Potts Law Firm filed a ...
Implementing a comprehensive health & safety program
In high-risk industry settings such as water and wastewater treatment plants, safety is a primary concern. Failure to manage risk and implement policies and procedures that protect workers can exact significant tolls on a business—from lost revenue as a result of downtime to lost lives. The municipal and industrial water industry, by nature, carries many unavoidable hazards, including rotating equipment, high-voltage electrical gear, toxic chemicals, confined spaces, hazardous energy, inclement weather conditions and more. While these hazards may be unavoidable, they are not unmanageable or uncontrollable.
To that end, organizations must institute a comprehensive health, safety, security and environmental compliance program designed to ensure the well-being of each employee, the general public and the environment.
Commitment to Safety
There is no single component or driver for developing the desired safety culture. Understanding the need for a healthy and safe workforce as an integral part of conducting business has prompted many organizations to develop a health and safety (H&S) department consisting of one or more full-time professionals. This often is the first step in senior management’s commitment to workplace safety.
The added value brought to an organization by an H&S professional is immeasurable. This position typically leads to the development of policies, procedures, audits and inspections, training programs, and the like. This functional support department or position, however, also can inadvertently create a safety program pitfall if boundaries and expectations are not set, agreed upon and communicated.
In a work environment with conflicting priorities (time, resources, money, etc.), managers, front-line supervisors, and their direct reports may opt to defer day-to-day safety-related matters to the H&S department rather than accepting responsibility as a partner in safety. Many of these safety decisions are not a matter of regulatory interpretation, and, as such, would be better addressed by the person or department actually planning and completing the task.
In order to develop and maintain the desired safety culture, it is important to ensure that there is a clear understanding of the role and responsibilities of the H&S department. If this is not distinctly communicated and understood throughout the organization, the safety culture will never reach its full potential.
A suggested and proven scope definition for the H&S department stresses the following actions:
Functioning in the role of champion, the H&S professional strives to engage all employees as safety advocates. Where successful, the entire employee population accepts this responsibility, and safe work behaviors and practices become the norm. For example, an organization with 100 employees and one full-time H&S professional is far better served when it considers its staffing commitment to safety as 100 strong.
A Closer Look
A review of several municipal water and wastewater treatment systems with at least one full-time H&S professional resulted in the following observations and recommendations for further consideration:
Observation: The H&S professional is responsible for monthly inspections of safety equipment (fire extinguishers, emergency lights, eyewash stations, emergency showers, etc.).
Recommendation: Inspections should be conducted by operations or maintenance personnel. This practice familiarizes plant personnel with safety equipment operation and location. It also allows H&S professionals to work on more complex projects and matters.
Observation: The H&S professional is responsible for all routine safety training.
Recommendation: Identify non-H&S professionals who are deemed competent on various safety training topics to present or co-present Occupational Safety and Health Administration-required recurrent training (e.g., personal protective equipment, hazard communication, etc.).
For example, a well-qualified, competent electrician may be better postured and perceived as more credible to teach a short course on basic electrical safety. It is important that subject matter experts be comfortable speaking and presenting in front of an audience. H&S professionals can assist with meeting materials, such as PowerPoint presentations, speaker notes or quizzes. H&S or human resources professionals also may want to provide formal training on effective presentations so less experienced trainers are more familiar with advanced learner training techniques.
Observation: The H&S professional conducts periodic and spot job observations.
Recommendation: Implement a peer-to-peer job observation program. A successful job observation program can include scheduled, unscheduled, or a combination of scheduled and unscheduled job observations. Implement a program with scheduled job observations. The element of surprise associated with unscheduled job observations often adds to the uneasiness of those being observed and those conducting the observations. It is especially important that both parties in a peer-to-peer job observation program have a positive view of the process for program success.
As previously mentioned, best practices often are developed by those who perform the tasks. The H&S professional defines the program and conducts training on it.
Observation: The H&S professional is
responsible for incident investigation (e.g., work-related injury).
Recommendation: The injured employee’s supervisor should be assigned responsibility for incident reporting and investigation. The H&S professional provides reporting and investigation training for supervisory personnel, and takes a lead role in more complex investigations. Supervisors might take a more proactive stance on injury prevention having been subjected to the non-productive time associated with incident documentation and review.
Observation: The H&S professional promotes a safe and healthy work environment.
Recommendation: Expand H&S training and communications to include “take-home” messages and practices. Additionally, organizational leaders and managers should encourage employees to participate in a wellness program to learn about and improve their health by reducing lifestyle-related risk factors. There is increasing evidence that the overall health, safety and well-being of an organization’s employees are strongly connected. Workplaces with low risk of injury and enhanced opportunities for the total health of workers can lead to a vibrant, engaged and high-performing workforce.
In summary, a desired safety culture is the result of management commitment and employee participation. The role of the H&S department or professional is one of champion, challenge and support. Organizations and departments should not fall into the false sense of security that the safety department is responsible for worker and workplace safety. It has been said that the desired safety culture is one in which employees do the right thing—even when no one is looking.