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The Dangers of Managing Safety to the Minimum Standards


“Safety – it’s all I ever hear about anymore. I just want to build buildings and do my job.” This was a direct quote heard at a roundtable discussion with the leadership team of a large construction firm.

The days of “it’s just the way we do things around here” are gone. If a company is not penalized for OSHA compliance, it will pay for it with downtime, decreased productivity, poor safety culture and project opportunities out of reach due to tightened prequalification requirements.

Unfortunately, the approach that many companies take with regards to managing their safety and health exposure is to crack the OSHA CFR and focus on compliance. Establishing baseline compliance and maintaining it is an important activity, critical to sustainability in nearly all construction industries. However, a company can be 100 percent in compliance and still experience a “life-changing” incident and struggle with poor injury performance. Instead of compliance being the primary metric, consider shifting that mindset to commitment. Commit management and the organization to always do the right things such as pre-planning, risk assessments, inclusion of the workforce in developing safe work methods, field observations, capability verification and reducing the risks associated with tasks to the lowest possible level. These processes will yield a much greater benefit than an occasional programmed safety training or lifeless checklist.

Too many companies drive their safety culture around compliance and completing tasks such as training and inspections for outside regulatory agencies. Commitment must be purpose-driven and centered on continuous improvement. Building a “for purpose” culture that includes everyone in this continuous improvement process not only amplifies current safety efforts, but keeps it on the radar of everyone, because they can see and feel the benefit themselves.

Once consistency with these fundamentals is established, the challenge of managing compliance begins to take care of itself. Inspections are done daily because the value is evident. Work methods are regularly evaluated because the workforce appreciates the improved environment and reduction in fatigue. Companies can never ignore regulatory requirements; they must still manage their organizations by the letter of the law.

However, if the need to even be on a ladder is eliminated as a result of a risk reduction plan and engaged worker suggestion, then a worker cannot fall from it, it does not need to be inspected and workers will not be fatigued from hours of standing on it. The worker can simply move on to the next well-planned task.

For example, an employee is performing fire stopping-related work on piping penetrations in a multi-story building. He is working on a ladder, has been properly trained multiple times and is considered to be a “top” tradesman. The tooling is in acceptable condition, the SDSs are on hand and have been reviewed, the ladder was inspected at the beginning of the shift and all PPE is donned and in working order. Everything is 100 percent compliant.

However, in the installation process, a tool slips from his hand and as he tries to catch it, he loses his balance and begins to fall. His feet get tangled in the rungs and he falls face first onto the concrete deck. He suffers a fractured eye socket, a broken arm, multiple contusions and a traumatic brain injury. He undergoes multiple surgeries and months of rehabilitation, but ultimately never returns to work. Before, saying “we can’t fix stupid” or “you can’t prevent someone from making a mistake,” perhaps the better question is “could they have performed this task without having to work on a ladder in the first place”? Was there a better way to perform this task that could have minimized the risk and increased productivity?

While this is an extreme, but probable example, the cost of the approach to complete the task resulted in significant medical expenses, worker replacement, investigation downtime, lower morale and more. Although this scenario is not the norm, the potential remains the same. A competitor to this contractor capitalized on the unfortunate situation and began to focus on preventing the same outcome. The solution to eliminate this exposure resulted in an upfront cost difference of approximately $25 for materials, but generated an average of 12 minutes per hole savings, allowing the work to be performed in less than 30 seconds. This risk reduction approach eliminated the need for a ladder, as well as the strain and fatigue of overhead work. Simply satisfying OSHA compliance did not prevent this incident.

OSHA is a means of establishing minimum safe working standards and enforcing those requirements, however meeting these standards alone will not improve EMR, reduce worker fatigue or differentiate a company in a competitive marketplace. The “Best in Class” contractors recognize the difference between safety and compliance and embrace it. Establishing safe work methods involves revising the way work is done and incorporating field employees in discussing best practices. Further investigation and validation are always necessary to ensure that innovation and more expensive products provide true cost savings and improved workplace safety as a result of the reduced risk. The upfront cost savings on a cheaper style of product or failing to look at an alternative work method could eventually cost much more when labor and injury exposures are applied.

The regulations established by OSHA are minimum requirements for injury prevention, with a focus on minimum. The risk of the activity in question is not discussed in these standards and frequently is not evaluated at all. Consider elevating the approach to include focusing on risk reduction techniques to craft safer work methods. Employees will appreciate increased productivity and improved communications around additional areas of concern, resulting in sustainable opportunities to earn the next job.

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