- OIL & GAS
There is no easy answer.
A worksite champion who has an earnest desire and management support to keep workers healthy and safe is a prerequisite. Approach every situation with the understanding that safety and health improvements are always available, look for them, and best practices will materialize. This past June I helped a client in Michigan update their Powered Industrial Truck (PIT) program. Follow along to see how best practices were identified.
Federal to state
The first activity was to visit the Michigan OSHA State Plan (MIOSHA) website and download the most current version of MIOSHA’s PIT requirements. Requirements better than federal OSHA’s showed up. For example, MIOSHA requires an operator’s I.D. number and restrictions, if any, on the PIT permit. The feds don’t. This added information moves an OK practice to a better practice. Neither the feds nor MIOSHA require an operator’s picture to appear on their PIT permit. Further, there are no legal requirements to laminate the permit so that it may last three years before expiration. A picture and laminated PIT permit are beyond OSHA requirements. These are examples of best practices.
Incorporation by reference
Conformance with minimum legal requirements and pursuit of best safety practices is frustrated by OSHA’s “incorporation by reference” (IBR) actions at 29 CFR 1910.6. IBR means that OSHA may require conformance with standards developed by organizations such as ANSI, NFPA and ISO. MIOSHA’s PIT requirements contain many IBR connections. The frustration is that each IBR has required payment to the IBR organization to obtain and read the applicable standard.
Want to understand the PIT IBR requirements at ANSI B56.1-1969? MIOSHA’s revised (5/14) rule includes the cost: $60.00. ANSI B56.1-1993? Cost: $61.00. ANSI B56.10-1992? Cost: $105.00.
Since about November 2013, however, IBR organizations have established portals that allow free access to their IBR standards. A lawsuit involving Public Resource opened free access to hundreds of IBR standards. Registration at portals sites such as NFPA and ANSI (links to other IBR standards) is necessary but read-only access is free. The next step in finding best safety practices is to do a lot of reading.
Understanding OSHA and IBR requirements gives a better understanding of good to best practices. But OSHA rules are often out-of-date. Do you believe the above IBR ANSI standards from 1969 to 1993 are the most current? They are not. Standard-setting organizations may not include free read-only access to all of their standards, only those that are IBR by date into legal standards may be available. When available, always read the latest IBR standard.Expand the scope?
In the PIT example, the client stored LPG tanks for fork-trucks outside in an enclosed fenced cage. The company did not require the cage to remain locked until immediate use. NFPA 58 LPG Code was IBR in the MIOSHA PIT rules. The 2014 version of the code required storage units for LPG tanks sold to the public to remain locked when not in use. Private locations such as a manufacturing worksite were not required to lock the storage unit. Should locking the LPG storage cage be a best practice for the private worksite?
Keeping the LPG storage caged locked until immediate use appears to be a best practice. But is the practice really necessary? The current level of “safe” may be safe enough. “Safe enough” discussions help reveal employer and worker tolerance or avoidance to risk. This opens up questions on safety culture.
What’s the risk of an unlocked LPG storage unit? Any history of harm or near-miss? In this particular example, several LPG tanks were stored with the emergency vent value below the liquid level that was inconsistent with the current version of NFPA 58. A locked cage now expands into best practices for worker training, audit and enforcement procedures for LPG tank storage.
Cigarette butts on the ground near the LPG tanks opens discussion on fire protection, housekeeping, and possible smoking cessation incentives for workers. Possible theft of full LPG tanks opens up questions on site security that may expand into suggestions for best safety practices such as worksite procedures for an armed intruder.
Where should expansion into other direct and fringe safety areas begin and end? In this case, only an update of the facility’s written PIT program is needed. A safety pro’s best practice may mean a compromise in tactical (short-term) and strategic (long-term) objectives. A best practice is to consider if the written PIT program is useful and sustainable, even in brief and incomplete form. Is the written PIT program “safe” enough?
What are “best practices”?
We are conditioned to believe best safety practices are extensive in design, development, and implementation. The best safety programs should then have the thickest safety manuals. But this is not the case. Best practices are what works for your organization. Best practices should be measured in injury and illness performance. No injury, no illness, no near-miss? Then regardless of what is being done or not done at a worksite, best practices are being displayed.
It’s not the thickness of your safety manual
Keeping up with best practices means being able to see safety in the whole and not as a separate part, as illustrated by the PIT example. Be inquisitive to find best practices. Approach every situation knowing safety improvements are always available. Performance – not the thickness of your safety manual – reveals if best practices exist or are being implemented.