By Lee Senter
It is unfortunate that many professionals in our industry have been taught that a healthy and safe workplace is solely about compliance with regulations.
When a cleaning or restoration company abides by prescribed regulations, the action is seen as something that needs to be done in order to follow the law. However, simply remaining compliant does not teach employers how to develop a health-and-safety program, nor does it offer suggestions on how to create a culture of health and safety in the workplace.
They say the establishment of a safety regulation is usually the result of a person losing his or her life. In other words, many regulations are created in response to a situation in which a person died or became seriously injured or ill in an effort to ensure that situation and outcome do not occur again.
However, there is more to health and safety than just following the law. There is a philosophy of health and safety based on the recognition, assessment, and control of hazards; this philosophy is easy to remember with the acronym REACH, although we won’t discuss each of the below steps in this particular order.
R – Recognition
E – Evaluation
A – Assessment
C – Control
H – Hazards.
What defines a hazard?
In occupational health and safety jargon, a “hazard” is anything with the potential to cause death, harm, illness, or damage to people or property. Hazards have many contributing factors. The principal factors are people, equipment, materials, environment, and process. There are many processes and activities that also are known to be hazardous, such as those originating from machines, energy, confined space, material handling, work practices, ergonomics, and chemical/biologicals.
Recognizing a hazard
It is important for an employer to create a culture within the workplace where all supervisors and workers continually assess their worksites for hazards and are aware of what chemicals and processes are hazardous. In our industry, this is critical since our sites often change and the changes may progress from hour to hour and day to day. For example, the nature of cleaning, maintenance, and restoration can result in workers attending sites that have been altered in ways that create every possible form of hazardous condition, such as wet and slippery floors, ceilings collapsing, biological hazards, and electric shock hazards, to name a few.
There must be a continual process of hazard assessment on these worksites. This can help to identify hazards that lurk in a workplace. The U.S. Department of Labor’s Occupational Health and Safety Administration (OSHA) requires all employers perform hazard assessments by qualified persons and have it certified in writing by their representative.
Another way to develop a safe workplace is to conduct a job-hazard analysis, a systematic evaluation of a task performed by a worker. The analysis should take place at a site where the job task would normally occur, with a person who normally performs the task, and with the normal tools and materials they would use to perform the task.
The work should be broken down into segments. Then each segment should be evaluated to determine any hazardous conditions or potentially hazardous conditions that are present or may occur. If the job-hazard analysis is performed at a site where there are many possible scenarios due to changes in process, material types, or environment, then a change analysis would be added to the inspection. To perform a change analysis, look at each task in the job-hazard analysis and ask: “What if x were to occur?”
OSHA PPE Regulations
1910.132(d)(1): The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer shall:
1910.132(d)(1)(i): Select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment;
1910.132(d)(1)(ii): Communicate selection decisions to each affected employee
1910.132(d)(2): The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment.
A good example of change analysis is performing a job-hazard analysis on changing a vehicle tire. You would break down the tasks like so:
- First, take out the spare tire, then the jack.
- Raise the vehicle.
- Loosen the lug nuts and remove them.
- Remove the tire.
- Put on the spare.
- Tighten the lug nuts.
- Lower the vehicle.
- Return the jack and lug wrench, and stow the damaged tire.
During each step, you should ask yourself questions, such as: What if this were a different vehicle type? What if this were on a different road? What if this were at a different time of day? What if this were performed while it was raining or windy? What if this were being done on a sloped, gravel shoulder? This should help prepare for different scenarios.
After your job-hazard analysis is finished, tabulate the hazardous conditions and perform a job-safety analysis. The job-safety analysis is the process of taking the information gathered and making the necessary changes in the company’s standard operating procedures by adding safe work practices to them and the company’s safety plan.
All employers are required to have health-and-safety programs that address issues such as hazard identification, emergency response, and bloodborne pathogens. It is also important for companies to have forms and checklists to reinforce and maintain their health and safety systems.
The foundation of formally communicating potential chemical hazards is often referred to as a written HAZCOM program—all companies are required by law to have one. Most countries in the world, including the United States, have adopted the Global Harmonized System (GHS) as a means of communicating chemical hazards to workers and others who face exposure to chemicals in the workplace. The GHS uses product labels, safety data sheets, and worker education and training as the means for communicating the hazards of a chemical product to materially interested parties.
The GHS has simplified the process of hazard communication with simple signal words, hazard statements, precautionary statements, and pictograms that are placed on the label of each chemical product in the workplace. Most information the worker needs to ascertain the hazards of a product can now be found on the supplier label.
Setting up and prioritizing controls
Most serious hazards on well-established worksites already have some sort of safety control placed on them. Workers must ensure that the controls in place have not been compromised when entering a worksite and assess the risk of all identified hazards from the hazard assessment.
Hazards are to be controlled at the source as much as
possible; the worker’s personal protective equipment (PPE) is viewed as a means of last resort. It is recommended that hazard controls are implemented following the below hierarchy.
Control type no. 1: Technical hazard controls
First, eliminate the hazardous substance or process; if that is not practical, substitute the chemical or process with a less hazardous one. If eliminating or substituting the hazard is not possible, the next step would involve installing engineering controls around the hazardous item to reduce the danger to the worker and the environment. Engineering controls minimize the hazards at their source. Examples include:
- Building barriers/containments around contaminated sites,
- Placing areas under negative pressure to prevent
- Installing air filtration devices to rid the air of
- Installing mufflers on loud items,
- Insulating hot lines or pipes.
Control type no. 2: Administrative hazard controls
The next step in implementing hazard controls is the implementation of administrative controls, which include safe work practices. Administrative controls in our industry are policies the employer creates for the purpose of reducing risk. Good examples of administrative controls in our industry are:
- Scheduling work to be done when building occupants are not present,
- When using hot/humid/full PPE, schedule work assignments in short segments with many rest periods,
- Implementing wet processes versus dry processes,
- Purchasing products for safety versus recognition factors.
The best way to develop safe work practices is to have the workers involved with their development. There is no one who knows the hazards of the workplace, equipment, and company processes better than the workers who perform the tasks. Examples of safe work practices include procedures for properly dealing with:
- Biological hazards,
- Media blasting,
- Various cleaning protocol,
- Working at heights.
Control type no. 3: PPE controls
At the bottom of the hierarchy of controls is PPE. This is
because PPE does nothing to minimize the hazard at its source, such as by administrative controls or primary hazard controls. This can be a bit confusing for many in our industry because the initial hazard assessment is meant to determine the required PPE for the worker.
However, it’s important to consider that workers, depending on the task at hand, are entering sites that have changed, and will continue to change, until they return to
a pre-loss condition or until the cleaning project is complete. This is why constant evaluation is imperative until the project is complete. After the initial hazard assessment and placement of hazard controls, PPE should be worn as a precaution in case one of the other hazard controls is inefficient, insufficient, or impractical in rendering the hazard harmless.
It is highly recommended that all elements of a company’s hazard assessment and controls be incorporated in a company safety program. Other elements that should be incorporated into a health-and-safety program include elements on management leadership, worker training, and emergency response. No safety program would be complete without a means of evaluating its effectiveness and updating the program on a regular basis.
Accident and incident investigations
The last element to building a culture of health and safety in a workplace is accident and incident investigations. An accident is when there is a release of energy that causes harm, whether to an animal, person, or property. An incident is a release of energy that did not cause harm or damage but had the potential to do so. Incidents are often referred to as “near misses.”
The reason why we investigate accidents is to determine the root cause or initiatory phases of an event. This is why we investigate near misses the same way. We want to know what the initiatory phases were leading up to the incident that could have caused serious harm. In identifying what caused the accident or incident, we can then draw up safe work practices that will prevent or minimize the chance of this accident or incident occurring again.
Put it into practice
The elements outlined in this article are all essential to any company’s way of doing business. If all these elements are put into practice, the company will save money in downtime, workers’ compensation payments, and worker turnover and develop a more productive staff. It is the right thing to do and will encourage both employers and employees to work towards the common cause—a safe workplace.
James “Lee” Senter has been in the cleaning and restoration industry for more than 41 years. He is the chair of the IICRC Health and Safety Technician TAC and the IICRC Health and Safety Field Guides. He is also vice chair of standards at IICRC. Lee is a full-time IICRC instructor and flooring inspector. He owns a disaster restoration company and specialty cleaning company in Toronto, ON, Canada, and is the president of the Canadian Flooring, Cleaning & Restoration Association.