I have been working for several years with the Tampa Bay Regional Planning Council to help local businesses prepare for disasters.  In our area, the Florida west coast, the disaster we fear is a major hurricane.  As part of these efforts, we developed and presented a series of interactive workshops covering emergency planning, risk assessment and disaster preparedness. 

If you want to be prepared, the following points are key -

• Prioritization of Efforts – It is impossible to address every need at the same time.  Before a disaster strikes, you need to define your risks and establish what your recovery priorities are going to be and then, when disaster strikes, act accordingly.
• Clearly Defined Roles and Responsibilities – To repurpose an adage from cooking (i.e. “Too many cooks spoil the pudding.”) – too many bosses creates chaos.  Someone must be in charge and that has to be clear to everyone.
• Communication is Key – Without clear communication, you are likely to have incomplete response actions, wasted duplication of efforts and run the risk of festering anger, outrage and violence in those who are impacted by the disaster event.
• Protecting Your Responders - Heroics look good for TV but should be discouraged. Having responders taking unnecessary risks adds to the ultimate “body count” of those impacted by the disaster.

If you haven’t reviewed your emergency preparedness plans yet this year, pull them out and review them now.  While you are at it, update those emergency contact lists, chances are they are out of date.

© ENLAR® Compliance Services, Inc. (2009)

One of the challenges associated with all of these alarms – “What are you supposed to do when the alarm goes off?”

Since my husband is at the top of the call list when an alarm goes off at his facility, I am only too familiar with this question – particularly since the “alarm alert” often occurs in the wee hours of the morning  (as it did this morning).  I can tell you attempting to answer the “now what?” question at 4 am is no fun.

One of the important tasks associated with implementing an OH&S management system is making sure there are thought out, agreed upon, documented and acceptable answers to all the “now what” questions.  In determining the “acceptability” of the answers agreed upon, it is important to consider of the views and needs of multiple stakeholders –

• The views and needs of the individual(s) who are required to answer the calls in the middle of the night (as well as the other members of their households whose sleep is disrupted).
• The views and needs of the individual(s) who are required to physically respond to alarms – including the need for specialized training and PPE.
• The views and needs of those who will have to deal with the public relations issues if an alarm triggers a “911” call for emergency services.
• The views and requirements of insurers if alarms are ignored because of frequent false alarms.
• The views and needs of individuals who are relying on alarms to protect their safety or property.
• The views and needs of the individuals who have the responsibility of keeping the alarms working right.

Putting in alarms is fine…just make sure there are plans in place for when they go off.

© ENLAR® Compliance Services, Inc. (2009)

Disney Fireworks

Unfortunately, early Sunday morning tragedy struck Disney’s transit system when two monorail trains collided – killing one of the train operators.  According to news reports, the Occupational Safety and Health Administration (OSHA) is currently conducting an investigation into this accident. 

I was contemplating this accident – and the resulting negative publicity for Disney – as I reviewed the latest draft of ISO 31000 – ISO’s newly developed Risk Management standard.

One of the weaknesses of many risk management programs is failing to fully evaluate the risks associated with events that are rare (low likelihood) but with the potential for severe (highly negative) consequences.  In Section 5.5.2, ISO 31000 suggests that such events may warrant risk treatment even when it appears that action may not be justifiable on strictly economic grounds.  The typical assumption being that the event will never happen; therefore, the time and money expended to evaluate and address the risk will be wasted.

This monorail accident appears to be this type of an event. 

It was clearly rare.  According to Disney, this is the first fatal crash in the 38-year history of the monorail’s operation.   

Yet, the consequences of this accident are likely to be severe –

• death of an employee
• reduced confidence in – and utilization of – the transit system by guests
• the costs incurred associated with an OSHA fatality investigation – even if no fines are imposed
• negative publicity for a company that is very concerned about maintaining a positive public image

Take ISO 31000’s advice to heart in your own risk management programs – including the risk assessments conducted to meet the requirements of OHSAS 18001.  Be sure that your low likelihood risks are evaluated - including those associated with abnormal or unusual activities.  As the accident at Disney proved, just because an event hasn’t happened yet, that doesn’t mean it may not happen tomorrow.

© ENLAR^® Compliance Services, Inc. (2009)

So what does that have to do with an occupational safety and health management system?

A great deal, as it turns out.

As I mentioned in my last post, I attended the annual AIHce two weeks ago.  The keynote speaker on Wednesday morning was Dr. Robin Herbert.  She is the director of the World Trade Center Medical Monitoring Program Data and Coordination Center with the Mount Sinai Medical Center in New York, New York.

Her presentation covered, in sometimes graphic detail, the on-going health impacts to those who responded to the World Trade Center (WTC) attack on 9/11.  This includes both physical and psychological health effects – including respiratory disease, stomach problems and post-traumatic stress disorder (PTSD).  Some of these effects are the result of the fact that individuals worked long hours, ate their meals and slept outdoors at the site – in effect having 24/7 exposure to a toxic environment.

Dr. Herbert ended her presentation with a list of recommendations that every organization should consider in their annual review of their emergency plan to prevent future impacts to the health of their emergency workers and first responders:

• Ensure that each person has, and is trained to use, appropriate personal protective equipment

• Include the steps (and supplies) necessary to define a “boundary” around areas that are not safe and limit access to those areas

• Limit the time individuals spend in emergency response and in areas with unsafe exposures

• Record the name of each individual who participates in the emergency response in case future follow-up is needed

• Take action to prevent and address psychological as well as physical trauma

Just as we have learned for confined space entry, we need to be aware that emergency response to disaster events can kill or maim responders.  We need to have plans in place to prevent this from happening – before the disaster occurs.  In other works – we need to include emergency response as part of an OH&S management system.

© ENLAR^® Compliance Services, Inc. (2008)

There were no plane crashes – no one died. Why?

A report on ABC Evening News last night highlighted two key reasons – pre-planning and the availability of an alternate means of communication.

The FAA has a contingency plan in place to address the loss of air traffic control at a particular location by diverting control to other centers – pre-planning.  Individual air traffic controllers used their personal cell phones to contact other air traffic control locations – an alternate means of communication.

Within one hour, planes were diverted around the Memphis air space creating what one commentator described as “a black hole in the sky.”

In a previous blog, I discussed the importance of emergency preparedness in an occupational safety and health management system.  Having procedures in place so you are prepared when things go wrong (including telecommunication and computer failures) is a key requirement of OHSAS 18001.  More importantly, it saves lives.

For the last year and a half, I have been working with the local emergency planning committee (LEPC) conducting workshops for local businesses and emergency responders to assist them with business continuity planning in regional disasters.  We have focused our outreach to organizations that handle significant quantities of hazardous materials.

During these workshops, two critical needs keep coming up.

Know what they are?

Adequate pre-planning (being prepared) and a functioning communication system.

As one attendee in our workshops put it, “As long as you have a plan and can talk, you can figure the rest out.”

© ENLAR^® Compliance Services, Inc. (2007)

What is an emergency?

According to the dictionary – it is an unexpected occurence requiring immediate action.

One of the critical parts of being prepared for emergencies is the anticipation of the unexpected.  One way of accomplishing this “anticipation” is to include it as an explicit part of your hazard identification and risk assessment processes.  As you are identifying hazards, ask – “What if ….”  The answer may surprise you.

Explicit requirements for management of change were added into section 4.3.1 of OHSAS 18001 in the 2007 revision of the standard.  This addition was an explicit request of the American Industrial Hygiene Association for purposes of aligning OHSAS 18001 with the U.S. Occupational Health and Safety Management System standard – ANSI/AIHA Z10-2005.  In addition, management of change is also an explicit requirement for safety management systems implemented to comply with the Seveso II Directive (see Annex III of EU Council Directive 96/82/EC).

 The following requirements related to management of change were added in section 4.3.1:

 The procedures for hazard identification and risk assessment shall take into account:

g) changes or proposed changes in the organization, its activities or materials; h) modifications to the OH&S management system, including temporary changes, and their impacts on operations, processes and activities;…. For the management of change, the organization shall identify the OH&S hazards and risks associated with changes in the organization, the OH&S management system or its activities, prior to the introduction of such changes. 

These new requirements cover four important concepts:

• Identification of the hazards associated with “change”
• Assessment of the risks associated with “change”
• Consideration of OH&S hazards and risks prior to the introduction of the “change”
• Implementation of the controls needed to address the hazards and risks associated with the “change”

For purposes of management of change within an OH&S management system, the changes that need to be addressed include:

• Organizational changes (e.g. personnel or staffing changes)
• Activity changes (e.g. changes to processes, equipment, infrastructure, software)
• Material changes (e.g. new chemicals, packaging)
• Changes to the OH&S management system (e.g. procedures)

Why is management of change so important?

Ineffective management of change is one of the leading causes of serious incidents.  To quote the U.S. Chemical Safety and Hazard Investigation Board (CSB), “In industry, as elsewhere, change often brings progress.  But it can also increase risks that, if not properly managed, create conditions that may lead to injuries, property damage or even death.” (from CSB press release announcing its 8/28/2001 Safety Bulletin concerning “Management of Change”)  Ineffective management of change is one of the major contributing factors in many of the incident investigations conducted by the CSB.  To check it out, go to the CSB web site at http://www.csb.gov  and enter “management of change” as your search term at the link “Search this Site.”

© ENLAR® Compliance Services, Inc. (2007)