Do you believe that other manufacturing-centric areas of safety that regularly make the OSHA Top 10 list (such as hazard communication, lockout/tagout, respirators and machine guarding), will begin to see training compliance move on to the list?
DONY: This is not something I am really able to offer an opinion on directly, as this is much more up to OSHA than an organization like NSC. However, I will say that the above discussion around the evolution of training is relevant for all areas of safety, including haz com, confined space entry and rescue, LOTO, and machine guarding. Additionally, advances in the sorts of technology now leveraged for training (such as VR) and in other areas of operations/manufacturing (such as additive manufacturing) are transforming these risk areas. For instance, VR can not only be used for training, but for prevention through design work before changing or starting up a manufacturing process. Additive manufacturing can be used to manufacture safer tooling and even create machine guards on the spot.
See this visual snapshot of the haz com standard in the infographic: “The Evolution of the Hazard Communication Standard.”
Does anything on this year’s OSHA Top 10 list stand out to you as being unique or a major shift from past years?
DONY: There haven’t been many major shifts except for the bottom of the list—which has changed year to year (wiring-related in 2017, eye and face protection in 2018). You had another question in a follow-up about how significant this is. I think that violations that are near the bottom of the Top 10 list tend to have more variability year over year and don’t necessarily indicate a major shift or indicate that there has been a huge amount of increased risk in this area, as these may have changed based on the industry profile of OSHA inspections that were completed year to year. However, some macro trends may be influencing the change that are worth paying attention to—for instance, with an uptick in construction and building activity over the past few years has come a shortage in skilled labor that may be driving both newer and older workers into jobs where they don’t well understand the risks posed on a jobsite. Temp and contractor work can create similar challenges. Given that eye and face protection are often associated with the sorts of activities on the uptick, there may well be a connection.
What is the role of safety and hazard assessments today? How has that evolved over the past decade?
DONY: Safety and hazard assessments continue to be the bedrock of safety activity today, but I think that the evolution has been from a compliance-oriented discussion to a more risk-based discussion. Safety and hazard assessments based solely on compliance are likely to miss a significant amount of potential risk. As safety professionals continue to learn more about the importance of identifying potential risk and precursors of significant injuries and fatalities, assessments have become much more nuanced and mature. This mirrors the regulatory framework that exists in places like the United Kingdom and Europe, which are far less prescriptive and focus on risk reduction versus compliance to a particular set of standards.
What does it mean to have a “culture of safety”? You see this term used a lot, but what does it mean to really have one? What metrics and other indicators can be implemented to help move a company toward becoming a safety culture?
DONY: Culture may sound “fuzzy,” but it is absolutely measurable. Tools such as employee perception surveys are ways to get at the actual culture of an organization as it relates to occupational safety and health. The metrics derived from these sorts of activities are only half of the puzzle, though—the other half is addressing the feedback and input you get from these tools. Action planning and communicating on the steps taken and improvements made are just as important as asking for input and fixing the problem. Often, this sort of work is paired with an effort to move away from “lagging” indicators of performance (recordables, fatalities) to “leading” indicators of performance (quality of reporting, timeliness of corrective actions, etc.). I know that these are not explicit definitions of a safety culture, but are ways to measure and test the culture that already exists in your organization and move it forward. At the end of the day, though, culture is the way people do things when no one is watching—whether that’s around safety or other aspects of the work.
What is your advice to best engage with OSHA to resolve infractions and citations for compliance violations?
DONY: Working to resolve the root cause of compliance violations is always the best policy—no matter what the citation is around, there is almost certainly a systemic cause or set of causes that can be addressed to avoid future compliance violations and reduce risk. It is key to remember, even in the face of a compliance violation or citation that you may not agree with, the goal of everyone in the safety profession (regulator and practitioner) is to prevent injuries and save lives. In the end, the ways we try to do this may differ, but we should always be looking for solutions that aim to prevent an incident or potential incident from occurring in the future.
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