September/October 2012
Free, confidential OSHA consulting services can improve the safety of small- and medium-sized scrap facilities. Those that achieve “SHARP” status get both bragging rights and peace of mind knowing they’re a model of safety for the industry.
By Diana Mota
General Recycling, a Flowood, Miss.-based scrap metal processor, knows what it takes to keep employees safe. It has been more than four years since the Nucor subsidiary has experienced an OSHA recordable incident and five years since a lost-time incident, says General Manager Don LeMar. “We want our employees to go home the same way they came to work every day,” he says. “As managers, that’s our goal.” The firm is not resting on its laurels, however. It uses its safety record to justify doing and spending more on safety, says Safety Coordinator Mike Conway. The additional investments will pay for themselves by further lowering the costs associated with worker illnesses and injuries, he says.
To achieve this level of safe operation, General Recycling enlisted the assistance of the On-Site Consultation Program, a free service the U.S. Occupational Safety and Health Administration (Washington, D.C.) offers through state agencies and universities. The program’s consultants help small- and medium-sized businesses identify and correct potential workplace hazards, comply with OSHA standards, and establish or improve their injury and illness prevention programs. From its initial consultation in February 2010 to a follow-up consulting visit in May 2011, General Recycling worked to create and maintain a safe work environment—one that exceeds OSHA requirements—for its 35 full-time employees and 15 contract workers, LeMar says. That achievement helped it qualify for OSHA’s Safety & Health Achievement Recognition Program, or SHARP, in June 2011, earning the site a two-year exemption from OSHA programmed inspections.
Although some companies see OSHA as the enemy, General Recycling and other companies that use the On-Site Consultation Program to achieve and maintain SHARP status make the agency their ally in their quest to become safer and healthier workplaces. Attaining SHARP status means a facility actively protects workers from workplace safety and health hazards and creates a workplace safety culture that engages everyone, says Diana Jones, who directs Oklahoma’s consultation program through the Oklahoma Department of Labor (Oklahoma City). As Dennis Cummings, a safety consultant with that department, puts it, “SHARP is for companies that want to be the very best—that want to be models of excellence.”
SHARP Purpose and Process
OSHA started the On-Site Consultation Program in the late 1970s, says Doug Kalinowski, director of OSHA’s Directorate of Cooperative and State Programs, because it realized small businesses struggle with workplace safety and health issues due to limited resources. “Oftentimes, the human resource director for a small business wears 10 hats, and one of them [is] safety director.” At Main Metal Recycling (Jacksonville, Fla.), for example, its staff of 31 employees does not include a full-time safety professional, says Ferrous Manager Adam Hicks. When he joined the company two years ago, he took on that role. Members of Main Metal’s management team first heard about SHARP from a presentation by University of South Florida (Tampa, Fla.) representatives at a Florida Recyclers Association meeting in June 2010, and they thought it would benefit the company’s budding safety culture. Main Metal scheduled a consultation soon after that meeting and earned the SHARP designation in November 2011. The process “helped us improve on our already-strong safety culture,” Hicks says.
In each state, the District of Columbia, and several U.S. territories, a state agency or university provides the consulting services with OSHA oversight and direction. Federal money covers 90 percent of the costs, with the state entity picking up the remainder. The program targets high-hazard private-sector companies with no more than 250 employees at a site and no more than 500 employees companywide, Kalinowski says. (For larger corporations, OSHA offers the Voluntary Protection Programs; visit www.osha.gov/dcsp/vpp/index.html or read the March/April 2009 Scrap article “Opening the Door to OSHA” for more information.)
The On-Site Consultation Program is “completely voluntary, free, and confidential,” says Oklahoma’s Jones. “There may be some expense to correct problems [the consultant discovers], but there’s no fee for the service, including occupational industrial hygiene monitoring. That’s a really good value for a small employer.” Voluntary and free are easy enough to understand, but confidential might raise eyebrows from skeptical business owners. One of the biggest challenges to participation, Jones says, is employers’ fear that “the process is not confidential or that federal OSHA will become involved.” That’s not the case, Cummings says. The program website confirms that “your name, your firm’s name, and any information you provide about your workplace, plus any unsafe or unhealthful working conditions that the consultant uncovers, will not be reported routinely to the OSHA inspection staff.” There is one catch, however: Participating companies must correct “in a timely manner” serious job safety and health hazards the consultation reveals.
Even if they have no interest in pursuing SHARP status, scrapyards can use the free consulting program for a comprehensive audit or a limited consultation that looks at as little as one piece of equipment or process, Kalinowski says. “We do about 30,000 consultation visits across the country every year, but only 1,590 companies have SHARP,” he says. (Not all of those consultations were for companies seeking SHARP approval, notes Patrick Showalter, director of the OSHA Office of Small Business Assistance. OSHA doesn’t track companies participating in the SHARP process until a consultant recommends a company for approval.) “Sometimes a limited consultation is what gets a consultant’s foot in the door,” Kalinowski says. “Once an employer is comfortable [with the process], he might talk to a consultant about SHARP.” That’s what happened at QuikService Steel Co. (Oklahoma City), one of three facilities of the Yaffe Cos. (Muskogee, Okla.) that has gone through the SHARP process. After using the consulting service, SHARP was the next logical step, says Robert Cadenhead, QuikService’s president and general manager.
A facility that applies for SHARP must show it meets the program’s requirements: It must identify and correct hazards the consultant discovers before they harm anyone, implement and maintain an injury and illness prevention program that actively engages employees, maintain illness and injury rates below the national average for the industry, and notify a SHARP consultant about changes to work conditions that could introduce new hazards. Facilities that achieve SHARP status are exempt from programmed OSHA inspections for up to two years initially and up to three years upon renewal if they meet SHARP requirements. QuikService has kept its SHARP designation since 2008; the two other Yaffe facilities to earn the designation—Yaffe Iron & Metal Corp. (Fort Smith, Ark.) and Ball Pipe & Supply (Shawnee, Okla.)—lost their status because their OSHA recordable rates were no longer under the national average for the industry, says Johnnie Johnson, Yaffe’s corporate safety manager.
The road to SHARP starts with a comprehensive audit via the On-Site Consultation Program. (Businesses can locate their state’s service provider at www.osha.gov/dcsp/smallbusiness/consult_directory.html.) In general, the auditing consultant evaluates whether the facility has an effective comprehensive injury and illness prevention program in place, is committed to worker safety, involves employees in the process, has proper safety equipment and training for employees, and uses a system that identifies and corrects hazards before they result in an injury, Showalter says.
Oklahoma’s Cummings describes the process he typically follows: The audit takes three days, during which he interviews managers and employees; reviews training records and other documents, OSHA-required programs, and company safety programs; and walks through the facility to look for OSHA violations or unsafe practices, such as issues with machine guarding or lock-out/tag-out procedures.
Guiding the audit is “Safety and Health Program Management Guidelines,” a set of best practices OSHA issued in 1989 for the systematic identification, evaluation, and prevention or control of general workplace hazards and specific job and task hazards. (Access the guidelines at www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGISTER&p_id=12909.)
During his audits, Cummings says he grades companies on 58 different items derived from the guidelines. Thus, if a facility follows the guidelines, it’s likely to do very well. The audit was “the most intense part of SHARP,” says Main Metal Recycling’s Hicks. The auditor looked for safety violations from floor to ceiling, including evaluating tools and equipment workers use.
After Cummings completes his evaluation, he reviews his findings with the employer, and together they set a timeline to correct deficiencies and schedule follow-up visits to verify that the hazards were abated. Employers must correct hazards discovered during the audit, Kalinowski emphasizes. “That’s the one caveat going in that they have to understand.” Typically, OSHA will give an employer 30 to 45 days to correct a violation unless it’s an imminent danger, Cummings says. QuikService Steel Co. was committed to fixing whatever the consultant found, Cadenhead says. Fortunately, the inspection turned up only minor problems, such as the need for additional machine guarding, barriers across open overhead doors, and electrical changes to alleviate the need for extension cords. He estimates none of the changes cost more than $500. If an employer refuses to correct hazards that leave employees at risk, the consultant must report it to federal OSHA, Jones says, but “in my 29 years here, that’s happened three times. People don’t get involved with SHARP unless they want to improve their workplace.” Instead, she says, consultants help employers find feasible and economical solutions to safety problems that won’t overburden them, she says. “That’s one of our top priorities.”
Are You Ready?
Only a small fraction of the companies that seek SHARP are ready before a consultant arrives, Showalter says. It’s more than just being OSHA-compliant, Cummings explains. “That’s the minimum. Companies that pursue SHARP are doing things that aren’t required of them that really make a difference in providing a safe and healthy workplace for employees.”
Most companies fall short by not having a systematic approach to safety and health management, he says. A company must integrate its comprehensive injury and illness prevention program into every level of the organization, from top management to line management to employees, Showalter says. “That’s a requirement for being SHARP.” No OSHA standard requires a safety and health management system, Cummings says, “but if [companies] want to be a model of excellence, then having [one] is the way to go.” They don’t have to develop it in a vacuum, however. “We give them a blueprint for an effective injury and illness prevention program and the guidance they need.” Effective systems focus on top management commitment, employee involvement, continuous improvement, and training.
Several scrap facilities that have achieved SHARP status note the efforts they have taken to engage employees in safety facilitywide. Demonstrating such engagement is part of qualifying for SHARP, Cummings says. At QuikService Steel Co., employees help design and run safety programs with management oversight, Cadenhead says, from leading safety meetings to documenting unsafe behaviors or near misses to conducting monthly safety audits. “We rotate [workers] through the audits so everyone does it about twice a year,” he says. Employees also have written job safety analysis reports on every piece of equipment at the facility, from forklifts to balers. “They’re written so simply that anyone outside the industry could understand the perils of [a given] machine.”
Like QuikService Steel, General Recycling continuously looks for ways to involve its employees, whom the company calls teammates, in safety. Teams of employees audit the company’s processes and equipment, including housekeeping and lock-out/tag-out procedures, Conway says. Employees also observe each other’s work habits using a program they call PAUSE: Prevent Accidents Using Safety Evaluations. The observation program is a competition—Conway and LeMar track participation by department—but they don’t use incentives to encourage or reward participation, they point out. “We don’t believe in incentive programs,” LeMar says. “Employees are rewarded for being safe by being able to go home to their families each day. Safety is our most important job.”
Monthly safety audits were one change Main Metal Recycling implemented as a result of its SHARP experience, Hicks says. A different employee accompanies either Hicks or the nonferrous manager in scrutinizing the ferrous yard and the nonferrous facility for potential hazards each month. By doing so, employees “see how their job contributes to promoting safety.”
Follow-through and documentation are important as well. “You need to verify all training and improvements,” LeMar says. “If you say you’re going to fix something, you have to fix it.” General Recycling documents and tracks hazard improvements in several ways, Conway says. For example, employees photograph identified hazards, correct them, and then photograph the corrections. It’s a huge commitment to implement and maintain these programs, LeMar says, “but it’s a moral commitment. We truly believe we have a moral obligation to send teammates home safely every night.”
Companies that meet most of the SHARP eligibility criteria can earn “Pre-SHARP” status as long as they commit to working toward SHARP approval, Cummings says. To do so, they must undertake the comprehensive audit, correct the hazards the consultant identifies, inform workers of the corrections, be implementing an effective safety and health management system, and meet all SHARP requirements by the end of the deferral period—no more than 18 months from when they earn the designation. If companies can’t meet the requirements in that time period, “we close out that case, and they call me when they’re ready,” Cummings says. “There’s no pressure on our part.” Once a facility satisfies all SHARP requirements, the consultant recommends it for SHARP by sending the application to the regional OSHA administrator for approval.
Maintaining Excellence
Facilities that achieve SHARP are exempt from programmed OSHA inspections for either one or two years depending on the maturity of their injury and illness prevention program and so long as they meet the requirements for participation. They must notify their state on-site consultation office when they make changes to work conditions or introduce new hazards into the workplace, Kalinowski says. “Once a year, or any time they change a process or add a new piece of equipment, they should be calling [the consultants] out and having them go through that process or piece of equipment,” Jones says. The facility also must keep its days-away, restricted, or transferred rate and total recordable case rate below the national average for the industry, Cummings says. And the facility must provide information to the SHARP program administrators about those rates as well as what type of improvements it has made to its management system, Showalter says. SHARP does not exempt employers from their workplace health and safety responsibilities or strip employees of their rights under the Occupational Safety and Health Act, the OSHA website states. Formal complaints, fatalities, catastrophes, imminently dangerous situations, and any other significant event can still trigger an OSHA enforcement inspection.
After its initial SHARP approval, a facility can request a three-year renewal in the last quarter of its exemption period. To receive the renewal, the facility must undergo another comprehensive audit via the consulting program to ensure it’s effectively maintaining or improving its injury and illness prevention program, continue to meet all eligibility criteria and program requirements, and agree to conduct interim-year self-evaluations and submit those, as well as worksite injury and illness logs, to its on-site consultation program manager.
General Recycling’s re-auditing period starts in April. The firm hired a permanent safety specialist this summer to track and demonstrate how it has improved as it goes through the recertification process. QuikService Steel Co. has gone through the certification process three times, earning the designation for two one-year terms and one two-year term. “We go back over everything,” Cadenhead says. “You learn something new every time.”
Maintaining SHARP status can be a challenge. If a facility shows signs of slipping, it might receive renewal for one year or be removed from the program, Jones says. Ball Pipe & Supply, which has about 35 employees, held the designation for two years but then lost it in 2010, says Bill Staggs, general manager. Maintaining the program was more difficult than working toward it, he says. “Once we reached the goal, it was, ‘Now what do we do?’ You need to find new ways to keep everyone involved.”
QuikService Steel recently had some recordable incidents, Cadenhead says, which he expects will knock it out of the program. “It’s hard to accept even a minor incident when you feel like you’re doing everything right. We asked ourselves whether we had become complacent because we received SHARP so many years in a row. We looked at the data and don’t feel like we have.” The weak link appears to be temporary employees, he says. The company has decided to work more closely with its hiring agencies to explain what the job requires. If QuikService Steel loses its SHARP status, it will pursue it again, he adds. “From that first year to now—even though we’ve had some incidents lately—we’re so much better than we were when we started,” he says. “It wouldn’t make sense not to continue.”
Ball Pipe & Supply also plans to purse SHARP again. “We are meeting with the Oklahoma Department of Labor this fall,” Staggs says. The company has gone more than two years without a lost-time incident, he says, which should make its rates compare favorably to the industry averages. Most companies fall off due to injury/illness rates above the national average, Jones says. Increases in injuries or illnesses often indicate that something in a company’s safety and health management system isn’t working and its program needs further evaluation, she notes. Companies that lose their status can reapply after once again meeting the program’s criteria.
Benefits of Being Sharp
Companies that achieve SHARP status enjoy several benefits, Jones says. “First and foremost, [they experience] fewer injuries and illnesses in the workplace. What that can mean for employees is better working conditions. For management, that could mean fewer financial losses due to lower turnover and insurance costs.” Indeed, QuikService Steel has seen lower turnover, Cadenhead says, with more employees reaching their five-year anniversaries than ever before. The program also improves communication and morale, which also can affect turnover, he says. “We communicate well here, and our safety program is one way we do that.”
Pursuing and achieving SHARP status is “a tremendous feeling of accomplishment,” Hicks says. “It’s changed our culture. All our employees have been enlightened to the fact that safety is a group effort. Instead of making safety something we have to do, we make it something we get to do.” It also can be humbling, however, to discover operations you thought were perfectly safe were still lacking, he says. On the surface, everything looks OK, but as people look closer, they begin to see little things that could potentially harm or injure someone, such as an electrical outlet without a faceplate. It was tough to open the company to that level of scrutiny, Hicks says. “We thought we were doing everything possible, and then someone comes along and says, ‘No, you’re not.’ It’s a gut-check moment. We don’t want to just think we’re the best.”
SHARP recognizes companies that go the distance, Jones says, celebrating their achievement with their employees and customers. Businesses that achieve SHARP receive a certificate and flag from OSHA and the agency they worked with, and they typically hold ceremonies with their community leaders to celebrate the accomplishment, Showalter says. Though such recognition is nice, “SHARP is not about receiving a certificate or flag,” Cadenhead says. “It is about having a safe place for your employees to work every day.” He and others interviewed for this story say they would like to see more scrapyards aim for SHARP. As he puts it, “It builds a relationship with your local OSHA. You come up with a program that works for you. It’s not rocket-science stuff. It’s management making a commitment that says, ‘We want to do this. We’re going to do this. How do we do this?’”
Diana Mota is associate editor of Scrap.
Free, confidential OSHA consulting services can improve the safety of small- and medium-sized scrap facilities. Those that achieve “SHARP” status get both bragging rights and peace of mind knowing they’re a model of safety for the industry.