Our ExpertsBob Brown, president, Blue Collar Safety, Houston, Texas
Kyle Dotson, CIH, CSP, PE, group vice president, safety, health and environment, BHP Copper, San Francisco, Calif.
Mark Hansen, CSP, CPE, PE, manager of safety services, Union Texas Petrochemicals, Houston, Texas
Ernie Huelke, CSP, CHMM, RPIH, president of safetywoRx; assistant safety manager, O'Hare Airport Transit System, Chicago, Ill.
Dan Markiewicz, CIH, CSP, CHMM, senior industrial hygienist, Aeroquip Vickers, Maumee, Ohio
Gayla McCluskey, CIH, CSP, president, Global Environmental Health Services, Radnor, Pa.
Daniel Patrick O'Brien, MS, CSP, safety manager, Engineered Carbons, Inc., Borger, Texas
Robert Pater, MA, director, Strategic Safety Associates, Portland, Oregon
Michael Pinto, Ph.D., CSP, chief executive officer, Wonder Makers Environmental, Inc., Kalamazoo, Mich.
David Sarkus, MS, CSP, safety management consultant, Monongahela, Pa.
Barry Weissman, REM, CSP, CHMM, safety management consultant, Piscataway, N.J.
How to encourage reportingHealth complaints are probably being hidden as much as injuries. Employees are hesitant to relate those health effects to the workplace. The workgroup peer pressure is going to be active in this area. Co-workers are going to harass employees who complain of headaches, skin rashes and other problems. -Bob Brown
I encourage employees to call me directly. I will let their supervisor know what's going on. I don't even mind giving an employee my home phone number. I've given it out a couple of times, but I've never received a call at home. -Dan Markiewicz
Specifically how a complaint is handled is not as important as having a system in place to ensure that it is handled. -Daniel Patrick O'Brien
- Peer pressure can stifle reporting
- Be accessible
- Have a response system in place
Building credibility, gaining trustComplaints should be handled face to face. The person who is most likely to receive the complaint should be trained in the correct techniques of handling complaints. Oftentimes this duty is assigned to the company nurse, and he or she may have had very little direction on how to handle the situation. Not only should they know what questions to ask, but also they should be trained in feedback skills.
The only thing a person should be told during the initial response is that the concern will be investigated and that you will get back with them. -Bob Brown
Initially, don't make promises, but be sure to do what you say you will do. Don't speak to an area of expertise if you don't have the expertise. -David Sarkus
Make promises sparingly, but keep them faithfully. -Mark Hansen
Always attempt to resolve the complaint. Sometimes just listening and empathizing is enough. -Gayla McCluskey
Always take complaints seriously. If they do not seem health-related, they could provide a clue to the real problem even if it is stress, work conditions, mass hysteria, politics, contracts or anything else. -Michael Pinto
- Handle complaints face-to-face
- Don't make promises
- Sit back and listen
How to define a complaintHealth complaints arise either from signs or symptoms of health problems.
Signs are measurable or can be seen. A runny nose, irritated eyes, or a fever are examples. If signs of health problems are noticed, the issue takes on a more urgent pace. Actual signs of health problems, however, are fairly rare.
Symptoms of health problems cannot be seen. The person experiencing the symptoms only reports them. Examples of symptoms include, "The odor makes me sick," "This stuff gives me a headache," and "The chemical leaves a bad taste in my mouth." -Dan Markiewicz
Sometimes for vague non-descriptive complaints I've asked employees to keep a log of home and work activities, time of day and day of week when they feel ill, and other details. -David Sarkus
When a health complaint is made it's important to review the employee's health and injury records. Also contact their immediate supervisor to see if there are any other unusual activities occurring and to assure that the supervisor knows of the complaint. Documentation of every contact is essential. -Bob Brown
Do your homework. Know the exposures and chemicals in your workplace that people may be exposed to and the symptoms of exposure. For example, blue coloring under fingernails can indicate cyanide exposure. -Mark Hansen
- Know signs and symptoms
- Know your workplace
- Review employee records
- Interview supervisors
Dealing with threatsI don't shy away from an employee who says they are going to call OSHA. I encourage it if it will ease their mind. I think OSHA helps. If I miss a problem, and they spot it, everyone is still better off in the long run. A couple of times over the past several years, an employee got OSHA to come in to sample after I had sampled. So far, OSHA's numbers have been right in line with mine. I like that, it builds my credibility. -Dan Markiewicz
- Are you confident enough in your own sampling & problem-solving skills to let OSHA come in?
Starting your investigationIt is hard for me to describe, but I just talk with employees to feel out their problem. I will ask people if the problem is in their head or if they just have a beef with management. So far, no one has taken offense at the question. I then explain that finding an OSHA violation may not be likely, but if I find an issue that should be resolved to eliminate their health complaints, I will ensure that management addresses the issue.
NIOSH uses a questionnaire to help define a pattern among people with indoor air quality complaints. I think the questionnaires work, but I'm reluctant to use them. The questionnaire seems too impersonal for me. I prefer the one-on-one approach. -Dan Markiewicz
Always visit the workplace before forming your opinions regarding cause. For example, one person who complained of headaches did not mention that his company truck had open holes in the floorboard and an exhaust system full of leaks until we researched his workplace and measured high levels of CO while riding in his truck. -Kyle Dotson
It's critical that the employees involved be heard. If the employees don't feel like they are being listened to and that their concerns are being addressed, matters can get more serious and escalate quickly. -Daniel Patrick O'Brien
Because of the transient nature of the exposure behind most of these complaints, the site should be investigated immediately. You might be able to smell, taste or otherwise experience some of the exposure symptoms.
Additionally, if the exposure is real it may be necessary to stop the source of the exposure, remove the employee(s) from the area, or summon emergency response services. You cannot take emergency action if you are not there at the site. -Ernie Huelke
- Act quickly, think deliberately
- Visit the site of the complaint
- Don't rush to judgment
- Listen openly, talk honestly
Responding to employee questionsI don't beat around the bush too much when responding to questions. Employees, even the bluest of blue collars, can tell when you're blowing smoke. I will tell employees right off if I don't think there's anything around them which is causing harm. If there could be a problem, I state this opinion as well. -Dan Markiewicz
Avoid promising the sky. You know you can't deliver and the employee knows you can't as well. Tell the employee the truth, anything else only leads to bitterness and bad feelings. Tell the employee that it's your responsibility to ensure that the problem is addressed and resolved. -Daniel Patrick O'Brien
Do not offer any solutions prematurely. The complainant is usually not familiar with exposure hazards or sources, regardless of how much hazcom training, if any, has been received. Ask the complainant to describe all symptoms, smells, times of day, activities conducted (routine, non-routine, out-of-the-ordinary), any unusual activities recently by others (new process, procedure, chemicals, equipment, machinery) or by outsiders (paint, remodeling, etc.).
Follow each response with more probing questions, building on the previous responses. -Ernie Huelke
Never make light of the concerns or questions. Don't suggest or imply that these complaints are in the employee's head and are psychological only. This suggests there is something wrong with him or her. Also, if employees feel humored or put down, they will be less likely to bring you information in the future that you might need. And don't suggest treatment unless you are the physician who has already examined them.
Really listen to what they have to say until their energy level lowers. Thank them for confiding in you and bringing the matter to your attention. -Robert Pater
- Don't humor or put down employees
- Listen until their energy lowers
- Show genuine concern
Asking your own questionsI learned the hard way to 'bite my tongue,' just listen intently, and then acknowledge that I've heard what they said, no matter how preposterous. One employee "assumed" that a UFO was giving him his headaches. I'm not making this up. In these cases, I then suggest that while they have arrived at an interesting theory, I would like to take a scientific look at a whole range of potential causes, rather than jump to one solution and possibly miss the true cause of the problem. Then you should refuse to speculate with them regarding causes. -Kyle Dotson
I will ask if anyone in the family or a close friend has gone through a recent serious illness. Oftentimes this is the case, and the employee may just be overly cautious about his or her own health. -Dan Markiewicz
Avoid any non-politically correct questions, just like in a job interview. Don't ask leading questions. After getting an earful of the complaint, ask, "Do you think that this is work-related or did you do something in the other 16 hours off the job?" If it's not work-related, tell them to see their personal physician. -Mark Hansen
Be just like a reporter: Ask the who, what, why, when, and how (much, many) questions. Avoid putting ideas or suggestions into the employee's head. Let them talk. You listen and take notes. Taking notes also shows your interest. -Barry Weissman
Knowledge of the employee's past sensitivities, complaints, hobbies, etc., is always helpful. -Daniel Patrick O'Brien
To draw out additional information, offer possible examples. For example, follow up on a comment about odors by asking if they smell like nail polish; car exhaust; musty, rotten fruit; dirty socks, etc. Just be careful that you are not coaching the person.
Ask questions individually. Otherwise everyone tends to adopt and repeat all the symptoms of the whole group. -Michael Pinto
Open-ended questions seem to work better than leading questions. When you ask questions such as, "Do you get headaches?", "Do your eyes water?", and "Is your work environment making you ill?" the answers are "Yes," "Yes," and "Of course, yes." -Gayla McCluskey
- Ask open-ended questions
- Don't lead or coach responses
- Take notes
- Be direct; refuse to speculate
- Avoid group interviews
How to determine if the complaint is legitimateSafety can be the 'complaint department' for whatever ails you, so handle each complaint and person with care, until you get enough information to make an informed judgment I prefer face-to-face meetings. That way I can read the person's sincerity and urgency. Also, know your workplace exposures and symptoms. Know your employees. Is someone a model employee or a chronic complainer? -Mark Hansen
I treat all complaints as being legitimate. -Dan Markiewicz
Take all complaints seriously, investigate immediately at the site of the complaint, and listen actively and in an unbiased manner.
Your Q&A, with follow-up questions for more specific detail, can reveal legitimacy by way of consistent response from the complainant. Vague and inconsistent responses, or responses that place blame on others may, reveal some other agenda.
Question other employees (the maintenance personnel can be especially helpful for HVAC, water treatment, remodeling schedules and other pertinent information), and supervisors and managers in and around the immediate area.
The supervisors or managers may be able to shed some light on the recent goings-on that could establish legitimacy. However, supervisors and managers may, oftentimes, minimize the importance of the complaint or even attempt to hinder your investigation. Do not offer premature judgments or biases. -Ernie Huelke
I simply try to ignore the issue regarding the legitimacy of complaints. Everyone expects and deserves to have health symptoms taken seriously. I tend to believe that they have whatever symptoms they describe, and acknowledge the symptoms. It only impedes communication to suggest disbelief, and if there is another agenda, you are playing into it by 'ignoring' their 'health hazard.' -Kyle Dotson
Try to find out what else is going on at work and at home. I've had a situation where the employee's complaint was based on problems at home. They couldn't do anything about the home situation so they "wanted to get even" and made a work complaint.
Talk to supervisors and other employees. When I talk to other employees, I do it one at a time. I don't want one person to influence the others. After an investigation starts, I might have a group meeting to give them all some follow-up. -Barry Weissman
- Keep an open mind
- Look for consistent answers
- Conduct background research & interviews
Conducting exposure monitoringConduct monitoring if there is any indicator that a source of a contaminant exists that would cause the symptoms, or if there is a need to eliminate potential causes through sampling. -Kyle Dotson
If a possible problem exists, I let the employee help me conduct the sampling. In one case this year, I taught a group of employees how to use my sampling equipment. Then I let them keep it for a full week and repeat sampling each day to catch variable exposures. When sample results came back from the lab, I helped the employees interpret the results.
No overexposures were found (I was pretty sure of this before we started sampling), and the complaints about the 'bad' air stopped. -Dan Markiewicz
Typically, I believe experts would say if greater than 10 to 20 percent of the population has the same complaint or symptoms, you should do the monitoring. -David Sarkus
I conduct monitoring based on known vulnerabilities in the workplace, such as if I know we're conducting a turnaround and equipment is opened and employees are exposed to chemicals. Also, I'll monitor if I get reports of odors that I can link to certain chemicals (such as almond for cyanide); or if I see employees exhibiting physical symptoms similar to that of workplace chemicals, like blue under the fingernails for cyanide exposure. -Mark Hansen
- Don't monitor blindly - have an idea of what you expect to find, and how you'll use the results
- Devise a sampling plan - know what samples will be collected, how many, where, and why you're sampling
- Have a working hypothesis before sampling
- Don't sample just to look impressive
What if monitoring shows no problems?Have the employee keep a log of all their activity. Do more monitoring. Perhaps move the person or the potential source. -David Sarkus
If the monitoring doesn't reveal a problem it's advisable to keep working conditions under surveillance. -Bob Brown
Find out where else in the facility the employee has been. Bounce chemicals against the symptoms. What do the complaining employees do outside of work? Where have they been? If there is no problem, tell the employee that you could find no physical cause and effect link between the symptoms of the complaint and what they have been exposed to at work. Encourage them to see a personal physician if the problems persist and worsen. -Mark Hansen
Here's what I've said to an employee after such a situation: "Dave, you told me about the problem you and some of the others were experiencing with that strange odor. We hired a consultant to perform some testing for odors. The results of that investigation did not provide us with anything conclusive. We've done other things to help, such as a . . . b . . . c . . . etc.
"At this point, I don't know what else we can do. I will continue to check this area periodically. If the problem reappears, please call me and I'll be back. Do you have any other ideas as to the cause or the solution? [pause] I'll let you know if we discover any new information." The employee wasn't happy that we weren't able to come up with an answer, but he knew we tried. -Barry Weissman
If monitoring reveals no problems, dig deeper. Something is happening. Especially if multiple employees are involved and showing signs. Often something totally innocent has happened. The hand soap has changed, the paper towels are different, and a new wall was erected. Seek out everything that has changed at home and at work.
If all the searching and digging shows nothing and you're not going to pursue the effort anymore, tell the employee so there are no false expectations. -Daniel Patrick O'Brien
As a normal course of complaint follow-up, and before monitoring has commenced, I request that the employee start a log which includes date and time of subsequent symptom onset, activities conducted by themselves, non-routine or outside contractor activity, descriptions of smells, sounds, etc.
If monitoring does not reveal a specific hazard exposure (this time), the log information can be used to assist in the event of future complaints. The employee's willingness to comply with this request can also reveal whether there is another agenda at work. -Ernie Huelke
- Have employees keep logs of their activity
- Look for small, innocent changes in the workplace
- Shoot straight with employees