Budgeting for Work Injury Prevention & Safety Risk Management Strategy

As we begin to budget for strategic objectives in 2015, several work safety topics centered around an important theme come to light.  Posts ranging from safety training to workers comp/EMR risk, the importance of conducting fall hazard assessments and engineering fall prevention design — each capture elements of what I believe to be the annual theme for our blog, and what may be the most notable national work safety theme of 2014: Preventive Safety Risk Management Strategy.

Comprehending and preparing for the preventive work safety trend will prepare you for 2015 budgeting and set your organization on the path towards a beneficial work safety culture. While this may sound complicated, strategy setting will become easier after considering the benefits of preventive safety strategy.

First, Consider the Benefits of Safety Risk Management

The concept of pursuing Injury Prevention tactics for Safety Risk Management is not a revolutionary approach, nor is it a simple strategy to follow. The motivation behind injury prevention strategies that minimize risk to reap long term safety benefit is based in the complementary advantages provided by a preventative safety culture. Risk prevention strategy involves foresight and planning, and requires a greater upfront investment cost. Over time it will result in fewer injuries, worker lost time reductions, improved workers comp rates, and other indirect savings and benefits. From this perspective, preventative safety risk management ultimately provides inherent value to businesses that are financially stable and well-managed.  These businesses are typically set up to plan ahead strategically and invest accordingly. If they are able to effectively implement safety risk management strategy, they will thrive when compared to protection-focused strategies with stringent safety controls.

Safety risk management investments provide ROI via reduced workers comp claim costs, less lost worker time, culture and morale benefits

…then brainstorm Injury Prevention Strategies

The elements of successful injury prevention strategies are not unlike those of a typical work safety program, with respect to procedural elements. Hazard assessments, incident recording, policies and training remain standard work safety objectives. The subtle difference between injury prevention through safety risk management versus protection and control strategies is that prevention policies and controls are engineered to prevent risk, as opposed to simply identifying risk areas and protecting workers. For example, while injury risk hazard assessments are an element of most work safety programs, an overarching preventive strategy will interject that step into the initial processes of any new development or work activity.  The goal is circumventing, not simply mitigating, potential risk areas. With this in mind, preventive strategy is most effective when work safety culture is established and new initiatives are supported by an acknowledged organizational safety commitment.

Reassess work processes with a risk prevention approach and inject the process into strategic planning

Preventive Safety Incentives & Training Ideas

In support of building a work safety culture that values and supports injury prevention ahead of protective measures, safety incentives should be structured to reward preventative innovation as opposed to strict adherence to performance metrics such as injury rates or lost time. For example, an organization might hold a contest that challenges employees to propose an injury risk prevention strategy that reduces injury risk for the work process that had the highest injury rate the previous year. This approach delivers the strategic preventative message while working to solve a problem, and also helps to increase employee commitment through involvement. Similarly, training documentation should emphasize the importance of avoiding unnecessary risks as much as utilizing the proper protective equipment or following the recommended procedure. In an injury prevention safety environment, the goal should be to efficiently avoid risks, not plow through them with precautionary measures.

Safety policies that require PPE can often be improved via equipment investments that increase efficiency and reduce injury risk

Now You’re Ready to Budget Your Injury Prevention Risk Management Investments

We at the Safety & Numbers blog encourage you to invest in injury prevention engineering strategies and equipment as you write the 2015 budget. Establishing preventative work safety as a cultural value will not only offer the ‘usual suspect’ benefits (monetary expenses, less lost worker time, improved morale, etc.). Over time it will provide indirect benefits such as workers comp rate and hiring advantages. Need help with your injury prevention safety planning? Contact IAS


Know the Standards: OSHA Fall Protection Compliance

Most informed industry professionals are aware that OSHA has emphasized the importance of awareness and compliance to fall protection safety standards that are designed to reduce injury risk and fatalities from falls from heights.  What may be less clear to business owners in both construction and general industry is OSHA’s dedication to proactively prosecute violations to the letter of the law.  Several recent examples of OSHA’s commitment to fall protection injury prevention have shed light on risk areas for small business owners to be aware of.

OSHA Fall Protection Policy Enforcement

In February this year, OSHA drafted and delivered a warning to the communication tower industry of the increasing fatality rate in that industry, it’s relationship to fall protection, and how strictly OSHA will be enforcing fall protection standards as a result.  Another example of OSHA’s firmness on fall protection is in their willingness to prosecute compliance gaps even when a business has taken significant precautions to protect employees.  OSHA attempted to prosecute Ryder Transportation Services for an injury to a subcontractor at their site for a fall fatality through a roof skylight that was safely inaccessible to employees.

OSHA Fall Protection Standards

The most important point for concerned business owners in light of OSHA’s increased emphasis on fall protection compliance is their strictness and strategy for standard enforcement.  OSHA may potentially cite your business not only for injuries resulting from a failure to provide fall protection, but also in cases where the business did not conduct an appropriate hazard assessment, even at seemingly low-risk heights of 4′. This result is effectively a double whammy effect for a single employee fall incident.

As a result, while it’s important to provide proper fall protection, it’s even more critical to conduct and document the proper precautionary procedures for any potential risk area, to save money and administrative battles in the case that a fall injury does occur.  Here’s a brief summary of OSHA’s fall protection standards policy, with this in mind.  Of course, anyone subject to OSHA violations should fully research the topic on their own with OSHA or a certified compliance consultant.

Construction Industry Fall Protection Compliance

Found in Section 1926.501, these can generally be summed up to require businesses to provide fall protection (guardrail systems, safety net systems, personal fall arrest systems) on walking or working surfaces with an ‘unprotected side or edge which is six feet or more above the lower‘.

General Industry Fall Protection Compliance

General industry standards are also stringent, with Section 1910.23 stated to include ‘every wall opening from which there is a drop of more than four feet‘, with that also applying to open-side floor or platforms.  This requirement stipulates that risk areas be guarded by a standard railing or other means of fall protection.

And remember, the typical fall protection standards citations could be coupled with a citation for Section 1910.132 for failing to conduct a hazard assessment.

Fall Protect Your Business for Compliance

The application of these OSHA standards and enforcement policy strategies can thus be applied to a variety of settings, ranging from loading docks and flatbed truck beds to onsite or offsite machinery and equipment.  Business owner/operators should be aware that even for fall hazards of 4′ or less, a hazard assessment must be conducted and fall protection compliance equipment provided.

Trucker® & IAS Custom Access Fall Protection Products

Of course, we at Innovative Access Solutions are well-prepared to help with your flatbed truck and loading dock fall protection, starting with safety engineered Trucker trailer access ladders and working platforms.  In addition, IAS has a great deal of experience providing custom fall protection access equipment to machinery/equipment and multi-level walking or working surfaces at manufacturing facilities, dockyards, construction and mining sites, and public/retail settings.

To learn how IAS can design a fall protection access solution for your business, call our engineering team at (800) 388-6884 or submit our Contact form on IAScustom.com.

Fall Prevention Through Design: A Case Study from ASSE

Putting safety first applies not only in day to day operations, but also in the planning stages of new projects, investments and expansions.  In 2012 ANSI/ASSE created a consensus standard to promote this mentality.  Prevention Through Design as a concept in work safety began in the 1940’s and today has gained enough momentum and regulatory support to provide several models that prove its effectiveness.  A recent article at ASSE.org charts the effectiveness of engineering safety controls in the design process while considering the defeatability of safety hazard risk.

The most effective controls include elimination, substitution and engineering solutions, each ideally suited to be planned in the design phase of new projects.  Doing so will provide safety, productivity, and cost benefits.  In fact, the cost of implementing fall prevention through design can be thousands of times less expensive than the same solution integrated post completion.  Compromised solutions are often less effective, leaving hazard risks and associated costs.

Fall Prevention Design Case Study

The ASSE article provides a case study from a petrochemical organization building a new offshore platform.  The company had experienced the challenges of implementing fall prevention after the design stage and instead chose to hire a fall protection consultant early on to assist the engineering design team.  The combined expertise resulted in fall prevention safety measures that focused on productivity and risk abatement.  The process consisted of the following steps.

  1. Kickoff Meeting with Design team
  2. Virtual Fall Hazard Risk Assessment
  3. Design Team Workshops
  4. Specification Binder for Hazard Abatements
  5. Follow-Through During Construction Process

The benefits of foreseeing and engineering fall prevention through design are long term: safety advantages, productivity gains, and ultimately lower costs.  The case study resulted in hazard risk controls addressing elevated platforms, floor openings, ladders, and stair guardrails, helping to prevent the need for PPE and optimize processes, equipment placement and usage.  Indirect long term benefits included ‘less equipment purchases, less training and fewer elements to manage.’

Innovative Access Fall Prevention Design

Contacting a consultant while engineering an offshore platform was effective for the company from the ASSE case study.  The consultant costs were compared favorably to erecting scaffolding, the cost of which would have been required to address just one of the safety risks post-completion.  Innovative Access Solutions is available to contribute similarly during the design or redesign stages at your organization.  IAS has worked with Fortune 500 companies as well as SMB businesses to design solutions that provide long term cost and productivity benefits and accomplish your safety goals.  IAS designs ladders, platforms and fall prevention equipment and has provided solutions for a range of industries.  For a brief review of our access solutions, visit us at IAScustom.com.  Or call (800) 388-6884 to schedule an appointment with our team.

Fall Protection PPE Equipment

Personal Protective Equipment (PPE) covers a wide range of industries and safety objectives, from law enforcement to sports, industrial settings, contractors and even casual retail environments.  The various functions of PPE are designed to protect hazards in support of work safety policies and controls.  These can range from bodily injury, exposure to environmental threats, breathing mechanisms, and much more.

With OSHA having a renewed focus on Fall Protection and having imposed new rules for Fall Protection PPE, businesses in a range of industries are investing heavily in fall protection equipment.  Consider the following review of Fall Protection PPE equipment and how it can help to reduce injuries at your workplace.

Personal Protective Equipment Options for Workplace Fall Protection Safety

Personal Protective Equipment is required by OSHA when positive fall protection such as guardrails, access platforms, gangways, catwalks, and stairways are unavailable.

When guardrails and other positive fall protection are not available to protect from falls, workers must use personal fall protection systems (such as harnesses, lanyards, lifelines). [29 CFR 1910.6729 CFR 1915.7129 CFR 1915.73, and 29 CFR 1915.77]

Harnesses & Lanyards

Harnesses and lanyards are considered personal protective equipment since each individual worker must be fitted with the equipment for fall protection safety, as opposed to an all encompassing solution.  A lanyard is the rope or other length of connection between a single point anchor source and a safety harness, worn by an employee.  Snap hooks, D-rings and caribiners are utilized to ensure a safe connection.  Anchors must be secured and can be affixed to a variety of stable structures.  The complete fall protection system must be able to adequately support the weight of the employee.  Fall protection PPE systems are typically categorized as a fall restraint system, which prevents falls similar to a car seat belt, and a fall arrest system, which catches a falling worker prior to contact with the ground or other solid structure.

Fall Restraint Systems

The advantage of fall restraint systems is the prevention of the need to absorb the shock and otherwise prevent further injury in the event of a fall.  Further, in cases where the environment requires rescue efforts in the case of a fall, a fall arrest system is preferred.  Generally speaking, fall arrest systems are more safe and less expensive, while more limiting and often less efficient in a workplace.

Fall Arrest Systems

Fall arrest systems often require shock absorbing lanyards and must be carefully considered to avoid further injuring the employee when a fall occurs.  These systems are often used in work environments such as roofing, construction, and shipyards.  In these work environments, a fall is more permissible compared to a mining operation or manufacturing plant with heavy machinery.

Horizontal and Vertical Lifelines

Lifelines are a broad range of fall protection equipment that can be applied for horizontal applications such as roofs or ship decks, as well as vertical applications such as enclosed spaces or ladder systems.  As opposed to a single point anchor, lifelines provide more freedom of movement as they are typically connected to a cable, pipe, or other continuous structure.  Horizontal systems can be designed to provide ultimate movement flexibility via pass through systems, overhead connections, and other similarly unobtrusive mechanisms.  Vertical lifelines can be track based or climb assist systems on ladders at heights, or pulley operated systems for confined spaces and similar applications.  In each case, lifelines generally differ from harness and lanyard systems in so much that they are less mobile and more of a direct method for cases where fall protection risk is consistent and eminent.

OSHA’s Fall Prevention Campaign: Ladders

In previous posts, we have discussed the importance of Fall Prevention and the national focus on providing training, guides, and resources in support of this fall protection safety risk management. Falls are the leading cause of death in construction and a frequent safety issue in many other industries. Even falls at minimal height can result in broken bones, lost worker time, and worker’s comp injury claims.  Nearly a third of fall fatalities in construction are falls from ladders.

Recently OSHA has produced several resources to provide guidance to safety managers with respect to ladders. Specific guidelines include:

  • Use the right ladder for the job
  • When using a ladder to access another level, secure and extend the ladder at least 3 feet above the landing point
  • Wear proper footwear
  • Place the ladder on stable and level ground
  • Ensure that the ladder is fully extended before accessing
  • Prevent passersby from walking under or near ladders while in use
  • Do not work on the top rung of the ladder
  • Maintain three points of contact at all times
  • Do not carry tools or materials while using a ladder
  • Do not lean on the ladder while working and keep your weight centered
  • Do not use ladders near accessible doorways
  • Check, maintain and safely store ladders
  • Do not use faulty ladders: bent, missing a step, or unable to be locked open

In addition, the California Department of Industrial Relations provides additional resources for specific ladder requirements, including design and construction (complete with ANSI regulations); ladder types and proper ladder selection; care, use, and maintenance; and employee training.

ANSI: Follow the Proper Guidelines

The number of variations between ladder designs, applications, and composition is nearly as unique as the people that use them.  It can be difficult to determine the applicable ANSI standard and rating that applies to each ladder at a workplace.  As an example, the ANSI category for portable metal ladders (ANSI-ASC A14.2-2007) covers a wide range of ladders, and excludes others that may seem to fit the category:

Ladder styles include ladder type step stools, portable extension, step, trestle, sectional, combination, single, platform, and articulating ladders, but excluding ladders in and on mines, the fire services, mobile equipment, hoisting equipment, work platforms, antenna communications towers, transmission towers, utility poles, and chimneys. It does not cover special-purpose ladders that do not meet the general requirements of this standard, nor does it cover ladder accessories, including, but not limited to, ladder levelers, ladder stabilizers or stand-off devices, ladder jacks, or ladder straps or hooks, that may be installed on or used in conjunction with ladders.

The importance of being informed to prevent falls from ladders and conform to trending OSHA regulations is clear.  For details about requirements for your workplace access equipment, visit the ANSI website or contact a safety professional.

Preventing Falls in Construction

Falls in construction are a well known cause of work injury.  A common misconception is that fall injuries are primarily of concern to individuals that work at heights.  This is not an accurate representation of the danger presented by slips, trips, and falls, even at minimal height.  In heavy and highway construction, also known as horizontal construction, falls account for approximately 25% of workers compensation claims.  These consist of falls from trucks, trailers, and construction equipment (45%); ladders, stairs, and scaffolding (20%); and walking or working surfaces (5%). Fortunately, a recent national focus on fall prevention has raised awareness of the issue and improved the quality of resources available to safety professionals.  Resources are published daily at sites like OSHA’s Stop Falls Initiative, CDC’s Campaign to Prevent Falls in Construction, and StopConstructionFalls.com in support of this important work safety trend.

Source: Tennessee Road Builder Magazine

Falls from Trucks, Trailers, & Equipment

As a leading cause of injury in the workplace, the risk of falls from trucks, trailers, and equipment is an important hazard for which to mitigate risk.  Communicating the need to maintain three points of contact, wear proper footwear, and clean debris from ladders and steps is a good first step.  For many types of equipment, upgrading to access ladders that provide three points of contact and durable weight support can provide additional injury risk management.  United Rentals is one example of a company that has provided a Safety Best Practice document recommending all employees at their 800+ locations upgrade to the Trucker portable side truck mount ladder.  The Trucker ladder provides 3 points of contact, ANSI rated weight support, and slip resistant tread in a sturdy, lightweight design.

Indirect Costs from Fall Injuries

It is important to remember the indirect costs of work injuries when considering falls from minimal heights.  It is easy to take for granted the risk of a fall from a 4′ flatbed trailer, particularly under the stress of work timelines.  Nevertheless, while these may not always be a fatality risk, the consequences of a work injury extends far beyond broken bones and injury claims.  Individuals can suffer long term complications that affect their ability to work and your company’s ability to excel.  Even when injuries are minor, your company’s workers’ comp EMR (Experience Modifier Rate) is affected, causing insurance rates to go up and potentially limiting your ability to win valuable contracts.  Clearly, the national focus on construction fall protection is a worthy cause for the sake of workers and the industries that employ them.