May/June 2015 Each scrap facility’s
safety program must address a unique set of processes, hazards, and working
conditions, but the strongest programs also share certain characteristics that
build buy-in and participation at every level.
By Commodor Hall
According
to public information, the scrap recycling industry had three worker fatalities
by late April of this year. The first was a tractor-trailer driver who was
transporting scrap. The police report indicates the driver came upon a
tractor-trailer crash that had occurred moments earlier. The driver took
evasive action, and as a result, his truck flipped over. In the second
incident, a scrapyard worker died instantly when a forklift struck him in the
head. The third death was that of a worker cleaning a mixer machine. The worker
became caught in the rollers and was dragged through the machine.
Specific safety training and behaviors
regarding defensive driving, operating and working around forklifts, and lock-out/tag-out
might have saved those three lives. But many factors that contribute to
fatalities are systemic. Companies that do not conduct background checks or
pre-employment drug tests, those that provide only limited new-hire training
and ongoing training, and those that don’t hold managers or employees
accountable—they have few safety rules or don’t make workers comply with the
rules—are setting themselves up for accidents, injuries, and fatalities from
the start.
You have a responsibility to provide a safe and
healthy workplace for your employees, customers, contractors, and vendors. You
must evaluate your operations, processes, and equipment to ensure that you have
identified and appropriately controlled all hazards. Each company’s safety
system is unique. It’s up to you to decide how best to operate a safe and
healthy workplace and how to put your plan into practice. At the same time,
safety professionals have learned that the most successful safety and health
systems have 10 elements in common. Consider whether your safety and health
system has each of the following elements.
1. Managers are
committed to creating a safe work environment. Employees know you
expect them to follow safe work practices—and everyone at the company, starting
with the chief executive, follows those practices as well. All managers play a
role in and have responsibilities for leading and managing safety. A company
policy statement describes management’s commitment to safety. Safety objectives
are part of each manager’s annual evaluation and bonus. The company responds to
all reports of unsafe or unhealthy conditions or work practices.
2. Employees are
devoted to the safety program. The company has an active workplace safety and
health committee. Daily safety inspections are part of some employees’ jobs.
The company keeps employees informed about safety inspections, injury and
illness statistics, and other safety-related issues. It values employee input
and feedback and acknowledges that employees often know more about safety problems
and solutions than managers do. The employees help review and improve the
safety program.
3. The company has a
system to identify and control hazards. It reviews records of accidents, injuries,
illnesses, and close calls to look for trends or common factors. It reviews
workers’ compensation reports and customer and motorist complaints. It surveys
its employees about safety. It reviews inspection reports from insurance
companies, government agencies, and the like. It uses a checklist to locate
dangerous conditions. It performs a job hazard analysis and follows through by
prioritizing the hazards discovered, making plans to correct the hazards, and
correcting the hazards, such as by modifying the yard or equipment design or,
if that’s not possible, by providing personal protective equipment. It
evaluates the changes to make sure the problem has been corrected without
creating other hazards. The company uses ISRI’s safety services and other
safety consultants.
4. The company complies
with OSHA and other government regulations. It provides a workplace free from
serious recognized hazards and complies with the standards, rules, and
regulations issued under the Occupational Safety and Health Act. It examines
workplace conditions to make sure they conform to applicable OSHA standards.
Employees have and use safe tools and equipment and properly maintain the
equipment. Color codes, posters, labels, or signs warn employees of potential
hazards. The company establishes or updates its operating procedures and communicates
them so employees follow safety and health requirements. It provides safety
training in a language and vocabulary workers can understand. The OSHA poster
(or the state equivalent) informing employees of their rights and
responsibilities is posted at a prominent location within the workplace. The
company reports to the nearest OSHA office all work-related fatalities within
eight hours and all work-related in-patient hospitalizations, amputations, and
losses of an eye within 24 hours. It keeps records of work-related injuries and
illnesses. Employees, former employees, and their representatives have access
to the company’s log of work-related injuries and illnesses (OSHA Form 300).
When applicable, the company posts the summary of the OSHA log of injuries and
illnesses (OSHA Form 300A) by Feb. 1 each year and keeps it up for at least
three months.
5. The company trains
employees in safe work methods and requirements. It trains workers
about the hazards they may be exposed to at work and how to protect themselves.
It keeps records of all training. Training consists of a general safety
orientation for new employees and employees starting new jobs, including
company safety regulations and emergency procedures; specific training on the
hazards of each job and how to do that job safely; and retraining as the
standards require, such as when an employee’s job changes or he or she returns
from a long absence.
6. The company exhibits
mutual respect and open communication about safety and employee well-being. It establishes
effective two-way communication between employees and managers. It responds to
workers’ needs and concerns. Management goes beyond regulatory requirements—and
encourages workers to do so as well—to ensure a safe workplace. The work
environment fosters trust, creativity, and general well-being. It celebrates
successes such as the company’s participation in OSHA’s Safety and Health
Achievement and Recognition Program or Voluntary Protection Program.
7. The company
dedicates resources to safety. The company provides equipment, training,
modifications, upgrades, and similar items as needed to keep workers safe.
8. The company holds
both employees and managers accountable for safety. Safety rules—such as
those for lock-out/tag-out, machine guarding, working in confined spaces,
mobile equipment operations, and fall protection—address the facility’s safety
issues and potential hazards. The company addresses at-risk behavior by
providing training and corrective action—up to and including termination. Employees
receive positive recognition for safe work practices, such as verbal
recognition before peers. The recognition is timely, consistent, certain,
significant, and sincere. Corrective actions and positive recognition both are
documented.
9. The company participates
in safety recognition programs. Such programs include ISRI’s annual
Transportation Safety Awards as well as those that insurance companies and
state trucking associations might offer. The company observes ISRI’s national
Safety Stand-Down Day (to be held this year on June 24) and shuts down
operations for one hour on each shift that day to focus on safety. It has
joined ISRI’s Circle of Safety Excellence. (For more information on that group,
see the advertisement on the facing page.)
10. The company focuses
on continuous improvement. It regularly reviews its safety program’s strengths and
weaknesses and whether the program accurately reflects how the company wants to
manage safety and health. It frequently inspects specific equipment and
processes and evaluates its injury and illness statistics. A safety committee
consisting of managers, mechanics, yard employees, and drivers meets monthly to
address accidents, injuries, unsafe acts, close calls, equipment/facility
inspections, and employees’ safe work methods. Front-line employees receive
feedback through safety meetings and monthly meeting notes. The company uses
OSHA’s Safety and Health Assessment Worksheet to gauge its performance.
If your company’s safety program does not
contain each of these 10 elements, adjust it accordingly. As David Michaels,
assistant secretary of labor for occupational safety and health, put it,
“Making a living shouldn’t have to cost you your life. Workplace fatalities,
injuries, and illnesses are preventable. Safe jobs happen because employers
make the choice to fulfill their responsibilities and protect their workers.” Commodor Hall is ISRI’s
director of transportation safety.