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Back Injuries:
Improving Lifting Decisions
& Reducing Back Pain
in Your Workforce

Re-thinking Back Injuries:

Improving Lifting Decisions & Reducing
Back Pain in Your Workforce
Back pain is a huge strain on:
• productivity
• workers’ compensation costs
• overall injury rate
How do you protect against back injuries? It requires a lot more
than a back belt and 15 minutes of instruction on safe lifting
techniques. Download our free guide to get started.

Download the free guide at
Winter/Spring 2016 Contents

DEPARTMENTS Practical Tips

28 If the Shoe Fits—
Keeping Up Don’t Charge for It!
6 EOSHA Penalties Up … Counting Ensuring employees have the tools to
Inspections … Aging Workforce … Sitting perform their jobs safely should be a
Isn’t So Bad … Opioid Painkillers … Tracking win-win for both worker and employer. But,
Toxic Exposure … Quick Reminder … you need to consider all aspects of your
Cal/OSHA and Healthcare Violence … safety program—or you might get sued.
AIHA Mold Resource … Ergo Shovels … By Jasmin Rojas, JD

Strategy 30 Preventing Employee Chemical

16 Power Up Your Efforts to Protect Exposure at the Source
Workers from Hazardous Energy Keeping employees safe from hazardous
Here are a few ideas that may change the materials requires constant vigilance. We
way you think—and what you do—about have tips for companies and their workers
lockout/tagout. for preventing exposure.
By Evelyn Sacks By Clare Condon

20 Why Safety Culture Is More

Important Than You Think
Safety should be universal, but many
organizations find themselves falling short.
The key difference? A clear and consistent
safety culture.
By Jim Holland

22 Incentivizing Safety: How 33

10 Companies Are Linking CEO
Bonuses to EHS Goals
There has been a lot of controversy Day to Day
Cover Story surrounding safety incentives, and some
33 Understanding OSHA’s
programs are now targeting executive

10 Lockout/ compensation. But, is it a good idea?

By Jennifer Busick
Procedures When Reporting
Severe Injuries and RRIs

Tagout: Don’t Flip

Since the Occupational Safety and Health
Beyond Compliance Administration’s (OSHA) new reporting
requirements (29 CFR 1904.39) went into

Out over LOTO 25 Locking Out Decision Fatigue

By Ray Prest
effect in January 2015, the Agency has
been inundated with workplace
incident reports.

Compliance By Ana Ellington

Update your understanding of this 36 ‘But It Came That Way’—

life- and limb-saving standard.
The Roles, Responsibilities, and
By Evelyn Sacks
Accountability of Machine Guarding
Each year, more than 200,000 workers
suffer cuts, lacerations, and amputations
PLUS from operating machinery in the United
States. Incident investigations often
4 Editor’s Letter discover that the machines lack adequate
41 Reprints safety mechanisms, including guards and
42 Advertising Index safety switches.
42 Reader Resources By Adam Haroz, EIT

Safety Decisions is published 4 times a year by BLR, 100 Winners Circle, Suite 300, Brentwood TN 37027. Periodicals postage paid at Brentwood, TN, and at additional mailing offices. Postmaster: Send address changes to
Safety Decisions Magazine, PO Box 5094, Brentwood, TN 37024. Safety Decisions | Winter/Spring 2016 3

Editor’s Letter


Executive Vice President


Managing Editor
continues with perspectives on LOTO that STEPHEN D. BRUCE, PHD, PHR
will help any employer improve its program.
Please read these articles, and be sure your
lockout/tagout 1910.147 procedures are in JENNIFER BUSICK
place and are rigorously observed. JASMIN ROJAS, JD
Elsewhere in this issue, regular colum-
nist Ray Prest adds his take on LOTO. He CLARE CONDON
notes that while the process, when followed ANA ELLINGTON
faithfully, has a remarkable success rate at

preventing accidents, decision fatigue and Editor

other factors can cause problems.
BLR® Legal Editor Jasmin Rojas, JD, says

Production Editor
if the shoe fits—don’t charge for it! She re- JAMES K. DAVIS
ockout/tagout (LOTO) is one of views a case involving impermissible work-
the most effective tools for pre- ers’ compensation employee contributions. DEBBIE FLYNN
venting serious—and often grue- Need to know a little more about OSHA’s
some—accidents. Unfortunately, to new procedures when reporting severe in-
some short-sighted supervisors, it juries and rapid response investigations? LINDA COSTA
appears to be a productivity killer, BLR Legal Editor and safety specialist Ana
so they try to get by without it. But Ellington clarifies the new guidelines.
nothing kills productivity like an accident, Meanwhile, what else is in store in this
and circumventing LOTO procedures is issue? ART
Design Services Director
begging for trouble. • ‘But It Came That Way’—The Roles, VINCENT SKYERS
Responsibilities, and Accountability of
A welder was crushed to death by a hydrau- Machine Guarding Art Director
lic door on a scrap metal shredder. He was • Incentivizing Safety: How Companies
trying to remove a jammed piece of metal Are Linking CEO Bonuses to EHS Goals Illustrators
from the door. • Preventing Employee Chemical Expo- KELLY CHURCH
sure at the Source RJ CLARKE
A mechanic was fatally crushed in an esca-
lator while performing maintenance. He had Plus, Keeping Up brings you another
removed the escalator stairs and crawled round of ten timely items in safety news.
inside the escalator mechanism. When a As always, please share your comments MARKETING AND
coworker dropped the escalator’s electrical about the magazine—in general or any of Marketing Manager
circuit box, it triggered a relay that sent the articles—and please let me know what AMANDA HURLBURT
power to the escalator. you want to read about next. Several read-
ers have sent in some great ideas that we’re Marketing Associate
These grizzly examples are typical of the working on for future issues.
estimated 150–200 fatalities (and 50,000 or Marketing Operations Assistant
so injuries) that occur each year due to a Thanks for reading,
failure to control the release of hazardous
energy. In this issue of Safety Decisions, SALES
Sales Manager
Contributing Editor Evie Sacks takes a PAUL MANKO
fresh look at LOTO, offering expert advice
on how to manage your program, where Sales Associate
to go for detailed guidance, and what the Stephen D. Bruce, PhD, PHR
Occupational Safety and Health Adminis- Managing Editor Copyright 2016 BLR®—
tration (OSHA) expects of employers. She Business & Legal Resources

4 Safety Decisions | Winter/Spring 2016

Keeping Up

increased to provide a real disincen-
tive for employers accepting injuries
and worker deaths as a cost of doing

HEADING UP ... WAY UP business.”

Between now and August, Mavity
advises employers to prepare for the
likelihood that these new “sledgeham-
After 25 years at current levels, The agency will adjust or increase mer penalties” will be implemented.
the Occupational Safety and Health civil penalties through an interim He suggests the increases can be used
Administration (OSHA) is increas- final rulemaking no later than Au- to get the attention of corporate lead-
ing its civil penalties by as much as 82 gust 1, 2016. In comments before the ership, and he advises business own-
percent. The change, which will begin Committee on Education and the ers, “Rather than just treating safety
in August 2016, was a result of the Bi- Workforce, Subcommittee on Work- as a cost center, you should work with
partisan Budget Act of 2015 and came force Protections, Assistant Secre- your company safety professionals
as a surprise to many in the regulated tary of Labor for OSHA David Mi- to develop a business plan to achieve
community. chaels said OSHA penalties “must be your company’s goals in this area.”
According to Howard Mavity, a
partner with the labor and employ-
ment law firm Fisher & Phillips LLP,
“The agreement requires OSHA to
make a one-time ‘catch-up’ increase to
compensate for more than 2 decades
of no increases. The catch-up increase
cannot exceed the rate of inflation
from 1990 through 2015, which is ex-
pected to be around 82 percent.”
If the maximum catch-up in-
crease is applied, the current highest
fine—$70,000 for repeat and willful
violations—would top $125,000. And,
the $7,000 maximum fine for serious
and failure-to-abate violations would
jump to $12,744. Once the catch-up is
implemented, says the law firm, OSHA
will then annually increase maximum
penalties according to the rate of infla-
tion for the prior fiscal year.

OSHA Done with Counting Inspections

OSHA says it’s the quality, not the quantity of inspec- said agency chief David Michaels. These complex inspec-
tions that matters. To that end, the agency announced it tions will include chemical exposures, ergonomic issues,

will no longer count the number of inspections it conducts multiemployer worksites, workplace violence cases, and
(which, in case anyone is counting, is about 40,000 per others that require more in-depth analysis.
year). Under what it’s calling an Enforcement Waiving Sys- The agency will continue its use of the General Duty
tem, OSHA will no longer tally inspections, but will con- Clause (GDC) even in cases where a standard exists but
centrate on the more complicated, time-consuming cases. an employer could have provided more protections for its
“I think you’ll see more complex inspections, and I employees. Under GDC, employers are required to provide
think those end up being the more impactful inspections,” employees with a safe and healthful place of employment.

6 Safety Decisions | Winter/Spring 2016

One out of every five American
workers is over 65, and the number is
on the rise. By the year 2020, one-quar-
ter of the workforce will be over 55,
according to the U.S. Bureau of Labor
Statistics. The National Institute for Oc-
cupational Safety and Health (NIOSH)
has established the National Center for
Productive Aging and Work and a de-
tailed webpage with information and re-
sources on this timely topic. This infor-
mation can be found at http://www.cdc.
NIOSH says productive aging “in-
volves providing a safe and healthy
work environment for everyone
through comprehensive strategies
that allow workers to function op- than their younger colleagues. This ism when they are feeling ill but come
timally at all ages.” Arthritis and hy- may be due to accumulated workplace to work nonetheless.
pertension (high blood pressure) are experience or factors like increased NIOSH recommends strategies for
the two most common health condi- caution and awareness of physical creating a more age-friendly work-
tions affecting older workers. An even limitations. When accidents do occur, place, including giving workers a say
greater proportion of workers (more however, older workers often require in their schedule; matching tasks to
than 75 percent) are estimated to have more time to heal, which reinforces abilities; avoiding prolonged, seden-
at least one chronic health condition, the importance of a well-planned re- tary work; managing hazards like noise
such as diabetes or heart disease, that turn-to-work program. In addition, and fall risks; managing post-absence
requires management. senior employees may experience accommodation; and training super-
Older employees actually tend to more absenteeism when they feel ill visors on effective ways to supervise a
experience fewer workplace injuries and may experience more presentee- multigenerational workforce.

INNOVATIVE DEVICE record a person’s exposure to chemicals. The wristbands,

which are similar to the popular bands worn to show sup-

TRACKS TOXIC port for various causes, have a porous surface that mimics
a cell that absorbs the contaminants people are exposed to

EXPOSURES at work or in the environment.

In an OSU experiment, the bracelets soaked up nearly
50 chemical compounds, including traces of fragrances,
Employees are exposed to a range of pollutants every flame retardants, pesticides, caffeine, nicotine, and chem-
day but do not often know which ones—or to what degree icals from flea medicines for pets. Roofers also wore the

they’ve been exposed. Measuring contact with toxins can wristbands, which showed exposure to polycyclic aromat-
be difficult, requiring expensive and bulky devices that ic hydrocarbons—12 of which are on the Environmental
people are reluctant to wear for long periods of time. Protection Agency’s priority list.
Oregon State University (OSU) says it has come up with The bracelets are not yet available to the public, but
a more accessible method that uses silicone bracelets to additional studies are planned. Safety Decisions | Winter/Spring 2016 7



Regulate Healthcare ACTION ON OPIOID
Cal/OSHA, which is often ahead of The National Safety Council (NSC) has called on the U.S. Drug Enforce-
federal OSHA in regulating work- ment Administration (DEA) to require education and additional training for
place risks, has proposed a standard medical practitioners who prescribe opioid painkillers. The council wants DEA
that addresses violence in healthcare to make education and training a part of initial and subsequent registration
facilities. The proposal would affect under the Controlled Substances Act of 1970.
hospitals, outpatient medical offic- “The most fatally abused drug today is legal and sitting in our medicine cab-
es and clinics, home healthcare and inets,” said Deborah A.P. Hersman, NSC president and CEO. “DEA has been on
home-based hospice, paramedic and the front lines of the fight to end this epidemic, and we applaud its efforts. We
emergency medical services, drug urge DEA to take another critical step by requiring prescriber education and
treatment programs, and ancillary training to prevent overprescribing and save lives.”
healthcare operations. Covered em- According to the council, opioid painkillers such as OxyContin, Percocet,
ployers would be required to devel- and Vicodin lead to more fatal drug overdoses than heroin and cocaine com-
op a written plan that would be part bined. The rise in fatal opioid painkiller overdoses has paralleled the huge in-
of the already required Injury and crease in prescriptions. Yet, the United States has not seen a decrease in the
Illness Prevention Plan. overall number of people reporting pain, and studies suggest these medicines
The proposal includes provi- are not always the best method for reducing acute pain.
sions for: Twenty-three percent of the U.S. workforce has used prescription drugs for
• Active employee involvement nonmedical purposes. NSC says that even employees who take a regular dose
in developing the plan and may be too impaired to work, especially those in safety-sensitive positions.
identifying and correcting Workers who are prescribed even one opioid have average workers’ compensa-
hazards; tion total claims costs that are four times greater than claims for workers who
• Employee training and pro- were not prescribed opioids. Receiving more than a 1-week supply of the drugs
cedures for reporting, inves- soon after an injury is said to double a worker’s risk of disability 1 year later.
tigating, and recording vio- Employers concerned about the issue are advised to:
lence incidents; and • Partner with insurance, healthcare, and employee assistance program
• Procedures for correcting providers.
hazards, such as configuring • Reevaluate their policy and testing for prescription drugs.
space so that employee access • Invest in supervisor and employee education on the topic.
to doors and alarm systems • Increase and ensure confidential access to help and treatment for
cannot be impeded; main- employees who need it.
taining adequate staffing; and
having an effective response
plan for violence emergencies.

AIHA Now Offering Online Mold Resource

The proposal was met with en-
thusiasm by the California Nurses
Association. The group cites federal
government statistics that a worker The American Industrial Hygiene evated and prolonged humidity, or
in health care and social assistance is Association (AIHA) has launched damp conditions.
nearly five times more likely to be the an online Mold Resource Center at The online content is aimed at pro-
victim of a nonfatal assault or violent fessionals and consumers who want
act than the average worker. The Cal/ resources/TopicsofInterest/Hazards/ to learn facts about mold, potential
OSHA measure would implement Pages/Mold.aspx. According to AIHA, adverse health effects of exposure,
SB 1299, the Healthcare Workplace mold refers to “a group of filamentous and information about remediation
Violence Prevention Act. In April, fungi that are common on food or wet and prevention. It also provides flood
federal OSHA updated its guidelines materials.” Indoors, mold needs mois- response information, additional
for preventing workplace violence for ture to grow. Mold presents problems resources about mold, and AIHA
healthcare and social service workers. only where there is water damage, el- consultant listings.

8 Safety Decisions | Winter/Spring 2016

Ergo Shovel May Be the Wait, So Now
Next ‘Better Mousetrap’ They’re Saying
Sitting Isn’t
All shovels are not created equal, The Bosse shovel features a 16-
claims Bosse Tools. The company has position locking handle that can be
introduced what it calls a revolution- customized for various jobs, tasks, and
ary reinvention of the shovel. The er-
gonomic version is said to reduce job-
site injury while boosting productivity.
users. The company says the configu-
ration can reduce stress and strain on
backs, wrists, and shoulders. The new
So Terrible?
Notes Bosse CEO Stephen Walden, shovel is in use by a large waste and New research from the Unit-
“We see so many products change and recycling company whose safety di- ed Kingdom is challenging the
adapt to modern technology, but when rector says the adjustable center grip popular claim that sitting for long
we look at shovels today and shovels allows employees to minimize twist- periods of time increases health
from a hundred years ago, we have ing and torquing of the body. Bosse risks, even if the sitter is otherwise
seen no innovation or improvement has brought out a variety of ergonom- physically active.
that can reduce exposure to risk in ic shovels, including a scoop shovel A study published in the Inter-
these highly labor-driven industries.” and a snow shovel. national Journal of Epidemiology
followed more than 5,000 par-
ticipants for 16 years. The results
point to the fact that sitting, either
at work or at home, is not associat-
ed with an increased risk of dying.
These findings are at odds with
previous research suggesting that
the act of sitting itself causes harm
even when people routinely walk a
lot or do other exercise.
Melvyn Hillsdon, PhD, from
the University of Exeter explained,
“Our study overturns current
thinking on the health risks of sit-
A QUICK REMINDER COULD ting and indicates that the problem


lies in the absence of movement
rather than the time spent sit-
ting itself. Any stationary posture
Every winter, there are scary news stories about individuals caught in their where energy expenditure is low
vehicles in a fierce winter storm, struggling to stay warm and living for 2 days may be detrimental to health, be it
on a single granola bar. Although staying in the vehicle when stranded is often sitting or standing.”
the safest choice, preparation is the key to survival. Share these tips from the Future research will consider
Centers for Disease Control and Prevention with your workforce to be sure whether long periods of sitting are
they don’t end up as the subject of a headline: associated with increased incidence
• Tie a brightly colored cloth to the antenna as a signal to rescuers and, if it is of diseases, such as heart disease
not snowing, raise the hood of the car. and type 2 diabetes, and will inves-
• Move anything needed from the trunk into the passenger area. tigate the biological mechanisms
• Wrap your body, including your head, in extra clothing, blankets, or newspaper. underlying previously observed as-
• Stay awake. sociations between sitting time and
• Run the motor and heater about 10 minutes per hour, opening a window health outcomes.

slightly to let in air. Make sure snow is not blocking the exhaust pipe.
• While sitting, keep moving arms and legs to improve circulation and stay Keeping Up is compiled by Evelyn
warmer. Sacks, a contributing editor of Safety
• Do not eat unmelted snow, as it will lower your body temperature. Decisions.
• Huddle with others, if anyone else is around, for warmth. Reprint: SD_0116-1 Safety Decisions | Winter/Spring 2016 9


Don’t Flip Out over
LOTO Compliance
Update your understanding of this
life- and limb-saving standard.
By Evelyn Sacks

welder was crushed to death by a hydraulic door on a scrap met-
al shredder. He was trying to remove a jammed piece of metal
from the door. The system’s energy had not been released, and
the door had not been blocked open.
A mechanic was fatally crushed in an escalator while per-
forming maintenance. He had removed the escalator stairs and
crawled inside the escalator mechanism. When a coworker
dropped the escalator’s electrical circuit box, it triggered a relay that sent power
to the escalator. The stairs began moving, and the mechanic could not escape.
The escalator had no locks or tags on any power controls.
These grizzly examples are typical of the estimated 150–200 fatalities (and
50,000 or so injuries) that occur each year due to a failure to control the release
of hazardous energy. Lockout/tagout (LOTO) 1910.147 refers to the Occupa-
tional Safety and Health Administration (OSHA)-required practices and proce-
dures to protect workers from unexpected start-up of machinery or from haz-
ardous energy released during service or maintenance. The standard is based on
the fact that simply turning equipment off is not enough to block stored energy.
Lockout devices hold energy-isolating equipment in a safe or off position.
They prevent equipment from becoming energized because the lockout devices
cannot be removed without a key or other unlocking mechanism. Tagout devices,
by contrast, are prominent warning devices that are fastened to energy-isolating

devices to warn employees not to reenergize the machine while they are being
serviced or maintained. Tagout devices are easier to remove and, alone, provide
less protection than lockout devices.

10 Safety Decisions | Winter/Spring 2016 Safety Decisions | Winter/Spring 2016 11

If You’ve Got Equipment, the issue of “who’s covered” can be confusing. LOTO cov-
You’re Probably Covered ers servicing and maintenance of machines and equipment
According to OSHA, “If your employees service or main- where release of stored energy or unexpected startup could
tain machines where the unexpected startup, energiza- harm employees.
tion, or the release of stored energy could cause injury, She explains, “Normal production operations are not
the standard likely applies to you. The standard applies covered by the LOTO standard. However, servicing and/or
to all sources of energy including, but not limited to me- maintenance activities that take place during normal oper-
chanical, electrical, hydraulic, pneumatic, chemical, and ations are covered if an employee is required (1) to remove
thermal energy.” or bypass a guard or other safety device or (2) if an em-
Incidents related to the control of hazardous energy are ployee is required to place any part of his or her body into
perennially on OSHA’s top 10 list, but there seems to have an area on a machine or piece of equipment where work
been an uptick in cases in recent months. “One of the rea- is actually performed on the material being processed, or
sons we’re noticing so many amputations and related cita- where an associated danger zone exists during a machine
tions is OSHA’s new reporting rules that, since January, have operating cycle.”
required employers to notify the agency of all work-related
amputations,” explains Nickole Winnett, shareholder in the Understand the Exemptions
Washington, D.C., office of Jackson Lewis. The reporting LOTO does not apply to work on cord- or plug-connect-
serves as a red flag and is triggering more inspections. The ed electric equipment and certain hot tapping operations.
culprit behind amputations is often a failure to lock out or (Hot tapping refers to the installation of connections to
tag out hazardous energy when employees are working on pipelines while they remain in service.) Minor servicing
or near a machine, or a failure to use machine guarding. activities that take place during production are also not
Winnett says that although the standard is fairly straight- covered as long as the employer provides effective alterna-
forward and relatively easy for employers to understand, tive protection from hazardous energy, such as guards.

Compliant (and
• Exposure to electrical hazards from
work on equipment in electric utilization

Inquiring) Employers • Oil and gas well drilling and servicing;

• Work on cord and plug-connected

Want to Know … equipment if it is unplugged and the

authorized employee has exclusive
control of the plug; and
There are, to say the least, many moving Q. What is not covered? • Certain hot tap operations.
parts when it comes to protecting employ- A. Servicing and maintenance performed
ees from hazardous energy. The following during normal production operations are Q. What are the basic elements of an
are OSHA’s answers to several key ques- not covered, but only if the safeguarding energy control program?
tions about LOTO compliance. provisions and other standards are effective A. There are three: energy control proce-
in preventing worker exposure to hazards dures (with specific information an autho-
Q. Who is covered by the standard? created by the unexpected energization rized employee must know), employee
A. The standard applies to general industry or startup, or the release of energy. Also, training, and periodic inspections.
workers performing service and mainte- minor tool changes and adjustments that
nance on machines and equipment, and are routine, repetitive, and integral to the Q. Can I develop my own program,
who are exposed to unexpected startup, en- use of the equipment are not covered as or does OSHA dictate what should
ergization, or release of hazardous energy. long as workers are effectively protected by be included?
alternate measures. Also not covered are: A. Yes. In fact, employers are expected to
Q. What activities or operations are • Construction, agriculture, and maritime develop programs and procedures, training,
covered? work; and inspections that meet their particular
A. Any source of energy, which can include • Installations under the exclusive control needs and the types of equipment in use
mechanical, hydraulic, pneumatic, chemi- of electric utilities for power generation, as long as they meet the requirements of
cal, thermal, or others. transmission, and distribution; the standard.

12 Safety Decisions | Winter/Spring 2016

OSHA requires that in order to be exempted, the minor
servicing exemption applies only to activities that are: “IN MOST INSTANCES,
• Routine—part of a regular procedure.
• Repetitive—repeated regularly as part of the production UNLESS IT’S WORKING ON
process or cycle.
• Integral—inherent to and performed as part of the A CORD OR REALLY MINOR
production process.
Watch Out for Small Changes
OSHA applies a broad interpretation of servicing and
maintaining, according to Winnett. “In most instances,
unless it’s working on a cord or really minor servicing,
OSHA will say that LOTO applies and the system needs
to be de-energized. But many employers don’t understand
this and tend to stretch their understanding of servicing
and maintaining.” • The service or maintenance does not create hazards for
She offers the example of a pizza box manufacturer other employees.
making a small change to the line in order to produce a
box of a different size. It’s not enough to hit the stop or off In order to apply this exception, the employer must have
button, Winnett emphasizes. “If the system is not de-ener- had no accidents involving unexpected activation or reen-
gized, it could cycle on and injure someone. But the em- ergizing of the equipment during service or maintenance.
ployer may wrongly believe that turning off the machine If the above conditions are not met, written procedures
was enough.” In fact, the system needs to be fully de-ener- must be developed for each piece of equipment.
gized in OSHA’s view, and that status must be verified by an
authorized individual. Advice for Avoiding Citations
Verification varies by machine, but essentially involves Another area of regulatory concern is businesses that op-
reviewing the equipment to understand how it will be shut erate out of more than one location. “If you have multiple
down, then shutting it down and isolating the energy by worksites, OSHA looks at the history of the company to
putting a lock or tag on it so that it cannot be restarted. determine whether to issue serious, repeat, or willful viola-
Once de-energization has taken place, the next step is to tions,” says Winnett.
cycle the equipment through and test the system by trying She adds, “If you have a LOTO citation at a plant in one
to start it up to ensure that it is de-energized. city, but have not made and verified the fixes, OSHA could
issue a repeat violation with penalties up to $70,000 (and
Will Your Efforts Stand up to Scrutiny? higher after August 2016) for the same problem at another
What gets employers into trouble with OSHA when it comes location.” For that reason, employers should communicate
to LOTO? Winnett points to a variety of causes, including OSHA citations received at one location to other sites so
failure to ensure that energy control procedures have been they can review their practices and make any necessary
developed, documented, and are in use for each piece of changes.
equipment where service and maintenance occur. Excep- Winnett urges employers to be mindful of the federal
tions are situations in which the following are all in place: government’s practice of issuing contracts to employers
• The equipment has no potential for stored or residual with a strong record in safety and other compliance areas.
energy or reaccumulation of stored energy after shut “If you’ve received a citation, the government is going to
down, which poses a risk for employees. weigh that in determining who gets contracts.” Winnett
• The equipment has a single energy source, which can be also reminds employers that they must provide equipment-
readily identified and isolated. and program-specific training to employees and must not
• Isolating and locking out the energy source will com- rely solely on off-the-shelf LOTO safety videos.
pletely de-energize the equipment. Winnett recommends creating a worksheet or an ap-
• The machine or equipment is isolated from the energy pendix (paper or digital) for the LOTO program for fore-
source and is locked out during service or maintenance. men and crew members to ensure they complete all steps.
• A single lockout device will achieve a lockout condition. The appendix walks personnel through every step of lock-
• The lockout device is under the exclusive control of the ing and tagging out each piece of equipment and trains
authorized employee. them on specific expectations. Safety Decisions | Winter/Spring 2016 13


NIOSH Serves up compliance officers on the agency’s interpretation of the

relevant standards and its procedures for enforcing them.

Food for Thought As such, it contains important insights for employers.

When asked what’s missing in programs he inspects,
Schlumper points to the requirement for periodic inspections.
on LOTO Hazards “One of the main requirements is that employers perform pe-
riodic—at least annual—inspections of each procedure. But,
many companies I’ve dealt with are not meeting the require-
The National Institute for violation in 2012–2013 for ments.” OSHA requires that the inspection be performed by
Occupational Safety and Health food manufacturing. an authorized employee not involved in the energy control
(NIOSH) found that food man- What’s going on? NIOSH be- procedure being inspected. The inspection includes identifi-
ufacturing workers experience lieves the pressure to maintain cation and correction of any deficiencies or deviations, review
a higher rate of injuries and ill- a fast pace on assembly lines of each authorized employee’s responsibilities, review of au-
nesses than workers in private could cause food-process- thorized and affected employees’ lockout duties, and certifica-
industry overall. Their rate, 5.4 ing facilities to fall short on tion by the employer that the inspection has been performed.
per 100 workers, is consider- hazardous energy control. The The review must be equipment-specific. “If you have 50
ably higher than the 3.4 per 100 researchers state, “Given the pieces of equipment that are all different from one another,
workers for private industry. production pressures in this each procedure needs to be inspected,” advises Schlump-
According to NIOSH research, industry, workers may feel that er. But if two or more pieces of equipment are the same,
many machine-based injuries managers would rather have only one procedure needs to be written and inspected. An
in the food business are related them risk injury than stop annual inspection should be the minimum, he suggests.
to failure to use lockout/tagout production to properly apply “Don’t skimp on this step and just go through the motions.
procedures. From 2003 to 2013, LOTO procedures.” The goal is to ensure that your procedures are effective and
28 fatalities and 227 serious NIOSH encourages food that employees are actually following them.”
injuries such as amputations manufacturers to follow all


were related to LOTO, with the OSHA requirements for LOTO,
largest number in meatpacking and to make sure workers
and poultry slaughtering and
processing. LOTO was also the
have a clear understanding
of when hazardous energy OF SAFETY-FIRST CULTURE THAT
most frequently cited OSHA control procedures apply.
Business owners should be sure their company policies
provide employee stop-work (or stop-equipment) author- SERIOUS ACCIDENT.”
ity. “OSHA loves to see the sort of safety-first culture that
empowers employees and could hopefully prevent a seri- Another compliance problem Schlumper observes
ous accident,” adds Winnett. “Having those sorts of poli- is LOTO programs that fail to provide sufficient detail.
cies and programs in place can possibly affect the severity “OSHA’s CPL (compliance directive) document discusses
or classification of an OSHA penalty.” this at some length. Two words that come up frequently in
the document are ‘specificity’ and ‘detail.’”
Hundreds of Inspections Under His Belt The intent is to produce a document that is specific and
Paul Schlumper is a safety supervisor with the Georgia detailed enough so that anyone could follow it, not just
OSHA Consultation Program. A certified safety professional someone who is intimately familiar with the equipment
and engineer, Schlumper also heads the Safety Engineering and the process of de-energizing it. “You want to see a pro-
Branch of the Human Systems Integration Division at the cedure with lots of pictures, arrows, and accompanying
Georgia Tech Research Institute. He has helped hundreds text that is somewhat technical and really describes what
of organizations step up their compliance and safety perfor- people need to do,” Schlumper adds.
mance and frequently advises on lockout/tagout.
Schlumper often recommends that employers review Evelyn Sacks is a contributing editor of Safety Decisions.
OSHA’s lengthy (130-page) but valuable compliance di-
rective on LOTO. The document, CPL 02-00-147, advises Reprint: SD_0116-2

14 Safety Decisions | Winter/Spring 2016®
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nergy fuels enterprise.
Properly channeled and
managed, energy keeps
processes humming, equip-
ment producing, and plants
running. When released
uncontrolled, energy in
diverse forms—electrical, nuclear,
gravitational, thermal, and chemi-
cal among them—can injure or kill.
Hazardous energy releases may oc-
cur during installation, maintenance,
service, or repair of equipment or sys-
tems. The best way to avoid the risk is
to shut off power, lock out energy, re-
lease stored energy, and confirm that
it’s been done.
The Occupational Safety and
Health Administration’s (OSHA)
lockout/tagout (LOTO) standard re-
quires that equipment be locked or
tagged out of service when there is a
chance for injury. Personnel must not
attempt to operate switches, valves, or
other energy isolating devices once
they are locked or tagged. An autho-
rized person must turn off and dis-
connect equipment from its energy
source during service or maintenance.
Locks, tags, and other methods pre-
vent those who are unauthorized from
reenergizing equipment.
Lockout/tagout perennially ap-
pears on OSHA’s annual list of
most-violated standards. The agency
maintains that compliance could pre-
vent hundreds of deaths and thou-
sands of injuries, including ampu-
tations, each year. That’s why OSHA
continues to aggressively enforce this
bedrock standard.

Power Up Your Efforts Clearing Up

to Protect Workers from Rockwell Automation is a global lead-
er in industrial automation and infor-

Hazardous Energy
mation. With annual sales in excess of
$6 billion, the Milwaukee-based com-
pany helps customers in more than
80 countries achieve “smart, safe, sus-
Here are a few ideas that may change the way you think— tainable operations in a wide range of
and what you do—about lockout/tagout.

industries throughout the world.” In

October 2014, Rockwell Automation
By Evelyn Sacks acquired ESC Services, Inc., a global

16 Safety Decisions | Winter/Spring 2016

provider of lockout/tagout services ly, and companies are realizing that More Efficiency, Not Less
and solutions. LOTO is not a production killer un- According to Michalscheck, an effi-
Experts from Rockwell Automa- less you let it be,” notes Michalscheck. cient and modern LOTO program is
tion and ESC Services answered our By taking a close look at their over- based on five basic components:
questions (and, we hope, yours) about all LOTO safety program, companies 1. Corporate policy. LOTO policy
automation, lockout/tagout, and new can often reengineer processes to in- describes enforcement protocol,
approaches to persistent hazards. corporate alternative protection mea- includes guidance for onsite con-
We talked with Jimi Michalscheck, sure procedures. These control the ma- tractors, and details who has re-
ESC Services director of market chines in a safe state and keep them in sponsibility for correcting identi-
development; Steve Ludwig, pro- compliance. OSHA requires that using fied deficiencies.
gram manager for safety at Rockwell alternative procedures must not intro- 2. Machine-specific procedures. Rock-
Automation; and George Schuster, duce additional risk to employees. well Automation and ESC Services
business development manager for “If you can design alternative pro- recommend creating graphical, ma-
Rockwell Automation. cedures and an overall alternative pro- chine-specific procedures for every
Michalscheck says a basic yet es- gram to ensure effective protection for piece of equipment in the facility and
sential concern is that many employ- specific tasks, then the sky is the limit installing procedures at the appro-
ers misunderstand what businesses to enhancing productivity,” Michals- priate point of use.
are covered by the standard. “Lock- check adds. While it may be possible 3. Training. Compliant and effective
out/tagout applies to every industry, to engineer out many servicing activ- training targets authorized per-
not just manufacturing,” he explains. ities with well-designed safety proce- sonnel, affected employees, and
“That includes hospitals, banks, casi- dures and high-performance hard- contractors with specific modules
nos, and hotels. Any company that has ware, Rockwell Automation always customized to each group’s needs.
more than 10 employees is required recommends following LOTO reg- 4. Locks and devices. Locks and
to comply.” ulations when servicing equipment devices should be specific for
LOTO is as important in a hotel where no “company-approved” safe lockout/tagout and uniform in
or government building as it is in a alternatives exist. make and color. This discourages
production facility. That’s because
large nonmanufacturing buildings
house dozens or even hundreds of

Are Your Locks and Tags

pieces of equipment that can store
energy—from air handler units on
the roof to booster pumps, boilers,
and other industrial equipment with
high voltage and high hazards. Build-
All They Should Be?
ing owners and managers often fail to Are your locking and tagging devices doing all they should to keep your employees from
grasp the hazards of noncompliance contact with hazardous energy sources? If you can answer yes to the following, you’re on
and the requirements for compliance. the path to protection:
Another common misconception
is that safety and productivity are in- Locks are:
compatible priorities. It’s simply not • Standardized throughout the facility,
the case, says Ludwig, who believes • Strong enough to withstand all but heavy force or tools,
it is possible to have both without • Used only for lockout,
compromise. “Users of machinery no • Durable enough for conditions where they’re used, and
longer have to do a complete lockout • Identified with the name of the authorized employee who installs and removes them.
under many circumstances—you can
bring a machine to a safe state without Tags are:
completely shutting down.” • Used only when equipment can’t be locked out,
ESC Services helps organizations • Understood to be a warning only,
do this by conducting analyses and • Standardized throughout the facility,
providing procedures that help them • Used for this purpose only,
use their equipment in a safe, produc- • Strong and durable,
tive way that reduces both scheduled • Marked with bold, easy-to-read warnings, and
and unscheduled downtime. “Indus- • Identified when used with the name of the authorized employee who installs and
try best practices are evolving quick- removes them. Safety Decisions | Winter/Spring 2016 17


“THERE’S A GROWING RECOGNITION THAT fairly recently, however, that same

approach had not been applied to
“There’s a growing recognition that
MAKE MACHINERY SAFER ARE ALL PART OF lockout/tagout and other processes
to make machinery safer are all part
THE OVERALL PRODUCTIVITY OF A PLANT.” of the overall productivity of a plant,”
says Schuster. Applying the same
keen eye to maintenance reflects a
employees from using them for procedures, and training, opera- more holistic view of manufacturing.
other purposes, such as locking tors and authorized employees are If a machine is down due to a jam,
their toolboxes, which can lead to less likely to have an accident. failure, or other reason, getting the
an OSHA citation. Beyond the basic program elements, maintenance performed quickly and
5. Annual audits. Every procedure ESC Services offers advanced tools, safely presents another opportunity
must be reviewed, and authorized including a software application that for optimizing productivity. The key
employees must be audited annu- includes open source Microsoft® Excel is ensuring that the equipment can
ally to ensure program integrity. files, a website portal for housing the be shut down and LOTO can be per-
Maintain all findings from the au- files, and a tablet for scanning a QR formed and verified in an efficient and
dits as proof that your program is code on the procedures for quick access. orderly fashion. Strategies, like mak-
compliant in the event of an OSHA ing sure carts are supplied with need-
inspection. Case in Point ed tools and parts, contribute to more
A printing company found that re- expeditious restarting and less lost
ESC Services research suggests placing antiquated, text-based proce- productivity. “Downtime events are
that a well-designed and well-execut- dures with new graphical procedures being broken down into smaller slices,
ed LOTO program based on the above considerably cut the time required and each slice is being scrutinized for
elements can increase production for authorized employees to identi- optimization,” Schuster adds.
efficiency in a number of ways. fy breakers for remote disconnects.
• Reduced lockout time during Lockouts for even simple equipment So, Why Do LOTO
routine, scheduled, or unplanned like conveyors that did not previously Incidents Persist?
maintenance by an average of 50 have written procedures were reduced Despite new approaches and im-
percent or more. from 1 hour to 5 minutes with the new proved systems, lockout/tagout-relat-
• Reduced unlock time after mainte- system. For more complex equipment, ed incidents are not diminishing and
nance by an average of 50 percent like a printing press, a 4.5-hour lock- in recent years have risen. According
or more. out procedure was reduced to 30 min- to Schuster, “LOTO is sometimes so
• Prevention of delayed starts. Lack utes, and employees had more confi- poorly engineered and so poorly in-
of communication between au- dence that it was performed correctly. tegrated into the rest of the machine
thorized employees and operators Using downloadable Excel files function that it is bypassed.”
leads to idle equipment. Hours made it easier and quicker to identi- Michalscheck concurs and also
of downtime can result when fy and make changes to procedures. notes the many “incentives” for by-
equipment repairs are complete, And, an iPad application that syncs passing LOTO procedures. For exam-
but the message is not conveyed to with the employer’s secure website ple, a worker in a hospital setting might
operators. portal substantially reduced the time take a shortcut because he is concerned
• Prediction of inefficiency trends. needed to audit hundreds of proce- about being able to complete a mainte-
Trend identification is improved dures over a 12-month period. nance task in the time allowed on the
with data collection tools that work order. Michalscheck warns that
track minimum, maximum, and Why Not Optimize such “false finish lines” can contrib-
average lockouts per machine Maintenance, Too? ute to incidents and inefficiency, and
and per authorized employee. If a George Schuster of Rockwell Automa- offers the following example. A work
trend emerges, it’s easy to see and tion expands on the idea that lockout/ order allots 35 minutes for changing a
address. tagout can actually boost rather than belt on an exhaust fan, and the main-
• Accident reduction. Accidents lead diminish productivity. He points to tenance employee feels pressure to stay
to downtime, regardless of wheth- the long tradition of optimizing man- on schedule. If the employee has the
er an injury is involved. Supported ufacturing tasks to make them faster, parts and knows how to lock out the
by proper lockout/tagout policy, easier, and more productive. Until fan, 35 minutes may be sufficient, says

18 Safety Decisions | Winter/Spring 2016

Michalscheck. But, if the employee
approaches the task and realizes he or
she does not know the procedure, the
temptation might be to bypass lockout
altogether rather than conduct the nec-
essary research to do it properly.
In a different type of work environ-
ment, such as a manufacturing plant,
production pressures may be the rea-
son the employee fails to lock or tag
out the equipment before performing
service or maintenance.
Consider a case packer that jams
repeatedly. An employee knows how
to lock out the equipment, but he
might not know that lockout may not
be the most efficient safe procedure
for unjamming this particular ma-
chine. If the case packer jams three
times in 1 hour, and cutting all ener-
gy sources takes 7 or 8 minutes each
time, an alternative and compliant
method (such as remotely operated
tools or guarding with redundan-
cy and verification) could cut that
downtime to 30 seconds per jam.
Ludwig of Rockwell Automation says
one reason incidents occur is because
employers fail to understand alternative
protective measures and the require-
ment that the alternative measures must Automation advise clients to train at Schuster reflects the views of his col-
not add risk to the procedure. “Under- least annually. The training should be leagues when he advises safety profes-
standing the procedures and technolo- dynamic. That is, it should not be a sionals to “Consider holistically the way
gies you are working with is a vital skill rehash of the past year’s training but people interact with machinery. If you
set,” he adds. “You can’t assume that rather should include new content do it in a piecemeal manner, you’re go-
because you unjam something multiple and fresh perspectives. Examples are ing to miss the most critical, systematic
times you can do it without LOTO and reviewing near misses and equipment aspects of a comprehensive compliance/
call it an alternative method.” pain points (like the machine that safety approach, including the people,
jams three times in 1 half hour). Go the culture, management support, and
When Training Is the Culprit beyond discussing how to perform other elements of what we describe as a
In some cases, incidents are a result lockout/tagout, and address why it company’s ‘safety maturity.’”
of poor or improper training, such as matters to your business. Best-in-class companies go beyond
failure to customize the training to the Also, be aware of the requirement considering lockout/tagout as solely a
industry or failure to involve hands- to train contractors—a frequently compliance issue. Done right, it can
on demonstration or proof of compe- overlooked requirement. Michals- actually drive productivity.
tency. Says Schuster, “A good system is check notes that while contract em- For additional perspectives and
a combination of technology, systems, ployees may not need to know every tips on lockout/tagout, readers may
and people who are trained and un- detail about your system, they do wish to visit the ESC Services learning
derstand how to use it.” need to be trained and authorized center at
Despite OSHA’s requirement that just like your own employees. This ing-center.
a LOTO-authorized employee need can be accomplished in a relatively

only be trained once (except in cases quick, on-the-floor session focused Evelyn Sacks is a contributing editor of
of job reassignment or new equip- on the equipment contractors will be Safety Decisions.
ment), ESC Services and Rockwell working on. Reprint: SD_0116-3 Safety Decisions | Winter/Spring 2016 19


Why Safety Culture afety is a topic that is uni-
versally shared. It is rare

Is More Important that a company or opera-

tion will consider its safety

Than You Think

program and performance
proprietary, even when
differentiating itself from
competitors. So why, with the abun-
Safety should be universal, but many organizations find dance of ideas, programs, standards,
themselves falling short. The key difference? A clear and best practices, all of which are in
the public domain and easily acces-
and consistent safety culture. sible via the Web, do companies see
very different outcomes in their safety
By Jim Holland performance?
The answer is culture. Specifical-
ly, the safety culture of the operation
and how it is adding to or detracting
from safety performance. Culture is
both the first and last line of defense
against injury and loss. It ensures that
employees follow designated process-
es and systems, and when those pro-
cesses fail and those systems break
(and they always do), culture asserts
itself to drive the proper response
through the value system that is in
place within the organization. Inci-
dent analysis will almost always show
a chain of events occurred that led to
an injury; it is never one thing that
causes an accident.
“Culture” is defined as a shared
set of common values, experiences,
beliefs, and characteristics. The chal-
lenge of any management team is fig-
uring out how to create a shared view
of safety throughout the organization
that will be that extra line of defense
against accidents and injuries.
Introducing and embracing the
concepts of culture and values in most
firms, and especially those in techni-
cal or engineering endeavors, remains
an uphill fight.

Replacing Hope with Belief

In my 30 years of work in safety, I have

rarely encountered a management

team that deliberately made short-
cuts to safety. A majority of teams I
have encountered have made a signif-
icant investment of time, money, and
personal commitment. What tran-
spires too often is the diffusion of the

20 Safety Decisions | Winter/Spring 2016





This graphic of the Bradley Curve displays the shifts in mind set and action that occur over time to achieve a mature safety culture.

Implementation Cost (Zero

THE ‘TONE AT THE TOP’ CANNOT BE To successfully build a safety culture,
spend little on external resources, and
GUARANTEED TO BE TRANSLATED TO spend a lot internally.
The external investment that com-
A ‘BELIEF AT THE BOTTOM.’ ” panies should consider is one that
yields an objective that:
a) Identifies existing roadblocks,
message, either verbalized or acted out, months a year and have only lim- shunts, or short circuits that diffuse
from senior management regarding ited contact with loved ones. safety culture messages, and
safety. When the message is diffused, • Employees work and live in tight, b) Identifies the proper solution to
the “Tone at the Top” cannot be guar- confined spaces. improve the culture.
anteed to be translated to a “Belief • The facility is operated under ex-
at the Bottom” because the culture is treme pressure and in cold and The internal investment is demon-
lacking—that is, common beliefs and corrosive environments. strated by the willingness of the organi-
experiences do not exist. • Any accident would almost cer- zation to undertake the journey toward
However, there are numerous ex- tainly result in death to all the an interdependent safety culture. There
amples of a culture driving phenom- employees and catastrophic devas- is no third party that can lead the orga-
enal safety outcomes. Two surprising tation to the surrounding environ- nization through the transformation,
examples are the U.S. Navy Nuclear ment and communities. and there is no substituting capital for
Program and the U.S. Coast Guard. labor on this path forward.
The U.S. Navy Nuclear Program has The U.S. Coast Guard’s safety This approach is analogous to uti-
completed 60 years without an acci- culture may seem less surprising lizing a personal trainer. The trainer
dent. That’s quite a feat when you con- than the U.S. Navy Nuclear Program can advise you on what and how to
sider the operating environment: because, like most first respond- achieve fitness—but cannot do the
• The majority of employees have ers, they train for every scenario. work for you.
only a high school education. Regardless, every emergency call
• Employees are paid approximately the U.S. Coast Guard undertakes Jim Holland is the director of consulting at
minimum wage. requires adapting on the spot to be Triumvirate Environmental, a full service
• Those in the program are required successful without losing sight of environmental, health, and safety firm.
to work away from home for 6 safety objectives. Reprint: SD_0116-4 Safety Decisions | Winter/Spring 2016 21


Incentivizing Safety: t 9:47 pm on April 20,
2010, an explosion

How Companies Are rocked the oil well drill-

ing platform Deepwater

Linking CEO Bonuses

Horizon just 41 miles
off the coast of Louisi-

to EHS Goals
ana in the Gulf of Mex-
ico. The explosion left 11 men dead,
17 workers injured, the rig destroyed
and sunk—and 3.19 million barrels
There has been a lot of controversy surrounding safety of oil spilled into the Gulf. The owner
incentives, and some programs are now targeting of the well, BP p.l.c., set aside almost

$54 billion to cover costs from the
executive compensation. But, is it a good idea? spill. The company’s top executive was
given no bonus that year. Since the ex-
By Jennifer Busick plosion, more than 90% of companies

22 Safety Decisions | Winter/Spring 2016

in the energy and utilities sector have
linked executive compensation to en-
vironment, health, and safety (EHS)
performance metrics.
Other industries, perhaps lacking
the motivation of a Deepwater Hori-
zon-scale disaster, have shown less ENVIRONMENTAL CLEANUP COSTS,
alacrity in linking pay to safety and en-
vironmental performance. But, there’s AND WORKER SAFETY ON THEIR
definitely an increasing trend. Here’s
how companies are starting to link ex- REPUTATIONS, PROFITABILITY,
ecutive compensation to EHS goals.
Measuring EHS
the Bonuses
A study published in 2014 by GMI Rat-
ings looked at what it called “sustainabil- COMPENSATION STRUCTURE.”
ity metrics”—mostly measures of EHS
performance, although some had to do
with customer satisfaction, reputation,
and other factors affecting a company’s while EHS metrics are increasingly focus on avoidance of errors rath-
long-term survival—to determine ex- “factored in” to executive compensa- er than proactive enhancements of
actly what metrics companies listed in tion, there doesn’t seem to be a lot of operational performance.
the S&P 500 Index are connecting to consensus on which specific metrics A company’s safety and environ-
executive pay, and how they’re doing it. are the most motivating. mental compliance and performance
Companies tend to link CEO com- Some metrics that companies re- are critical to its long-term surviv-
pensation to corporate objectives in ported using included: al. One single catastrophic incident,
the form of bonuses and incentives; • Worker safety. Worker safety was such as the release of methyliso-
a certain percentage of the executive’s the most commonly cited factor cyanate gas from a Union Carbide
bonus will be linked to whether the connected to executive compen- plant in Bhopal, India in 1984 can
company achieves certain goals. Tra- sation. The total recordable inci- take down even a global corpora-
ditionally, these bonuses have been dent rate was the most frequently tion. And, the same can happen to
linked to factors like profitability and named metric. Occupational Safety smaller companies and can result
revenue growth. But as companies see and Health Administration report- from smaller-scale disasters regularly
the effect of product liability costs, able incidents and other measures enough to make wise employers cau-
environmental cleanup costs, and of workplace safety incidents were tious. But how to impress upon CEOs
worker safety on their reputations, also used. that these issues are as critical as pro-
profitability, and ultimate corporate • Environmental spills and acci- duction and profit?
survival, more companies are includ- dents. The thing being measured
ing an EHS component in their exec- depended on the industry. Some Playing the Percentages
utive compensation structure. companies measure volumes of oil One question that GMI Ratings looked
or chemicals released to the envi- at in its report Sustainability Metrics in
Factors, Metrics, and Targets ronment; others, the number of Executive Pay was “How much of an
As of 2013, just over half of S&P 500 category 3 or category 4 environ- executive’s compensation is linked to
companies included at least one “sus- mental incidents or the number of sustainability performance?” Most
tainability” factor in compensation regulatory violations. commonly, companies set aside a
decisions—but the specificity of the • Routine operational impacts. Not small percentage of executive bonus-
factors used varied widely. Only 16% many companies reported using es (often just 5 percent to 10 percent)
of the companies reported specific greenhouse gas emissions, water that is tied to a sustainability factor
performance metrics that were used usage, or other routine operational like worker safety or environmen-
in calculating executive bonuses, and impacts on the environment in their tal performance. Where more than
only one in ten reported specific sus- compensation calculations. For the one sustainability factor is included
tainability performance targets. So, most part, companies seemed to in the reckoning—for example, in Safety Decisions | Winter/Spring 2016 23


companies that use a “scorecard” of

multiple factors—the percentage may
go as high as one-quarter or one-third
of the overall annual bonus.
Another way of accounting for sus-
tainability metrics is to calculate the
bonus based on the business’s overall
financial performance and then to use
sustainability metrics as a “modifier”
that can result in an adjustment, either
up or down.
In either case, the overall effect
of sustainability metrics on CEO
compensation is generally small
and limited to short-term incentives
(annual bonuses) rather than long-
term incentives such as stock options.
But, is it enough to make a differ-

Bad Executive! No EHS

Bonus for You!
Unfortunately, the answer may be “No.”
An analysis performed by Bloomberg
and published in October 2015 not-
ed that, on average, only 12 percent of
executive compensation at mining and
energy companies is tied to EHS met-
rics. Regrettably, this didn’t have much
of an impact on Massey Energy CEO
Donald Blankenship’s compensation in
2010, when an explosion at the Upper
Big Branch Mine in West Virginia killed
29 miners. Blankenship, who was tried
on criminal charges relating to the acci-
dent, lost $150,000 in 2010 for “failing to incident rate in 2014 that was well how these incentives could be retooled
meet safety goals,” but he still received a below the industry average, while an- to have greater impact:
$669,000 bonus; only 10.5 percent of his other company, Oneok, Inc., had a re- • Increase the percentage of execu-
bonus was tied to safety performance. cordable incident rate nearly double the tive compensation that is linked to
For most of the other S&P 500 energy median despite linking 10% of executive EHS metrics. Unfortunately, there’s
and mining companies that tied execu- pay to its reportable incident rate. no firm data right now on what
tive pay to safety in 2010, the percentage percentage might be “enough.”
was even lower. Greater Percentage, • Link EHS metrics with long-term
Clearly, 10.5 percent wasn’t enough Greater Incentive? compensation, not just short-term
to effectively focus Blankenship’s at- Although the two 2010 disasters— compensation.
tention on worker safety. But was Massey Energy and the Deepwater
Blankenship an outlier? Horizon oil spill—resulted in ener- With more companies using EHS
Signs say no. According to gy companies increasing the direct metrics to encourage executives to be
Bloomberg, there’s no identifiable link between executive pay and EHS proactive in risk management, these

correlation between linking executive metrics, it doesn’t appear that those answers should eventually come.
pay to EHS factors and worker safety. links have yet reached a level that has
Bloomberg noted that Chevron, which a measurable effect on worker safety Jennifer Busick is a contributing editor of
does not tie executive pay to measur- or environmental performance. Two Safety Decisions.
able safety metrics, had a recordable suggestions have been offered as to Reprint: SD_0116-5

24 Safety Decisions | Winter/Spring 2016

Beyond Compliance

Locking Out Decision Fatigue

By Ray Prest

f you wanted to summarize the an otherwise foolproof process—peo- on ensuring that workers have the
safety profession for a layperson, ple need to follow it for it to work. physical ability to lock out machin-
you would do well to start with As every safety professional quick- ery. But when it comes to dealing with
lockout/tagout (LOTO) as a great ly discovers, people have a frustrating decision-making issues, safety folks
example of the contemporary knack for not always following rules, tend to rely heavily on discipline. Un-
approach to workplace safety. It and it doesn’t matter how good a safe- fortunately, punishment is a relatively
combines an engineering solu- ty management system is if people ineffective tool because it doesn’t ac-
tion and a behavioral process in order don’t adhere to it. In many ways, it’s tually lead to more compliant behav-
to prevent workers from coming into safety’s biggest challenge: How else do ior. After all, if the possibility of dying
contact with hazardous energy. And, you get workers to follow rules when isn’t enough of a deterrent, it’s un-
if LOTO best practices are followed, they already know straying from safe- likely that receiving a scolding from
they can protect employees with an ty procedures puts them at a very real management will be effective. So rath-
impressive degree of reliability. But and very significant risk? er than concentrating our efforts on

like so many other aspects of work- A great deal of technological de- disciplining a failure to follow safety
place safety, there’s only one chink in velopment and training effort is spent rules, it’s more productive to focus on Safety Decisions | Winter/Spring 2016 25


what actually hinders employees from they found that the ability to think Decision fatigue explains why it’s
making safe decisions like following through a problem can be severely harder to stick to a diet after a long
LOTO procedures. compromised by both an individual’s day—our mental reserves have been
A burgeoning collection of research state of mind and the number of deci- depleted, and we have less energy to
suggests that decisions are affected sions he or she has had to make earlier stave off cravings. It’s the same with
by a number of factors and that our in the day. choosing whether to exercise. It gives
ability to make decisions is effectively If you’re struggling with LOTO at credence to something I hear fre-
limited. Two of the biggest names in your organization, you should reach quently from safety professionals:
decision research are Roy Baumeis- for your highlighter, because this is Workers are more lax with following
ter and John Tierney, who note in a crucial and woefully overlooked the rules towards the end of the work-
their book Willpower that a person’s contributor to workplace deaths: De- day, the end of a project, or the end
ability to exercise willpower declines cision fatigue plays an enormous role of the week. And, it could also point
with every decision he or she makes. in a worker’s ability to carry out the to why obvious procedures like LOTO
In experiment after experiment, proper LOTO process. can be overlooked.


26 Safety Decisions | Winter/Spring 2016

When workers are suffering from
decision fatigue, they may be more
likely to make an error in judgment, “IF YOU DON’T THINK YOUR EMPLOYEES
such as thinking they can get away
with not locking machinery out “just HAVE TO MAKE MANY (OR ANY) DECISIONS
this once” or taking a shortcut that
they perceive is a lot less risky than AT WORK, CONSIDER THAT EVEN THE MOST
it actually is. Ask yourself when most
LOTO violations happen. I’m willing
to bet that the vast majority occur OF DECISIONS TO BE MADE.”
at the latter half of a shift after em-
ployees have had to make a number
of decisions that have depleted their like LOTO. For example, when work- In the end, there’s no obvious sin-
mental reserves. Or perhaps they’ve ers are asked to work faster to meet gle solution. One thing that’s clear,
had an ongoing struggle with a piece a ramped-up production schedule, though, is that one of the biggest
of equipment—they locked it out they’re also forced to make a number factors driving an increased risk
the first few times but at some point of mental calculations on the fly in to workers is compromised deci-
fatigue and complacency started to the quest to find increased efficiency. sion-making abilities. If your LOTO
set in. The end result is that rushing workers training doesn’t deliver to all staff
If you don’t think your employees spend brainpower at a much faster rate members at least some communi-
have to make many (or any) decisions as they hustle to find ways to execute cation and awareness that addresses
at work, consider that even the most their normal tasks more quickly. Each how decisions and team influence
basic jobs require a constant stream of additional decision may seem small— can affect compliance and increase
decisions to be made. Which tool to many people wouldn’t even recognize the risk of a serious injury, you’re re-
use, which route to walk across a con- these as discrete decisions—but col- ally missing a critical step.
struction site, or the best way to exe- lectively they can deteriorate a work- It’s time to rethink how we view
cute a task all seem like basic choic- er’s ability to make cogent choices that LOTO and see it as a process that
es, but they tax our decision-making affect his or her safety. starts with a decision. Viewed in that
muscles nonetheless. Additionally, The best way to prevent the poor light, it’s a process that’s a lot more
our willpower—or ability to make decision to circumvent a safety proce- complicated than the act of attaching
strong decisions—is strained in the dure is to cut the decision out of the a lock to a piece of machinery. And,
same way regardless of a decision’s process. That means coaching work- LOTO issues become a lot easier to
magnitude. This means that a series ers on essential procedures like LOTO deal with once you accept that prob-
of small decisions can be just as tax- until they become habits. While habits lems with the process are often a result
ing as a set of larger choices. It also can still fail, especially when workers of decisions—and that there are ways
doesn’t matter whether it’s job-related are in the sway of human factors that we can support employees’ critical
or personal. So when employees are affect their performance, they are an faculties and cut down on decision
forced to make more decisions than effective way to standardize behavior. fatigue.
normal off the job, such as choosing By teaching a habit rather than forc-
details like paint color and carpet type ing workers to choose to follow a rule,
in a newly built home, or continually employers help workers save their de-
deciding to resist the urge to overeat cision-making energy for when they
because they’re on a diet, they may be need it more.
less capable of choosing to wear per- But, habits can be notoriously diffi-
sonal protective equipment or follow- cult to instill in a large workforce—the
ing LOTO procedures at work. next-best option is to cut down on the
It’s impossible to eliminate every stressors that contribute to making the Ray Prest is marketing manager at
decision your workers make over the decision. Even simple awareness of the SafeStart, a family-owned company that
course of a day, but there are a num- states of mind that affect the decisions has provided safety training solutions to
ber of ways that management can we make can help workers recognize industry, education, and the military for
unwittingly increase the number of when they may be compromised by over 40 years. You can learn more and read
decisions its employees have to make, human factors, and they can take an Ray’s recent articles, blog posts, and safety
ratcheting up the risk of mental fa- extra few seconds to ensure they’re guides at
tigue and compromising processes properly thinking through the process. Reprint: SD_0116-6 Safety Decisions | Winter/Spring 2016 27

Practical Tips

If the Shoe Fits—
he Chipotle franchise is well known for its
“healthier” version of fast food. Indeed, its

Don’t Charge for It!

workers will quickly whip up tasty Tex-Mex
much faster than traditional sit-down restau-
rants. Not surprisingly, the company encourages
its workers to wear safety shoes, as the combi-
Ensuring employees have the tools to nation of food service and speedy employees is
perform their jobs safely should be a win-win notorious for inviting an on-the-job injury.

As a result, Chipotle received discounts on its work-

for both worker and employer. But, you need ers’ compensation premium for allowing its California
to consider all aspects of your safety workers to voluntarily purchase nonslip shoes, either
directly or through a payroll deduction, through a ser-
program—or you might get sued. vice called Shoes for Crews. This is commonly consid-
ered a safety program or good safety practice by workers’
By Jasmin Rojas, JD compensation carriers.

28 Safety Decisions | Winter/Spring 2016

As an added bonus, Shoes for
Crews gave the company a warranty These Shoes Can’t Walk Off
on its product. Indeed, making good
on its promise, Shoes for Crews paid
with Our Paychecks!
Chipotle $25,000 to offset the cost of Lewings v. Chipotle Mexican Grill, Inc. wasn’t the only lawsuit against Chipotle’s Shoes for
medical bills arising from injuries sus- Crews program that gained some traction. In Munoz v. Chipotle Mexican Grill, Inc., employ-
tained by Chipotle employees. ees sought to gain class certification for 26,000 nonexempt current and former employees
of Chipotle in California to pursue claims of wage and hour violations.
Sounds Like a Win-Win for
Chipotle, Right? The plaintiffs alleged that Chipotle’s policies required employees to purchase the slip-re-
The company was able to simulta- sistant shoes as a condition of employment, and then the restaurant deducted the costs
neously encourage employee safety from employees’ wages without obtaining their written authorization.
(Shoes for Crews reports about a 59%
decrease in injuries) and receive some While the plaintiffs failed to gain class certification both from a trial court and also on
additional compensation. On its face, appeal, it serves as a warning for those designing safety programs that include various
it appeared like a sound business deci- forms of personal protective equipment. Analyze who ends up paying for it, and make sure
sion. Nevertheless, a California appel- you’re compliant with all applicable laws, even those that aren’t specific to safety!
late court didn’t agree.
In Lewings v. Chipotle Mexican
Grill, Inc., the court found that the proceed in her class-action suit on the
safety program violated the law be- “GIVEN THE COMPETI- theory that, by financially benefiting
cause, through it, Chipotle received
a contribution from employees that TION FOR SAFETY from the program, Chipotle conduct-
ed an unfair business practice.
covered a portion of its workers’ com-
pensation costs.
PRODUCTS OUT THERE, Don’t Make This Misstep!
Like most states, California has IT IS EASY FOR EMPLOY- Although this is a California case, the
a law that prohibits employers from lessons learned apply to most employ-
making their employees contribute ERS TO BE LURED INTO ers that are covered by workers’ com-
anything towards workers’ compensa-
tion costs. As a matter of public policy, RECEIVING ADDITIONAL pensation. While Chipotle did take af-
firmative steps to encourage employee
it makes sense to ensure that the em-
ployer bears the bulk of this cost, as
INCENTIVES, ESPECIALLY safety, it also inadvertently violated the
law by receiving additional benefits
workers’ compensation programs are IN HIGH-RISK INDUSTRIES from its employee-sponsored program.
meant to indemnify employers. Given the competition for safe-
In Chipotle’s case, the court con- WHERE WORKERS’ ty products out there, it is easy for
cluded that the program was really an
employee-sponsored reimbursement of COMPENSATION employers to be lured into receiving
additional incentives, especially in
the company’s workers’ compensation
costs. The court relied on the fact that
COSTS ARE HIGH.” high-risk industries where workers’
compensation costs are high.
even though Chipotle did not cover the Employers should take caution
cost of the safety shoes, it did receive the The court reasoned that crimi- when establishing any safety pro-
benefit of Shoes for Crews’ warranty. nal violations required an element of gram where employees are expected
By making the employees pay for knowledge that was met when em- to make a contribution. It may make
the shoes, the warranty was, accord- ployers knowingly received warran- sense to review your safety program
ing to the court, a “windfall.” In other ties financed by their employees. The with a labor and employment attor-
words, had it not been for the employ- court also found irrelevant the fact ney. In this case, had Chipotle reim-
ees’ purchases, Chipotle would not that the program was voluntary. The bursed its employees for the shoes or
have collected any money. California statute (as do most other somehow returned the $25,000 to its
The court was not convinced with statutes) prohibits both voluntary and employees, it probably would have
Chipotle’s argument that this interpre- involuntary contributions to workers’ been in the clear.
tation was a trap for innocent employ- compensation costs.
ers because they could be criminally Accordingly, although the Califor- Jasmin Rojas, JD, is a contributing editor of
liable for receiving employee-funded nia law did not provide a private cause Safety Decisions.
warranties they knew nothing about. of action, the plaintiff was able to Reprint: SD_0116-7 Safety Decisions | Winter/Spring 2016 29


Preventing Employee
s environment, health,
and safety (EHS) pro-

Chemical Exposure
fessionals, we all want
to make sure employ-
ees are at home with

at the Source their families at the end

of the day and not at
the hospital—or worse—because of
Keeping employees safe from hazardous materials requires an inadvertent exposure to chemicals
on the job.
constant vigilance. We have tips for companies and their Many jobs might expose employees
workers for preventing exposure. to hazardous materials, causing vari-
ous health effects. Examples of work-
By Clare Condon place exposure can be found in facto-
ries, chemical plants, manufacturing
facilities, and automotive shops.
For workplaces that handle chem-
icals, there is a hierarchy of controls
that ranges from the most effective to
the least effective. These are, in order
of effectiveness:
1. Control at the source;
2. Control along the path; and
3. Control at the worker level.

Three Tips at the Source

Preventing chemical exposure at the
source is the most effective way to en-
sure that your workers are not exposed
to the dangerous chemicals they are
required to handle in the workplace.
The three most effective ways to
control and prevent chemical expo-
sure at the source are substitution,
mechanization or engineering con-
trols, and administrative and work
practices controls.

Tip 1: Substitute a safer

chemical or process.
Many harmful chemicals and process-
es are used as a matter of tradition
even though less harmful alternatives
exist. Substitution is complex and re-
quires research and experimentation.
If successful, however, it is the most

powerful and desirable control meth-

od. The Environmental Protection
Agency’s (EPA) Safer Choice initia-
tive provides a list of safer alterna-
tives for many chemicals used in the
workplace. The Occupational Safety
and Health Administration (OSHA)
provides a toolkit for employers that

30 Safety Decisions | Winter/Spring 2016

want to make the transition to using
less harmful chemicals.
If there are no reliable substitutes “PREVENTING CHEMICAL EXPOSURE AT
for hazardous chemicals, you can
change the way the process is carried THE SOURCE IS THE MOST EFFECTIVE WAY TO
out so it makes handling the chemical
safer. Sometimes a different process
with less potential for exposure can be EXPOSED TO THE DANGEROUS CHEMICALS
substituted. Examples include:
• Flow coating or dipping instead of THEY ARE REQUIRED TO HANDLE
• Water-based caustic or abrasive- or IN THE WORKPLACE.”
water-blasting for paint-stripping
with solvent-based strippers
• Water-blasting instead of abra- of airflow is into the restricted area Tip 3: Administrative and work
sive-blasting from the cleaner areas. Therefore, practices controls.
• Controlling dust with a wet the isolated area must be under These types of controls to reduce ex-
method negative pressure compared to sur- posure to chemical hazards involve es-
• Steam-cleaning instead of using rounding areas. This can be done by tablishing efficient processes and pro-
solvents exhausting extra air from the isolat- cedures. This can be accomplished by:
ed area to the outdoors using fans • Rotating job assignments.
OSHA’s Process Safety Manage- in either general or local exhaust • Restricting access only to a limited
ment (PSM) of Highly Hazardous ventilation. Exhaust air must be de- number of essential employees.
Chemicals Standard requires covered contaminated before being released • Isolating by time. The amount of
employers to identify processes that to the outdoors. time that employees spend in iso-
pose the greatest risks, and begin If using a separate room is not fea- lated areas should be minimized.
evaluating those first. This involves sible, certain operations can be com- In addition, a hazardous opera-
performing a process hazard analy- pletely enclosed in other ways to pro- tion can sometimes be performed
sis (PHA)—a careful review of what tect workers. Examples of enclosing a during the second or third shifts to
could go wrong and what safeguards process include: reduce the number of workers po-
must be implemented to prevent re- • Splash guards. tentially exposed.
leases of hazardous chemicals. • Hoods over machine operations
using cutting fluids. A Worker’s Trinity to
Tip 2: Engineering controls. • Use of pumps to handle solvents. Prevent Chemical Exposure
This type of control implements phys- • Fume hoods. All workers who are exposed to haz-
ical changes to the workplace, which • Use of wet methods to reduce the ardous chemicals on the job must be
eliminate or reduce the hazard on the generation of dusts or other parti- trained to protect themselves (and
job or task. For example, handling of cles. their families) from exposure to these
hazardous chemicals can be done by • Use of glove boxes, which are small chemicals. If your job involves contact
using mechanical arms or robots to units that have two or more ports with hazardous chemicals and mate-
keep workers away from the source in which arm-length rubber gloves rials, there are three basic things you
of exposure. An example would be are mounted. The worker places can do to reduce your exposure:
using an automatic parts dipper in- his or her hands into these gloves
stead of manually dipping metal parts to perform tasks inside the box. 1. Read and follow instructions pro-
in a degreaser. • Enclosing individual workers with- vided by your employer.
Engineering controls can also in- in a special isolated booth or room 2. If you come into contact with dust,
volve isolating or enclosing the pro- from which they can observe and fibers, chemical fumes, radiation,
cess. Isolating the source of chemi- control an operation using chemi- or biological agents on your job,
cal exposures can be accomplished cals. Worker enclosures must have ask for and wear all required per-
through actual physical enclosure, heat, air-conditioning, and clean sonal protective equipment (PPE)
preferably with separate rooms or air from an uncontaminated loca- such as gloves, masks, coveralls,
buildings, and closed doors. When tion. These enclosures should be and respirators.
isolating a process in a separate under positive pressure to keep out 3. Shower or change clothes before
room, make sure that the direction contamination. leaving work. Otherwise, you can Safety Decisions | Winter/Spring 2016 31


“ALL WORKERS WHO ARE EXPOSED TO refer to the SDS, or take a sample
for analysis. There have been in-
HAZARDOUS CHEMICALS ON THE JOB MUST BE stances where workers were hurt
by tasting or smelling a material to
7. Use materials only for their intend-
8. Don’t eat or drink while handling
carry contaminants home from sure it is in prime operating condi- hazardous materials.
work on your clothing. tion. 9. Be familiar with emergency pro-
3. Inspect containers to make sure cedures and equipment, including
A Dozen Additional they are properly labeled, that the evacuation procedures, emergency
Measures to Remember material in the container is appro- reporting procedures, and proce-
Although different types of chemi- priate for that container, and that dures for fires or spills.
cals require different handling, there the container is not damaged. If 10. Store all materials properly in
are some basic safety rules that ap- there are any indications other- ventilated, dry, cool areas.
ply to the handling of all hazardous wise, don’t use the material. 11. Separate incompatible materials.
chemicals. 4. Report damaged containers or il- 12.Clean work surfaces at least once
1. Be cautious and plan ahead. Know legible labels immediately. during a work shift to minimize

what could go wrong with the par- 5. Read the label and safety data sheet contamination risks.
ticular chemicals you are handling (SDS) before using any material so
and what you would do in case of that you understand the hazards Clare Condon is a contributing editor
an accident. and precautions to take. of Safety Decisions.
2. Always use the required PPE, and 6. If it is necessary to identify a ma-
inspect it before each use to make terial, make sure to read the label, Reprint: SD_0116-8

32 Safety Decisions | Winter/Spring 2016

Day to Day

Understanding OSHA’s Procedures When

Reporting Severe Injuries and RRIs
Since the Occupational Safety and Health Administration’s (OSHA) new reporting

requirements (29 CFR 1904.39) went into effect in January 2015, the Agency has
been inundated with workplace incident reports. By Ana Ellington Safety Decisions | Winter/Spring 2016 33


nticipating a large in- Response Investigation (RRI). If an • Are employees still being exposed
crease in reports, OSHA RRI is deemed best, OSHA will send to the factors underlying the haz-
issued an internal en- the employer a letter requesting that ards that resulted in the injury
forcement memoran- the employer conduct an investiga- or illness?
dum on December 24, tion and report back to OSHA the • Was the incident the result of a
2014, to help the field root cause of the incident and the safety program failure, such as
offices manage these re- corrective actions that will be tak- permit-required confined spaces,
ports. It provides new procedures for en to prevent future incidents and lockout/tagout, or process safety
when to launch an inspection. protect employees. management?
The likelihood of an employer Under the memorandum, OSHA • Was the employee exposed to a
having to report a covered severe in- will triage each report into three cat- serious hazard (e.g., explosive
jury to OSHA is much higher under egories: materials, combustible dust, falls,
the new rule. Specifically, the revised 1. Category 1—Must be inspected. heat)?
standard requires employers to report • All fatalities and reports of two or • Were temporary workers or other
all work-related inpatient hospital- more inpatient hospitalizations; vulnerable populations injured or
izations, amputations, or losses of an • Any injury involving a worker un- made ill?
eye within 24 hours of the event. The der the age of 18; • Has another government agency
requirement to report any work-re- • Employers with a known history of (federal, state, or local) made a re-
lated fatality within 8 hours has not multiple injuries (same or similar ferral?
changed. The broad definitions for events in the previous 12 months); • Does the employer have a prior
inpatient hospitalization and ampu- • Employers considered repeat of- OSHA inspection history?
tation, which now includes fingertip fenders (history of egregious, will- • Is there a whistleblower complaint/
amputations with or without bone ful, failure-to-abate, or repeated inspection pending?
loss, probably contribute to the in- citations); • Is the employer a Cooperative Pro-
crease in workplace incidents reports. • Employers in the Severe Violator gram Participant (e.g., SHARP)?
According to OSHA, the Agency Enforcement Program; • Did the incident involve health is-
is averaging about 250 new reports • Injuries from hazards covered un- sues, such as chemical exposures
each week—taking up a great deal of der National Emphasis Programs or heat stress?
resources. or Local Emphasis Programs; and 3. Category 3—Reports will involve
When reporting an incident, the • Any report of imminent danger. situations where the majority of
following information is required: the responses to the Category 2
• Establishment name; If the reported incident does not questions were “No.” The field of-
• Location of the work-related inci- meet the criteria in Category 1, the fice will then likely initiate an RRI
dent; area director will have the discretion for Category 3 reports.
• Time of the work-related incident; to determine whether to conduct an
• Type of reportable event (e.g., fa- on-site inspection based on “yes” re- The procedures also create a new
tality, inpatient hospitalization, sponses to multiple questions. database that will capture all of the
amputation, or loss of an eye); 2. Category 2—The following list of information received from employers.
• Number and names of employees questions is not exhaustive, and OSHA has not said how these data
who suffered a fatality, inpatient other factors to particular inci- will be used or whether they will be
hospitalization, amputation, or loss dents may be considered. made available to the public.
of an eye;
• Contact person and his or her
phone number; and
• Brief description of the work-relat- “IF YOU RECEIVE A LETTER FROM YOUR
ed incident.
The memorandum provides valu-
able insight into additional questions
employers may be asked and outlines
the triage process field offices will
use to sort through the data and to
determine whether to open an on-
site inspection or to initiate a Rapid INCIDENT WILL NOT HAPPEN AGAIN.”
34 Safety Decisions | Winter/Spring 2016
being,” such as employee fatigue. Un-
safe and inappropriate employee and/
or manager behavior includes failing
to comply with the rules, taking short-
cuts, horseplay, failing to train, or fail-
ing to report hazards.
Root causes can include inade-
quate training, an outdated hazard
communication program, no inspec-
tion policy, or less-than-adequate
tools or equipment.
How do you find the root cause or
causes of an accident? By repeatedly
asking the question “Why?” (four or
five whys is a good rule of thumb),
you can peel away the layers of symp-
toms that can lead to the root cause of
an incident.
For example:
A worker is struck in the eye by a
flying object.
• Why? The machine had no guards
(surface cause).
• Why? The guards were removed
(surface cause).
• Why? To work faster (surface
• Why? Less-than-adequate train-
ing, procedures, and/or policies
(root causes).
RRI and Root Cause
Analysis “THE LIKELIHOOD You can use’s inci-
If you receive a letter from your lo-
cal OSHA office initiating an RRI, OF AN EMPLOYER dent analysis tool to help complete a
root cause analysis of an incident.
you must respond within 5 working
days to “confirm abatement and steps
that have been taken for abatement”
so that the incident will not happen
TO OSHA A COVERED When completing the RRI report for
OSHA, state the known facts, not
again—an extension can be requested SEVERE INJURY IS your opinion or speculation. Under-
for complicated events. stand that root causes identified in
OSHA’s written letter requires that MUCH HIGHER UNDER an employer’s report can amount to
you provide it with the results of an
investigation into the incident that THE NEW RULE.” an admission of a violation, such as
failure to conduct required training or
documents findings and corrective repair a faulty safety device. Be careful
actions taken. The goal of the investi- which always preexist surface causes. because your responses can be used
gation is to identify the immediate or Surface causes are hazardous con- against you by OSHA. As such, sim-
contributing causes (known as surface ditions and unsafe or inappropriate ply respond with conclusions to your
causes) and the underlying causes (or behaviors that are the direct cause of investigation and corrective actions

root causes) of the incident. Accord- the incident. that have been taken to ensure that no
ing to OSHA, you can usually trace Hazardous conditions include de- future incidents will occur.
surface causes to inadequate or weak fective or unsafe equipment; defects
safety systems, such as policies, pro- in processes or procedures such as Ana Ellington is a contributing editor of
grams, plans, processes, procedures, unguarded machines, a ladder in dis- Safety Decisions.
or practices. These are the root causes, repair, or slippery roads; or “states of Reprint: SD_0116-9 Safety Decisions | Winter/Spring 2016 35


‘But It Came That Way’—

The Roles, Responsibilities, and
Accountability of Machine Guarding
Each year, more than 200,000 workers suffer cuts, lacerations, and amputations from
operating machinery in the United States. Incident investigations often discover that the
machines lack adequate safety mechanisms, including guards and safety switches.
By Adam Haroz, EIT


36 Safety Decisions | Winter/Spring 2016

he Occupational Safety
and Health Administration
(OSHA) is getting more
stringent with regulations
and enforcement regard-
ing machine guarding
violations. It is targeting
industries with higher risks of poten-
Left: Potential pinch point hazards from exposed chains on a lumber transfer deck.
tial injuries from machinery. Despite Right: A guarding solution that is hinged for maintenance access and that covers
this move by OSHA towards greater the exposed hazard points.
expectations from industry, there is
still a large cultural gap between em-
ployers and original equipment man-
ufacturers (OEMs) regarding who is
ultimately responsible for ensuring
that the machinery is guarded in com-
pliance with OSHA regulations. In
this article, we’ll explore this gap and
shine light on internal inspections by
OEMs and end users along with dif-
ferent ways to identify, and therefore
abate, guarding problems. Left: A potential pinch point hazard from an exposed conveyor belt. Right: A guard-
ing solution that is hinged for maintenance access and that covers the exposed
In my years of consulting our clients
hazard point.
in regards to OSHA and general safety
compliance matters, there has been one
notion that my clients keep telling me:
“I don’t understand why this machine
is unsafe.” Or, they do not fully under- cidental contact with hazardous areas of regulations state, “One or more
stand why they have received an OSHA a machine, and it can also prevent haz- methods of machine guarding shall
violation. Another phrase I com- ards like debris and noise from exiting be provided to protect the operator
monly hear is, “The equipment came the machine. A guard controls the in- and other employees in the machine
from the manufacturer that way.” This teraction between the operator and the area from hazards such as those creat-
confusion is common among employ- machine, and can be a significant factor ed by point of operation, ingoing nip
ers within general industry. Through in optimizing a machine’s performance. points, rotating parts, flying chips,
some research, it emerged that several Examples of guarding solutions that and sparks.”1 In fact, it is mentioned
equipment manufacturers and distrib- have been used in a variety of industries on the first page of OSHA’s Manual
utors were selling equipment that stat- can be seen above. on Safeguarding Equipment and Pro-
ed they “met OSHA requirements,” yet While there are countless examples of tecting Employees from Amputations
accidents were occurring, and OSHA facility personnel constructing mag- that employers are responsible for
violations were being distributed. nificent safeguards, machine guarding providing a safe and healthful work-
These occurrences prompted me to remains one of the most cited regula- place for their employees. Due to this
continue my research and investigate tions during OSHA inspections, and it initiative, any gap in machine guard-
this cultural gap between machine is one of the top causes of occupation- ing and overall safety on a piece of
manufacturers and the employers that al injuries in the United States. equipment falls on the shoulders of
purchase their machines, as well as the employer2.
the gaps in the OSHA enforcement of Machine Guarding Regula- OSHA relies on national consen-
these manufacturers. tions and Responsibilities sus standards for some of its regula-
Understanding machine safety stan- tions. In this case, OSHA falls back

What Is Machine dards can be a challenging step in onto the American National Stan-
Guarding? reducing risks in the workplace. Al- dard Institute’s (ANSI) standards on
Machine guarding is used as a precau- though the requirements for machine machine safety. ANSI standard ANSI
tionary safety feature on machinery and and employee safety may seem end- B11.19-2010, The Performance Crite-
other pieces of equipment. It is a shield less, there are ways to ensure proper ria for Safeguarding, provides valuable
or device protecting body parts from ac- safeguarding for employees. OSHA guidance on the design, construction, Safety Decisions | Winter/Spring 2016 37


installation, operation, and mainte- focused on the end users, since they equipment, who is responsible for the
nance of the guarding systems used are typically the ones that have em- guarding, and how a facility can com-
to protect employees from potential ployees at the point of operations ply with guarding requirements while
machine hazards. where hazards could exist. maintaining efficient productivity
With the understanding of what is There is some responsibility on and employee safety. There are four
expected of machine guarding equip- the side of the OEM, however. While main factors that contribute to this
ment and the regulations that are to the OEM is typically unsure of the fi- confusion.
serve as the guidelines for safeguard- nal location and process staging that
ing practices, probably the most con- the employer has designated for the 1. Multiple Functions
fusing aspect is that the same machine equipment, the OEM should con- Machine guarding often relies heav-
could pose different hazards and could sider any foreseeable use and mis- ily on these safeguards to perform
require different guarding depending use of the equipment, as well as the multiple functions. These safeguards
on its placement within a facility and potential point of operation hazards are expected to not only prevent the
depending on how and where in the for those who may come in contact accidental contact with hazards and
process the equipment is used. with the equipment. Also, the OEM’s moving equipment but they are also
As outlined in the ANSI standard, risk assessment should be provided expected to be easily removed and
it is the role of both the OEM and the with all new equipment the way that secured for maintenance, to protect
end user to conduct a risk assessment a safety data sheet (SDS) is provid- the equipment from falling objects
in order to determine the safeguard- ed with chemicals. This assessment or other moving equipment, and to
ing that is required for the equip- will allow the end user to examine not create any additional hazards. Of
ment. One thing to consider about the to what depth the potential risks and course, another significant goal is that
OEM’s risk assessment is that it is im- hazards were identified and mitigat- the safeguards don’t prevent an oper-
practical to expect a machine designer ed by the OEM, as well as what gaps ator from performing his or her job
to foresee all potential hazards associ- are present. efficiently and effectively.
ated with equipment setup, operation,
maintenance, and placement within a What Makes Machine 2. Failure to Assess Risk
facility. The end user should conduct Guarding So Difficult? As stated in ANSI B11.0-2010, Safety
a risk assessment separate from that Despite OEMs becoming increasing- of Machinery—General Requirements
of the OEM as a part of due diligence ly aware of the importance of ma- and Risk Assessment, Section 4.6:
for recognizing and reducing risk. The chine guarding—whether it be from
end user is the most knowledgeable a productivity, safety, compliance, or “The supplier shall provide safeguard-
party for interpreting how the equip- even an aesthetic standpoint—ma- ing as determined in the supplier risk
ment will be used, where it will be chine guarding continues to place on assessment and the appropriate ma-
stored, and where the operators will OSHA’s top 10 most frequently cited chine-specific standard. The user shall
be in contact with potential hazards standards3. This ranking demon- ensure that additional safeguarding is
based on the process the equipment is strates that there is still confusion on provided and installed as determined
involved in. what is required to properly safeguard in the user risk assessment.”
According to OSHA’s General Duty
Clause, the employer has an obliga-
tion to protect workers from serious
and recognized workplace hazards
even where there is no standard. Em-
ployers must take whatever abatement
actions are feasible to eliminate these
hazards. Based on this, it is not stan-
dard practice for OSHA to inspect a CONSTRUCTING MAGNIFICENT
machine manufactured by the OEM
prior to being set up in the end user’s SAFEGUARDS, MACHINE GUARDING
facility. Instead, an OSHA inspector
will inspect the equipment being used REMAINS ONE OF THE MOST CITED
for the manufacturing process, work
practices within the organization,
and the facility. Practically all OSHA
enforcement for machine safety is

38 Safety Decisions | Winter/Spring 2016

This graphic shows a standard bench grinder that has been listed to “meet OSHA requirements.” Items such as this,
although listed to meet OSHA requirements, are often received missing some essential guards that would constitute
an OSHA violation (e.g., missing tongue guards).

In many cases, employers can find sometimes be misled by OEMs or ma- but they were not mitigated, abated,
it difficult to assess risk as they take chine sales representatives. The phras- or somehow guarded due to difficul-
the OEMs’ word for it that the equip- es “OSHA compliant” and “meets all ty of guarding applications or because
ment is properly guarded, or the em- OSHA requirements” have been mis- it is simply too expensive, they could
ployer does not possess the expertise used by OEMs and machine sales rep- be considered willful violations by
to conduct a proper risk assessment resentatives in order to sell equipment OSHA and any associated fines could
to ensure safety and compliance. to employers who honestly may not increase exponentially.
Conducting a risk assessment of new know any better. OSHA does not cer-
equipment is not only required, it is tify equipment to be “compliant.” In Solutions
a great method of due diligence for fact, that idea helped start the path to- The solutions to the problems that I
determining the risks present for that ward the creation of this investigation have discussed in this article are not
piece of equipment as well as for that and the compilation of this article. simple. The knowledge, ability, and
section of the process. Guards are de- If an OEM claims that a piece of confidence to perform a risk assess-
signed and installed to protect against equipment is “OSHA compliant” ment on equipment is by no means
identified hazards. If hazards are not or that it “meets all OSHA require- easy. One has to keep in mind the
identified, then it is unlikely they will ments,” as seen in the example above, potential risks present on the piece
be protected against. you should first obtain any risk as- of equipment as well as understand
If an employer is unsure about sessments that have been conducted that employees do make mistakes,
the risk assessment process or the on that equipment and check for any and the potential for serious injury
risk assessment itself, there are a few Underwriters Laboratory (UL) or Na- is always present. For these reasons,
options. The employer can contact a tional Institute for Occupational Safe- it can be extremely beneficial to em-
third party or a consultant to come ty and Health (NIOSH) stamps on the ploy or cooperate with a third-party
on-site and conduct a risk assessment equipment. Those types of markings specialist.
in accordance with the standards, the will help indicate that the equipment Specialists include machine de-
employer can have the maintenance has at least undergone a safety in- signers, maintenance personnel,
staff or other employees conduct a spection by a reliable agency. Another consultants, and OSHA compli-

risk assessment, or the employer can thing to keep in mind is that regula- ance assistance specialists. While a
contact OSHA’s compliance assistance tions vary between different coun- third-party specialist will cost the
specialists. Whichever method is cho- tries, and any equipment that is con- facility a bit, machine guarding spe-
sen, it is a good practice to obtain structed outside of the United States cialists and safety consultants can
and review the original manufactur- should be purchased with caution, often find several potential viola-
er’s risk assessment and maintain it and a separate risk assessment should tions and potential hazards from
with the records for that equipment. be conducted. inadequate machine safeguarding
The OEM’s risk assessment should be techniques, standards, and practices
made available upon request. 4. Cost and Difficulty that many maintenance personnel
of Solutions may overlook. One thing that a con-
3. Misleading OEM Labels Any risk that is identified should be sultant is particularly good at is the
Along with the intricate principles mitigated to ensure a safe workplace. If ability to not simply focus on OSHA
of machine safety, employers can there are hazards present and identified, standards—they are able to use their Safety Decisions | Winter/Spring 2016 39


conducted on the equipment and

should review the potential hazards
with the OEM that built the equip-
ment. Since the OEM can only plan
“GUARDS ARE DESIGNED AND for so many potential hazards, the
responsibility for the final guarding
INSTALLED TO PROTECT AGAINST solutions falls on the employer. Once

IDENTIFIED HAZARDS. IF HAZARDS the employer has reviewed the OEM’s

risk assessment, it should conduct an
ARE NOT IDENTIFIED, THEN IT IS UNLIKELY alternative risk assessment with the
knowledge of the placement of the
THEY WILL BE PROTECTED AGAINST.” equipment and the location of the
operators. With these actions of due
diligence, further evolution of ma-
chine safety is within reach.
It is everyone’s responsibility to
knowledge of other applicable con- like a third-party specialist, or even change the culture of safety and to
sensus standards as well as their ex- a corporate representative, to fully look at it not just as a means to pre-
perience working with government comprehend. One thing that each vent costly accidents and citations but
agencies and other industries. Con- facility should not overlook in eval- also as an opportunity to employ the
sultants and other specialists hired by uating a piece of equipment’s guard- safest solution at every stage of the
a facility can explore the equipment’s ing requirements is the experience of design and implementation processes.
and guarding’s applicability for that employees and staff already employed While productivity and efficiency are
specific facility’s needs. by the facility. A facility’s employees important, the most vital part of any
The risk assessment itself, while have hands-on comprehension of the facility is the safety and well-being of
beneficial from a safety standpoint, equipment and the process, and they its employees.
is also a viable method for vetting the are often very aware of potential haz-
OEM that the equipment was pur- ards on the equipment that they see 1.
chased from. While it is pretty clear and use on a daily basis. Getting input oshaweb/owadisp.show_
that conducting risk assessments and from those who actually operate the document?p_table=STANDARD
obtaining any risk assessments per- equipment (and who are sometimes S&p_id=9836
formed on equipment by the manu- the ones constructing and maybe 2.
facturer will help identify potential even bypassing the safeguards) is a osha3170.pdf
risks involved in the operation of said vital tool when implementing guard- 3.
equipment, there is still the possibility ing solutions in a feasible way. This Standards.html
that the OEM was misleading in label- can also ensure that the guarding
ing a piece of equipment “OSHA com- solutions being implemented are safe, Adam Haroz, EIT, is the engineering manag-
pliant.” An internal risk assessment easy to operate and replace, and that er for the Occupational Safety Compliance
will not allow an OEM to mislead as much common sense went into the and Training Department for Conversion
anybody; the assessment will point design and placement of the safeguard Technology Inc. (CTI), an Environmental and
out if the equipment meets OSHA re- as possible. Safety consulting firm. He has performed
quirements and also reveal any gaps in extensive work related to industrial safety,
machine guarding. Any possible gaps Conclusion including mock OSHA inspections, machine
in safeguarding for the equipment For all of this to happen, there needs guarding risk analyses, and aiding in the
should be compared to the risk assess- to be a paradigm shift in the culture design and implementation of machine
ment conducted by the OEM, as there of safety all the way from concept to guards and OSHA-compliant employee
will always be items that the OEM construction. OEMs should consider training for a number of industries, includ-
cannot foresee prior to the installation all possible hazards present while the ing lumber and wood products, metal form-
of the equipment. equipment is operational and should ing, scrap recycling, rubber and plastics,
The costs, the difficulty of the safe- include any feasible guards on the and automotive and aviation parts. Haroz
guarding solutions themselves, the equipment as an original concept is a member of the American Society of
functionality of the safeguards in re- in the design. The employers that Safety Engineers (ASSE) and the National
lation to the equipment, and the oper- purchase the equipment should re- Safety Council (NSC).
ator are all very difficult for someone view any risk assessments that were Reprint: SD_0116-10

40 Safety Decisions | Winter/Spring 2016

Beyond Compliance
25 Locking Out Decision Fatigue
By Ray Prest
Reprint: SD_Quarter-6

Practical Tips
28 If the Shoe Fits—
Don’t Charge for It!
Ensuring employees have the tools to
perform their jobs safely should be a
win-win for both worker and employer. But,
you need to consider all aspects of your
safety program—or you might get sued.
By Jasmin Rojas, JD
Reprint: SD_Quarter-7

30 Preventing Employee Chemical

Exposure at the Source
Keeping employees safe from hazardous
materials requires constant vigilance. We
have tips for companies and their workers

Cover Story for preventing exposure.

By Clare Condon

10 Lockout/Tagout: Don’t Flip Out

Reprint: SD_Quarter-8

Day to Day
over LOTO Compliance 33 Understanding OSHA’s
Procedures When Reporting
Update your understanding of this life- and limb-saving standard. By Evelyn Sacks
Reprint: SD_0116-2 Severe Injuries and RRIs
Since the Occupational Safety and Health
Administration’s (OSHA) new reporting
requirements (29 CFR 1904.39) went into
DEPARTMENTS 20 Why Safety Culture Is More effect in January 2015, the Agency has
Important Than You Think been inundated with workplace
incident reports.
Keeping Up Safety should be universal, but many
organizations find themselves falling short. By Ana Ellington
6 EOSHA Penalties Up … Counting The key difference? A clear and consistent Reprint: SD_Quarter-9
Inspections … Aging Workforce … Sitting safety culture.
Isn’t So Bad … Opioid Painkillers … Tracking By Jim Holland 36 ‘But It Came That Way’—
Toxic Exposure … Quick Reminder … Reprint: SD_0116-4 The Roles, Responsibilities, and
Cal/OSHA and Healthcare Violence …
AIHA Mold Resource … Ergo Shovels … Accountability of Machine Guarding
Reprint: SD_0116-1
22 Incentivizing Safety: How Each year, more than 200,000 workers
Companies Are Linking CEO suffer cuts, lacerations, and amputations

Strategy Bonuses to EHS Goals

There has been a lot of controversy
from operating machinery in the United
States. Incident investigations often
16 Power Up Your Efforts to Protect surrounding safety incentives, and some
discover that the machines lack adequate
safety mechanisms, including guards and
Workers from Hazardous Energy programs are now targeting executive
safety switches.
Here are a few ideas that may change the compensation. But, is it a good idea?
By Adam Haroz, EIT
way you think—and what you do—about By Jennifer Busick
Reprint: SD_Quarter-10
lockout/tagout. Reprint: SD_Quarter-5
By Evelyn Sacks
Reprint: SD_0116-3

TO ORDER REPRINTS: Editorial reprints of articles are available in quantity for individual or corporate use. Contact Amanda Hurlburt at 800-727-5257 x2184 or email your request to Safety Decisions | Winter/Spring 2016 41

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