Letters

Responsibilities will always outpace roles

In the 2013 Job Outlook article (May 2013), I noticed some individuals may place much value in a title.

I’m in my 50s and I guess I’m just not impressed with titles, rock stars, politicians or the IRS anymore. No matter what our title or position is within our organization, even CEO, our responsibilities will always outpace our roles and authorities.

Great article – thank you.

Wayne Holt
Sr. HES Professional
Gulf of Mexico Asset Team, Marathon Oil Co.
Lafayette, LA

I2P2 should not be a government mandate

In the article titled “Michaels: I2P2 remains OSHA’s No. 1 priority” (“In the News,” April 2013), Michaels is quoted as saying: “Employers who use safety management systems experience ‘dramatic’ decreases in workplace injuries, accompanied by a transformed workplace culture that leads to higher productivity and quality, reduced turnover, reduced cost, and greater employee satisfaction.” Michaels then went on to say, “Now it’s time to take this message from the best to the rest.”

It is true that employers with safety management systems have more positive outcomes in safety. Employers with these well-functioning safety management systems have them because these employers have safety professionals on staff. Safety professionals first designed safety management systems to leverage ourselves, being few in number, across the management leadership and the employees. Safety management systems produce better safety outcomes not just because of safety professionals but because of the interaction between management leadership, employees and the safety professional staff that the safety management systems foster.

Visualize a three-legged stool. All three legs have to be in place for the stool to fulfill its function.

OSHA has chosen to embrace safety management systems as though they were OSHA’s invention. They were not OSHA’s invention, and OSHA does not have the option to mischaracterize what they were designed for and why. That is what Michaels is doing with the last portion of his statement: “Now it is time to take this message from the best to the rest.”

How are the “best” different from the “rest”? Safety professionals! The “rest” do not have safety professionals or do not have them onsite supporting the system every day. For safety management systems to be sustainable and produce great safety outcomes, they system requires relentless support, daily. It is estimated that of the 7.5 million worksites that OSHA says are covered by the OSH Act, only 1-2 percent have any daily safety staff support. The third leg of the stool is missing in the “rest” – which is 7.3-7.4 million worksites.

That is why written hazard communication programs still are in the Top 10 OSHA citations each year. Written lockout/tagout programs/procedures for the same reason. California’s version of I2P2 produced better safety? No. Just a new No. 1 in annual citations. And California then tried to “dumb down” its I2P2 version to try to make it workable by the sites without safety professionals. Not!

Safety management systems are not appropriate to be mandated by the government [because]:

1. Sites that have safety professionals don’t need it – as Michaels implies.
2. Those 98-99 percent of worksites that don’t have safety professionals will be unable to implement safety management systems and sustain them for safety results.
3. Safety management systems are entirely site-specific. The government will not be able to mandate a system that is greatly influenced by other workplace systems that are not safety-related and for which the government has no competence. Safety professionals, on the other hand, live in those systems and can design and adapt their safety management systems to them. Who will do that at the 98-99 percent of worksites that have no safety professionals?

Increased citations and fines and shaming press releases will be the only outcome of this government mandate. Minimal, if any, safety improvements.

Tom Lawrence, CSP, P.E.
Ballwin, MO

California FACE program responds to letter

The staff at the California Department of Public Health, California Fatality and Control Evaluation program would like to respond to a letter published in the June 2013 issue in regards to FACE Report #10CA010 (“FACE Value,” April 2013) summarizing a California FACE report about a wood chipper-related fatality.

We want to thank the letter’s author for reviewing and commenting on the case. The report from which the article was developed was written by the staff at the California FACE program, which is one of nine state-based FACE programs that receive funding from the National Institute for Occupational Safety and Health. The findings and conclusions in the report are those of the California FACE program and do not necessarily reflect the views or policy of NIOSH.

The comments by the author address an important point in regards to one issue of wood chipper safety: emergency shutoff switches. The author points out that the report ?highlighted in the article does not contain a recommendation regarding emergency shutoff switches. The chipper involved in the incident did have an emergency feed-roller stop bar at the end and around the sides and top of the feed chute. Therefore, no recommendation regarding a feed-stop roller could be made. The author may have been referring to a whole machine emergency shut-down switch that would actually stop the chipper engine and so de-energize the entire machine. Such a recommendation was cosidered. However, based on the machine type and the time it takes for the chipper disc to spin down, the rapidity and forcefulness of the movement that produced the injuries found at autopsy, and other incident site findings, shutting down the entire machine probably would not have prevented the fatality.

The California FACE program has investigated and published reports on five wood chipper-related fatalities. In one case, a chipper had no feed-roller stop system or emergency shut-down switch. In that case, the California FACE program made a recommendation for the inclusion of stop systems on chippers. Four of the fatalities involved chippers with feed-roller stops. In those four cases, the victim was unable to engage the feed-roller stop located on the feed chute, and whole machine emergency stop systems would not have prevented the deaths. These deaths highlight the importance of having a stand-by worker at the feed chute who is able to stop the rollers or shut down the machine when – or even before – a worker is entangled. These cases also highlight the work by manufacturers to include stop systems that will not require a positive action on the part of the worker to stop the system. Systems currently exist in Europe, using radio frequency tags that stop chippers whenever a worker wearing radio frequency ID-tagged clothing is pulled into a feed chute. As workers continue to be injured and killed in wood chipper-related incidents, attention to this problem should lead to improved engineering-based solutions as well as safer work practices.

Robert Harrison, M.D., MPH
Chief, Occupational Health Surveillance and Evaluation Program
Occupational Health Branch
California Department of Public Health
Richmond, CA