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Facility Safety

Could a DOT/FAA program turbocharge industrial safety?

By Mark Mehling
January 25, 2017

Imagine…

A light knock on your office door as a piece of paper appears underneath. The person vanishes. The form is a self-confession to a mistake, omission, or other safety incident. Without leaving your desk, you are getting a truer picture of the plant’s safety culture. Imagine these “under the door” voluntary confessions arriving every day. Wouldn’t life be great? Keep that thought...

Copying from others

Ever used a fast food drive-up window? Hamburger places “borrowed” the idea. The first drive up was at a bank in the 1930s. Fast food companies saw the potential and transferred this concept. And they are a smashing success!

Industrial safety has this same opportunity to borrow a program and see great success.

Will we use it?

DOL and DOT

The Department of Labor/OSHA governs workplace safety issues. But there is a business sector exception: aviation has two masters. The Department of Transportation/Federal Aviation Administration (DOT/FAA) oversees aviation safety. This means two oversight groups:  OSHA for “ground” safety and FAA for “aviation” safety.

But the waters that separate them are getting muddied as the FAA aggressively moves forward with new initiatives that solve both threats.

Aviation IS industrial

Aviation is a dangerous environment, with every challenge of an industrial plant. Falls, hazardous materials, caught in/between dangers, electrical threats- aviation has them all. And unique challenges like jet blast.

To increase the flow of safety information, FAA partnered with airlines to start a unique approach. The 15+ year-old initiative is known today as the Aviation Safety Action Plan or ASAP.  ASAP’s purpose is to understand both threats and errors, and reduce them through voluntary, non-retribution, self-disclosure.

Three legged stool

The program prevents future incidents by bringing three equal partners around a table to resolve issues: a company rep, labor rep, and an independent third party that knows and understands the process. A simple agreement or Memorandum of Understanding outlines the program and all agree by signature to abide by its methods.

Three principles govern

1) Voluntary, anonymous self-reporting:

Remember imagining confessions pushed under your door? This is ASAP- employee self-reporting. Anonymity is a critical trust element. Employees are more honest when there’s no retribution. Reports are initially handled by the impartial third, building confidence in the system. This third party “de-identifies” each report to ensure it cannot be traced to an individual. (Only the impartial 3rd party retains the name in case further information is needed.)

2) Joint resolution:

Instead of merely imposing rules or decisions, ASAP gains concurrence from all involved. An “Event Review Committee” made up of management, workers/union, and a trained, experienced, impartial third party, resolves reports. They may research reports to get more information or come to a decision immediately. ERC solutions become corrective actions, training, and feedback to educate employees.

3) Joint Investigation:

A joint safety investigation team examines every accident, incident, or mishap. Unlike lawyers circling the scene, this group is solely concerned with learning the events which led up the mishap- and how to break that “chain” in the future. While there may be lawsuits or other repercussions, they are outside the program.

How would this work in industry?

It’s easy to mirror the ASAP program. Leveraging the underlying themes and processes builds an Industrial Safety Accident/Incident Program (ISAIP). It doesn’t require government approval or participation. It is an in-house program using trained ASAP experts to get the program started.

An ISAIP generates savings several ways: reduced workers’ comp claims, lower work related absences, few or no OSHA fines, and higher production from workers who feel someone cares and listens.

(Want to read how caring for employee safety radically affected a company? Look for the book, “The Power of Habit” by Charles Duhigg. Read Chapter 4 about a large corporation operating foundries, an OSHA high-risk area. )

Give examples

Example 1: A worker tell his supervisor of a broken machine guard. Three days later, he fills out an ISAIP form as no action was taken. No one in safety would have known except for this report. While the guard may be fixed immediately, there are deeper issues. Why wasn’t it reported earlier? Why was the machine operated without the guard? Was there pressure? Was production more important than safety? Or no money in the budget to fix the guard? Is there an underlying training issue here?

Now, hopefully before someone gets hurt, the issue goes to the joint committee for a long-term fix, not just a short term mechanical correction.

Example 2: In a foundry metal-pouring operation, a supervisor almost dumps 800 lbs of molten metal onto the floor. By reporting this through an ISAIP form, he can share what happened to prevent others from making the same mistake. How could the event have happened? The ERC investigated the situation and found it could have happened during any of the pours. They were just lucky. The joint committee recommended a three-minute “team brief” before a pour. Plus a short checklist showing proper cable hookup, required safety equipment, and other basics so every team member could stop unsafe pours.

Do employees instantly “get” this program?

Anonymous? No retribution? It takes time to build credibility. But as word gets out participation- and results- climb. It can take a year to build confidence and overcome doubt. But when it happens, the floodgates open.

Can anyone participate?

Yes, it’s not limited to line workers, craft employees, etc. Anyone from the CEO on down to the least paid/just hired employee can participate anonymously.

Does organized labor participate?

Absolutely. In fact, most labor representatives are strong program advocates. It protects their members from potential retribution. The Event Review Committee doesn’t assess blame, unlike most company/labor meetings. Anonymity, joint resolution, and joint investigation make this a team building effort, not another western showdown.

Can ISAIP eliminate whistle blowers?

Whistle blowers feel helpless to report what they believe is a big issue. An ISAIP provides that outlet. When employees see concerns properly reviewed and handled by fellow workers, the need to be a “WB” goes down.

Would an ISIAP eliminate OSHA?

No. But it would make threat and error management much easier. Imagine employees reporting improper safety procedures instead of the safety staff finding out through an incident. Workers who discover OSHA violations would be more inclined to report them since there is no fear.  Employees participate when fear is eliminated.

Why would a company want an ISAIP?

Companies who care about their employees’ safety, want lower medical and workers’ comp premiums, and see the value of a positive safety culture all will make great strides with an ISAIP.

Has this been proven?

ASAP programs exist in every area of aviation. Dispatchers, Maintenance personnel, ground crews, overhaul facilities, and repair shops all have active programs.

Bottom Line

This is an advanced safety concept. Not every business could effectively use a program like this. Only those truly interested in their employees, recognize there is an ocean of information workers would be willing to share, and a cooperative environment in safety leads to dramatic improvements in other areas.

KEYWORDS: accident investigation aviation safety industrial safety

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Mark Mehling is the founder of Industrial Safety Associates, a group dedicated to ASAP methodologies to the industrial safety environment. For a comprehensive Research Report which gives more details than could fit here, contact him at Mark@IndustrialSafetyAssociates.com.

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