MANAGING BEST PRACTICES: When emergencies strike...
In days past, businesses used to claim â€œforce majeureâ€ or an â€œact of Godâ€ prevented them from delivering agreed upon products or services. They claimed they couldnâ€™t reasonably have anticipated or planned for extreme weather or some crazy event. Now businesses are expected to consider Katrina-like weather and 9/11 possibilities. This is necessary because if one business fails to provide a product or service, another business may fail. Itâ€™s the global supply chain. For want of a shoe a war was lost, so to speak.
BCP componentsBusiness continuity plan (BCP) now appears in legal, financial, and insurance documents. â€œBusiness continuity managementâ€ is a required element in ISO 17799:2005, the code of practice for information security management. Components of a BCP include: 1) Business impact analysis; 2) Risk assessment; 3) Risk management; and 4) Risk monitoring. If you add a comprehensive business impact analysis to a typical emergency action plan or emergency response plan, and then consider how to keep the business running, you have yourself a BCP.
Example: pandemic fluThe threat of a pandemic flu is prompting more employers to develop or revise a BCP. Experts worldwide predict that a pandemic flu, most likely a variant of the H5N1 avian flu, will occur. The experts are just not sure when this will happen. The flu weâ€™re talking about is the scary one: affecting upwards of one-third of the U.S. population and possibly causing more than 200,000 deaths in America. More than a million deaths could occur worldwide.
When the pandemic flu hits, business will not be â€œas usual.â€ Government authorities are telling employers to plan for employee absenteeism rates up to 40 percent for a couple weeks or even several months. Employees may be absent because theyâ€™re sick, caring for someone who is sick, or they may be affected by quarantines, travel restrictions, or other problems. Suppliers, contractors, and service providers that support businesses will face similar challenges with absent employees.
Reality questionWhen developing a BCP, a reality question is: â€œWill we bend or break any standard safety rules during the emergency?â€ The following are examples of how this might apply.
Respirators & PPEDuring a pandemic flu outbreak, which likely will occur suddenly, employers may require all their employees, including those traveling on business, to wear a respirator (e.g., minimum N95 disposable filtering facepiece), and maybe use other personal protective equipment, such as gloves. If people are dying because of an avian flu, employees may readily embrace the requirement to wear PPE.
Technically, employees required to wear respirators would need training, fit testing, medical qualification, etc., under OSHAâ€™s respiratory protection standard before they use the equipment. PPE hazard assessment and training may also be required by OSHA. Should all employees be trained now? And during an emergency, should time and resources be spent to ensure full compliance with this activity?
Equipment operationYour employer may designate moving stock around with forklifts, or keeping certain machinery running, as critical operations which may have to be handled by any employee, even those that normally work in the office. OSHA requires that no employee may operate mobile equipment until they have been trained and qualified to operate that specific piece of equipment. And employees should not operate any mechanical equipment until they have been trained in all necessary safety aspects of that equipment. Again, should all employees be trained now to operate critical equipment?
Hazard communicationIf a pandemic flu outbreak is anything like the outbreak of SARS a few years back, employers can expect dramatic changes in the use of cleaning and disinfectant chemicals in the workplace. Home-made disinfectant brews may even be brought in by employees. Chemicals that may have been exempted as a consumer commodity under OSHAâ€™s hazard communication standard could come under the full force of the law when used to scrub entire washrooms and all surfaces that may be contacted by an employee. How important is full compliance with hazcom during a flu emergency? The answer will be site specific.
Plant safety rulesNot covering your sneeze or failing to thoroughly wash your hands after leaving the rest room is only a minor breach of sanitary etiquette in most workplaces now. During a pandemic flu outbreak these actions could become major safety violations. Plant or corporate policy may also require that weekly safety inspections or other safety-related activities be routinely conducted. What rules should be elevated and which may be set to the side until the emergency is over?
Professional input & prioritiesDuring emergencies your boss will want to know, â€œWhat is the right thing to do?â€ And hereâ€™s your dilemma: You probably wonâ€™t have all the resources needed to do all youâ€™d like to do. Youâ€™ll need to prioritize. Prioritization will depend upon the critical business operations that must be kept running. Your challenge will be, say during a pandemic flu outbreak, that you wonâ€™t know what employees will be available for work. How does your employer safely manage business under these circumstances? Now consider that you are too sick with the flu to come to work. How are injuries and illness prevented?
There are basically three choices in this situation. One, every employee knows and is qualified to follow all safety precautions in all situations. Two, employees are allowed to use their best judgment on what activities are safe or unsafe and they act on their own. Or three, every critical safety operation has a written procedure that must be strictly adhered to and enforced by all levels of employees and management. The third choice is the best.
Critical operationsWhat are the critical safety operations in your workplace? If you donâ€™t identify something as critical, then proper safety precautions may not be followed. Use of respirators during a flu emergency is an example. If you donâ€™t believe their use is critical, then donâ€™t expect your employer to fully comply with OSHA regulations when theyâ€™re used. You may, however, believe that strict adherence by employees to sanitary practices, such as employees properly covering their sneeze, is critical to preventing the spread of flu. In this case, a written and enforced procedure is necessary.
ProceduresProcedures for safely performing critical operations must be understood by all employees and readily available where applicable, such as posting directly on a piece of equipment. The procedures should be written in brief and plain language and supplemented by visual instruction. These procedures may be all someone has to go on to perform an activity safely.
Experience has shown that during emergencies employees will take shortcuts to get the job done, even if this means not complying with all safety rules. A good BCP will be an extension of the safety and health professional and will identify what critical safety procedures must never be broken.