             reading it backwards, the reverse job haz-
                                                                                              ard analysis allows the SH&E profession-
                                                                                              al to focus on each task element and
                                                                                              anticipate potential risks. The task or
                                                                     Administration/          operational goal is placed at the beginning
    Operations              Logistics           Planning
                                                                          finance             and the analysis is defined step-by-step
                                                                                              backward toward the employee perform-
 Note. Adapted from Protecting Emergency Responders (NIOSH Publication No. 2004-144)          ing the task. The analysis must consider
 (Figure 3.2), by NIOSH, 2004, Washington, DC: Department of Health and Human Services,       the worst possible scenario and modify
 CDC, Author.                                                                                 operation methods and hazard controls
                                                                                              (above) until the least hazardous condi-
22   PROFESSIONAL SAFETY JANUARY 2009 www.asse.org
tion exists while maintaining the same operational authorities is encouraged, even when their jurisdic-
outcome. The preliminary methods are then dis- tion does not apply or has been temporarily sus-
cussed and refined with operational leadership.          pended due to a national emergency. Acceptance of
    When designing new policies, SH&E profession- the project’s safety and health policies by these
als must gather data concerning the physical, chem- authorities provides many important benefits. For
ical and other hazards in the work environment, example, including OSHA and EPA in the process of
then write “virtual” policies, where the safe work designing emergency field procedures lends credi-
practices are developed before the work is per- bility to those policies and plans, and it avails the
formed. Those policies would then be placed into project of the knowledge held by national experts.
the operational process, per-
sonnel would be properly
trained and the task would be         Lessons Learned: The Author’s Experience
analyzed for safety practice
efficiency. In most cases, the        Following Hurricane Katrina
SH&E professional actually              Challenge: Trucks hauling debris to landfills were prone to rollover, largely because of
designs the methods of opera-       unstable ground, unleveled loads (loads were often wet and adhered to truck beds) and the
tion through the safety prac-       weight of materials inside the truck beds, which differed greatly and created uneven
tices employed.                     weights on areas of the truck bed.
    The use of administrative       Rollovers occurred in transit to the
controls and PPE are generally      landfills as well as during the dump-
paramount in the process.           ing process at the landfill.
SH&E professionals should not           Correction: The hazard of rollover
be afraid to introduce signifi-     in transit was controlled through the
cant PPE to the program when        use of training and administrative
the potential hazard involves       controls. Haulers were required to
the unknown. However, such          maintain low speeds and avoid sharp
PPE should not be required to       turns, and loaders were required to
such a degree that employees        distribute load weights as evenly as
will simply not use it because      possible when placing debris within
of extreme discomfort or if its     the truck bed.
use presents a greater hazard.          The hazard of rollover during
    When analyzing the virtual      dumping at the landfill could not be
policy, one must consider not       adequately controlled. Therefore, an
only its effectiveness from a       administrative control was initiated.
safety perspective, but also the    It required that two truck bed

operational practicality and effi-  lengths be maintained between
ciency of the safety practices.     trucks dumping at the landfill, there-
                                                                                 Residential debris, such as that in Orleans Parish, New
Frequently, an analysis of the      by removing personnel and equip-
                                                                                 Orleans, LA, following hurricanes Katrina and Rita had
process in the field will require   ment from the hazard zone. This
some modification of the policy.    control was maintained through fre- to be hauled to landfills, which created many hazards.
Similarly, the process must be      quent training and the use of flaggers and spotters at the dump sites to control distance
continually monitored, as the       between trucks dumping.
needs for PPE will change as the        Challenge: The number of safety corrections necessary each day in the beginning of the
project evolves. It is during       project were difficult to manage in terms of maintaining a metric for performance and also
these stages that the initial       to put the severity of the deficiencies into perspective for project management. With thou-
extensive use of PPE may be         sands of personnel on the ground working in many different tasks and disciplines, the
adjusted to the most practical      number of monitored safe work practices was very high. Project personnel on all levels
level. It is important to remem-    needed a manageable way to place a hierarchy on safety concerns to better understand risk.
ber that no policy will fail faster     Correction: The project safety team instituted the use of risk assessment codes (RACs)
than one that is difficult to apply (U.S. Navy, 2002). Each safety hazard was analyzed and placed into a category as follows:
or severely impedes operations.         •RAC 1: Critical risk (e.g., electrical, chain saw, other hazards that could cause death or
    All nontraditional policies     critical injury).
must be documented and                  •RAC 2: Serious risk (e.g., climbing on trucks, flagger work practices, ground personnel
agreed upon by the relevant         working too close to heavy equipment, other hazards that could cause serious injury).
entities involved in performing         •RAC 3: Moderate risk (e.g., failure to wear PPE, equipment in disrepair, other hazards
the work. Whether compliance        that could cause injury).
is by contract or a condition           •RAC 4: Minor risk (e.g., failure to correct requested deficiencies, failure to use proper
of employment, the vehicles         temporary traffic control devices, other hazards that could contribute to injury).
of compliance must be clearly           With the use of the RAC system, personnel projectwide were able to better understand
defined and accepted. In addi-      the type and severity of the deficiencies. Later in the project, these metrics were used for
tion, collaboration with local      crew safety record evaluation for administrative decisions.
and federal safety and health
                                                                              www.asse.org JANUARY 2009 PROFESSIONAL SAFETY            23
                       Such collaboration also helps avoid future barriers           Generally, the sooner SH&E personnel are
                       when traditional authorities assume jurisdiction involved in this process, the better. Ideally, a senior
                       over the nontraditional environment.                       project SH&E professional will be introduced when
                                                                                  the incident command system, also known as the
                       SH&E Programs                                              National Incident Command System (Figure 1, p.
                          In general, the systems needed to protect person- 22), is initiated (NIOSH, 2004b). When SH&E per-
                       nel in the nontraditional work environment are sonnel are involved early on, they can begin collect-
                       similar to those found in the traditional work envi- ing industrial hygiene and safety data to establish
                       ronment. Their shared goal is to control hazards, baselines for environmental and worker impact.
                       employ safe work practices and reinforce safe work These data can then be used to design safe work
                       behaviors. The programs require written plans that practices that will set the pace for the safety program
                       encompass both the traditional and nontraditional throughout the project.
                       aspects of the tasks, including detailed job hazard           Successful nontraditional safety and health
                       analyses (USACE, 2008). In the nontraditional envi- programs have included the following elements
                       ronment, a balance must be achieved between the (OSHA, 2008a-d; NIOSH, 2004a, b):
                       necessity of the operations and worker safety.                •defined worksite(s);
                                                                                     •early identification of existing hazards and anti-
                                                                                            cipation of pitfalls;
 Figure 2
      Figure 2                                                                                  •detailed site orientation for new
 Risk Assessment Code Explanations                                                              •defining worker roles and maintain-
                                                                                            ing consistent roles for workers day to day;
    1) Hazard severity. The hazard severity is an assessment of the worst reason-
 ably expected consequence, defined by degree of injury or occupational illness                 •microworksites or work zones that
 that is likely to occur as a result of a hazard. Hazard severity is based on the fol-      designate established operations, tasks
 lowing criteria:                                                                           and compliance requirements;
    a) Category I - Catastrophic: The hazard may cause death.                                   •establishment of PPE-free zones
    b) Category II - Critical: May cause severe injury or severe occupational illness.      where workers can remove PPE, rest, eat
    c) Category III - Marginal: May cause minor injury or minor occupational illness.       and drink;
    d) Category IV - Negligible: Probably would not affect the safety or health of              •a sufficient number of clean restrooms;
 personnel, yet is a violation of a safety and health regulation applicable to this             •collaboration between operations per-
 contract.                                                                                  sonnel, SH&E professionals and govern-
    2) Mishap probability. The mishap probability is the probability that a hazard          mental authorities in designing safety
 will result in a mishap, based on an assessment of such factors as location, expo-         programs and communicating opera-
 sure in terms of cycles or hours of operation and affected population. Mishap              tional needs;
 probability is based on the following criteria:                                                •traffic control plans and established
    a) Subcategory A - Likely to occur immediately;                                         traffic routes, including proximity policies
    b) Subcategory B - Probably will occur in time;                                         for ground personnel, vehicles, trucks and
    c) Subcategory C - Possible to occur in time;                                           heavy equipment;
    d) Subcategory D - Unlikely to occur.                                                       •clearly defined safety policies for each
    3) Risk assessment code (RAC). RAC is an expression of risk that combines               task to be assigned;
 the elements of hazard severity and mishap probability. Using the matrix below,                •job-specific safety training;
 the RAC is expressed as a single Arabic number that can be used to help deter-                 •clearly defined administrative poli-
 mine hazard priorities.                                                                    cies concerning safety compliance and
                                                                                                •routine safety compliance audits of
                                                                                            each task to establish safety compliance and
                                                                                            analyze the practicality and operational
                                                                                            efficiency of safety requirements;
                                                                                                •immediate correction of unsafe work
                                                                                                •use of risk assessment codes to prop-
                                                                                            erly classify safety hazards and make
                                                                                            them easier to understand (Figure 2);
                                                                                                •documentation of safety compliance
                                                                                            by risk assessment code for analysis of pro-
                                                                                            gram compliance;
                                                                                                •routine safety briefings associated
                                                                                            with the most common safety compliance
 Note. Adapted from Hazard Abatement Processing and Tracking. Navy Occupational             challenges;
 Safety and Health Program Manual (Chapter 12, Section 1202), by U.S. Navy, 2002,               •investigation and documentation of
 Washington, DC: Department of Defense, Author.                                             incidents, injuries and near-hits for expe-
                                                                                            dient administrative and corrective action;
24   PROFESSIONAL SAFETY JANUARY 2009 www.asse.org
   •frequent communication between safety and             tions), employees
operational personnel concerning each incident of         must be repeated-
concern (e.g., safety corrections, security concerns,     ly guided toward
identified hazards);                                      safe work prac-
   •empowering SH&E professionals, supervisors            tices because in
and quality control personnel with authority for pro-     these situations
gram implementation and enforcement, and identi-          people are typi-
fying them through signage or color coding on             cally focused on
safety vests or hardhats so that they are easily recog-   operations.
nizable to workers;                                           The nontradi-
   •where multiple SH&E consulting firms are              tional work envi-

                                                                                                                                                  ANDREA BOOHER/FEMA
operating on the site, project leaders establish source   ronment will also
for the development of projectwide safety policies        present conditions
and implement policies with a unified top-down            rarely found in
approach.                                                 traditional work
   Policies and programs must be applied consis-          environments.
tently and well communicated throughout the               These include the
worksite. For example, the uses and applications of       need for food and water, sleeping quarters, bathing        Providing basic
various types of PPE for different tasks can be con-      facilities and sanitary facilities. Therefore, SH&E pro-   provisions, such as
fusing if not clearly defined, understood and fol-        fessionals must at times focus on these fundamental        food and water,
lowed equally by all personnel on the jobsite.            human needs. Providing basic provisions or access to       sleeping quarters,
Defining work zones where PPE is required can help        them is critical. SH&E personnel should also consider      and bathing and sani-
delineate policy requirements.                            the emotional health of workers during rescue-and-         tary facilities, is criti-
   Ideally, policy designers—who are the project lead-    recovery operations, training workers and supervi-         cal in a nontraditional
ers of both the safety and operations branches of the     sors to recognize the signs of significant fatigue,        work environment.
worksites—will remain involved in the process on a        posttraumatic stress disorder and other stress-in-
daily basis for the project’s duration. This consistent   duced conditions.
leadership ensures a continuity of policy, practice and       Additionally, training must be reinforced daily,
enforcement. As new jobs and new safety policies are      which includes immediately correcting unsafe work
introduced, communication, repetition and the contin-     behaviors and holding regular safety briefings to
ual presence of SH&E professionals are among the key      reiterate information covered during employee ori-
elements of success.                                      entation and job-specific training. As the project
                                                          evolves, changes to safe work practices must be
                                                          repeatedly communicated to personnel as well.
Employees & Safety
                                                              Employees should be included in the creation of
    Employees in the nontraditional work environ-
                                                          the emergency field procedures. They can provide
ment differ from traditional workplace employees in
                                                          valuable input on a task’s operational challenges and
many ways. They face significant physical, emotion-
                                                          how safety procedures may affect the overall efficien-
al and psychological stressors. They work in difficult
                                                          cy of the process. Ultimately, the workers determine
surroundings, often for many hours with few days
                                                          the success of the program, so collaboration with the
off, and they must perform work that is labor-inten-
                                                          workforce should be a goal of SH&E personnel.
sive, unique to the worker and stressful. In addition
to learning new tasks in such an environment, per-        Safety Compliance & Enforcement
sonnel are learning new safe work practices and               Compliance is often viewed primarily as a way to
wearing PPE to which they are unaccustomed.               avoid legal and administrative penalties, so it may
    In this environment, it can be difficult to distin-   be easy to lose sight of its real purpose. Instead, com-
guish between compliance-avoidance behavior and           pliance must be viewed as critical to avoiding injury.
a flaw in the task’s safety design. Therefore, supervi-       In the nontraditional environment, SH&E profes-
sors and SH&E personnel must continually monitor          sionals must take a more active role in solutions.
employees for special issues such as signs of fatigue,    If the goal of the operation is a part of the profes-
heat or cold stress, repetitive motion injuries and       sionals’ domain, so too is the task of ensuring
proper fit (and the need for) PPE. When new safety        compliance. During a disaster response, SH&E profes-
policies are introduced, those policies must be com-      sionals are not just consultants, they are also problem
municated repeatedly and through different modes,         solvers. To succeed, they cannot be hindered by tradi-
such as briefings, safety stand-downs and toolbox         tional concepts that safety is the responsibility of the
meetings.                                                 employer and they cannot be viewed as the enemy.
    Safety stand-downs—during which project opera-        During the rescue and recovery phases of an opera-
tions stop until a projectwide safety briefing can be     tion, compliance is sought by any means necessary—
held—should be used only when a severe incident           even if that includes following workers around the
has occurred or is considered imminent due to rec-        jobsite distributing PPE and providing one-on-one
ognized trends in operations or unsafe work behav-        retraining in safe work behaviors.
iors. During emergency or other high-stress                   When the operation transitions to a cleanup effort,
nontraditional activities (e.g., rescue stage of opera-   the level of urgency is tempered and the program
                                                                             www.asse.org JANUARY 2009 PROFESSIONAL SAFETY                25
                                             assumes a more organized routine.            owned or operated by their employers. SH&E pro-
                                             While the risks remain, the processes        fessionals in these environments must redefine their
                                             surrounding them can be better con-          ideals and methodologies, as well as their concepts
                                             trolled due to a slower, more structured     of risk management and perceived outcomes of haz-
                                             pace. When well-defined policies are in      ards. In essence, they are using “raw safety” and
                                             place, approved and accepted by each         making a transition from concrete to abstract think-
                                             employer, job hazard analyses have           ing. Through operational safety, the safety and
                                             been evaluated in practice and refined       health professional becomes part of the team—no
                                             for the most efficient and operationally     one makes decisions alone.
                                             effective practices (USACE, 2008), train-       In both traditional and nontraditional work envi-
                                             ing and retraining has been provided to      ronments, SH&E personnel must interject themselves

                                             program personnel, then administrative       into the process. They must bridge the gap between
            Receding flood     enforcement is the necessary next step.                    worker safety and meeting operational goals. SH&E
          waters following        No safety program is complete or effective without      professionals must strive to be an integral resource to
         hurricanes Katrina    enforcement. Enforcement is not only a means of gain-      help employers meet operational goals wisely.
       and Rita left a great   ing compliance, but it is also a necessary component of    Regardless of the work environment, it remains the
          amount of debris     a safety program that aims to reduce the injury rate. If   responsibility of SH&E professionals to adapt and
        and residual solids    the goal of enforcement is to influence compliance and     seek innovative ways to protect the most significant
       throughout Orleans      avoid injuries, then it should take on many forms and      aspect of any mission and the most valuable resource
             Parish in New     be accomplished through multiple techniques.               of any operation—those performing the work.
                   Orleans.       Enforcement practices in the field are not just for
                               the purpose of documenting deficiencies, they              References
                               should also be used to correct unsafe work behav-              NIOSH (2004a). Integrated incident-wide safety management.
                               iors. Optimal enforcement in the nontraditional            Protecting emergency responders (NIOSH Publication No. 2004-144,
                                                                                          Chapter 7). Washington, DC: Department of Health and Human
                               work environment may include the following                 Services (DHHS), CDC, Author. Retrieved Feb. 25, 2008, from
                               (NIOSH, 2004a; b):                                         http://www.cdc.gov/niosh/docs/2004-144/chap7.html.
                                  •regular patrols of the worksite by SH&E per-               NIOSH. (2004b). Protecting responder safety within the inci-
                               sonnel to collaborate with workers and supervisors         dent command system. Protecting emergency responders (NIOSH
                                                                                          Publication No. 2004-144, Chapter 3, Figure 3.2). Washington, DC:
                               to resolve emerging hazards;                               DHHS, CDC, Author. Retrieved Feb. 25, 2008, from http://www
                                  •enforcement of safety requirements at and by all       .cdc.gov/niosh/docs/2004-144/chap3.html#fig32.
                               levels and branches of the project (e.g., operations           OSHA. (2005). OSHA/NIOSH interim guidance: Chemical,
                               personnel enforcing safety regulations);                   biological, radiological, nuclear personal protective equipment
                                                                                          selection matrix for emergency responders. Washington, DC: U.S.
                                  •documentation of safety corrections made by            Department of Labor (DOL), Author. Retrieved Feb. 25, 2008, from
                               SH&E personnel in the field (on the spot);                 http://www.osha.gov/SLTC/emergencypreparedness/cbrnma
                                  •communication of corrected deficiencies to             trix/index.html.
                               worksite supervisors at the time of the correction;            OSHA. (2007a). Emergency preparedness and response:
                                  •written enforcement policies using risk assess-        General recommendations for working in all impacted areas.
                                                                                          Washington, DC: U.S. DOL, Author. Retrieved Feb. 25, 2008, from
                               ment codes that are clearly understood by personnel;       http://www.osha.gov/SLTC/etools/hurricane/recommenda
                                  •focus on the number of safety corrections rather       tions.html#manual.
                               than the number of safety deficiencies (information            OSHA. (2007b). Emergency preparedness and response:
                               that can be used to determine the practicality of a        Responders. Washington, DC: U.S. DOL, Author. Retrieved Feb.
                                                                                          25, 2008, from http://www.osha.gov/SLTC/emergencyprepared
                               safety requirement);                                       ness/responder.html#Safety.
                                  •employer initiated disciplinary action for recidi-         OSHA. (2008a). Hurricane eMatrix: General recommenda-
                               vist noncompliance (where retraining and other             tions—Animal bites, stings and aggressive behavior. Washington,
                               administrative actions have been ineffective).             DC: U.S. DOL, Author. Retrieved Feb. 25, 2008, from http://
                                  SH&E professionals in the nontraditional work           www.osha.gov/SLTC/etools/hurricane/recommendations.html
                               environment should not have a direct role in disci-            OSHA. (2008b). Hurricane eMatrix: General recommenda-
                               plinary action in response to noncompliance, and           tions—Hazard control. Washington, DC: U.S. DOL, Author.
                               such actions should be used by employers only after        Retrieved Feb. 25, 2008, from http://www.osha.gov/SLTC/
                               other enforcement methods fail.                            etools/hurricane/recommendations.html.
                                                                                              OSHA. (2008c). Hurricane eMatrix: List of activity sheets.
                               Conclusion                                                 Washington, DC: U.S. DOL, Author. Retrieved Feb. 25, 2008, from
                                  This discussion has only touched on some ele-           #waste.
                               ments of nontraditional work environments, which               OSHA. (2008d). Hurricane eMatrix: Waste/debris removal and
                               are becoming more commonplace. These environ-              reduction, debris collection. Washington, DC: U.S. DOL, Author.
                               ments range from personnel working in the                  Retrieved Feb. 25, 2008, from http://www.osha.gov/SLTC/
                               aftermath of disasters to emergency operations per-            U.S. Army Corps of Engineers (USACE). (2003). Safety:
                               formed by fire protection and law enforcement per-         Safety and health requirements. Retrieved Feb. 25, 2008, from
                               sonnel, from military personnel working in a war           http://www.usace.army.mil/publications/eng-manuals/em385
                               zone to emergency medical and rescue personnel             -1-1/toc.htm.
                                                                                              U.S. Navy. (2002). Hazard abatement processing and tracking.
                               working in the field. They also include work per-          Navy Occupational Safety and Health Program Manual (Chapter 12,
                               formed in personal residences (that of employees or        Section 1202). Washington, DC: Department of Defense, Author.
                               the general public) or in industrial environments not      Retrieved Feb. 25, 2008, from http://www.safetycenter.navy.mil.
       26   PROFESSIONAL SAFETY JANUARY 2009 www.asse.org

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