Happy Hump Day to you,



ProPublica reports this morning In the aftermath of the Gulf oil spill, a series of health complaints among cleanup workers led to widespread concerns about the adequacy of the safety training, protective equipment and chemical exposure monitoring provided by the government and BP.

Today, a new report by the Center for Progressive Reform contends that many of these problems stemmed from insufficient attention to worker safety in the government’s disaster response plans. The report says that these programs, called the National and Regional Contingency Plans, shortchange the role of worker protection agencies in planning for an oil spill response, leaving no mechanism for enforcing workplace safety.

“These documents, beginning at the national level, consistently pass responsibility for ensuring worker safety down the line to the next entity that has a duty to participate in planning process,” the report states. “But as they pass the buck, they never establish mechanisms for ensuring accountability at the next level for worker safety and health.”

The center describes itself as a pro-bono network of scholars that advocates “thoughtful government action” to protect the environment, safety and health. It is funded primarily by foundations, including the Deer Creek Foundation, Public Welfare Foundation and Bauman Foundation.

The report gives high grades to the worker safety agencies – OSHA and NIOSH – for improving worker training and health monitoring once they got involved in the Gulf spill response, but it maintains that they often were forced to react to decisions that were made without their involvement.

Frank Mirer, the professor at Hunter College who initially raised concerns about the safety training, he agreed with the report’s recommendation OSHA and NIOSH should have a greater role in contingency planning in order to prevent key worker safety decisions from being made on the fly.

“The most important thing is to learn from what happened and incorporate the protections that were eventually implemented into planning,” Mirer said. “Five minutes before the party isn’t the time to learn to dance.”


Yesterday we made the rounds on popular occupational health and safety internet forums to keep tabs on the topics of conversations. It is true in safety: the same headaches and challenges keep coming back. Health and safety pros from 50 years ago would feel right at home with these conversations.

OK, maybe not the first topic:



“Our policy stricktly discourages the use of cell phone while driving, except for urgent or emergency calls”

“We recommend that our drivers pull out of traffic to a safe place while making or receiving calls. “

“No personal calls during working hours, unless it is an emergency.”

”Do not use your cell phone in heavy traffic. Never text, read text messages, take notes or look up phone numbers while driving. On January 27, 2010 the DOT issued a Ban on all texting while driving a CMV. “

“In California, we have a hands free requirement, but I have not seen any decrease in the amount of cell phone usage. Most people still have their handset held to their head or some are using the speaker function and still holding the phone in a hand a foot or so away from their mouth. Not sure what people don't understand about 'hands free'. “

”But I am encouraging my clients to establish a total Driving Distractions Avoidance policy that includes not only company requirements regarding cell phone use, but also eating and drinking in the vehicle, GPS entry, checking maps and map books, checking addresses,etc “

”Of course, the driving force must be senior management and they must also be willing to 'put their cell phone down' and safely drive also.

“How can we possibly argue we provide a safe work place if we allow the use of cell phones while driving?

”In the end - it all boils down to how willing your leadership is to really make the hard choice to LEAD.”


Question: “I'm writing an article on handling people who won't follow the rules, procedures, policies etc and seek input and insight. The article will cover the role of discipline, but from this august group I hope for more sophistication than ‘fire them’. “

”Is he/she intentionally not following the rules? If yes, why he did it? Firing people will not be as easy as he/she does not follow the rules.”

”An indepth investigation need to be carried out on why someone behaving that way. We might not get the right people (skill, knowledge, passion, motivation, etc) for the job, there could be something not right for him/her on the job (peers behaviour, working environment, etc) “

”Some thoughts on this subject are is management giving the right message to its people? ie: building the correct safety culture with training and employee involvement or is management just hiring temporary employees to fill a surge of orders with no real stake in the outcome.”

”Behavior is a choice, if people have been adequately trained, do the job regularly, and have no obstacles in the way. Look for: when was the last time the person did the job? ; when and how was the individual trained; did the person have the time, tools, to do the job right? If the answer leads you to believe the person knew what to do and chose not to do it, then the result must be that the person performs in an appropriate manner or pursues his/her career elsewhere.

“Keep in mind that being in a hurry, etc are not acceptable excuses. In safety matters I really don't care what the excuse is, the approach is did you know what you were supposed to do, did anything get in the way of you doing it, or you made a choice not to do what you were supposed to do.Choices force choices.”

“In general, it's been my experience that those employees who have a track record of not following safety rules also have other performance issues. Not following safety rules (assuming the appropriate safety culture is in place)should be handled like any other performance problem with a progressive process towards correcting the behavior or parting company. Is safety part of everyone's performance assessment? It's important that the individual is "called" on the inappropriate behavior as soon as it's observed or reported. Feedback must be immediate and seek cause. Does the employee have the training and knowledge to do the right thing? I agree with what others have said regarding finding the root cause. What is causing the behavior? Is it the individual or the management of the individual?

“The comments that I have read are spot on. I agree with the “Safety Culture” aspect of this discussion in that behavior that is allowed to happen by both leadership and employees can often have and send out mixed messages. For example, a supervisor or manager may give lip service to safety however, management and employees are rewarded for production. This dichotomy has often been a major source of employee "confusion" and may be a reason employees do not follow safety rules on their own. Consulting with management and providing them with all the tools (policies and procedures, statistics, accident investigations information, cost analysis, oversight, etc.) necessary to help guide their employees to perform correctly will go a long way to solving this problem. If leadership is truly involved in this process, this problem may go away or they may ask for an employee to either be punished or ultimately dismissed. “


Question: Does anyone know of an industry standard or information that correlates number of employees & the need for a safety person? I'm trying locate information to help justify the addition to head count. Anyone willing to share a successful approach?”

“Good luck with this one. Unfortunately I dont think there is any industry standard. Some companies don't even have safety professionals - and expect HR personnel to wear multiple hats. So the ability to justify additional headcount will have to come from a business return on iInvestment.”

”Staffing needs to be adjusted based on additional duties and hazard levels. You should also look at the hazard level of specific critical jobs. For instance if you are doing 24-7 critical tunnel repair work, you may need a full time safety professional at EACH job to keep it safe. Staffing levels largely depend on risk and expected workload in the organization. Management expectations are critical here. If a request for safety services can be put in the queue and handled whenever you get to it thats one level of service, but if immediate handling is the goal, thats quite another. (Are you a "Nordstrom" type of service or a discount store? Service levels and resources will differ.) “

”An additional consideration is level of staff. I think a mix of staff levels are good. Having some senior, master's level, and certified staff is important, but so is having new safety grads who are very energetic and eager to learn. “

”I second the "Good luck!" wish.”

“At a former employer, I did calculation on implementing a respiratory protection and hearing conservation program, and got ROI's of over 900 to 1. In other words, I could save $900 for every $1 spent. That was in hard costs. If soft costs were added in, the level more than doubled. The finance people (a U. of Michigan MBA) did not believe it, and had their fiscal staff go over it. They found that I was wrong, the hard costs savings were even greater.

”But, only a portion of the program was accepted. Even with a confirmed ROI of that level, the senior managers said they just did not have the current funding for all of the program. So, I learned that just having a ROI thats positive would not necessarily justify a program.

Later, the employee union pushed the issue, and the programs became reality.”

“BNA has a 2010 EHS benchmark study and in it are average EHS staffing per size of population. (Avg was one EHS professional for every 300 EEs) Execs generally feel their operation is different-better than avg-so they tend to rationaize out the need to conform to industry averages.

”I would make the case based on need, first, and then secondarily mention industry averages. Note what further projects/activities you need to do but currently can't and/or current projects/activities you can no longer support. “

“Staffing levels reaqlly do depend on the industry in my expereince. for example the expectations in heavy construction is a safety person for every 30 or so workers employed on the site. However, at the other end in transportation or government services you would see a safety person for ever 100-200 staff. “

”The local requirements here in Abu Dhabi - UAE for construction is one full-time qualified safety officer / engineer fro each contract for every 150 workers. but for heavy construction industry you need to improve the ratio; hence we are implementing 1:50; in addition for large contractors the EHS Manager should be based on site.”


“You may wish to contact Bill Gulledge at the American Chemistry Council; he's THE go-to guy on nano issues. “

” I have done some recent work on employee exposure assessment for carbon nanotubes during decommissioning of a pilot plant manufacturing facility and the associated laboratories. Naturally, this also involved disposal. Some of this work we have posted in redacted form on the goodnanoguide wiki.”

From: EHSQ ELITE (#1 IN SAFETY) Topic: Near Miss Reporting

Question: “Companies often struggle to get to the true number of near misses because of insufficient reporting. The consequence is that many opportunities for improvement and future accident avoidance are wasted. Hence the potential accident continues to lure round the corner - and is probably going to happen at some point, as we all know.

”This may be because of cumbersome reporting process and tools, with many of them being electronic capturing systems. Whilst people are in the field they have no access to such tools, and alter they are busy with other tasks which are demanding their full attention.

”Do you recognize this as true to some extent for your company? “

”In my experience, the biggest change required is not the software used (I admit, easy accessible and easy to use software helps), but the safety culture in the company. As long as near misses causes feelings of shame or risk of blame, severe near misses are not reported.

”So you need to create a safety culture where near misses are not looked upon by colleagues or bosses as bad, but as great opportunities to learn something before something really bad happens.

”Do not only concentrate on near misses, but include also 'unsafe conditions' (easy to report) and 'unsafe behavior' (more difficult to report). “

”In my experience, reporting of one or some near misses we identified after an accident, most probably would have prevented the accident.

”Another thing we noticed in our company is that the line between a 'near miss' and an 'accident' is not that clear and not so easy to define. A small accident which could have had major consequences may be reported as a near miss, and not as an accident. This may create problems if you try to distill statistics from the reports in the software. Not so critical issue, though.

”We are using global software for reporting accidents, near misses, unsafe conditions and unsafe behavior, along with audits and inspections, safety talks, etc. All employees have access to this software, with their own username and password. They can report themselves, or talk with their boss, who makes the report. We do not have problems with the reporting being cumbersome. The software is used by the personnel in their own language - we have production in 40 countries (language version is set in the user settings). The software enforces the work process including data collection, investigation, preventive measures and assignment of those measures, follow-up of effectiveness of those measures, and closure of the case. “

”Near Misses and Hazard Conditions can be VERY cumbersome operationally. In my opinion, some type of software plays a key role in these proactive efforts. At my last facility, we required reporting of Near Misses and Hazardous Conditions. The program was still developing and much of it was manual. Reports were via paper then the reports were transposed to an Excel spreadsheet for tracking. The problem twas that one facility generated over 1,000 of these reports in one year and they ate up personnel time to perform the data entry. After that, any corrective actions identified would need to be tracked to completion and we would also attempt to look for trends and recurrences.

”In all, it was an administrative nightmare. A solid software would definitely help where all were tracked as one package. In lieu of a software solution (which none were yet identified), I hoped for a stronger culture development and a plateau and eventual decrease of the raw numbers of reports. “

”I have had some success with a behavioral observation program which involved one on one discussion with employees who when approached in their own environment and saw that things were being taken care of as a result of these discussions became more willing to talk.

”For every near miss that was reported I personally would thank the person that reported it and get back to them about any action taken. They also became an agenda item at the JH&SC to focus on prevention and generate discussion about what if's.”

“It begins with the little things, but if you report something and nothing gets done, my guess is your reporting system will never be credible, and the near miss reporting system will be another system that looks great from a corporate level but down at the coal face another story emerges.

”The system we have currently being used gives you the option of email reminders, 3 days, 7 days, 14 days and so on.However, as I am responsible for the actions being closed out I like to give feedback to the person reporting, no matter what stage of the corrective action I'm at, this way everyone is informed, and I can report that when it comes time to writing my monthly report it is not left off the HSE meeting minutes and that I have allocated a responsible person with an END date in sight. If that action has not been closed out then it gets esculated to a higher authority, as tracking the little things often lead to making my job easier at the end of the day.

If something is not recorded, then it could be the next accident waiting to happen.”

“In a way you hit a limit which is challenging: there was the right safety culture, however, the right software solution was missing. By not being able to create timely feedback, like 'this measure was taken because of your reported near miss', the willingness to report cases may decline. This may even cause a detoriation in the safety performance. I guess that more often than not you would see that the amount of cases reported in the beginning is relatively low, and it takes time before the numbers start to grow considerably.

”You will hit a plateau and after that, the amount of near misses will start to decrease, simply because there is less to report. One can also hit a plateau due to detoriating safety culture (e.g. lack of feedback to the persons reporting cases, or lack of measures taken due to these cases causes demotivation to report new cases). Normally, reaching this natural plateau, where the actual amount of near misses start to reduce will take time. 1000 reports in one year at one site sounds a lot, how many people were working at that site? Did people report unsafe conditions and unsafe acts as near misses?

”The facility is a facility with approximately 120 people. They either report near misses or hazardous conditions. Haz conditions are reported the majority of the time. The plant attempts to address as many of the near miss/haz condition corrective actions as possible. One method is copying all Maintenance Department reports to that department where work orders are generated. Corrective actions appear to be adequate although they always could be better. The facility had another plant engineer in the past and the talk from employees was "why should I report it? They won't fix it anyway." I haven't heard that talk since the plant engineer was replaced and the maintenance department became more responsive.

”I think we got over the hump of "I'm not snitching on anyone" or retaliation from a report. This was a problem early in the program. Now, people seem to be reporting better and more than once I would be talking to a line employee and something would occur where they would joke "near mis haha". The culture is thinking about near misses and hazardous conditionss more than ever. It seems that the reports for the most part are genuine although some seemed petty and probably could have been corrected on-the-spot. The problem I have is recurring instances. The same item (e.g. air hose at machine causing a trip hazard) could occur at several different work stations or on any shift. The ability to see trends by type of occurrance, shift, supervisor, etc. was not available. If we do not address the root causes, recurrances will continue. I do not know of any viable solution but software.

”Unfortunately to find the right plateau, there will have to be some evolution of the program. Then hopfully the decline due to less incidents will occur eventually assisting to make positive impacts on employee injuries.”