As you know, by now safety is important, but only addressing individual incidents and safety hazards will not change your company safety culture or have much of an impact on core safety issues.  To take control of your company's safety culture, you must perform a safety audit.

A safety audit is a methodical examination and review of your company's safety program.  The task of a safety audit may seem daunting, but don't let the thought overwhelm you.  If you are considering a safety audit at your company you must first decide if you will have a private safety company conduct the audit if you will do it yourself.  Outside companies are great when there is no safety expert on staff or when a third objective view is needed. 

A safety audit looks at all of the different aspects of the company safety program and its effectiveness. OSHA states that the effectiveness of a safety and health program depends on the credibility of management's involvement in the program; inclusion of employees in safety and health decisions; rigorous worksite analysis to identify hazards and potential hazards, including those which could result from a change in worksite conditions or practices; stringent prevention and control measures and thorough training. It also addresses whether or not hazards are regulated by government standards.  A safety audit must cover all of these aspects to be effective.

You may choose to audit specific jobsites, divisions of your company or the company as a whole. However large or small your audit, the best way to structure the audit is along the Plan-Do-Check-Act cycle guideline. The concept is simple, yet very effective and covers the following five points:

1. Occupational Safety & Health (OSH) Policy-(Plan)

2. Planning-(Plan)

3. Implementation and operation-(Do)

4. Checking and corrective action-(Check)

5. Management review-(Act)

1) OSH Policy

Is the OSH Policy integrated with business unit systems and policy implementation programs?  Are safety needs a core company value-something that can't be compromised-and as such should it be ingrained in all other aspects of company operation?

Does the OSH Policy include the commitment to provide sufficient and appropriate resources?  As a manager or owner, you may think so, but if you have a safety director, ask them this question with a request for open feedback with no fear of reprisal.  You may be surprised that they feel the $100,000 yearly safety budget, when divided among individual projects, is very inadequate and may be costing your company more money in accidents, injuries, lost time and employee morale than the few extra dollars he needs. Recently, a Jacksonville based underground utilities contractor, reduced their hand injuries to zero by investing in higher quality gloves for their employees. Previously, hand injuries topped the list as their No. 1 injury on the job!

Is the policy communicated to all employees with the intent of making them aware of their individual OSH obligations? (This should be conducted through a random sampling of employees with different levels of tenure at the company.) Often times, training is conducted through third parties with no management presence during training or follow-up. Having management visible and directly involved and engaged is the best training session any company can have.  This reaffirms the management commitment to safety and the program.

Can employees demonstrate an understanding of the organization's policy (again, based on sampling)?

Is the policy available to other interested parties (e.g., sub-contractors, developers, suppliers)?

2) Planning (for hazard identification, risk assessment and risk control)

Do all major activities have safe work procedures or other effective control measures developed and implemented based on the relevant risk assessment?   Be sure that your company has a risk assessment for all stages/phases of operation and types of work your employees do.  You should pick at least three major activities and check for safe work procedures.

Are the risk assessments conducted by personnel who have adequate knowledge of the activities involved?  A Job Hazard Analysis (JHA) should be conducted by qualified personnel or consultants for the following types of work:

• Jobs with the highest injury or illness rates

• Jobs with the potential to cause severe or disabling injuries or illness, even if there is no history of previous accidents

• Jobs in which one simple human error could lead to a severe accident or injury

• Jobs that are new to the operation or have undergone changes in processes and procedures; and

• Jobs complex enough to require written instructions

Are relevant personnel (e.g., direct employees, sub-contractors, suppliers, consultants) aware of the legal and other (e.g., subcontractor contract) OSH requirements that they must comply with?  Is training being conducted as required by OSHA? Are there established procedures to identify training needs and provide adequate safety training? Are subcontractors employees aware of safety rules (hardhats, safety glasses, etc.) for the jobsite and your company?  This should be dictated in the contract, but often does not make it down the chain to the workers unless made a priority by the hiring company.

3) Implementation and Operation

Is there clear evidence that the management is committed to continual improvement of OSH performance?  This goes back to the policy but actually looks at the follow-through of management commitment to the program.  One company that I work with starts every meeting in the company, no matter how large or small, with a "Safety Moment."  The "Safety Moment" can come from anyone participating in the meeting and may be a safe act seen by an employee, a hazard on an upcoming task, work completed safely, a safety recommendation, etc.  This clearly demonstrates that safety always comes first no matter the topic of discussion.

Are there measures to ensure that personnel who have OSH responsibilities are free from potential discrimination that could result from execution of their OSH duties? Often, employees feel they can not report a hazard to management.  For example, if additional safety equipment is needed on a job or tight schedules and a cranky superintendent may get in the way of better judgment.  Be sure that safety is always first, and if an unforeseen issue comes up, the penalty for not reporting the condition always outweighs the fear of reporting it.

Another reason employees may not report an injury or safety hazard is because of the actual safety program itself.  Unfortunately, "effective" safety programs can sometimes discourage employees from making a report because the program is structured in such a way that employees are penalized and incentives are taken away if there is an injury or safety violation.

Are personnel consulted when there are changes that affect workplace safety and health?  Another key point many companies overlook is the actual employee.  The workers performing the task are often a great source of information to find what may make a job easier, safer or an employee more productive.

4) Checking and Corrective Action

Are personnel at all levels aware of the key OSH performance indicators of the organization? A great way to do this is to include Occupational Safety KPI's or even just injuries or lack thereof in company reports and meetings when determining how a job or year is progressing. The KPI's will help you determine direction and any actions that are needed to keep on track.

Do auditors follow strictly to the audit procedures?  If you have audits which contain false or misleading information because the wrong people are conducting the audits, the audit may do you more harm than good.  The best person to conduct the audit is an uninterested third party either within your company or outside of it. 

Are deficiencies in the hazard control system or new hazards or risks found during audits and self-inspections and then reported immediately to the individual(s) responsible for performing preventive and corrective actions? After you receive your audit back for management review, ask the responsible party if they were notified after the audit of the unsafe situation noted on the audit and what they are doing to correct it. The best way to correct a problem is through prompt notification to the party that has the authority to inspect and correct it immediately.

Is management reviewing findings and using them to initiate preventive and corrective actions?  If safety issues are put on the back-burner, injuries are sure to result and employees will see the lack of management commitment to the safety program.

5) Management Review

Is the management review documented and disseminated to personnel with OSH responsibilities and relevant parties? The audit should not be kept private.  There should be a formal e-mail, meeting, company mailing, etc., covering some of the hazards found on different jobs and divisions and how the hazards will be corrected.  This should also be accompanied with a reaffirmation of management's commitment to safety, incentive programs for safe employees and teams and corrective actions for safety violations.

Establishing a safety culture is sometimes not an easy task.  Some employees who are set in their ways may be difficult to sway to the new way of doing things. Job processes may need to be changed, and policies may need to be modified, but through commitment and example, it can happen.  The safety audit is a fantastic tool to put in your company arsenal. It will not only give you a greater insight into your company's safety effectiveness, but it will also give you a great insight into the operation of the company. 

Q:

A:

• Inspect your equipment daily.
• Replace defective equipment. If there is any doubt about the safety of the equipment, do not use it, and refer questionable defects to your supervisor.
• Replace any equipment involved in a fall, including ropes. Refer any questionable defects to your supervisor.
• Every piece of fall arrest equipment should be inspected and certified at least yearly by a competent person.
• It is advisable to use shock absorbers if the arresting forces of the lanyard alone can cause injury.
• Use the right equipment for the job. Refer to OSHA regulations, or contact us for assistance.

• Inspect the entire surface of webbing for damage. Beginning at one end, bend the webbing in an inverted "U." Holding the body side of the belt toward you, grasp the belt with your hands 6 to 8 inches apart.
• Watch for frayed edges, broken fibers, pulled stitches, cuts or chemical damage. Broken webbing strands generally appear as tufts on the webbing surface.
• Replace according to manufacturers' guidelines.

• Inspect for loose, distorted or broken grommets. Do not cut or punch additional holes in waist strap or strength members.
• Check belt without grommets for torn or elongated holes that could cause the buckle tongue to slip.
• Inspect the buckle for distortion and sharp edges. The outer and center bars must be straight. Carefully check corners and attachment points of the center bar. They should overlap the buckle frame and move freely back and forth in their sockets. The roller should turn freely on the frame.
• Guarantee rivets  are tight and cannot be moved. The body side of the rivet base and outside rivet burr should be flat against the material. Make sure the rivets are not bent.
• Inspect for pitted or cracked rivets that show signs of chemical corrosion.

• Rotate the rope lanyard and inspect from end to end for fuzzy, worn, broken or cut fibers. Weakened areas have noticeable changes in the original rope diameter.
• Replace when the rope diameter is not uniform throughout, following a short break-in period.
• The older a rope is and the more use it gets, the more important testing and inspection become.

• Inspect hardware for cracks or other defects. Replace the belt if the "D" ring is not at a 90-degree angle and does not move vertically independent of the body pad or "D" saddle.
• Inspect tool loops and belt sewing for broken or stretched loops.
• Check bag rings and knife snaps to be sure they are secure and working properly. Check tool loop rivets. Check for thread separation or rotting, both inside and outside the body pad belt.
• Inspect snaps for hook and eye distortions, cracks, corrosion or pitted surfaces. The keeper (latch) should be seated into the snap nose without binding and should not be distorted or obstructed. The keeper spring should exert sufficient force to close the keeper firmly.

• Inspect for cut fibers or damaged stitches inch-by-inch by flexing the strap in an inverted "U." Note cuts, frayed areas or corrosion damage.
• Check friction buckle for slippage and sharp buckle edges.
• Replace when tongue buckle holes are excessively worn or elongated.

• Wipe off all surface dirt with a sponge dampened in plain water. Rinse the sponge and squeeze it dry. Dip the sponge in a mild solution of water and commercial soap or detergent. Work up a thick lather with a vigorous back and forth motion.
• Rinse the webbing in clean water.
• Wipe the belt dry with a clean cloth. Hang freely to dry.
• Dry the belt and other equipment away from direct heat, and out of long periods of sunlight.
• Store in a clean, dry area, free of fumes, sunlight or corrosive materials and in such a way that it does not warp or distort the belt.

At a recent speaking engagement for business owners addressing how to implement effective safety programs, I had a question from a member of the audience-we'll call him Bob.  Bob asked why he should invest in safety. He told me he has insurance if an employee gets injured, he has a safety manual, OSHA has never bothered him and the only employee injuries so far have been minor.  Why should he do more if what he's doing now is working?  

"Well Bob," I said.  "How much will it cost your business if an employee falls from a roof, and how much have those ‘minor injuries' cost you so far?" Needless to say, Bob, and everyone else in the audience that day were quite surprised as we revealed the actual costs of workplace injuries to their businesses.  Unfortunately, the only thing most employers are aware of is that they have to spend money to have an effective safety program, and that's where the train stops.  Successful companies, however, maintain very effective safety programs and pay the expenses involved even when business is slow and times are tough. 

Most employers maintain some semblance of a safety program at their company, either because they care about their employees or because they're required to by OSHA.  OSHA violations can range anywhere from just a warning, to $70,000 per incident with recent proposed legislation asking to raise fines even further into the range of EPA violations.  I would like to think that all employers care about their employees, but often profits come first.  What does that mean? It means one thing is certain-all employers care about their company because of the profits derived from it.   A for-profit business is created to make a profit 99.9 percent of the time.  You carry insurance to protect yourself and your business, you plan ahead to avoid unforeseen costs and cut expenses where they are not needed to ensure you are as competitive as possible while maintaining a good profit margin. 

Unfortunately, however, the cost of effective safety measures are all too often deemed an "unnecessary" expense.  When business is slow, what is the first expense to get to get cut? You already know the safety program.  Normally the responsibility gets transferred to the HR manager, and training and other expenses are cut which could really lead to disaster, especially for the new employee you just hired.  If you are not motivated to have an effective safety program by either OSHA, the threat of fines or care for your employees, one thing that will motivate you is the actual cost of a workplace injury to your business. So how much does it cost?

Statistics and Costs

Every year in the United States there are over 6,000 workplace fatalities.  The greatest majority of these fatalities are men ages twenty-five to forty-four, of which there are approximately 30 million in the United States.  That means, using this example, just over 1 in every 6,000 men aged twenty-five to forty-four dies at work each year.

Even with these staggering numbers, this does not include deaths related to occupational illness. Another 50,000 workers die every year in the United States from occupational illnesses due to exposure to a workplace hazard.  These occupational illnesses include asbestosis caused by exposure to asbestos, silicosis which can be acquired from concrete cutting operations (and any work involving exposure to crystalline silica dust if not using proper respiratory protection) black lung disease for miners, or brown lung disease for textile workers, etc.  (Just an FYI, though not usually fatal, poison ivy is an OSHA reportable illness.)

In addition to deaths, there are over 6 million U.S. workers that suffer non-fatal workplace injuries with an estimated cost to U.S. businesses of around $128 billion annually.  A person's life or health is obviously priceless, but incidents and injuries carry a tangible cost to business, one quarter of each dollar of pre-tax corporate profits, to be exact.

The actual cost of a workplace accident or illness to your organization depends on a few different things.  Costs depend on how many employees you have, how many incidents you have, the type of work you do and the value of your materials, products or services.    For companies that may be experiencing a tough time financially, any losses are serious.   Even for a large employer, losing an employee on a job who is skilled in their trade, for even a few days, can have a much larger impact on profits than the actual direct costs might suggest.  With smaller businesses this would be magnified because they often have very little buffer when it comes to accidental losses.  A serious incident could not just make it difficult to get by, but put them out of business.  In fact, according to a recent study, 60 percent of companies experiencing a serious disruption that lasted more than nine days went out of business.

"But Wait, What about My Insurance?  Isn't My Business Covered?"

Insurance only covers what is detailed in the policy, and it usually only pays for serious injuries or damage. Workers' compensation does cover all employee injuries, but you will end up paying for the cost of that injury and more-we'll get into that later.  Some of the costs that are not covered by insurance include lost time, sick pay, damage or loss of product and materials, lost time and failure to keep schedule, extra wages for overtime and temporary labor, investigation time and expenses, OSHA fines, loss of contracts, legal costs and loss of company reputation, to name a few.

The uninsured costs differ between businesses, the type of work being done, insurance and type injury.  No matter how you look at it, though, the uninsured costs are many times greater than the insured costs.  If your business is a ship, costs are like an iceberg. Most of the costs are hidden beneath the surface and are not immediately visible, but you feel it when you run into them.  Studies have shown that the insurance premium to uninsured cost ratios for the construction industry generally range from 1:9 to 1:41. That means that for every $1 paid in insurance premiums, the company has to pay an additional $9 to $41 themselves for losses arising from incidents.  Another way to look at it-uninsurable expenses often run up to as much as 4 times more than the actual costs covered by insurance.

Workers' Compensation Insurance
It may surprise even the financially savvy how much you can save on your insurance by being safe.  A poor claims record will affect the amount a company pays in insurance premiums.  Depending on the number of incidents a company may have, insurance premiums can increase, and coverage may even be cancelled.  Insurance companies set a base rate for a particular industry, and the number of incidents you have directly affects how much you pay as your base rate.  This is called an experience modifier.  Your workers' compensation insurance premium is determined by this easy formula:

Payroll x Workers' Compensation Rate x Experience Modifier

Workers' compensation rates reflect the average claim cost per $100 of payroll.  Workers' compensation rates can take a huge chunk out of your profits if you are not safe.  The average worker's compensation rate for construction is 7 to 8 percent of your payroll, but can be lower for executives, around 2 percent, or 25 percent for more high risk activities.  According to the U.S. Census Bureau, construction claims comprise around 21 percent of the total claims for all industries.  This is quite a large number considering that only 5.7 percent of the U.S. workforce is in the construction industry. 

An experience modifier of 1.0 means your company's workers' compensation claims experience is no better or worse than your industry.  If you have a lower experience modifier, you pay less. 

For example, if your business had a 1.47 experience modifier because of increased incidents and injuries and paid $85,958 in premiums, but reorganized, got serious about safety, and got down to a .82 experience modifier, your business would only be paying $47,950.  That is almost a $40,000 savings.  That $40,000 with a 9 percent profit margin equates to approximately $445,000 in new business each year! 

There are other savings to be had.  Many businesses find that by improving workplace safety and health standards, their investments are repaid by improved productivity and efficiency, less employee absence, good company reputation, less turnover and improved quality of work.  Tackling the causes of incidents and injuries is not unnecessary overhead, but an investment in your business.  An investment in an effective health and safety program is as valuable as any other for your company.  The American Society of Safety Engineers found in a recent study that for every dollar spent on a quality safety and health program, businesses saved $8.  That's a healthy return on investment.

An investment into an effective safety and health program for your business is just that, an investment.  Not only is it unethical to risk an employee's health or safety to save money and cut costs, but in reality, it does just the opposite.  It creates unnecessary risks, costs and headaches.  A safe company with limited incidents and injuries will not only have an increased profit margin, but will be more appealing to potential clients and good employees.  Successful businesses plan for the future, for growth and for potential risks.  Safety should play a key role in your strategy and is the reason long-term successful businesses invest so much into their safety and health programs, because as I am sure some of you know, gambling isn't a good long term, or short term investment.  Play it safe with safety.  You may skimp by for a while, but the house always wins.

Q:

Where do I get assistance for writing an effective safety program?

A:

First of all, I would like to say how important it is to have an effective, written safety program specific to your company. All too often, businesses go on the Internet and purchase a safety plan that claims to be "plug-and-play" where someone plugs in some names, clicks a few buttons and "poof," an effective safety plan appears on-screen ready to print out. If you have ever heard the saying it's too good to be true, then that's probably the case.  

Yes, there is good information contained within some of those safety plans, with regard to OSHA regulations and their requirements, but it does not negate the company's responsibility to have an effective safety program, which includes a safety plan specific to their company and the employee's job tasks, not to mention the plan must be enforced.  I would consider the "plug-and-play" plans a starting point, but just having a safety plan is not enough.

When setting up your safety plan, feel free to call OSHA.  Though they may not be as effective as a reputable private safety consulting firm, which holds your hand from beginning to end, OSHA offers a great deal of assistance for those that ask. One of the most importatnt parts of a safety program in ensuring that the employees all have the appropriate safety supplies and safety equipment.  They may even be able to help arrange a business-to-business mentorship for smaller companies.

Mary Lynn, OSHA consultation project officer for Region 8 is not new to companies that are looking for assistance.  She knows that many businesses may not be aware that OSHA doesn't only exist as an enforcement presence. "OSHA's website has quite a bit of information to assist employers," Lynn said. "Businesses can schedule meetings with compliance officers at their local office for more in depth questions or they can call if they just need a quick answer. Just ask for the duty officer. OSHA also offers a free onsite consultation service for small employers in higher hazard industries, which includes construction."

The onsite consultation service is a great resource for businesses that may just be starting and not have the money to invest in a private consulting firm but need direction as to what OSHA requires.  It is often a confusing time with so much going on. This free service helps ease the pain. "An OSHA compliance officer would not actually come out to the jobsite, so there is no risk of citation for the business.  Usually, it is a safety consultant from a local university acting as a representative of OSHA," said Lynn. "They are thorough and very good at what they do."

The visit includes help with any aspect of safety the employer would like. If they want a jobsite inspection, they can also ask for a review of the safety manual along with recommendations. The only requirement for these inspections is that the employer must fix any hazards the consultant notes, or it could result in a visit from OSHA, along with a citation.  "I don't remember a case of that happening, however. Employers are asking for our help because they want to do things the right way and because they care."

Q:

We have stackable trench boxes rated for 25 feet total. Do I need to use a Registered Professional Engineer (RPE) to design our protective system for our 22-foot deep trench? Could you also give me a brief overview of trenching and excavation safety facts?

A:

Even with fatalities from trenching and excavation work at a staggering 112 percent higher than the rest of the construction industry, injuries and fatalities continue to plague this type of work despite well-known control methods.  In a study of 542 trenching and excavation related deaths from 1992-2001, most deaths (76 percent) were caused by cave-ins, most involved excavation contractors (141, 26 percent) or water/sewer/pipeline construction (131, 32 percent) and most deaths occurred in small businesses (48 percent in companies with ten or fewer employees, 70 percent with fifty or fewer employees).

These deaths can be greatly attributed to lack of or improper use of protective systems. This is a direct result of inadequate training. In a 2002 survey of contractor members of the National Utility Contractors Association on the use of trench boxes and safety practices, they identified not using trench boxes when they are onsite and taking other shortcuts that violate OSHA standards and put workers at risk as the greatest safety problems.  The survey also identified that, as seen across the board in all areas of construction, increased worker training sessions per year was directly tied to lower reported injury rates.  

The 29 CFR 1926 contains the OSHA standards for construction.  It details all requirements for various trades including trenching and excavation. To prevent these types of injuries and deaths, OSHA standards require that protective systems for trenches over 20 feet deep must be designed by a RPE.  Depending on the soil type and design of the trench box however, you may not need a Registered Professional Engineer for your situation.  The reason why? Because you already are using a one. Let me explain.

OSHA requires that trench boxes be designed by a RPE, therefore when he/she rated your stackable trench boxes for 25 feet, it fulfilled the requirements of the standard for trenches over 20 feet as long as it is used in accordance with the manufacturers recommendations. In addition, OSHA issued a letter of interpretation clarifying this is in fact the case:

March 1992, response from Directorate of Compliance Programs, Patricia Clark:

"...In regard to whether manufacturer's tabulated data can be used to design protective systems for trenches more than 20 feet in depth, please be advised as follows: Protective systems that are designed using manufacturer's tabulated data can be used in trenches deeper than 20 feet provided the use is within the limits of the data, including depth limitations and soil type. It should be noted that all tabulated data, by definition (1926.650), must be approved by an RPE."  

Trenching and excavation is dangerous business.  Ensure that your employees are protected at all times, and you will be protecting not just them, but your business as well. Always consult with the manufacturer, OSHA or a Certified Safety Professional if you have any doubt because when a trench starts to collapse, it is too late to start playing it safe.