Commit to Safety

EP Editorial Staff | September 12, 2016

An injury-free workplace should be ingrained in all daily functions and fully supported at all levels of the company.

By Al Poling, CMRP, RAM Analytics LLC

Maintenance workers are exposed to countless hazards every day. Historically, injuries were considered inevitable, a result of risk associated with certain types of work. Many believed that injuries were a natural consequence of the industries in which we chose to work (in my case, chemicals, petrochemicals, and refining). It wasn’t until I lost a coworker that I not only recognized that injuries could be prevented, but committed myself to the concept of injury-free performance.

As with the overwhelming percentage of workplace deaths, my coworker had violated critical safety protocols. While there’s no antidote for poor judgment and, therefore, no guarantee that injuries will be prevented, adopting the proven maintenance-safety best practices outlined here will reduce risk and lower the probability of such incidents.

Importance of leadership

Achieving injury-free performance requires exploiting every opportunity to reduce risk and, thereby, avoid injuries. Committing to that type of performance, though, calls for leadership, something that often seems to be lacking when it comes to safety.

To reach world-class levels of safety performance in a plant or facility, there must be a heartfelt belief throughout the operation that injuries are preventable. Although some individuals may claim to have no control over it, success—or failure—isn’t a matter of happenstance. Safety really is everybody’s responsibility. Leaders, however, personally set an example for this responsibility; they don’t delegate it.

Remember that workers emulate their leaders. Accordingly, leaders must be visibly committed to injury-free performance. Any weak link, either a salaried or hourly person, will jeopardize the entire effort. Individuals who fail to comply must be dealt with swiftly and effectively. More to the point, safety deviations, i.e., behavioral non-compliance, aren’t to be tolerated—anywhere—in an operation.

Safety leadership begins with a clearly articulated vision: injury-free performance. This vision must be communicated, continually reinforced, and supported by expectations that align with the desired result. Consider the following aspects of a complete safety program.

Safety can’t be bought. Resist the temptation to buy the latest off-the-shelf safety program or methodology. Also avoid the flavor du jour practice of taking different trendy approaches to safety and hoping one or more catches on. Hope is not a strategy. Workers will see through these schemes and, consequently, won’t take safety seriously.

Leaders, however, must be willing to allocate resources, i.e., auditors, technicians, and supervisors, to drive safety improvement. Although all workers can have a profound effect on safety, they must be empowered, as well as encouraged, to intervene if they perceive unacceptable risks.

People must be held accountable. Safety goals and objectives begin at the top and provide a means to hold people accountable. To be effective, objectives must be specific and measurable. While they begin with top management, these objectives must cascade down through the organization to the shop floor. Performance evaluations, in turn, should include a review of safety-performance objectives. Individual accountability is imperative if risks are to be mitigated and injuries are to be avoided.

While management and supervisory personnel should be rewarded for positive safety performance, there also must be consequences for failing to deliver safe performance. That means every level of management must be held accountable—without exception.

Individual workers must be held accountable. Positive behaviors should be reinforced through recognition and reward. Conversely, unsafe behaviors must have consequences, including termination, if warranted. Ultimately, everyone at a site must be held accountable if injury-free performance is to be achieved.

Policies and procedures are crucial. Policies are strategic and set expectations. Procedures are tactical and specify actions. Procedures should be written and verified by people with “real world” experience. Garner input from workers who will be subject to the respective procedure.

Policies and procedures must be audited to ensure they are being followed. Policies must clearly state their objective, e.g., isolation of energy sources in a lockout/tagout (LOTO) procedure. A policy or procedure should be evaluated based on how well it meets its stated objective. Root-cause analysis (RCA) can aid in this process. In addition:

Use flowcharts to graphically illustrate procedural process flows or decision trees.
Clearly define roles and responsibilities—include safety requirements in job descriptions.
Use RACI (responsible, accountable, consulted, informed) charts, where appropriate, to facilitate understanding of roles and responsibilities.

Reporting must be consistent. Ensure prompt reporting of incidents and injuries with consequences for failure to report or to report in a timely manner.

Implement an injury-management process to help avoid the mischaracterization of injuries by medical professionals. Given the fact that personnel in off-site doctors offices, medical-clinics, and hospital emergency rooms aren’t always familiar with OSHA regulations and reporting, a less-severe injury could be inappropriately classified as more severe. This isn’t to suggest injured workers should not receive expert medical care: They definitely should! The difference between recommending a prescription medication and an equally effective over-the-counter medication, though, can be the difference between a recordable and a non-recordable injury.

Plant and facility staffs should include personnel with some degree of medical background or training and a strong grasp of injury-reporting requirements. These types of individuals should always accompany injured workers to off-site clinics, doctor offices, and/or hospital emergency rooms to assure prompt and effective treatment and correct reporting.

Strategic plans must address safety. Safety should be an inherent part of strategic plans—corporate, site, and department. Compliance with safety procedures must be mandatory, and failure to follow or enforce them will result in non-compliant behavior.

To be sure, safety policies and procedures must be realistic. Procedures should address specific regulations and/or hazards. Procedure compliance (especially critical procedures) should be verified through audits (see below). Any procedural exceptions need to be identified up front and formally approved. Sites, however, should be judicious in granting any exceptions.

Recognize that willful deviations in safety procedures increase risk and liability. Therefore, effective safety policies, procedures, and programs must be easily understood. Include the following:

Procedures should be written in layman’s terms (avoiding legal or technical jargon). Include helpful references for those seeking additional information, such as applicable OSHA regulations.

Make procedures readily available to anyone who needs them. Key word search-ability helps workers find the appropriate procedure for their application.

Review and update safety procedures through an appropriate frequency based on criticality, regulatory changes, and other parameters.

Safety audits are essential. This means conducting announced and unannounced audits with internal and external auditors. Sites should also implement a plant manager’s safety-inspection program.

The plant manager’s safety-inspection team should conduct an unannounced inspection at least once a month. Members of the inspection team should be assigned specific safety policies, procedures, and/or regulations to audit and re-inspect units or work areas to ensure that previously identified deficiencies have been addressed. Note that this type of team demonstrates that management is actively and visibly engaged in safety. Members should be trained (see safety-training sidebar) and thoroughly familiar with the policies and procedures they’re auditing.

The inspection team should use a corrective-action tracking system for non-compliance that includes due dates and overdue notifications. Although a simple spreadsheet will suffice, there are inexpensive software programs that track every action item through completion. They include an interface to the plant email system and send out notices and reminders of the status of corrective actions, especially those that are overdue.

It’s also important for inspectors to employ a structured root-cause analysis process or methodology that helps them identify root causes and contributing factors, along with specific corrective actions for each root cause and contributing factor. Based on that information, corrective actions can be implemented and, where practical, hazards can be engineered out.

Internal safety auditors/inspectors need to stay informed about pertinent industry incidents, evaluate internal application of that information, and confirm compliance and mitigation. Doing so involves participating in near-miss reporting activities, including investigation, if warranted. They should also analyze near-miss data to identify recurring problems and initiate preventive action(s). In doing this work, it may be helpful for inspection-team members to leverage advanced statistical methods with safety data to discern trends that may not be obvious to the untrained observer.

Keep in mind that a job safety analysis (JSA) should be performed prior to commencing any maintenance work. Risk assessments should be a part of the JSA process.

Measuring and monitoring is key. You can’t manage what you don’t measure. Accordingly, sites must measure and monitor safety to manage and sustain injury-free performance. That means tracking and reporting such performance, including trending. Among other things:

Capture, report, and analyze near misses.
Develop, implement, and communicate a site-safety scorecard in a highly visible way.
Employ leading and lagging indicators.
Use a robust, corrective-action tracking process, not just for root-cause items, but for all safety-related issues.
Strengthening commitment

In summary, injury-free performance begins with a personal commitment from those in a position to set expectations. Individual accountability is a prerequisite, without which improvement efforts will be ineffective.

A comprehensive safety strategy provides a roadmap and should be supported with realistic goals and objectives. Managing safety policies and procedures and soliciting input from those to whom they will apply are crucial aspects of robust safety programs and associated training—which should engage employees and contractors alike. Measuring and reporting safety performance continuously, and educating workers so they know how to recognize and analyze risks and interpret results are key.

In the process, your operations will be making safety, and, by extension, a commitment to injury-free performance, a core value, not a mere slogan. MT

Al Poling has more than 35 years of reliability and maintenance experience and is a Certified Maintenance and Reliability Professional (CMRP). His consultancy, RAM Analytics, is located in Houston. For more information and/or to offer additional safety tips, contact him at al.poling@ramanalytics.net.

EDITOR’S NOTE: Maintenance Technology is interested in any maintenance-safety best practices that your organization may employ. Please send them to the author at al.poling@ramanalytics.net for inclusion in future spotlights on successful maintenance-safety efforts.

Tips for Structured, Predefined Safety-Training Programs

The importance of plant and facility safety training can’t be overstated. It’s mandatory. Best practices call for safety training to start with site- and unit-specific safety orientations for new hires, as well as contractors. Such orientations set clear expectations on day one for those involved in regular site operations, capital projects, and turnarounds. New-employee orientation should include leadership participation to reinforce the importance of injury-free operations.

When it comes to the specifics of ongoing maintenance safety training, be sure to:

Train workers on risk recognition and analysis, i.e., show them how to interpret safety performance and understand its relative importance. Furthermore, provide them with training on the processes in which they work so they have a fundamental understanding of what’s going on inside the equipment and any hazards associated with it. Note that process training of maintenance workers is now a part of OSHA 1910.119 Process Safety Management.
Capture and communicate safety performance so all personnel are aware.
Make housekeeping everybody’s responsibility. This saves the time and expense of having laborers clean up after others—the image of which simply reinforces the misconception that safety isn’t everybody’s responsibility. Develop exceptional discipline relative to housekeeping, including the use of regular inspections.
Identify resident crane and rigging subject-matter experts (SMEs) who can review and approve all critical lifts.
Confirm the safety performance of crane companies and operators/contractors (see contractor safety sidebar). Don’t accept safety programs as a substitute for demonstrated safety performance. Establish criteria, i.e., certifications, for all internal and external crane operators.
Develop, implement, update, and store lifting plans for easy future reference.
Make safety meetings mandatory, structured, and interactive. Such meetings are a critical component in driving safety performance.
Provide detailed training on all life-critical subjects, i.e., LOTO, confined space entry, focusing on areas of greatest risk.
Include relevant off-the-job hazards as part of safety training, including areas such hunting, boating, chainsaw operation, weather emergencies, and defensive driving.
Avoid stale and ineffective training programs and recognize that computer-based training programs have limitations.
Invite internal and/or external SMEs and other plant personnel to conduct training.
Use innovation and interaction to keep interest high, i.e., consider role-playing techniques and leverage personal testimony, which can be very compelling.
Conduct regular toolbox safety talks to engage workers and employ visual aids to enhance and sustain awareness.
Conduct interdepartmental safety training, e.g., LOTO with operations and maintenance, where responsibilities are shared.
Recognize the seasonality of some training, i.e., hot/cold weather hazards.
Use giveaways to emphasize themes, such as safety glasses to promote eye protection.

Finally, make it a point to constantly garner feedback from safety-training participants and measure (anonymously) their comprehension. That’s one of the best ways to ensure the effectiveness of these training efforts.

“Partnering for Safety”