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MovingOnToOtherThings
Salty & Seasoned Contributor

Posts: 1,300

« on: March 02, 2018, 11:47:57 AM »

One of the questions I have come up in my Fundaments Class is why OSHA and Safety have to be so complicated?

1)   Do you think Safety is complicated?
2)   Do you think a “quick facts” type approach would be helpful in a safety program?
3)   Do you think this could be applicable in your organization?

A recent article highlights some of the industries concerns.
http://www.safetyandhealthmagazine.com/articles/16752-industry-reps-to-osha-we-want-more-than-enforcement?utm_campaign=Membership%20News%20Alert&utm_source=hs_email&utm_medium=email&utm_content=61059323&_hsenc=p2ANqtz--vl7DfUdHAfGWVkYun9GPdcxqwzR1sG2Q4MwaptBc3pkbshXvTeFuBfNSCmDvQoThxyTwztY6rS8vXs7dTZeEpc1BpaRpZGCKrFEGFZuc7_3_i86o&_hsmi=61059323
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TheSkyHornet
Salty & Seasoned Contributor

Posts: 1,471

« Reply #1 on: March 02, 2018, 12:16:45 PM »

1)   Do you think Safety is complicated?

Very much so. It's filled with regulations that can often be difficult for the "average person" to understand/interpret. This is why safety industries, including their extensions into industry, have a need for specialists and trained evaluators/inspectors to ensure proper compliance.

If your organization takes regulations and makes them into SOPs, and then the enforcement of those SOPs are overseen by a competent management team, your line crew guy might not have so much difficulty in doing his job. But where he is on the floor stems from a lot of work since the publication of the regulation---from management review, to the development of policy, to the training and awareness of that policy, to the enforcement of that policy, to the evaluation of that policy, and subsequent corrective action cycles.

Consider this:
Most regulations are written in legal language and including a numbering convention. This makes it scary for the reader if they aren't familiar with it.


2)   Do you think a “quick facts” type approach would be helpful in a safety program?

I think this is way too broad of a question. A safety program can be small or fairly expansive depending on the organization.

We're a company of around 1,500 employees, give or take. Most of our line employees don't read fact sheets or information newsletters, even though they're published and readily available. A lot of it doesn't make sense to them, or they think, "I have a manual to follow. Why do I need to read this?" A great deal of publication comes from, not really the intent to provide more awareness, but because we have an obligation to provide it.

Data is more useful to managers and policymakers than it is to the line employee. Giving a list of measurable goals and saying "Here's where we are in meeting our goals" can be useful as a tool to promote morale and effort in the workplace, but it's very basic information, and most employees will think "Okay, but what can I do about this? I'm just one person."

Managers would be better off asking their employees "What information do you think you need to know/would like to know for your job?"


3)   Do you think this could be applicable in your organization?

We're a data-heavy company. We have performance measures based on OSHA, DOT/FAA, IATA, DOD, DHS/TSA, and a few other bodies. Most of it doesn't mean anything outside of our Safety Department and high-level management/directorship.

A great deal of what I do is build data based off of the safety program that I evaluate. How many violations? What are the root causes? What are the risk levels? What is the time it takes to correct? All of this data is virtually useless to me, but important to others that do the number-crunching. On a 100,000-foot overview, it ends up briefed to the company in conjunction with other metrics. As management changes, and employees turn over, it cycles itself over time.

So a key statement I see in this article is:
"The fact sheet urges employers to ensure a competent person identifies the types and number of confined spaces before each project. The competent person does not need to perform a physical assessment of each space if he or she possesses previous knowledge of similar confined spaces."

Competence is crucial. This means trained and qualified.

I see one of the fact sheets, under the Training section for ladders and scaffolds, says:
"The training requirements of 29 CFR 1926
Subparts L – Scaffolds (§1926.454) and X –
Stairways and Ladders (§1926.1060) apply to
ladder jack scaffolding."

This is confusing as ever to the average worker. This fact sheet is made by an OSHA compliance specialist who can crunch out regulation references with his eyes closed and ears blocked. Most compliance specialists can do this. I can do it with various regulations myself.

You have to make it applicable, and appropriate, to the person using the information. To reiterate my comment following the first question:
Most regulations are written in legal language and including a numbering convention. This makes it scary for the reader if they aren't familiar with it.

This topic could go on for a long time. I'll leave it here and check out some of the other replies. Good discussion, though.
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etodd
Salty & Seasoned Contributor

Posts: 1,251

« Reply #2 on: March 02, 2018, 10:12:44 PM »


... why OSHA and Safety have to be so complicated?


Because one day a 350 lb fellow broke a ladder and a lawyer sued and won big $$$. So 100 pages of new regulations affecting ladder strengths and capacities had to be written.

Another day someone spilled hot coffee in their lap and blamed folks for coffee being hot. Lawyers won big $$$ again and here comes more legislation.

Multiple the above by a few hundred thousand scenarios (or millions) and think of how much legal mumbo jumbo gets generated to try and protect companies, organizations, and people ... from lawyers.

 >:D
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lordmonar
Too Much Free Time Award

Posts: 10,651

« Reply #3 on: March 02, 2018, 11:34:35 PM »

One of the questions I have come up in my Fundaments Class is why OSHA and Safety have to be so complicated?

1)   Do you think Safety is complicated?
2)   Do you think a “quick facts” type approach would be helpful in a safety program?
3)   Do you think this could be applicable in your organization?

A recent article highlights some of the industries concerns.
http://www.safetyandhealthmagazine.com/articles/16752-industry-reps-to-osha-we-want-more-than-enforcement?utm_campaign=Membership%20News%20Alert&utm_source=hs_email&utm_medium=email&utm_content=61059323&_hsenc=p2ANqtz--vl7DfUdHAfGWVkYun9GPdcxqwzR1sG2Q4MwaptBc3pkbshXvTeFuBfNSCmDvQoThxyTwztY6rS8vXs7dTZeEpc1BpaRpZGCKrFEGFZuc7_3_i86o&_hsmi=61059323
Safety is not complicated.   Safety Compliance is.

When the Safety Guys come to my office to check compliance....they are not looking to see if we actually do our job safely.  The check to make sure if the paperwork is okay.  The get bent out of shape if you do not use the right form.   They make sure you got the big 3'X3' small print safety poster on the wall.  They make us stop work to spend 30 minutes at a safety meeting that does not address any safety issues involved with my actual job or has nothing to do with safety at all (One of the topics at my last safety meeting was Sexual Harassment!).  They send out weekly safety training on stuff that is either so obvious or has no bearing to my job. 
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PATRICK M. HARRIS, SMSgt, CAP
Pacific Region
Live2Learn
Salty & Seasoned Contributor

Posts: 667

« Reply #4 on: March 03, 2018, 12:54:53 AM »

Safety is not complicated.   Safety Compliance is.

Succinct, true, and quotable.  :)

Quote

When the Safety Guys come to my office to check compliance....they are not looking to see if we actually do our job safely.  The check to make sure if the paperwork is okay.  The get bent out of shape if you do not use the right form.   They make sure you got the big 3'X3' small print safety poster on the wall.  They make us stop work to spend 30 minutes at a safety meeting that does not address any safety issues involved with my actual job or has nothing to do with safety at all (One of the topics at my last safety meeting was Sexual Harassment!).  They send out weekly safety training on stuff that is either so obvious or has no bearing to my job.

This isn't an example of "safety", it's just that peculiar human creation known as  "bureacratic Hades", a closely related organizational phenomena to good 'ol 'empire building'. 
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Live2Learn
Salty & Seasoned Contributor

Posts: 667

« Reply #5 on: March 03, 2018, 10:21:25 AM »

Safety is not complicated.   Safety Compliance is.

Succinct, true, and quotable.  :)

Quote

When the Safety Guys come to my office to check compliance....they are not looking to see if we actually do our job safely.  The check to make sure if the paperwork is okay.  The get bent out of shape if you do not use the right form.   They make sure you got the big 3'X3' small print safety poster on the wall.  They make us stop work to spend 30 minutes at a safety meeting that does not address any safety issues involved with my actual job or has nothing to do with safety at all (One of the topics at my last safety meeting was Sexual Harassment!).  They send out weekly safety training on stuff that is either so obvious or has no bearing to my job.

This isn't an example of "safety", it's just that peculiar human creation known as  "bureacratic Hades", a closely related organizational phenomena to good 'ol 'empire building'.

Now, here is an example of an "unsafe act":  http://www.khq.com/story/37637643/body-spray-lit-cigarette-cause-car-explosion.  We might argue "ya' can't fix stooopid", we might write a three page 'safety' alert PLUS a 'safety policy that targets this hazard with surgical precision, or we might discuss the hazard of flammable aerosols in confined spaces in a general conversation/safety meeting.  It's clear that an obvious hazard to one person may not be so loomingly clear to another.  How many years have we heard cautions against using charcoal braziers for indoor heat?  Yet, local news media reported just yesterday that a couple did that not far from my home... with predictable (and fatal) results.  Were they 'stooopid', or simply uninformed?  I kinda doubt they went to bed the night before and said to themselves, "it's a nice night for the long sleep".


[ed - fixed quotes]
« Last Edit: March 03, 2018, 07:36:27 PM by SarDragon » Logged
Live2Learn
Salty & Seasoned Contributor

Posts: 667

« Reply #6 on: March 04, 2018, 09:09:44 PM »

I re-read the linked article posted by Capsafetyhybernation [need a shorter handle as part of the "clear and easily understood direction mantra"  :) ]  I agree wholeheartedly that regulatory language has to be clear, easy to understand, and use clear examples.  Among the comments at the end of the article this stood out:  "I have been in safety for more than 25 years and have trouble understanding some of the language in the regulations."   That was my own reaction the first time I experienced CAP's "Introduction to Safety" online powerpoint.  I wonder if the authors of our safety materials were paid by the word?  Or did they stay up late at night reading Webster's, searching for obscure words unlikely to be known to 90% of the SM (not to mention 12 year old cadets) who are required to pass the quiz as a sacred rite of CAP?
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MovingOnToOtherThings
Salty & Seasoned Contributor

Posts: 1,300

« Reply #7 on: March 05, 2018, 11:06:11 AM »

I re-read the linked article posted by Capsafetyhybernation [need a shorter handle as part of the "clear and easily understood direction mantra"  :) ]  I agree wholeheartedly that regulatory language has to be clear, easy to understand, and use clear examples.  Among the comments at the end of the article this stood out:  "I have been in safety for more than 25 years and have trouble understanding some of the language in the regulations."   That was my own reaction the first time I experienced CAP's "Introduction to Safety" online powerpoint.  I wonder if the authors of our safety materials were paid by the word?  Or did they stay up late at night reading Webster's, searching for obscure words unlikely to be known to 90% of the SM (not to mention 12 year old cadets) who are required to pass the quiz as a sacred rite of CAP?

I have seen Safety training written by Safety Professionals that was very confusing and tried to push too much information to the group.
I have also seen Safety training written by Non-Safety Professionals that was written very well and presented the exact information needed.

I think the difference between the two was an understanding of how to prepare that material for the audience.

One of the best classes I have had the chance to take was the State of Georgia Train the Trainer Training Training. It was a week long course sponsored by the State and the local Technical College. During that week they had course developers teach us on how to write training courses by looking for certain elements. The nickname of the class "No death by Power Point" process.

There were several others as part of my undergrad courses but I enjoy the 4T Training more.

Both of the colleges I teach for put the Adjunct Professor's through a FOCUS Course. Faculty Online Course to teach us how to "Instruct" by their standards. They are also pushing for us to become "Certified Online Instructors" through a 3rd party.

I recommended several years ago that we should have courses written for Cadets only and Senior Members and when they logged in it would take them to the training developed for their age group.

I believe that the new direction that CAP Safety is taking, may work towards the very thing you speak of. As noted in the National Safety Staff requests they are looking for SME's to join the National Safety Team. They also highlight in the Feb Beacon that they had several applications for the positions.
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