In the US, our first approach to a worksite hazard is to add protection to the worker from what will harm them when we should just remove the harm itself. The Occupational Safety and Health Administration (OSHA) says the following on the topic.
Employers must institute all feasible engineering and work practice controls to eliminate and reduce hazards before using personal protective equipment (PPE) to protect against hazards.
That is a worthy and correct approach to workplace hazards.
The following are my thoughts on the value of the OSHA requirements for a hazard assessment, the risk that a firm takes when we blindly pass out PPE, and why the idea of "prevention" is taking a front seat in how we keep our workers uninjured and alive.
Eliminating Hazards Is Best
If you have taken the subway in New York City, the first thing you must do when entering any station is look around for what or who can hurt you. Are there any police or guards to watch over you? Any crazies shuffling about? Do you feel confident standing on the edge of the platform with people you don't know at your back? About two dozen commuters each year are pushed onto the subway track in New York City. In Japan, this is almost unheard of since they have erected screens along the platforms to prevent a fall.
The ideas of recognizing a hazard and eliminating it must be the goal of any firm before sending our sons and daughters to work. And, if we can't control the hurt, we must ensure an injury hurts less.
The first, best step to understanding the threat is a hazard assessment. OSHA's approach to hazard elimination must be commended.
Employers must institute all feasible engineering and work practice controls to eliminate and reduce hazards before using PPE to protect against hazards.
You can physically change the machine or work environment to prevent employee exposure to the potential hazard,
Then…
You have eliminated the hazard with an engineering control.
Putting up a railing rather than hoping workers will tie off near the edge of a building is a great example. Should the risk be unavoidable, like dust from concrete cutting, they next suggest Work Practice Controls, such as using a vacuum-equipped saw or one that uses water to eliminate the dust.
Another OSHA approach to hazards is PPE to protect workers from the hazard. Though it's common in the construction industry to claim that "PPE is the last resort" on most construction sites, PPE is often the first resort.
Conduct Hazard Assessments
Before you issue PPE to your team, an assessment must be completed per OSHA to ensure the protection offered defeats the hazard. That standard is below, and few firms follow it.
1910.132(d)
Hazard assessment and equipment selection.
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). [Emphasis added.] 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;
The need to perform and reasons for a specific hazard assessment is best exemplified by those firms who still supply the conventional hard hats to their workers. Aside from keeping your head dry in the rain, they provide little protection to the user, unlike helmets designed for head protection. It's true that OSHA recognizes the better protection these helmets offer over a hard hat. Though there is no OSHA standard requiring helmets, they have acknowledged the additional protection. Regretfully, they can only mandate this superior protection for their staff. Sigh.
WASHINGTON—The U.S. Department of Labor's Occupational Safety and Health Administration announced that the agency is replacing traditional hard hats used by its employees with more modern safety helmets to protect them better when they are on inspection sites. [Emphasis added.]
[A]dvanced, safety helmets … now provide further improvements to enhance worker safety and reduce the risk of severe head trauma. [Emphasis added.]
Source: OSHA, Safety and Health Information Bulletin SHIB 11-22-2023.
OSHA confirms that helmets provide better protection for our workers, yet we consistently see the archaic hard hat on workers across the US.
Today's PPE hazard assessments must include the best of prevention and protection. When you're conducting a hazard assessment, remember that protection must be like birth control: It needs to work the first time and every time.
Should you have a worker fall, a head injury results, and you chose to supply a conventional hard hat to that worker, you could be cited by OSHA for inadequate protection. And during an investigation or litigation, your firm will be in a tough spot to support your PPE decision. And they will be looking for your hazard assessment….
Site Assessments Are Hazard Assessments
I truly enjoy walking a site before work has started. This simple task is really your chance to assess any obvious risks to the work and workers, and the walk provides indicators of unseen hazards that can hurt. The following are some tips.
Always look for a rail line adjacent to the site. Special insurance (covering railroad protective liability) and planning will be needed to work alongside so you don't "foul the rails."
Ensure an environmental site assessment is completed to characterize if the site is clean or dirty. Never start a project before an environmental assessment has been done of the land you are disturbing or the building you're impacting. See, for example, Dunstan McNichol, "Cost of Second Version of Trenton School Jumps $10M," NJ.Com, September 26, 2007.
Get a feel for your neighbors. Is there a condo nearby that will be calling the complaint line daily due to excessive dust or noise?
Will trucks need to enter or exit, traveling across a busy sidewalk?
If trucks are staging on the road to enter the site before the gates open in the morning, will they obstruct local traffic?
Don't forget to consider what's under your feet. Ensure that you call 811 to locate any underground hazards before you dig.
As you walk, look to see what 811 would not have been aware of. An example is vent lines for underground storage tanks attached to a building. The fill pipe and dispensers may be gone, but the tank remains. The environmental site assessment should have documented that tank but still … look around.
Conclusion
To sum this all up, take the time to assess the hazards to good people and eliminate what could hurt your team, plan from there, and always take the time to walk a site before any work is performed. John Gambates, one of the pioneers in incident prevention, once said to me, "Safety pays. Safety earlier pays better."
Opinions expressed in Expert Commentary articles are those of the author and are not necessarily held by the author's employer or IRMI. Expert Commentary articles and other IRMI Online content do not purport to provide legal, accounting, or other professional advice or opinion. If such advice is needed, consult with your attorney, accountant, or other qualified adviser.
In the US, our first approach to a worksite hazard is to add protection to the worker from what will harm them when we should just remove the harm itself. The Occupational Safety and Health Administration (OSHA) says the following on the topic.
That is a worthy and correct approach to workplace hazards.
The following are my thoughts on the value of the OSHA requirements for a hazard assessment, the risk that a firm takes when we blindly pass out PPE, and why the idea of "prevention" is taking a front seat in how we keep our workers uninjured and alive.
Eliminating Hazards Is Best
If you have taken the subway in New York City, the first thing you must do when entering any station is look around for what or who can hurt you. Are there any police or guards to watch over you? Any crazies shuffling about? Do you feel confident standing on the edge of the platform with people you don't know at your back? About two dozen commuters each year are pushed onto the subway track in New York City. In Japan, this is almost unheard of since they have erected screens along the platforms to prevent a fall.
The ideas of recognizing a hazard and eliminating it must be the goal of any firm before sending our sons and daughters to work. And, if we can't control the hurt, we must ensure an injury hurts less.
The first, best step to understanding the threat is a hazard assessment. OSHA's approach to hazard elimination must be commended.
For example, OSHA offers the following solution.
Putting up a railing rather than hoping workers will tie off near the edge of a building is a great example. Should the risk be unavoidable, like dust from concrete cutting, they next suggest Work Practice Controls, such as using a vacuum-equipped saw or one that uses water to eliminate the dust.
Another OSHA approach to hazards is PPE to protect workers from the hazard. Though it's common in the construction industry to claim that "PPE is the last resort" on most construction sites, PPE is often the first resort.
Conduct Hazard Assessments
Before you issue PPE to your team, an assessment must be completed per OSHA to ensure the protection offered defeats the hazard. That standard is below, and few firms follow it.
The need to perform and reasons for a specific hazard assessment is best exemplified by those firms who still supply the conventional hard hats to their workers. Aside from keeping your head dry in the rain, they provide little protection to the user, unlike helmets designed for head protection. It's true that OSHA recognizes the better protection these helmets offer over a hard hat. Though there is no OSHA standard requiring helmets, they have acknowledged the additional protection. Regretfully, they can only mandate this superior protection for their staff. Sigh.
OSHA confirms that helmets provide better protection for our workers, yet we consistently see the archaic hard hat on workers across the US.
Today's PPE hazard assessments must include the best of prevention and protection. When you're conducting a hazard assessment, remember that protection must be like birth control: It needs to work the first time and every time.
Should you have a worker fall, a head injury results, and you chose to supply a conventional hard hat to that worker, you could be cited by OSHA for inadequate protection. And during an investigation or litigation, your firm will be in a tough spot to support your PPE decision. And they will be looking for your hazard assessment….
Site Assessments Are Hazard Assessments
I truly enjoy walking a site before work has started. This simple task is really your chance to assess any obvious risks to the work and workers, and the walk provides indicators of unseen hazards that can hurt. The following are some tips.
Conclusion
To sum this all up, take the time to assess the hazards to good people and eliminate what could hurt your team, plan from there, and always take the time to walk a site before any work is performed. John Gambates, one of the pioneers in incident prevention, once said to me, "Safety pays. Safety earlier pays better."
Opinions expressed in Expert Commentary articles are those of the author and are not necessarily held by the author's employer or IRMI. Expert Commentary articles and other IRMI Online content do not purport to provide legal, accounting, or other professional advice or opinion. If such advice is needed, consult with your attorney, accountant, or other qualified adviser.