OSH professionals can find the following sentence in OSHA standards for general industry (29 CFR Part 1910.6), construction (29 CFR 1926.6), shipyard employment (29 CFR Part 1915.5) and marine terminals (29 CFR Part 1917.3): “The standards of agencies of the U.S. government, and organizations which are not agencies of the U.S. government which are incorporated by reference in this part, have the same force and effect as other standards in this part.” What does this mean?
The noted paragraphs are a list of the consensus standards written primarily by industry that OSHA has adopted as the law, officially called incorporation by reference (IBR). The OSH Act was signed into law Dec. 29, 1970, by President Richard Nixon. At Section 6(a), the OSH Act authorized the U.S. Secretary of Labor to adopt other federal standards and national consensus standards for a period of 2 years without having to go through the official rulemaking process.
Congress decided that since national consensus standards were written by highly knowledgeable, experienced professionals and had gone through a comprehensive review process, adopting these standards would simplify standards promulgation and provide immediate protection for America’s workforce.
This new agency (OSHA) chose to adopt several hundred of these other standards, and those adopted standards are incorporated into the law by means of a specific OSHA standard referring to that adopted standard.
Emery, Robert J. (University of Texas Health Science Center at Houston and School of Public Health) | Patlovich, Scott J. (University of Texas Health Science Center at Houston and School of Public Health) | Jannace, Kalyn C. (University of Texas Health Science Center at Houston and School of Public Health)
A variety of safety and health risks exist on college and university campuses based on the types of teaching and research activities conducted. OSH programs are typically implemented to help identify and control these risks to keep students, faculty, staff and visitors safe. A significant challenge for decision makers at these institutions is how to determine appropriate staffing and resourcing levels for such programs. A further challenge to staffing is ensuring that the job description and duties accurately represent those activities that truly fall under the purview of the position.
Existing methods of measuring efforts often include some level of intense observation or surveillance, which staff may consider to be intrusive and cumbersome (Sewell, Barker & Nyberg, 2012). As a result, the Hawthorne Effect, described in other time and motion studies, may alter the way a staff member conducts his/her routine activities leading to an observed effect further from the normal (Fernald, Coombs, DeAlleaume, et al., 2012). Brown, Emery, Delclos, et al.’s (2015), recently developed predictive models provide the ability to estimate staffing and resourcing needs in academic settings using institutional drivers such as total net assignable square footage, but the models do not account for staff productivity.
In this pilot study the authors utilized the ecological momentary assessment (EMA) research technique to record the work activities being undertaken by OSH personnel during a typical 8-hour work day in an effort to augment the Brown, et al., models by addressing worker productivity. Practicing OSH professionals were evaluated 1 day per week over a 5-week period (for a total of 5 work days, all weekdays) to determine the type of work conducted during the normal 8-hour work shift.
Marcham, Cheryl L. (Embry-Riddle Aeronautical University) | Turnbeaugh, Treasa M. (Board of Certified Safety Professionals) | Gould, Susan (Board of Certified Safety Professionals) | Nadler, Joel T. (Board of Certified Safety Professionals)
For more than 40 years, the multiple-choice examination has been the standardized assessment tool used in the certification process of OSH professionals (Wright, Turnbeaugh, Weldon, et al., 2015). The use of a multiple-choice exam to award a credential, however, has been criticized by many OSH professionals. This may be primarily due to a perception that relates to their previous academic experience with multiple-choice exams and a misunderstanding of the science behind the development of such exams.
The use of standardized tests clearly ensures a consistent and rapid method of scoring, but the use of such tests is legally defensible only if the test is developed through a systematic, psychometric process that objectively measures the relevant skills and knowledge of the individuals being assessed (Wright, et al., 2015). These exams are not, as many perceive, developed solely by individual certificants intending to make the test questions as hard or as trivial as possible.
Components of High-Quality Certification Examinations
The process of establishing and delivering a high-quality certification examination involves several steps and many subject matter experts (SMEs), as well as extensive statistical evaluation. The process must generate an examination that is valid, reliable, fair and practical. Each component plays a role in the development of a high-quality examination for the certification process (Figure 1, p. 46).
Consider the following descriptions of three incidents in which work zone intrusions resulted in injuries and fatalities of construction and transportation workers.
Case 1: On March 13, 2017, two construction workers were killed in a work zone by a hit-and-run driver. A third was severely injured. The workers were conducting a ditch inspection when a car veered off the lane and crashed into the work zone (Johnson, 2017).
Case 2: On April 7, 2017, at approximately 3:00 a.m., a vehicle drove into a cut-off emergency lane and struck four DOT employees who were sanding and painting metal structures beneath an overpass. One worker was declared dead at the scene of the crash while two workers were severely injured (Park & Clark, 2017).
Case 3: Following some erratic driving upstream, a vehicle entered into a highway work zone and hit a company vehicle parked in the work zone, then ran over several barrels before coming to rest. Prior to crashing into the stationary company vehicle, a worker was hit and killed (Reese, 2016).
A consistent undertone in the three cases is the cause of the fatality: a motorist intruding into a predetermined and closed-off work zone. To keep the roadway open to the public during construction, highway construction workers are often exposed to the hazards of working in close proximity to live traffic. According to CDC (2016), 1,435 workers died on duty between 2003 and 2014, averaging about 115 fatalities per year. Vehicles intruding into a work zone are considered a primary source of worker fatalities. In addition, CDC (2016) reports that approximately 50% of fatalities recorded between 2011 and 2014 were attributed to vehicles hitting a worker in a work zone. The results from a survey conducted by Associated General Contractors of America (AGC, 2015) indicate that approximately 50% of all U.S. roadway contractors witnessed a work zone intrusion in 2014.
The machine shops at Woods Hole Oceanographic Institution (WHOI) play a critical role in enabling its mission of world-class ocean science through the design, fabrication and maintenance of ships, vehicles and facilities that are used to work anywhere in the world’s oceans. WHOI has approximately 25 machine shops in all major laboratory buildings on two campuses located in Woods Hole, MA.
The machine shops range in size and type, from a larger than 900 m2 facility operated by professional machinists to one smaller than 20 m2 operated by research personnel. These machine shops use various large floor-type and small tabletop machinery, including water jet cutters, press brakes, lathes, milling machines, table saws, band saws, drill presses, laser cutters and grinders. The machine shops perform maintenance, repair, fabrication and installation work on scientific instruments, shipboard equipment, hoisting equipment, physical plant and other mechanical systems.
WHOI has experienced serious injuries in its machine shops, including a 2015 incident involving a waterjet machine that cuts thick metal parts. The incident led to enforcement action from OSHA, which served as a wake-up call for WHOI to comprehensively review and enhance the safety of its machine shops. This article describes WHOI’s machines shops and their purpose, hazards, controls, key elements of a comprehensive safety program, fire prevention and waste management.
This article is part of an ongoing collaborative effort to promote learning and innovative engagement in the risk space. The initiative includes ongoing research, bringing industry’s perspective to the classroom as well as educational publications and student mentoring initiatives.
The study presented aims to deconstruct the challenges and opportunities in the risk and insurance industry from the perspective of the large employer. The large employer space has been selected as a focus of study due to the collective baseline of knowledge and resources that this sector of industry offers. Large employers attract some of the best and most forward-thinking professionals who are continuously making advancements through working in larger, more complex environments that allow for accelerated industry learning and evolution of trial and error.
The study focuses on what large employers do best-in-class and where they struggle. Best-in-class practices provide industry learning that is transferable at all levels and sizes of organizations. Struggles are transitioned into development to explore better, more efficient and innovative ways for risk teams to operate. To this end, the article explores the differences, connections and opportunities between traditional risk management and enterprise risk management.
TRM & ERM
Risk management breaks down into traditional risk management (TRM) and enterprise risk management (ERM), which are two different methods used to achieve some of the same goals. Dionne (2013) defines TRM as a system that focuses on pure risks and views each risk separately.
OSH professionals may experience an increased interest in and concerns about providing gender equal protection from their employer’s management team, occupational medicine providers and human resources partners. The protection of reproductive health for all genders must be ensured in the workplace. There have been significant changes to regulatory and legal aspects of gender equal protection in recent years (Pisko, 2016). International conversations have re-energized the discussion about providing inclusive and gender equal protection in the workplace.
In the U.S., state-based laws have generally been termed a Pregnant Workers Fairness Act (PWFA) or similarly named acts. As of November 2017, 22 states, the District of Columbia, and four municipalities have enacted PWFA legislation, including: Alaska, California, Colorado, Connecticut, Delaware, Hawaii, Illinois, Louisiana, Maryland, Massachusetts, Minnesota, Nebraska, Nevada, New Jersey, New York, North Dakota, Rhode Island, Texas, Utah, Vermont, Washington and West Virginia (National Partnership for Women and Families, 2017). A PFWA has been proposed at the federal level (S.1512), but progress in passing the act is slow. Congress has “attempted multiple times to pass” the federal PWFA, but the law has been opposed by several sessions of Congress (Pisko, 2016).
Upcoming regulatory changes associated with revisions to EPA’s Toxic Substances Control Act are also relevant. As part of the Frank R. Lautenberg Chemical Safety for the 21st Century Act (2016), a definition for “potentially exposed or susceptible subpopulation” has been established to include a group of individuals with greater risk than the general population for adverse health effects relating to chemical exposure. This greater risk is further explained to be either from greater susceptibility or greater exposure, and includes infants, children, pregnant women, workers and the elderly.
When confronted with change, autopilot automatically drives people to think, “what’s in it for me?” Realistically, most want to understand the context of what is being asked of us, and personal context is typically the greatest concern. That is not to say people are necessarily selfish by nature, rather that they try to determine how the suggested change can provide some benefit to their career, business or personal life. The motto, “What’s In It For Me (WIIFM)” has been the basis for helping implement change in business for many years. If an OSH professional can show how an individual (or group) can benefit from the request, they are more likely to accept it. Whether change must be implemented on the production line or to policy, procedure or roles, one of the first filters used to consider the change request is to determine WIIFM.
The term WIIFM was initially coined from a marketing perspective, that a salesperson should always address the benefits that customers would get from the product or service (Doyle, 2011; Jordan, 2016). More recently, the term has come to be used as a concept in integrating change management. It is a shift from the traditional way of thinking in which employees are expected to do what they are told to a more fetching approach in which employees make the decision to adopt the change on their own.
Most successful businesses are beginning to understand that the reactive approach to employee health, providing group health insurance to cover employees when they get sick, is far less effective than one that combines preventive efforts with transparent/reactive medical services. In the past, adding a traditional wellness program to group health benefits was the first step for employers that sought to proactively reign in their increasing group healthcare costs. This approach is slow, sometimes ineffective and makes measuring success difficult. More importantly, this philosophy is becoming obsolete.
By adding new, nontraditional wellness programs to existing healthy workforce strategies, employers can take their programs to a new level. Employers can look to a new generation of comprehensive healthy workforce programs to address not only nutrition, cessation education, exercise and disease management, but also disease prevention, functional employment testing, job analysis, ergonomic assessment and injury prevention.
Conducting an OSH risk review is a common safety management practice, allowing to systematically recognize, evaluate, prioritize and control OSH risks for a particular industry, organization or project. OSH system deficiencies such as lack of leader commitment to safety, lack of management and employee participation in safety programs, nonexistent or not followed management of change procedures, inadequate hazard analysis and design for safety, flawed communication and reporting systems, and inadequate learning from prior events constitute significant OSH risks (Leveson, 2011). Engineering, management and PPE controls are applied to avoid or mitigate the risks to acceptable levels.
The aforementioned OSH risks are known and discussed in the OSH profession. This article reviews several less frequently discussed risks related to nonoptimal OSH models:
This noncomprehensive list of conceptual deficiencies provides an additional perspective on improving the effectiveness of OSH programs.