Professional Safety - May 2019

A Hierarchy of

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CONTENTS
Features

Peer-Reviewed

34 44 53

RISK TREATMENT REMODELING HEINRICH VALUE STREAM MAPS
STRATEGIES An Application Improving Procurement
Harmonizing the for Modern Safety of Ergonomic Office
Hierarchy of Controls Management Equipment
& Inherently Safer
Design Concepts By E. Scott Dunlap, Bryan By Marie Hayden and Diana
Basford and Michelle Smith Schwerha
By Bruce K. Lyon and Georgi
Popov This article presents the authors’ This article presents research that
analysis of current data to deter- shows how value stream maps
A fundamental concept within mine whether simple revisions (VSMs) were used to document
operational risk management is the to Heinrich’s theory are in order the procurement process for of-
ranking of hazard controls and risk rather than dispensing with it en- fice equipment to establish better
treatment strategies known as the tirely. The authors determine that methods of helping users obtain
hierarchy of controls. Various hier- the theory has merit in contempo- equipment to reduce the risk of
archy of controls models exist, each rary safety management through overuse injuries in their office jobs.
having slight differences in control an analysis of recordable, restrict- The benefits of using a VSM include
options and applications, present- ed work, lost-time and fatality obtaining user input, creating better
ing some confusion to the user. A data at the national and industry documentation and streamlining the
new risk reduction hierarchy model sector levels. They determine process. VSMs are recommended
is presented that incorporates in- that instead of a singular model, as a structured way for OSH profes-
herently safer design strategies in multiple models are in order as sionals to obtain information about
a more comprehensive format ac- evidenced by the “house” models user needs and ways to improve pro-
companied by a decision tree. presented in the research findings. cesses to reduce workplace injuries.

MAY 2019 ABOUT PROFESSIONAL SAFETY
VOL. 64, NO. 5
Professional Safety is a blind peer-reviewed journal published monthly by
COVER the American Society of Safety Professionals, the oldest professional safety
society. Professional Safety keeps the professional OSH specialist informed on
Ranking hazard developments in the research and technology of incident prevention, industry
controls and best practices and safety management techniques.

risk treatment Judgments made or opinions expressed in Professional Safety feature articles,
strategies is a news sections, letters to the editor, meeting reports or related journal content
fundamental do not necessarily reflect the views of the editor, nor should they be considered
concept within an expression of official policy by ASSP. They are published for the purpose of
operational risk stimulating independent thought on matters of concern to the OSH profession
management. Photo and its practitioners.
jamesteohart/
iStock/Getty Correspondence should be addressed to the editor. Editor reserves the right
to edit manuscripts and other submissions in order to improve clarity and style,
Images Plus and for length.

2 PSJ PROFESSIONAL SAFETY MAY 2019 assp.org



CONTENTS
Departments

6 President’s Message 31 Leading Thoughts EDITORIAL STAFF
Creating a diverse, inclusive Society Attracting a diverse workforce Tina Angley, Editor
(847) 768-3438;
8 ASSP Connection 32 Worth Reading [email protected]
Society election results, women Book reviews of Physical Hazards of the
and safety, global collaboration Workplace and The Safety Training Ninja Sarah Astra, Associate Editor
(847) 768-3414;
11 Safety Matters 59 Standards Insider [email protected]
Sustainability, mold, vaping hazards How standards are developed
Griffin White, Assistant Editor
18 PSJ Asks 63 Checkpoints (847) 768-3468;
Diana Stegall, ASSP President-Elect How to keep safety toolbox talks fresh [email protected]

20 Leading Thoughts 64 Training Tips Publication Design Inc.
Safety leadership during times of Top three benefits of on-site training Design Consultants
uncertainty
65 Product Pulse EDITORIAL REVIEW BOARD
24 Best Practices Safety training innovations Frank G. D’Orsi, CSP, ARM, Chair
Using FEMA’s STAPLEE process to
drive critical thinking in OSH 67 Continuing Education Frank J. Bruzzese, CSP, CIH, CPCU
May, June and July events
26 PSJ Asks Salvatore Caccavale, CHMM, CPEA
Q&A with Jim Ramsay on the Council 70 Vantage Point
on Academic Affairs and Research What safety can teach us about David A. Dodge, P.E., CSP
unconscious bias
27 Best Practices Cari M. Elofson, CHST
Understanding the contractor 72 By the Way
management paradox A case of mistaken identity E. Andrew Kapp, Ph.D., CSP, CHMM

Professional Safety copyright Professional Safety is available Steve Minshall, CSP, CIH
©2019 by American Society of free online to ASSP members at
Safety Professionals. All rights www.assp.org/publications/ Justin J. Molocznik, CSP, CHST
reserved. No copyright is claimed in professional-safety. Articles are
any works of the U.S. government also available via microform SOCIETY OFFICERS
that may be published herein. and/or electronic databases Rixio E. Medina, CSP, CPP
For information on reprinting or from ProQuest, P.O. Box 1346, President
reproducing articles published in Ann Arbor, MI 48106-1346 USA;
Professional Safety, visit www.assp phone +1 (800) 521-0600. For Diana M. Stegall, CSP, CFPS,
.org/publications/professional-safety. specific format details, visit www.proquest ARM, SMS, CPCU
.com. President-Elect
PSJ (ISSN 0099 0027) is published
monthly by the American Society of Safety POSTMASTER: Send address changes Deborah R. Roy, M.P.H., R.N.,
Professionals, 520 N. Northwest Highway, to Change of Address Dept., ASSP, 520 N. CSP, COHN-S, CET, FAAOHN
Park Ridge, IL 60068-2538 USA; phone (847) Northwest Highway, Park Ridge, IL 60068- Senior Vice President
699-2929; [email protected]. 2538 USA.
Periodicals postage paid at Park Ridge, IL, Christine M. Sullivan, CSP, ARM
and at additional mailing offices. Vice President, Finance

Todd William Loushine, Ph.D.,
P.E., CSP, CIH
Vice President,
Professional Development

Jennifer M. McNelly
Chief Executive Officer

ADVERTISING REPRESENTATIVE
Michael Sanders
(847) 232-2038;
[email protected]

4 PSJ PROFESSIONAL SAFETY MAY 2019 assp.org



PRESIDENT’S MESSAGE

CREATING A DIVERSE & INCLUSIVE SOCIETY

Rixio Medina The Board of Directors has been For ASSP to live this value statement, we
talking a lot lately about diversity must strive to maintain a multidimensional,
Connect With Rixio and inclusion, particularly in our dis- diversified staff and membership that is
cussions about Society elections, our pro- reflective of the entire profession. We must
Join Rixio on LinkedIn, follow fession’s talent pipeline and the Society’s also encourage staff and volunteers to adopt
him on Twitter or comment on volunteer leader development. Our desire an inclusive language and presentation style
his message at www.assp.org/ to be more inclusive was also a key factor that positively reflects and supports the cul-
news/presidents-message. in the decision to change our Society’s tural diversity the Society strives to develop
name last year. and maintain. In addition, we need to make
ASSP is sure our programs accommodate members
committed to Diversity and inclusion are top-of-mind with physical challenges. And, we need to
principles of topics in many of our organizations as well. ensure that we are providing education that
fairness and That is likely because more companies are is culturally, socially and gender inclusive in
respect for all. recognizing the strategic value of having a our publications and courses.
Our goal is to diverse workforce and providing an inclu-
encourage free and sive workplace. In fact, a growing body of In addition, each of us can work to better
open exchange research indicates that companies with a understand the role that unconscious bias of-
of ideas that diverse workforce are more profitable and ten plays in how we interact in the world. We
will advance the more innovative. These companies also all can take steps to acknowledge and stop
Society and our tend to embrace and incorporate differenc- acting on stereotypes that we have assigned
es rather than try to mitigate them. to groups of people based on personal tradi-
profession. tions, values and cultural experiences.
Having a diverse workforce also can help
organizations identify and address more The current makeup of the Board of Di-
safety risks, which can lead to greater buy- rectors reflects progress in this area. I am a
in around safety initiatives. And, because Hispanic immigrant and we have five women
today’s workplaces have such a wide variety board members, two of whom are our next two
of workers, it follows that having more presidents. But our board changes each year
diversity within our profession would in- and we must remain committed to achieving
crease the impact of our safety messages. diversity within our leadership pipeline.

Organizational leaders play a key role Each of you can help us deliver on this
in creating a diverse, inclusive culture. commitment. Here are three quick ideas:
Through their influence, they can help iden-
tify and remove systemic and cultural bar- 1) Encourage diverse members in your
riers that prevent individuals, particularly professional network to consider a leader-
marginalized groups, from succeeding. That ship position with the Society. Share this
is why increasing diversity within an orga- link (https://assp.us/volunteer) with them
nization’s leadership team is so important. so they can learn more about the roles
When this team reflects the makeup of the available and the benefits we all will receive
organization’s workforce, it is more likely to through their active involvement.
recognize and address the many challenges
facing its various populations. 2) If you have served in a volunteer role,
consider mentoring potential leaders. Your
We all recognize the importance of bring- coaching and insight will help them navigate
ing more diverse voices into our profession. their volunteer path and encourage them to
We also know that we must provide an in- remain actively involved.
clusive environment that encourages more
members to engage as volunteer leaders. A 3) Encourage your colleagues to explore
diverse group of leaders will enable ASSP to the value they may receive from joining one
best represent its global membership and be of our common interest groups: Blacks in
the best possible advocate for the OSH pro- Safety Excellence, Emerging Professionals
fession and OSH professionals. in OSH, Hispanic Safety Professionals and
Women in Safety Excellence.
This value statement from the Society’s
operating guidelines directs our efforts in ASSP is committed to principles of
this area: “We will encourage the ongoing fairness and respect for all. Our goal is to
equal opportunity for participation of all encourage the free and open exchange of
within the Society without regard to race, ideas that will advance the Society and our
ethnicity, religion, personal beliefs, age, gen- profession. PSJ
der, sexual orientation, nationality or phys-
ical challenges. We will also foster a Society Rixio Medina, CSP, CPP
culture that values and responds to the rich
diversity of its staff and members.”

6 PSJ PROFESSIONAL SAFETY MAY 2019 assp.org

Join the National Safety Stand-Down.
Stop falls and save lives.
May 6 - 10, 2019

Falls from elevation are a leading cause of death in
construction. Using ANSI/ASSP Z359 fall protection and
fall restraint standards, safety professionals can identify
risks, prevent injuries and create a comprehensive
program to keep worker’s safe.

Learn more at assp.us/safetystandards

ASSP CONNECTION
ASSP’s 2019-20 BOARD OF DIRECTORS

Diana Stegall Deborah Roy Bradley Giles Christine Sullivan Jennifer McNelly
President President-Elect Senior Vice President Vice President, Finance Chief Executive Officer

Joel Haight Carl Heinlein Thomas Kramer Pamela Walaski Anil Mathur
Director-At-Large Director-At-Large Director-At-Large Director-At-Large Public Director

2019 Society Elections Complete, Terms Begin July 1

Election results were announced by James D. Smith, M.S., vice president. This office will lead to the office of president in
CSP, ASSP’s Nominations and Elections Committee Chair. Smith 2021-22. Members also elected Thomas E. Kramer, P.E., CSP,
reported that 5,035 ballots were received for a return rate of 13%. as director-at-large.

Board of Directors The officers will join current Vice President, Finance
Per ASSP Bylaws, President-Elect Diana Stegall, CSP, Christine M. Sullivan, CSP, ARM, and Directors-At-Large
Joel Haight, Ph.D., P.E., CSP, CIH, Carl W. Heinlein, CSP,
CFPS, ARM, SMS, CPCU, will succeed to the office of pres- OHST, STS-C, ARM, and Pamela Walaski, CSP, CHMM,
ident. Senior Vice President Deborah R. Roy, M.P.H., R.N., Public Director Anil Mathur, and the Society’s CEO Jennifer
CSP, COHN-S, CET, FAAOHN, will succeed to the office of McNelly on the 2019-20 board. The board will be sworn in
president-elect. She will become ASSP president in 2020-21. June 9, 2019, in New Orleans, LA, during the annual House of
Bradley Giles, P.E., CSP, STS, GIOSH, was elected senior Delegates meeting. Their terms begin July 1, 2019.

Council Vice Presidents
At the Society level, ASSP members

elected Michael Behm, Ph.D., CSP,
as vice president, academic affairs and
research, C. Gary Lopez, M.S., CSP,
as vice president, professional affairs,
and Steven B. Gray, CSP, CHST, as
vice president, region affairs.

Michael Behm Gary Lopez Steven Gray

8 PSJ PROFESSIONAL SAFETY MAY 2019 assp.org

Region Vice Presidents James Boretti Jim Rainwater Eric Hallerud Chet Brandon Ajay Sachdeva
In addition, members in

five of ASSP’s nine regions
voted for their respective vice
presidents.

Region I: James Boretti,
CSP.

Region III: Jim Rainwater,
M.S., CSP.

Region V: Eric W. Hallerud,
CSP.

Region VII: Chet Brandon,
CSP, CHMM.

Region IX: Ajay Sachdeva,
CPEA, AcSAP.

Alexis Jeffrey Steven Daniel Practice Specialty & Common Interest Group Election Results
Westin Citrone Guillory Rollino Five practice specialties elected assistant administrators.
Consultants Practice Specialty: Alexis Westin, CSP, ASP, OHST, WCP.
Oil, Gas, Mining and Mineral Resources Practice Specialty: Jeffrey M.

Citrone, CSP, CIH.
Public Sector Practice Specialty: Steven T. Guillory Jr., M.S., CSP, IP-

MA-SCP, CPM.
Risk Management/Insurance Practice Specialty: Daniel Rollino, CSP,

ARM.
Utilities Practice Specialty: Jeremy Presnal, CSP, OHST, CHST, CESCP.

One common interest group elected new leaders.
Emerging Professionals in OSH Administrator: Alyssa Weber, CSP.
Emerging Professionals in OSH Assistant Administrator: Rick Sanders,
M.S., CSP.

Jeremy Alyssa Rick
Presnal Weber Sanders

Jennifer Nathan Brandon Alex Area Directors
Harris Spencer Smith Scott Area directors were elected in regions I, II, IV, VI and VIII.
Region I, Area 2: Jennifer Harris, CSP.
Matthew Patrick Region II, Area B: Nathan H. Spencer, CSP, CIH.
Wilcox Karol Region IV, Louisiana Area: Brandon M. Smith, CSP.
Region IV, South Florida Area: C. Alex Scott, CSP, ARM-P.
Region VI, Southern Area: Matthew Wilcox, CSP.
Region VIII, Keystone Area: Patrick J. Karol, CSP, ARM, CMS.

Congratulations to ASSP’s most
recently elected leaders. We thank the
candidates who participated and members who
voted. This important election process gives all
involved the opportunity to influence the

Society’s direction and the safety
profession’s future.

assp.org MAY 2019 PROFESSIONAL SAFETY PSJ 9

ASSP CONNECTION

WOMEN & SAFETY REPORT
Offers Solutions to Make Workplaces Safer

ASSP has published a report on women and safety in the As the impetus behind the
modern workplace, a follow-up to our Women’s Workplace report, the Women’s Work-
Safety Summit held last fall. The report focuses on three main place Safety Summit involved
challenges faced by women in the workplace and offers potential more than 50 diverse safety
solutions. This report is one outcome of the Society’s ongoing ini- experts from businesses,
tiative to improve diversity and inclusion throughout the safety nonprofits, labor, academia,
industry while ultimately better protecting workers everywhere. government and professional
associations. The objective was
Helping women advance into leadership positions in the OSH to stimulate change and help solve longstanding issues experi-
profession, increasing the availability of PPE for women, and re- enced by women in the workforce.
ducing violence against women at work are the targets of “Wom-
en and Safety in the Modern Workplace: Creating a Diverse and ASSP’s Women in Safety Excellence (WISE) Common
Inclusive Workplace Can Boost Safety, Productivity and Prof- Interest Group helped drive the summit and the production
itability.” Sponsored by Amazon, the report is accompanied by of the report. A leading member community within ASSP
three videos that discuss the obstacles women face on the job. promoting equity and advancement of women in the safety
profession, WISE is committed to influencing industry and
“Women make up nearly half of the global workforce and identifying solutions to safety and health challenges that im-
experience occupational risks differently than men,” says ASSP pact women worldwide.
President-Elect Diana Stegall, CSP, CFPS, ARM, SMS, CPCU.
“But safety interventions often take a one-size-fits-all approach. Read the report and watch the videos at www.assp.org/
This report advocates for gender-specific solutions.” womensreport.

ASSP & KOSHA Collaborate

ASSP and the Korea Occupational Both organizations understand great progress on important issues
affecting workers’ well-being.”
Safety and Health Agency (KO- the importance of research and
According to the MOU, the
SHA) have formalized a memo- shared knowledge in developing collaboration between the two
organizations may consist of the
randum of understanding (MOU) and applying preventive measures transfer and implementation of
research results; development
that outlines how the organiza- and best practices in OSH. and dissemination of workplace
safety information at conferences;
tions will collaborate to advance “We have a common mission to sharing staff training techniques;
exploring scientific activities of a
workplace safety and health over prevent or reduce workplace inju- common interest; and other coop-
erative ventures that aim to ad-
the next 5 years. ASSP President ries, illnesses and fatalities, so we vance OSH outcomes worldwide.

Rixio E. Medina, CSP, CPP, and want to benefit from each other’s

KOSHA President Dooyong Park experience and combine resources

signed the agreement at the where possible to improve occu-

recent global workplace safety pational safety and health perfor-

and health sustainability event in mance,” Medina said. “Joint efforts

Paris, France. can go a long way in achieving

ASSP Director-At-Large Joel Haight ASSP Emerging OSH Pros Learn About the
(left), joins ASSP President Rixio Featured on Podcast Z15.1 Fleet/Motor
Medina as he signs the KOSHA mem- Vehicles Standard
orandum of understanding in Paris. Three members of ASSP’s Emerging Profession-
als in OSH Common Interest Group were recently Motor vehicle crashes are the leading
Encouraging featured on The Accidental Safety Pro safety podcast cause of work-related deaths in the U.S.
diversity of series from Vivid Learning Systems. The three share Addressing this hazard requires a struc-
thought. their stories about the various paths that led them to tured, proactive approach to identify
the safety profession. They discuss the value of be- system gaps and implement industry
longing to a professional organization, mentorship, best practices. The ANSI/ASSP Z15.1-
community and engagement, as well as share stories 2017, Safe Practices for Motor Vehicle
from the field. Operations, standard can guide an or-
ganization’s efforts to develop policies,
Hosted by Jill James, the company’s chief safety procedures and management processes
officer, the series serves the OSH community through to control risks associated with the oper-
storytelling and consists of guest interviews with ation of motor vehicles.
OSH leaders across the country. According to James,
the title reflects a common theme for safety profes- Download a brochure on Z15.1 to learn
sionals, who often end up working in the safety field more about the standard at http://bit.ly/
unexpectedly, which was James’s own experience. 2W0Dmcu.

Listen to the episode at http://bit.ly/2UMGe0e.

10 PSJ PROFESSIONAL SAFETY MAY 2019 assp.org

SAFETY MATTERS

ASSP Update GETTY_DUMY67/ISTOCK/GETTY IMAGES PLUS NIOSH Video Aims to
Protect Emergency Responders
INSTALLATION OF Against Exposure to Drugs
DRILLED SHAFTS
NIOSH has released a video, Illicit Drugs, Including Fentanyl:
ANSI Approves Preventing Occupational Exposure to Emergency Responders, to
A10.23 Standard help emergency responders understand the hazards of exposure
to illicit drugs and the steps they can take to protect them-
The A10.23-2019 Safety selves. Emergency responders such as law enforcement officers,
Requirements for the Installa- firefighters and emergency medical service workers are often
tion of Drilled Shafts standard exposed to illicit drugs through inhalation, ingestion, dermal
has received ANSI approval. and needle exposure, and mucous membrane contact through
A revision of ANSI/ASSP the eyes, nose and mouth. These exposures can result in light-
A10.23-2014, the standard headedness, drowsiness, nausea and vomiting, dizziness, rapid
provides guidance for pro- onset of respiratory depression, and slow and shallow breath-
tecting workers from hazards ing, often requiring medical attention and preventing emergen-
associated with the installation cy responders from performing their duties.
of drilled shafts. It applies to
employment and places of Created in collaboration with the Fredericksburg, VA,
employment where workers police and fire departments, and the Federal Bureau of Inves-
are exposed to hazards associ- tigation Laboratory, the video shows real police officer body
ated with the construction of camera footage of a response to an overdose call and inter-
drilled shafts for foundations views with officers to provide information and reinforce the
and earth retention elements. importance of following safe work practices to protect first
It does not apply to driven responders. The video describes what exposures contribute
biles, which is covered by negatively to health effects, what practices can set officers up
A10.19, or to caissons, which is for success, and provides additional lessons and takeaways.
covered by A10.16.
“This video was developed to educate first responders using a
real-life example that should resonate with many emergency re-
sponders and gives recommendations for minimal, moderate and
high-exposure situations,” says NIOSH’s Jennifer Hornsby-Myers.

Watch the video at www.cdc.gov/niosh/docs/video/2019-126.

Study Finds Motor Vehicle Towing Industry

Injury & Fatality Rate Higher Than Other Emergency Responders

A NIOSH study has found a high rate ees, which is more than double the rate During the same period, 191 deaths

of work-related injury and death in the of 98 per 10,000 full-time employees for occurred in the motor vehicle towing

motor vehicle towing industry. Work- all U.S. private industries. The leading industry. According to research-

ers in this field may assist individuals causes of injury was contact with objects ers, this translates to 43 deaths per

in emergency situations that present and equipment, overexertion and bodily 100,000 workers, which is more than

risks to the worker, such as traffic in- reaction from bending, kneeling, crawl- 15 times the rate of 2.8 workers per

cidents requiring work on the side of ing or reaching. Most injuries involved 100,000 workers for all U.S. private

highways or busy roads. Historically, sprains, strains and tears. industries. The leading cause of death

studies have focused on the was motor vehicle incidents

safety of other types of first (commonly involving work-

responders, such as fire- ers on the side of the road

fighters, police or emergency being struck by passing

medical personnel; NIOSH vehicles) and contact with

investigators aimed to ad- objects and equipment.

dress this research gap using NIOSH investigators

data from Bureau of Labor note that nonfatal injuries

Statistics’ Survey of Occupa- and deaths in the motor ve-

tional Injuries and Illnesses, hicle towing industry have

and Census of Fatal Occupa- been largely overlooked.

tional Injuries. SHAUNL/E+/GETTY IMAGES They say the findings from

From 2011 through 2016, this study underscore the

6,400 nonfatal injuries and ill- need for additional re-

nesses occurred in the motor search and tailored preven-

vehicle towing industry. The tion efforts.

rate for this industry was 204 Read more at https://bit.ly/

per 10,000 full-time employ- 2VmaQ8j.

assp.org MAY 2019 PROFESSIONAL SAFETY PSJ 11

SAFETY MATTERS

ASSP Update

EU-OSHA Report Putting People Into Sustainability
Highlights
Technology to The Center for Safety and Health shareholders on nonfinancial metrics, in-
Help Identify Health
Problems at Work Sustainability (CSHS) recently held a cluding the safety, health and well-being

European Agency for Safety and global summit to gather world-leading of their employees. There are often dis-
Health at Work (EU-OSHA) has pub-
lished an observatory report about organizations and experts in the fields crepancies between the safety standards
the early detection of new risks and
work-related diseases. The report de- of human capital, sustainability and of a business’s staff and its supply chain
fines alert and sentinel systems as an
umbrella term for timely surveillance OSH to sign a commitment to position contractors.
systems that collect information on
diseases to initiate health interven- the safety, health and well-being of peo- CSHS and delegates signed a commit-
tions and prevention.
ple at the center of the sustainable busi- ment to “put people back into sustain-
The report discusses how this technol-
ogy operates to identify emerging health ness agenda. Attendees were told the ability.” CSHS Chair Kathy A. Seabrook,
problems at work, detect new combi-
nations of health problems, identify investment community is increasingly CSP, CFIOSH, EurOSHM, said, “This
exposure and work settings at an early
stage to prevent work-related health requiring companies to demonstrate in commitment is a call to action that safe-
problems, and support evidence-based
policy making. Often, these systems are reports that the safe, sustainable man- ty and health is integral to sustainable
made up of sensors that capture events
or changes in the environment; event agement of their staff and contractors is business performance. And this means
detection equipment; tools to aid the de-
cision-making process after detecting an a core strategic goal. businesses must measure, evaluate and
event or signal; and subsystem tools to
generate messages for stakeholders de- Held in Paris at L’Oreal’s Aulnay publicly report their performance on
rived from a detection system. These all
work together to forecast and identify Campus, “Human Capital Project Glob- safety and health.”
adverse health effects and provide time
for response to minimize the impact of al Summit: Putting People Back Into The summit was the fourth in a series
potential health threats.
Sustainability,” hosted companies such of CSHS workshops aimed at highlight-
Researchers identified 75 surveillance
systems used in 26 countries, then pro- as Google, Nike, L’Oreal, BNP Pari- ing the role OSH plays in sustainability
vided in-depth analyses on 12 of them
to show the different approaches that bas, Hermes and AP Moller-Maersk. and the management of human capital.
can be used. In each analysis, the re-
searchers evaluate the system’s aim and Approximately 80 delegates heard that The Institution of Occupational Safety
objectives, reporting parties, workflow,
work-relatedness, communication, data many companies are not treating the and Health, a CSHS cofounder, helped
storage and usage, and financial aspects.
sustainable management of their people organize the event.
“Work-related ill-health and injury
are costing the EU 3.3% of its GDP,” as a priority. Too few are reporting to Learn more at www.centershs.org.
says EU-OSHA Director Christa Sed-
latschek. “That’s €476 billion every Report Ranks Most Dangerous FUZZNAILS/ISTOCK/GETTY IMAGES PLUS
year that could be saved with the right States, Cities for Pedestrians
occupational safety and health systems,
policies and practices. We hope that Smart Growth America has published its report,
EU-OSHA’s project will serve as an Dangerous by Design 2019, which documents a
inspiration to implement alert and sen- steady increase in pedestrian fatalities over the
tinel systems in those countries where past decade in the U.S. According to the report,
they do not already exist.” pedestrian fatalities have increased 35% in the past
decade, while walking has seen only a marginal in-
Download the report at https://bit crease and driving has increased about 8% over the
.ly/2UIZDeP. same period.

The report ranks states and metropolitan areas
based on the number of people struck and killed
by drivers while walking, accounting for the pop-
ulation of the state or metro area and the percent-
age of people who walk to work. According to the
report, states and metropolitan areas across the
southern continental U.S., older adults, people
of color and pedestrians in low-income commu-
nities experience the most danger. The report is
based on data from the Fatality Analysis Reporting System and includes traffic
deaths that occurred between 2008 and 2017.

The report calls for a strong federal policy that requires state DOTs to consistently
plan for even the most vulnerable pedestrians. It also identifies the need for perfor-
mance measures to ensure that states make progress toward safer streets and are
held accountable for reducing serious injuries and fatalities. The report also calls for
high-quality data on street conditions where fatalities occur.

It also identifies the need to prioritize safety over vehicle movement, and to
change the language used to discuss preventable deaths. “Stop referring to pedes-
trian fatalities as unavoidable ‘accidents,’” the report says. “City and state leaders
should set an example by replacing the word accident with crash when discussing
these preventable deaths.”

Download the report at https://smartgrowthamerica.org/dangerous-by-design.

12 PSJ PROFESSIONAL SAFETY MAY 2019 assp.org

NIOSH Develops Tool to SMRT CORPORATION LTD.Singapore Company Wins
Identify Mold In Buildings Prize for Laser Track Trolley

NIOSH recently developed the Dampness and Mold A Singapore rail operator,
Assessment Tool, one for schools and one for general SMRT Trains, won first prize
buildings, to help employers identify and assess areas for its laser track trolley, a
of dampness and potential mold. According to the device that has reduced the
agency, dampness and mold in buildings are associated risk of musculoskeletal disor-
with health problems such as respiratory symptoms, ders, and slips, trips and falls
development or worsening of asthma, and bronchitis. for workers. The award was
presented at Institution of Oc-
The tool guides users through assessing buildings cupational Safety and Health’s
for areas of dampness or mold and identifying the annual International Rail
possible sources. It includes an easy-to-use checklist Awards in Manchester, U.K.
and instructions for assessing and recording damage
and tracking conditions over time. It also includes The trolley is used to mon-
photos of mold and dampness to help inspectors itor tracks for wear and tear,
identify and determine scoring for the areas. and can be transported by two
people with minimal effort. By
“Implementing regular visual inspections for damp- reducing the number of working hours required to conduct track testing, the
ness can help to identify trouble areas before they trolley helps reduce the risk of musculoskeletal disorders in workers. Based
become major problems and help to prioritize mainte- on the company’s assessments, the trolley can test a 5-km stretch of track in
nance and repair,” says director of NIOSH’s Respiratory one operation, which is five times more than was previously possible when
workers alone had to test the tracks. SMRT Trains has also stated that the
Health Division Da- laser track trolley has significantly reduced the possibility of disruptions for
vid Weissman. “The trains and derailments.
Dampness and Mold
Assessment Tools “We are delighted to win the award. By acquiring the trolley, we took
provide an inexpen- away the manual pushing required to do track maintenance, and the as-
sive mechanism to sociated risks this brought,” says Jean-Francois Chassin, vice president of
investigate, record SMRT. “We used to have to ask our patrols to go on the tracks and do the
and compare condi- measuring, which was tough considering temperatures were over 30 °C
tions over time.” (86 °F) and humidity was 98%, and the average age of workers is 48. The
process is much more streamlined now. It has helped make us more effi-
Access the tools cient as we can better plan resources and our budget.”
at https://bit.ly/1w
2mtuy. Read the press release at https://bit.ly/2IzHYU8.

assp.org MAY 2019 PROFESSIONAL SAFETY PSJ 13

SAFETY MATTERS

Amazon Implements Tech Vest to AMAZON NIOSH, Coast Guard
Promote Worker-Robot Safety Partner to Safeguard
Fishing & Maritime Workers
Amazon recently implemented a new
device that helps robots recognize human According to NIOSH, commercial fishing is one
presence in its facilities to avoid collisions. of the most hazardous occupations in the U.S. with
Dubbed the Robotic Tech Vest, this device is a fatality rate 29 times higher than the national
designed to fit like a belt with suspenders to average. To help address this issue, the agency has
avoid bulkiness. The vest is made for workers partnered with U.S. Coast Guard to make $6 million
who primarily need to enter work areas to in grant funding available for commercial fishing
repair robots or perform other duties. safety research and training.

The vest is equipped with obstacle Administered by NIOSH, these grants will pro-
avoidance systems and beacons that notify vide up to 75% of an organization’s costs to complete
facility robot systems of a human presence. a safety research program. The grants will range
In response, the robot slows down to avoid from $250,000 to $650,000 over a 2-year funding
colliding with humans. period, and will be awarded to individuals in ac-
ademia, businesses, nonprofit organizations and
“All of our robotic systems employ mul- municipalities that are involved in the fishing and
tiple safety systems ranging from training maritime industries.
materials to physical barriers to entry to pro-
cess controls to on-board,” says Amazon Robotics Vice President Brad Porter. “These grant programs will help further edu-
“In the past, associates would mark out the grid of cells where they would be cation and awareness throughout the commercial
working in order to enable the robotic traffic planner to smartly route around fishing fleet, as well as provide research into better
that region. What vest allows the robots to do is detect the human from farther equipment and operational processes,” says Coast
away and smartly update its travel plan to steer clear without the need for the Guard’s Joseph Myers. “Enhanced education, equip-
associate to explicitly mark out those zones.” ment and processes go hand-in-hand with the Coast
Guard’s longstanding premise that being properly
The technology is currently available in more than 25 Amazon sites and prepared increases survivability and prevents loss of
tests have proven successful with more than one million unique activa- life at sea.”
tions, according to Porter.
Read the press release at www.cdc.gov/niosh/up
For more information, visit www.amazonrobotics.com. dates/upd-01-02-19.html.

SAFETY 2020

Promote your Present at SAFETY 2020
expertise, June 22-25, Orlando, FL.
leadership and
commitment to For more information
the profession. visit www.assp.org/call-for-presenters.

Proposals are due July 17, 2019.

14 PSJ PROFESSIONAL SAFETY MAY 2019 assp.org

GAWRILOFF/ISTOCK/GETTY IMAGES PLUS AIHA White Paper Warns of
Potential Hazards of Vaping

AIHA has issued a white paper that reviews current scientific
data and evaluates the effects of chemicals used in e-cigarettes
as well as those emitted by them during use. The paper presents
evidence that the devices can release airborne contaminants
that may affect not only users and those around them as well.

“Scientific evidence is growing that supports the concern
that emissions from e-cigarettes contain potentially hazardous
chemicals that can impact both the user and bystanders,” says
Cheri Marcham, lead researcher of the white paper, who also
coauthored “E-Cigarettes: A Hazy Hazard,” published in the
June 2017 issue of Professional Safety. “It’s important that users
and the public are aware that the emissions from these devices
are not just water vapor, but instead contain a myriad of poten-
tially harmful chemicals.”

While e-cigarettes have been marketed as a beneficial smok-
ing cessation tool, according to AIHA, research shows that vap-
ing solutions and their emissions contain potentially hazardous
chemicals, including aerosolized flavorings such as diacetyl,
propylene glycol, nicotine and formaldehyde.

To help protect the public and to better understand the po-
tential safety and health risks associated with vaping, AIHA
recommends the following:

•E-cigarettes should be considered a source of aerosols, vola-
tile organic compounds and particulates in the indoor environ-
ment that have not been thoroughly characterized or evaluated
for health risk or safety.

•Additional research should be conducted on the health ef-
fects from inhaling e-cigarette flavorings and other ingredients;
the effects of secondhand emissions, thirdhand exposure and
nicotine addiction; and the life cycle and end-of-use issues as-
sociated with e-cigarette manufacturing, use and disposal.

•The health risks and economic consequences of accidental
exposure for children, adults and pets should be addressed,
including proper labeling and child-resistant packaging re-
quirements.

•Because e-cigarettes are a potential source of pollutants, it is
prudent to manage and control vaping in indoor environments
consistent with current smoking policies until and unless re-
search shows that these devices will not significantly increase
the risk of adverse health effects to occupants.

Access the white paper at https://bit.ly/2DroRY6.

assp.org MAY 2019 PROFESSIONAL SAFETY PSJ 15

SAFETY MATTERS Remote Office Workers
Lack Workstation Support,
NSW Study Finds High Numbers According to Survey
of Work-Related Spinal Injuries
A survey of 897 U.K. remote office workers found that 37%
A study investigated 824 say they have experienced new back pain since beginning
cases of people admitted to to work regularly from home. Health insurer Birmingham
New South Wales (NSW) Hospital Saturday Fund (BHSF) surveyed individuals who
hospitals over 3 years with work from home at least 2 days a week. The survey found that
work-related spinal injuries. only one in five workers received a workstation assessment
The goal of the study was in person; the remainder reported receiving no help or guid-
to describe epidemiological ance from their employer on how to set up their workstations
characteristics, the occupa- correctly. Older workers were less likely to have received an
tional context and the cost assessment with only 26% of those over age 50 receiving assis-
of hospitalized work-related tance from their employer.
traumatic spinal injuries
across the NSW area. Along with a lack of workstation setup support, many work-
ers admitted to not working at a desk environment. Alternative
The study revealed that seating locations may not offer the same support as a tradition-
50% of work-related spinal al desk and can result in musculoskeletal strain. The survey
injuries observed occurred found that 30% of women and 43% of men did not have a ded-
in the construction industry icated office in their homes. Of those surveyed, 27% said they
and 31% in the transpor- worked at tables rather than desks, 11% worked from their sofas
tation industry. Of those and 3% admitted working from their beds.
injuries in the construction
industry, 78% of spinal in- Stressing the importance of employers extending ergonomic
juries were due to falls, predominantly falls from heights office setups to remote office workers, BHSF’s Philip McCrea
such as structures, ladders or scaffolding. In addition, nearly says, “As more employers embrace the benefits of flexible
one-quarter of spinal injuries observed in the transportation working practices, they need to think about how they can help
industry were the result of heavy vehicle crashes. prevent an even sharper rise in musculoskeletal issues, which
could lead to an increasing level of sickness absence.”
“Work-related traumatic spinal injuries represent a sig-
nificant burden of cost and disability to the Australian Read more at https://bit.ly/2USCcDt.
workforce, but they are preventable,” says University of DRAZEN LOVRIC/E+/GETTY IMAGES
Sydney School of Medicine’s Lisa Sharwood, lead author VGAJIC/E+/GETTY IMAGES
of the study. “There is an urgent need for more effective
policies, risk management strategies and countermeasures
for prevention.” She also explains that work-related spi-
nal trauma, especially those related to falls, continue to
be prevalent despite safety measures being in place. The
study’s authors conclude that additional research is re-
quired to better understand the factors that contribute to
spinal injuries in the workplace.

Read the study at www.mdpi.com/1660-4601/15/10/2121/htm.

Program Helps Workers Stay Safe When Traveling for Work

Motor vehicle incidents are the cause describes eight steps OSH professionals “The goal was to take these somewhat

of almost 40% of workplace traumatic or managers can take to create a traffic complex, specialized safety and health

fatalities in Canada and have remained so safety program, including making a processes and break them down into ac-

from 1994 to 2018, according to Ontario business case, identifying a company’s cessible steps employers can apply direct-

Workplace Safety and Insurance Board. traffic hazards, performing a risk assess- ly to their workplaces,” says SHERM’s

Employees may travel for work if driving ment and getting buy-in from employ- Stephanie Kibbee. “The hope is that our

company vehicles, riding bikes or walking ees and management. The training book guidebook, when combined with the

to complete work-related tasks. A new also includes interviews with leaders of employee training, will provide a solid

program, En Route to Safety, helps com- companies that have integrated their foundation for Ontario business owners

panies create traffic safety programs for own transportation training, checklists to really give traffic safety the attention it

their workplaces to help employees reduce for implementation, risk assessment deserves in the workplace.”

vehicle incidents, injuries and fatalities. tools and incident review committee According to the website, although the

The program was created by Wilfrid best practices. The employee training modules reference Ontario, they are ap-

Laurier University’s Safety, Health, guidebook and online modules are plicable to any worker or drive, walk and

Environment and Risk Management available free online. Also available is a cycle at work.

(SHERM) department in Waterloo, On- module highlighting driving, cycling, Read the guidebook at www.enrouteto

tario. An 84-page training document and walking risks and best practices. safety.ca/guidebook.

16 PSJ PROFESSIONAL SAFETY MAY 2019 assp.org

NIOSH Report Highlights Firefighter Risks

NIOSH has published a report that •using thermal imaging to locate fires AIHA Issues
Public Policy Agenda
summarizes findings from the agency’s burning below or between floor systems;
AIHA has released its first-ever public
firefighter fatality investigations. The •securing an uninterrupted water sup- policy agenda, covering 2019 through
2020, to focus attention on the most im-
report, “Workplace Solutions: Preventing ply for fire extinguishment; portant worker safety and health issues
in the U.S. The agenda identifies 15 criti-
Deaths and Injuries of Firefighters Work- •immediately evacuating a struc- cal issues facing American workers:

ing at Basement and Other Below-Grade ture if the f loor above it has been •big data;
•cannabis industry safety and health;
Fire,” highlights the risks firefighters face weakened. •disaster planning, response and re-
covery;
when fighting basement and below-grade The document highlights post-incident •hazard banding and occupational
exposure limits;
fires, such as risks due to limited entry controls as well as training materials and •hearing protection;
•opioids in the workplace;
and egress, working above the fire, weak- additional sources of information. View •professional title protection;
•sensors;
ened floor structure, unknown fire load, the report at https://bit.ly/2VVoMTS. •teen workplace safety and health;
•temporary and contract workers;
ventilation problems and being caught in •total worker exposure;
•transportation safety;
the fire’s flow path. •worker fatigue;
•workforce development;
NIOSH also provides control recom- •workplace violence.
“Addressing a problem of this scale
mendations for fire departments when calls for bold actions that are driven by
scientific knowledge,” says AIHA Presi-
they are dealing with basement or be- dent Cynthia Ostrowski.
Learn more at www.aiha.org.
low-grade fires. Preincident recommen-

dations include:

•developing and enforcing standard

operating procedures for safely attacking

fires in these situations;

•ensuring that a safety officer trained PRATHAAN/ISTOCK/GETTY IMAGES PLUS

to recognize hazards is present/assigned;

•ensuring that an incident manage-

ment system and a personnel account-

ability system are in place and used at all

incidents. In addition, everyone involved

in firefighting operations must wear full

PPE and have a portable radio.

The document also recommends con-

trols to use during the incident, such as:

NEW FROM ASSP

FRED MANUELE ON

SAFETY MANAGEMENT

By Fred A. Manuele

Fred Manuele is a respected thought leader in
safety whose many works have influenced the
safety profession and inspired some of the profes-
sion’s most prominent authors, leaders, speakers
and educators. To highlight the significance of his
work, this book presents a collection of his contri-
butions to the profession that have appeared in
Professional Safety over the years.

Topics include: Addressing serious injuries and
fatalities; risk assessments; prevention through de-

sign; acceptable risk; and oc-
cupational safety and health
management systems.

Visit www.assp.org or call
(847) 699-2929 to order

List Price: $39.95
Member Price: $31.95
Hardcover, 332 pp, ©2018
Product number: 4460
ISBN 978-0-939874-21-7
e-book also available

assp.org MAY 2019 PROFESSIONAL SAFETY PSJ 17

PSJ ASKS

DIANA STEGALL

2018-19 ASSP President-Elect

Like many in the OSH profession, President-Elect Diana Stegall, CSP, CFPS, ARM, SMS, CPCU,
had not heard about safety as a career option while growing up. Yet, while she may not
have realized it at the time, Stegall was already assessing risk in childhood.

Diana Stegall “Growing up, my older brother and sister, and raphy, Stegall suggested the chapter include officer
other kids in the neighborhood would jump off a photos. “That was my first volunteer role, and I did
Diana Stegall, CSP, 6-ft retaining wall, or jump out of a treehouse,” she kind of raise my hand,” she recalls. Not long after,
CFPS, ARM, SMS, CPCU, says, recalling her youth. “I was thinking ‘yeah, she became the chapter’s president-elect, which led
has been a member of that’s fun, but you could break a bone.’ And that to attending her first Leadership Conference about 7
ASSP since 1990. She didn’t sound like a whole lot of fun.” years after first joining the Society.
has served as chair of
the Professional De- In college as a chemistry major, she began to learn “I was blown away. It was my first time being
velopment Conference about protective gear, the dangers associated with around 100 other safety professionals who were also
Planning Committee, lab activities and materials students worked with, passionate about what they did,” she says. Stegall was
and the Council on and how to read MSDS. But it was not until she impressed by the breadth of the Society’s impact and
Member and Region graduated and interviewed for a trainee position at how her work as a volunteer could help. “I really start-
Affairs Education and the United States Fidelity and Guarantee Co. (US- ed to see the ability to make a difference—not just
Training Committee, F&G) in the company’s Insurance Engineering and within my chapter, not just within the employers that
and as a member of Audit Program that she learned about safety as a I work with, but really a widespread difference.” With
the Council on Profes- career, and began to put the pieces together. that she was hooked. “I got the bug,” she says. “I got
sional Development, infected and I haven’t found the cure yet.”
and the Governmental Getting into that program felt like a good fit to
Affairs and Bylaws Stegall. “It also really capitalized on a couple of One aspect of volunteering that Stegall found chal-
committees. Stegall things that I later discovered were my strengths,” lenging was understanding the time commitment and
is a senior loss con- she says. Stegall’s parents were both educators, the work involved in each Society position. In talking
trol specialist for which fuels her lifelong drive to keep learning, gain- to potential volunteer leaders through the years about
United Heartland in ing knowledge from her experiences and applying it getting more involved, she noted a common question
Minnesota. She holds to other situations. about the time commitment for the different positions.
a bachelor’s degree
from Wake Forest “I know we have many members who go to uni- “I’m really excited that the role descriptions we’ve
University. Stegall’s versities and study to become safety professionals, now developed provide members with that infor-
notable awards in- and that’s wonderful,” she says. “But that’s not how I mation so that they can make an informed decision
clude being the first came into it. I’m really glad that I found it. It’s been about their volunteer roles,” she says. “As a Society,
woman to receive the a great career.” we want to help our members be successful, not just
Society’s Safety Pro- to succeed despite the challenges, but to succeed
fessional of the Year When asked what she finds most rewarding about because we’ve provided them the knowledge and
(SPY) Award; receiving the safety profession, Stegall again points to her up- resources to be successful.”
the Charles V. Culb- bringing for the answer. “I come from a long line of
ertson Outstanding ministers, so a big part is really helping people,” she When asked what drives her continued commit-
Volunteer Service says. Growing up, she adopted the mind-set of im- ment and service to the Society, Stegall points to her
Award twice; and be- proving the world for everyone, not just for herself. lifelong commitment to learning and the opportuni-
ing recognized as the ties that her volunteer service has provided. “Being
SPY for two chapters Stegall recognizes that the safety profession drew involved in the different committees, task forces and
and two regions. her in for this reason. “In the safety field, we are pro- member communities has given me the opportunity
actively helping to make the world a better place one to learn how different people think, experience differ-
workplace or even one employee at a time,” she says. ent leadership styles and to see what works and what
might not be the best way of doing things,” she says.
The Value of Volunteering
Like many, Stegall learned about ASSP through Another aspect driving her volunteer commitment is
the latitude to try different ideas that ASSP roles offer.
her first job, where her supervisor suggested she join “Being able to take on projects and see them through
the organization. She attended meetings and began to completion is really exciting,” she notes. “You don’t
to meet fellow professionals and learn from them. always feel that in an employment setting.” But within
ASSP, “if you’re willing to do something, as long as it’s
“Being new in my career, it was helpful to see aligned to the mission, goals and scope of that member
what other people were working on, what other or- community, let’s see if it can have an impact.”
ganizations were dealing with, and how they were
addressing certain issues,” she says. Being a Woman in the Safety Profession
In 2005, Stegall became the Society’s first woman
Career moves over the course of several years pre-
vented Stegall from answering the call when asked to earn the Safety Professional of the Year Award, and
to get more involved in a volunteer capacity for her she will be only the 6th woman to serve as ASSP pres-
chapter. But eventually she found a way to help out. ident. Stegall views this relatively unique position in a
Her chapter was working on its directory, which was
printed at that time. Having an interest in photog-

18 PSJ PROFESSIONAL SAFETY MAY 2019 assp.org

positive light. “We have to keep in mind that women standing adult learning principles and maintaining Companies
make up about 20% of our membership,” she says. “So communication skills. “People don’t care how should in-
when we have a high number of women in leadership much you know until they know how much you clude safety
roles, we need to celebrate that.” care,” she says. “As safety professionals, it’s easy to in their mis-
default to a position of telling versus understand- sion state-
Stegall sees her tenure as president not only as an ing and helping the person we’re talking to, un- ments and
opportunity to demonstrate that safety is a viable derstanding what’s important to the person, inside integrate it
profession for women, but also to better represent and outside of the workplace.” in their dai-
the larger community. ly culture.
These skills all converge for safety professionals We need to
“When we think about our society as a whole, we who need to ensure that workers are engaged and help them
are becoming more diverse, whether it’s with age, participating in their own education. “How do we understand
gender, race, ethnicity or religion, and we should ensure that they have the ability to react appropri- that safe
embrace that,” she says. “We need to continue reach- ately versus just doing things because this is the way production
ing out so that there is more diversity within our we’ve told them to do it?” she asks. “It’s not just us, is efficient
Society and our profession as we better represent the as safety professionals, ensuring that we understand production.
people all around us.” risk, but we’re helping workers understand risk so
they’re able to make better decisions based on what
When asked what changes she sees ahead for they are seeing each day.”
women in safety, Stegall sees a need to expand
opportunities in fields that are traditionally Goals for 2019-20
male-dominated, such as oil and gas, and con- With her term as ASSP president beginning July
struction. She also notes that manufacturers are
beginning to recognize women workers as a target 1, Stegall sees herself as a steward of the Society’s
market, which she believes can only help. “I know goals and strategic plan. One of her major areas of
that our Women in Safety Excellence (WISE) group focus is communicating the value of the OSH pro-
has been working to convey the message that per- fession. “Sound safety practices are both socially
sonal protective equipment for women is not just responsible and good business,” she says. “This leads
about it being pink or being high fashion,” she says. to increased productivity, a better reputation and
“It actually needs to be sized correctly and work higher employee satisfaction.”
properly for a woman’s body.”
Risk management is another focal point for
Advice to Future Generations Stegall. “Companies should include safety in their
When asked what she has learned during her mission statements and integrate it in their daily
culture,” she says. “We need to help them under-
career that she can pass on to future safety profes- stand that safe production is efficient production.”
sionals, Stegall recommends getting out of the office,
where some OSH professionals tend to stay. “They Preventing workplace violence is another priority
aren’t out on the floor or on the jobsite enough for Stegall. She notes that violence impacts women
talking to the workers,” she says, adding that it’s the workers disproportionately, but that violence can
only way to truly learn how the work is done and take many forms. “Employers need a comprehensive
what hazards people face. “Without having those approach that addresses mental health along with
conversations, we’re going to miss that,” she says. the physical wellness of their workers,” she says.
“We’re going to think we’re doing everything we “Simply looking at the harms that arise from work
can, but we haven’t talked to the people who can itself is too limiting.”
really help us come up with a solution that will help
them be safe and address the needs of the organiza- Stegall sees the member experience as fun-
tion at the same time.” damental to all of her ASSP service. Whether
its ensuring that volunteers have the education,
She notes the importance of building a career net- training and skills to be successful in their roles,
work. “Find a couple of people who are supportive, or making sure conference attendees feel wel-
who are willing to answer questions, and who you comed and have a great learning experience,
can bounce ideas off of to get a different perspec- Stegall’s work with the Society is rooted in the
tive,” she says. member experience. “I think that helps with our
other major objectives, such as making sure our
Asking questions is another key recommenda- members are engaged and that the education we’re
tion. “It’s a balance when you’re new because you providing is relevant,” she says.
want people to take you seriously. But sometimes
people will take you more seriously if you’re asking She sees the coming year as another fresh oppor-
questions that show you’ve done your homework,” tunity for the Society. “This year the board will be
she says. “If you do your homework up front and if able to be truly strategic and we can look at who
you’re asking from a caring perspective, it’s amazing we want to be as a Society,” she says. However, she
what you can learn.” keeps it all in perspective. “I’m only president for
a year. You always hope to make a difference,” she
On skills that safety professionals will need in says. “You want to leave the world a little better than
the future, Stegall notes the importance of un- you started. I’m hoping at the end of the year that we
derstanding risk and risk assessment techniques, are focused on those things that are taking us to the
investing in one’s own learning to stay current on next level.” PSJ
rapidly changing trends and best practices, under-

assp.org MAY 2019 PROFESSIONAL SAFETY PSJ 19

LEADING THOUGHTS

SAFETY LEADERSHIP
DURING UNCERTAIN TIMES

By Anil Mathur and Robert Pater

Master strategists know that certainty is an illusion, that the best leaders are most
needed and actually make their greatest impact when everything is up in the air,
changing, shifting and buffeting.

Anil Mathur During those times even the most clear-eyed much larger tankers. All this in an industry with SUAT GÜRSÖZLÜ/ISTOCK/GETTY IMAGES PLUS
visionaries can at most predict a wide range of significant ups and downs and looming uncertain-
Anil Mathur is pres- possibilities that might be marginal at best. When ties. He has found, and he has a long track record
ident and CEO of branching paths veer toward vastly disparate, not to back him, that people can achieve extraordinary
Oregon-based Alaska readily predictable futures and where the only performance under difficult conditions.
Tanker Co., which certainty is stress. In the land where the classic
operates oil tankers VUCA situation (volatility, uncertainty, complex- So, here’s the secret of best leaders: they don’t wait
from Alaska to Wash- ity and ambiguity) prevails. Situation normal for for the storm to hit to start steering. They prepare in
ington, California many leaders. advance. And, like master internal martial artists,
and Hawaii. Mathur they live in each moment as much as possible so
earned an M.B.A. Ultimately, safety (and safety leadership) entails they are ready for any attack of change. Seems obvi-
from University of anticipating and evaluating hazards, and recogniz- ous? As that martial arts saying goes, “The best se-
California, Berkeley, ing that the hazards that actually manifest depend crets keep themselves.” Saying is easy, doing during
an M.S. in Engineering on which particular uncertain outcome unfolds. stress-thumping times, not so much. The key is hav-
from University of And uncertainty always poses a wide range of risks ing concrete, detailed plans for different outcomes.
Tulsa and a B.S. in to operational integrity and to organizational fit- These plans can become something to adapt from if
Chemical Engineering ness (or even survival). To avoid getting blindsided, yet a different path manifests.
from Indian Insti- the best safety leaders dedicate time and emphasis
tute of Technology, to dealing with current unknowns and toward pre- High-level safety leadership is a subset of overall
Kharagpur, India. He paring for different or even greater uncertainties. leadership. One article cannot cover everything
is an alumnus of Har- They know it is not possible to know everything we’ve experienced and learned about leading during
vard Business School. and that what they don’t see can lead to hurting times of uncertainty, and by nature of the medium,
Mathur serves as Pub- workers and to damaging company capabilities. it has to be generalized. Words aren’t always im-
lic Director on ASSP’s pactful change-provokers. As a reader, you’ll get the
Board of Directors. Uncertainty has many shapes and flavors. Ex- most by framing the situations you face in such a
ternal contributing forces include wild market way that the plan results in tangible, effective action.
Robert Pater fluctuations, looming-or-only-maybe mergers or In the end, only action produces results.
acquisitions, leadership upheavals, who-knows-
Robert Pater, M.A., what-or-when changing regulations (or regulators), Seven High-level Strategies, Principles &
is managing direc- shrinking or folding operations, partial downsizing, Practices for Leading Through Uncertainty
tor and founder of market shifts, customer or competitor upheavals,
MoveSMART (www and more. Safety (and safety leadership) ultimately entails
.movesmart.com). anticipating and evaluating hazards. To avoid
Clients include Am- But uncertainty is not just external forces that getting blindsided, which can result in mounting
trak, ArcelorMittal, are outside leadership control. Internal factors also injuries and eroding culture, wise leaders rely more
BHP Billiton, BMW, boost uncertainty. These are potentially more influ- on managing potential uncertainties than just on
BorgWarner, BP, Cum- enceable by leaders and are often related to a lack of scrambling to react effectively to emerging prob-
mins, Domtar, DuPont, strong planning, weak communication or a culture lems. This is how we think of strongest leadership.
Hawaiian Airlines, HD that doesn’t allow thinking through how to execute And our experience with many organizations
Supply, Honda, Mara- work safely. over numerous years (Anil in the oil and shipping
thon Oil, MSC Indus- industries with a wide array of risk exposures for
trial Supply, Nissan, It’s during these times of unsureness or upheaval over two decades, Robert consulting with hundreds
Northrop Grumman, that best leaders are most needed and best shine, of such companies) consistently shows the core
ONE Gas, Rio Tinto, relying on their well-developed perception, deci- attributes for successfully leading during rocky
S&C Electric, United sion-making and make-it-happen skills to right a conditions boil down to: 1) taking care of people
Airlines, U.S. Steel, rocking ship, prevent capsizing and steer it toward first; and 2) setting protective daily practices into
Wacker and WestRock. safer or at least calmer waters. place. How to accomplish this?
Pater is a professional
member of ASSP’s Anil has been CEO and president of Alaska Tank- 1) Turn to Your North Star
Columbia-Willamette er Co. (ATC) for 18 years. During that time, the When faced with difficult choices, turn to your
Chapter. company has been profitable and even working with
a myriad of potential risk exposures (e.g., rolling/ North Star for navigation. Best safety leaders are
listing vessels, long hours, working in the dark, willing to take career risks to reduce the physical
vertical ladders, physical work with slip/trip/fall risks their teams have to deal with. Rather than tell
potential), ATC has worked 23 million hours with workers, “You should stop this job any time you feel
one lost-time injury (a broken finger), going through it’s less than safe,” find opportunities to actually do
times of letting ships go, changing over to fewer but

20 PSJ PROFESSIONAL SAFETY MAY 2019 assp.org

so yourself. Lead by example, not by articulating necessary to do a job safely. And let your team see Leaders
highly cerebral commitments that can’t be verified that you’re doing this. should best
or put into practice. rely on their
Yet another enlisting North Star opportunity:
Tack to and take comfort in your beliefs. Re- how you handle it when job safety analyses (JSA or underly-
member that there’s no way to know for certain JHA) are being discussed. Do you raise objections ing belief
that any implemented strategy will produce desired and concerns or try to talk workers out of bringing system to
effects. Leaders should best rely on their under- these up? be their
lying belief system to be their guiding North Star guiding
in stormy or dark times. And remind themselves General rules of thumb: Talk less and engage North Star
to trust in this, to be comfortable with being un- more. Remember that choices and actions reveal in stormy or
comfortable. So, of course, be sure to know and your priorities. Speak in terms that workers relate to, dark times.
strengthen your own belief system; after all, how rather than in well-meaning but too general terms, And remind
can you change others’ beliefs if you aren’t deeply such as, “Safety is number one” or “We want you to themselves
anchored in your own? be able to go home unhurt at day’s end.” to trust in
this, to be
During dynamic times, keep your end point in You may not receive many kudos in the short comfortable
mind (e.g., uncompromising worker safety) even term, but a consistent and sincere belief in and with being
when you’re not always sure how to get there with- passion for safety will show itself in your actions uncomfort-
out being wedded to any one preset method. and, for many companies, actually accrue respect
and allow you to do even more. Anil is a living ex- able.
How to best use your North Star? Have the cour- ample. But, according to him, if this doesn’t work
age (and we recognize this is a lot easier to write out too often, think through and consider whether
or say than to do) to take visible stands that might your company is a good fit for you in the long term.
disagree with or go against the prevailing norms or Working out of sync with the navigation signals
current culture. Anil relates several stories of the from your North Star typically leads to job dissatis-
importance of him standing up for his beliefs even faction and eventually burnout.
when, in fact especially when, this could risk his
leadership position. For one, when he was working 2) Cultivate Trust
offshore (in the North Sea) for BP Exploration, he Trust is a critical foundation supporting recep-
shut down an expensive-per-day rig due to lack of
adequate planning for safe transfer of new equip- tivity to change, engagement and leadership, all of
ment and supplies. His boss later tacitly backed which are essential high-performance ingredients
him up, even though Anil knew when he took ac- especially in uncertain times. And leaders can go
tion that he risked getting disciplined or fired. And a long way toward forming, rebuilding and rein-
this is far from the only such story that Anil shares forcing stronger trust. Your team has to trust you
where he has stood up for his North Star safety to follow you, and you can’t be a leader without
commitment and beliefs when doing so was poten- followers.
tially dangerous for him.
We’ve seen during times of stress that people
That’s the point of a North Star. When land is in tend to listen less to what leaders say and watch
sight, when weather is clear, an inner navigation more what leaders actually do. And anything a
compass is not needed as much. Compare this to leader says or does will be examined even more
moving through choppy or worse seas where visi- closely when the organization is under the stresses
bility is obscured; this is when to seek out and latch of uncertainty. Leaders should keep this in mind,
onto such guidance. not relying on the assumption that saying the right
things is enough to reassure or redirect a stressed
Asking pointed questions is another way to workforce. Most of your team have heard the right
demonstrate your values. Remember that asking high-level statements made many times, and have
is better than telling (management guru Peter likely become tone deaf to them.
Drucker contended that asking the right ques-
tions is more important and useful than trying to Studies such as the 2019 Edelman Trust Barome-
come up with the right solutions). Better than just ter continually reassert that the trust link in many
saying, “I care about your safety,” sample concrete relationships has become more rusted. Three take-
North Star questions of workers that delve deeply aways from the 2019 Edelman study: 1) the more
into the specific safety aspects of the job they are informed people are, the significantly greater their
executing. Examples might be, What job are you levels of trust; 2) both the informed and mass public
working on? How does safety fit into this task? share an urgent desire for change; and 3) “engage-
When you’re lubricating that valve, how old is the ment and action” are critical to elevating trust. An
grease? Does this action actually create any safety Edelman (2019) recommendation? “Employees are
concerns for you? How do you check the brakes ready and willing to trust their employers, but the
on that to know they are engaged? If the O-ring trust must be earned through more than ‘business
needs changing and you don’t have the right one as usual.’”
on hand and this is a potential safety risk, what
will you do? Think of two pillars of trust: intent and com-
petence. The first basically means “Do you care?”
Another example of demonstrating your values: While saying the right words are important, these
fighting for the time, money and people resources are even more potentiated when linked to experi-
ence and consistent with actions.

assp.org MAY 2019 PROFESSIONAL SAFETY PSJ 21

LEADING THOUGHTS

Uncertainty The second pillar of trust, competence, refers to (although making sense is also prerequisite, but
is like the whether I believe you have the power and ability not enough by itself, for building strong working
storm. to get done what you say you’re going to do. Many relationships).
Leaders managers and professionals undercut trust by over-
have to promising what they can effectively accomplish in a Further, don’t underestimate the power of indi-
given period. vidual communications, rather than only broad-
develop the casting mass messages to change mind-sets. This
flexibility During times of uncertainty, it’s critical for is one reason that it’s critical for leaders to get out
to handle leaders to demonstrate consistent intent (e.g., un- and about on work sites, where workers are doing
how it compromising dedication to worker safety) and their daily tasks. What you say even in a small
plays out. competence (following through on complaints, group is bound to spread to others, sometimes in
concerns, potential safety and other pitfalls that a much more effective way than announcing it to a
arise). While there is a lot that goes into this, some large group.
tips include:
Listen, listen, listen. We can’t underestimate how
•Avoid the trust impatience trap, the desire to very powerful it is for your team to experience the
build trust quickly. If leaders push too hard for sensation of being fully heard and understood.
acceptance, it will fail or even backfire. The song Don’t wait for issues to come to you; sincerely seek
lyrics say, “You can’t hurry love” and neither can out and sample others’ concerns. Have you heard a
you hurry trust. leader say, “There’s no point in going to the work site
because I don’t have anything new to say”? Better
•When instituting less-desirable changes that look to listen than to tell, especially in times of uncer-
like takeaways, fully explain the reasons for this: tainty and stress. There’s significant value in leaders
how times have changed, how even if this is not an becoming a lightning rod for concerns, fears and
ideal option it is better than the alternative (e.g., lay- hopes during times of change. As well as potentially
offs). Always present a balanced view. Clearly show reducing worker negativity and heightening trust,
the potential advantages and downsides of any con- this can spur more creative alternatives in leader-
sidered change (explaining how the chosen change ship planning.
has more upsides than downsides).
5) Monitor Others’ Reactions
•Exemplify leadership. Do what you expect of Remember that all actions are actually interac-
others rather than broadcasting that rules don’t ap-
ply to you. tions. It’s essential to go back to what the workforce
believes in as a starting point in change. Almost all
•Find common ground in times of conflict and difficult and successful change takes individuals
distrust, even if this initially appears to be minimal. through a four-step process: denial, anger, accep-
Build on this to strengthen relationships. tance and then cocreation. Patience and excellent
listening skills are both needed to let this cycle play
•Focus on being hard on issues and gentle on peo- out to effectively implement change.
ple, but remember that people can take any criticism
as a personal attack. So leaders have to do their best Bear in mind that uncertainty always involves
to reduce defensiveness. current or potentially looming change, which al-
ways involves losing something (at the very least,
3) Practical & Ongoing Scenario Planning accustomed ways of doing things, even when these
Project the varying effects of different potential are only minimally effective or pose undue safety
risks). Impending loss and having to adjust to new
futures. For example, determine what kinds of methods is a main reason that people tend to resist
events might ripple out from a significant downturn change, especially change over which they have lim-
in product (oil) prices or if regulators change direc- ited control.
tion on safety or environmental regulations. The
keys to strong scenario planning are: 1) do this over 6) Boost Self-Control
time, not just in a one-shot retreat; 2) involve several So, provide workers with as much control as fea-
people with different perspectives, including some
who are in opposition to senior leaders’ perspective; sible. At the very least, transfer mental and physical
and 3) be open to considering even least-desirable or skills that workers can deposit into their internal
unlikely possible futures. safety bank to draw from as they need. Mental skill
sets include: practical mindfulness, attention con-
4) Experience It trol, better assessment and decision-making, how to
Understanding comes from experience. Don’t elevate sleep health, a mind-set of taking control of
personal safety and more. Physical skill sets include:
underestimate the power of showing up. Face time balance (a truly internal skill that can significantly
is key to building trust. Leaders have to spend time help prevent a wide range of injuries from soft-tissue
with workers beyond meetings or conferences to to slips/trips/falls), redirection of forces away from
deeply understand workers’ issues and concerns. more vulnerable body areas (e.g., lower back, knees),
It’s critical to visit sites while people are actually elevating usable strength and employing leverage.
working. Too many leaders we’ve seen don’t under-
stand this, assuming this is wasted or low-leverage Uncertainty typically elevates stress. We define
usage of their in-demand schedule. Remember that stress as the feeling of being out of control. And
developing organizational relationships takes time
and patience, it’s more emotional than cerebral

22 PSJ PROFESSIONAL SAFETY MAY 2019 assp.org

most people’s first mental reaction to stress is nar- lenges and exploration can be exciting and further
rowing attention; this tunnel vision is associated achievements possible.
with a wide range and numbers of close calls and
injuries. Tunnel vision also results in short-term Changing mind-sets during times of uncertainty
thinking or planning. entails leaders developing the wisdom and skill of
knowing what to say and when and how to say it.
A common reflexive reaction to uncertainty or Yes, this can entail taking leadership risks. But, as
change is “how will this affect me?” Often, the the saying goes, fortune favors the bold.
immediate response to this is panic-projecting,
imagining a worst-case scenario. Any safety strat- Uncertainty is like the storm. Leaders have to
egies, methods or techniques that boost self-con- develop the flexibility to handle how it plays out.
trol will also help people enlist rather than be Communicate with the underlying mind-set that
victimized by the stress of uncertainty. Note that together we will find a way to do well. Even in
this doesn’t necessarily change outside forces at times of threatening turmoil, miraculous results
play, but will help leaders and everyone else better can occur when people really trust that leaders
utilize, redirect and minimize adverse impact of are both truly concerned about them and are able
these forces. navigators. Strong leadership steadies a ship and
an organization before, during and after uncertain
7) Change Mind-Sets times. PSJ
This is the both the most difficult thing to
References
do but also the most leveraging. One important
aspect of this is for leaders to send consistent Edelman. (2019, Jan. 20). 2019 Edelman trust barometer.
messages to members of the workforce that they Edelman. Retrieved from www.edelman.com/trust-baro
care. We have repeatedly seen how much good can meter
come from this.
Mathur, A. & Pater, R. (2009, April). Propelling next level
There are two critical elements to changing safety culture [Webinar].
mind-sets: 1) Leaders should be open to their own
mind-set being modified by others’ thoughts, Mathur, A. & Pater, R. (2014, April). Seven safety lead-
perspectives or concerns. If you want to influence ership mind-sets: Activating an organization. Professional
others, it’s important to be receptive to their influ- Safety, 59(4), 22-24.
encing you. Information or perspectives may come
up that you didn’t think of. 2) Communicate with Pater, R. (2005, Jan.). Boosting trust for safety perfor-
concern, even if/when your ducks are not totally in mance [Webinar].
a row, and your ducks will never be totally lined up
in a row during uncertain times. Let them know Pater, R. (2005, Sept. 1). Boost trust for better safety: 35
early. Your team’s capacity to understand and ac- specific steps you can take. ISHN. Retrieved from www
cept that a situation is still developing may amaze .ishn.com/CDA/Archives/e6f5dbf7161c7010VgnVCM
you. People can handle this. This demonstrates ac- 100000f932a8c0
tual concern much more than just words (e.g., “I’m
concerned about you”). Pater, R. (2005). Building trust for safety leadership. The
Compass, Fall.
Be willing to share partial/interim information and
plans, rather than waiting until everything is signed Pater, R., (2006, May 12). Safety catalyst: Becoming a
and sealed even if this means communicating, “I can’t courageous leader. EHS Today. Retrieved from www.ehs
tell you more at this time, as some things are unde- today.com/columns/ehs_imp_38234
cided or up in the air. Here’s what I can say. And I’ll
let you know more as soon as I can.” Pater, R. (2007, Oct. 1). The zen of safety leadership. Oc-
cupational Health and Safety. Retrieved from http://ohson
Enlist curiosity and wonder as positive refram- line.com/articles/2007/10/the-zen-of-safety-leadership.aspx
ing mind-sets during uncertainty. Uncertainty is
stressful, but stress definitely has positive elements: Pater, R. (2009, July/Aug.). From the top down: Enhanc-
excitement, energy, wonder. Adam Smith is famous ing safety through culture change. Maritime Executive,
for being the “invisible hand” free market proponent 13(4), 48-51.
of capitalism. In his 1795 book, History of Astrono-
my, Smith wrote that wonder is crucial for science Pater, R. (2010, June 1). No fear safety leadership. Occu-
(in that it’s a strong driver for scientists and all other pational Health and Safety. Retrieved from http://ohsonline
explorers/breakers of new ground), defining wonder .com/articles/2010/06/01/no-fear-safety-leadership.aspx
as that staring and sometimes that rolling of the ?sc_lang=en
eyes, that suspension of the breath and that swelling
of the heart (Prinz, 2013). Pater, R. (2011, Jan.). Two types of leaders: Which are
you? Advanced safety leadership skills part 1. Professional
In both personal face-to-face and written commu- Safety, 65(1), 25-26.
nications to his entire company, Anil often lauds the
power of curiosity. This reframes uncertainty as a Pater, R. (2011, Feb.). Advanced safety leadership skills
time of new rather than hopelessly dire possibilities, part 2: 9 critical mind-sets, skill sets and tool sets. Profes-
where change is possible for the better, when chal- sional Safety, 65(1), 26-28.

Pater, R. (2011, March 1). Leadership: Dust and rust
and trust. Occupational Health and Safety. Retrieved from
https://ohsonline.com/articles/2011/03/01/dust-and-rust
-and-trust.aspx?admgarea=magazine

Pater, R. (2014, July 1). (Re)Building a foundation of
trust. Retrieved from https://ohsonline.com/Articles/
2014/07/01/Rebuilding-a-Foundation-of-Trust.aspx

Pater, R. (2018, Sept.). Changing the hidden safety cul-
ture. Professonal Safety, 63(9), 20-23.

Prinz, J. (2013, June 21). How wonder works. Aeon. Re-
trieved from https://aeon.co/essays/why-wonder-is-the
-most-human-of-all-emotions

assp.org MAY 2019 PROFESSIONAL SAFETY PSJ 23

BEST PRACTICES

USING FEMA’s STAPLEE PROCESS

to Drive OSH Critical Thinking

By Bart J. Eltz

Today’s leaders demand critical thinking skills from all levels of the organization. This is especially true for
the OSH professional whose actions often affect the entire organization and the way it conducts business. That
is why it is imperative that the OSH leader take a holistic approach to implementing controls in the workplace.

Workplace controls must be not is by following a set of guidelines to Combining STAPLEE PHOTOTECHNO/ISTOCK/GETTY IMAGES PLUS
only effective but also accepted by help when analyzing the information. & Critical Thinking Skills
those who are being protected. The The Federal Emergency Management
purpose of this article is to provide a Agency (FEMA) has been using the OSH leaders may use this checklist as
tool to help OSH professionals think STAPLEE tool, which may help OSH a high-level overview of what must be
critically and holistically about the professionals ensure that they are addressed, but they could also use it to
potential impact of the controls they thinking critically and looking at all of inspire their respective teams to think out-
select to protect employees. the possibilities. side the proverbial box when it comes to
ultimately controlling workplace hazards.
Critical Thinking STAPLEE STAPLEE is not meant to be an exhaustive
Critical thinking is one of the most The STAPLEE tool is broken down tool but it does help the OSH professional
in decision-making when it comes to miti-
important tools an OSH professional into seven different criteria: social, gating a hazard in the workplace.
can possess. It is not an innate ability, technical, administrative, political,
rather it is a skill that we must work on legal, economic, and environmental. Much like performing a five-why or
improving to be successful. Some peo- Each criteria area may help the OSH what-if analysis, STAPLEE may be used
ple think that students develop critical leader to perform critical thinking in to generate other questions. Each ques-
thinking skills in school, but that is that area to ensure a holistic view of tion posed presents an opportunity to
not always the case. According to Jin, what OSH controls s/he wants to put explore another avenue of whether the
Bierma and Broadbear (2004), many in place. workplace control would violate one
college-level OSH students struggle to of the areas of STAPLEE. Therefore,
develop critical thinking skills. Critical thinking is not an STAPLEE may be used by an individ-
ual to ensure that s/he has considered
Critical thinking is a form of ad- innate ability, rather it is everything when it comes to a control,
dressing a problem, subject or specific or it could be used by a group of OSH
content where the individual’s thinking a skill that we must professionals or a cross-functional
is improved by skillfully analyzing, as- team of professionals to determine the
sessing and reconstructing the thought work on improving best path forward. OSH professionals
(King & Kitchener, 1994). Many pro- should consider using a cross-function-
fessions thrive on critical thinking to be successful. al team not only because it may help
skills. Persky, Medina and Castleberry with finding solutions to discovered
(2019) allude to the need to teach crit- Generally speaking, emergency problems, but it may also make front-
ical thinking skills to all college-level managers can use the STAPLEE tool line leaders and employees feel that
students in multiple career paths. Today, to ensure that the mitigation steps they have a part in the outcome or suc-
students as well as mid- and senior-level they employ for their community will cess of the workplace control.
professionals, are expected to be able to not cause issues among the different
utilize their critical thinking skills to aspects associated with that commu- This tool should not be used only for
analyze all the different angles of a po- nity. While STAPLEE may not catch new processes or procedures that require
tential problem. every aspect of a potential mitigation controls. Previously established pro-
project, it certainly identifies major cesses and tasks should also be reviewed
This disciplined process of think- categories of work that need to be rec- to learn whether change is needed.
ing can be used in the context of both ognized and addressed. Perhaps workers are not wearing the
professional and personal situations. appropriate gloves while performing the
On a professional basis, most OSH A simple Internet search for “FEMA task for which they are required. Is the
practitioners use critical thinking skills STAPLEE” will return the STAPLEE answer to retrain workers? Is the answer
during the incident investigation por- Criteria Worksheet for review, the same disciplinary consequences? Would it
tion of their duties, where they look document used by many emergency be worthwhile to revisit the use of the
beyond human error for incident root managers across the country. However, STAPLEE process to ensure that a holis-
causes. On the personal side, critical with some modifications, we can take the tic approach was taken when the current
thinking skills are often used when major categories and use them as a holis- controls were recommended?
making family, financial or other tic tool for OSH purposes. The categories
decisions that require rich analysis in Table 1 are from FEMA (2003) but the Conclusion
and evaluation of the subject matter. description for each category has been To be truly successful in any profes-
One way to practice critical thinking modified to meet OSH needs.
sional career field, one must demonstrate

24 PSJ PROFESSIONAL SAFETY MAY 2019 assp.org

TABLE 1

FEMA’s STAPLEE PROCESS

Acronym Questions to ask during process
S Social
T Technical Is the workplace control socially acceptable? That is, will workers appreciate the
control, or will they not use it or try to bypass it? Will it affect all worker populations,
A Administrative including disabled workers? Will workers complain or welcome the controls? Is there a
plan to clearly communicate the purpose of the new controls?
P Political Is the control technically feasible? Is it a long-term solution to addressing the hazard?
L Legal Are there any secondary or tertiary impacts to the process, product or people? Is the
control aligned with modern thinking (e.g., does it move as fast as the business or is it
E Economic cumbersome)? Does the control meet the hierarchy of controls model? Does the
E Environmental control introduce a new risk?
Does the control require additional staffing or funding to make it happen? What type
of burden will this control put on the maintenance departments or the operations
group? What rigor of training will be needed to implement the use of this control?
Does the control still lend itself to potential human error? What routine checks will be
needed to ensure that the control is working as intended?
Will departmental politics be an issue in completing the control implementation for
these hazards? Is a champion or high-level sponsor needed to help smooth over the
different departments? Does this control offer so much of a change that a worker
could complain to OSHA or EPA? Is leadership aligned with the change?
Is the intended control legal? Are you meeting the requirements of due diligence and
guidance from organizations such as ANSI, ASTM and NFPA, and adhering to building
codes, professional societies and trade associations? Are the controls set up in a way
to disprove negligence on the part of the employer? In short, are the controls put in
place to show that the employer is doing everything it can to protect employees?
What is the true benefit of the recommended controls? What is the cost of the action
in terms of time, money, resources and ongoing maintenance? What is the
contribution to the organization’s economic goals? Has a cost/benefit analysis been
performed and briefed to senior leadership?
Are there any effects on land, water or air? Any effects on endangered species? Effects
on HazMat waste streams or storage? Are the controls consistent with the community
and company environmental goals? Is it consistent with federal and state laws?

critical thinking skills (Paul & Elder, tool will also help to refine the OSH pro- undergraduates and implications for the profession.
2006). This is especially true for the OSH fessional’s critical thinking skills to en- Journal of Environmental Health, 67(3), 15-20.
professional who makes recommenda- sure that the profession continues to have
tions that may affect the entire manufac- a seat at the table and be considered as an King, P.M. & Kitchener, K.S. (1994). Devel-
turing line, service delivery system, or added value to the organization. PSJ oping Reflective Judgment: Understanding and
research and development facility. Rather Promoting Intellectual Growth and Critical
than focusing on an in-depth discussion References Thinking in Adolescents and Adults. San Fran-
of critical thinking skills, this article cisco, CA: Jossey-Bass.
describes a tool that can be used to catch Federal Emergency Management Agency
some of the situations that may require (FEMA). (2003). Developing the mitigation Paul, R. & Elder, L. (2006). The Miniature
critical thinking skills. This tool is rooted plan: Identifying mitigation actions and imple- Guide To Critical Thinking: Concepts and Tools.
in the concept of mitigating hazards for mentation strategies. Retrieved from www Dillon Beach, CA: Foundation for Critical
a community that is potentially faced .fema.gov/media-library-data/20130726-1521 Thinking.
with a disaster (e.g., hurricane, massive -20490-5373/howto3.pdf
earthquake, tornado). However, the OSH Persky, A.M. Medina, M.S., & Castleberry,
professional may use it as a tool to take Jin, G., Bierma, T.J. & Broadbear, J.T. (2004). A.N. (2019). Developing critical thinking skills
a holistic approach to thinking of all of Critical thinking among environmental health in pharmacy students (Review). American Jour-
the different situations and scenarios that nal of Pharmaceutical Education, 83(2), 161-170.
could arise when making recommenda-
tions for workplace controls. Using this Bart J. Eltz, Ph.D., CSP, CIH, is a global industrial hygiene and safety leader for Duracell
Corp. He is a faculty member of Columbia Southern University and Embry-Riddle Aeronautical
University. Bart holds a Ph.D. in Emergency Management from Capella University and an M.S. in
OSH and Environmental Management from Columbia Southern University. He is a professional
member of ASSP’s Georgia Chapter and a member of the Society’s Manufacturing, Engineering and
Industrial Hygiene practice specialties.

assp.org MAY 2019 PROFESSIONAL SAFETY PSJ 25

PSJ ASKS

Council on

ACADEMIC AFFAIRS & RESEARCH

Q&A With Jim Ramsay

The Council on Academic Affairs and Research (COAAR) is ASSP’s newest council whose
goals include advancing a research agenda, bringing more students into the profession
and engaging universities to improve academic standards. Instrumental in COAAR’s
development, Jim Ramsay served as the council’s inaugural vice president.

Jim Ramsay PSJ: Why is the creation of this new council an safety for 6 months at a work site, I’m a safety profes-
important step for ASSP? sional.” That should not happen. Education standards
Jim Ramsay, Ph.D., Jim: Never before for the Society have education standards, help turn safety into a bona fide profession because
M.A., CSP, is a profes- research and education been so important as to warrant they establish the kind of education we seek when we
sor of security studies, council status. By creating a council focused on academic hire people to do certain kinds of jobs.
coordinator of the affairs and research, ASSP is moving into the parlance of
Homeland Security other mature, established disciplines, such as medicine and It sets us apart from the people who are liable to hurt
program, and found- law, whose professional associations highly value education or kill people because they don’t have the education and
ing chair of the De- and use it as the barrier of entry to the profession. Like these training to be a safety professional. Think about law. You
partment of Security disciplines, safety is not a vocation, it’s a profession. These can’t earn a B.S. in history then start practicing law. You
Studies at University disciplines value research to drive the field forward and to could do a lot of harm to society by not knowing the law,
of New Hampshire. improve the body of knowledge in a concerted, mindful and not knowing how to do all the things lawyers are trained
He has more than 20 budgeted way. By creating this council, ASSP is essentially to do and yet representing someone whose livelihood
years’ experience in telling the world that safety is a mature profession focused might be in your hands. Same with medicine, same with
occupational safety, on education and education standards so that we can qualify nursing, same with nutrition. That’s why those profes-
public health, emer- the people entering into the workforce, drive the body of sions are so keyed in on education standards at the heart
gency management knowledge and answer practitioner questions with our re- of what it means to be a profession. The stakes aren’t any
and environmental search function for the betterment of society. lower when it comes to worker safety.
health. Ramsay served
on the NIOSH Board PSJ: How will the council support the profession? PSJ: There seems to be a disconnect between
of Scientific Counsel- Jim: When we take a comprehensive look at education research and the practice of safety itself. How do we
ors, the ABET board and education standards, we are ultimately taking a com- help members understand what to do with research?
of directors, and on prehensive look at how we educate and train tomorrow’s Jim: That’s always a vexing challenge. In the world of
NIOSH’s Institutional workforce. The discipline of medicine does that: there is no research, we’re structured and taught to articulate the
Review Board and question about the learning outcomes that all physicians results of our inquiries in a certain way. The rest of the
its Disaster Research get coming out of medical school. In safety we do not have world is not necessarily operating along those same lines.
Institutional Review a good distribution of safety education standards through- So, what makes sense in a research journal is not always
Board. Ramsay served out the academic world. We would really like to get the in a digestible form for practitioners. The rub with spon-
as the inaugural Vice education standards we developed as widely distributed as soring research in a practitioner organization is this
President of ASSP’s possible, and the council provides that avenue. translation. We’re very keen to answer this question.
Council on Academic
Affairs and Research, The academic objectives involve bringing more PSJ: How do we ensure that our research agenda
and has chaired the students into the profession and advancing academic will influence the work that researchers pursue?
ASSP Education Stan- standards of program accreditation. Those are two Jim: The council can help us answer the questions of
dards Committee for important end-state metrics. We think we’ve built a the industry, work with the federal government at a
the past 12 years. lot of safety programs in the U.S. But one could argue level that we’ve never been able to before, and create
that we need to build more programs than we currently and manage a national research agenda.
have because the need for OSH practitioners generally
exceeds our national capacity to produce them. We have a vision of total collaboration and integration
in terms of how we structure our research agenda. It will
PSJ: Can you explain how education standards be borne out of an interest in and knowledge of how the
benefit the OSH profession? various disciplines that comprise a safe and healthy work
Jim: Education standards are critical to a characteristic environment will work together in the research world.
that I like to call occupational closure: That a vocation
becomes a profession when, first and foremost, educa- For example, is it the domain of safety research to just
tion is a barrier to entry. If you don’t need an education look at ergonomics? No, ergonomics is an interdisci-
to be a full-fledged working member of a discipline, it’s plinary concept whose problems and solutions are best
hard to call it a profession. We define professions around understood in an interdisciplinary way. The same is true
many different characteristics. There’s literature around of occupational stress. Factors that affect worker safety
this and several articles published in Professional Safety and health are often psycho-emotional, for example, oc-
over the years talk about what’s required. cupational stress or depression. They are not purely the
domain of the healthcare or the psychology disciplines;
Education standards will ultimately benefit the they should also be part of safety disciplines. The same
profession because we will lean on them to become a is true for business. Safety has a strong business compo-
profession by definition such that not anyone can wan- nent. The safer and healthier your employees, the more
der in with, say, an anthropology degree and say, “I did productive they are, the less turnover you have and the
less cost you have from an insurance perspective. PSJ

26 PSJ PROFESSIONAL SAFETY MAY 2019 assp.org

BEST PRACTICES

Understanding the

CONTRACTOR MANAGEMENT PARADOX

By Stefan Malhotra

In almost every major organization, contract work is a reality if not an operational obligation. It is not often
that a company has all the necessary internal resources at its disposal to accomplish every project at a level
sufficient to satisfy company stakeholders while maintaining quality standards.

At some point, a business model remains an elusive and difficult process agement system, mainly relegated to
without contractors becomes unsustain- to define, especially for growth compa- whoever is willing to assume the task.
able and outside expertise becomes an nies. This is due to an inherent paradox
inevitability for operational success. whereby a contractor must seamlessly While any OSH professional will
integrate with a client’s system, com- openly profess the intrinsic importance
Entire industries have been built on bining OSH elements that are at times of contractor management, few may re-
performing a single technical task or contradictory, misaligned, out of scope alize just how much hazard mitigation
developing one particular product for a or extremely difficult to gauge, either on a client abdicates to them (Beale, 2003).
handful of clients or, in some cases, a sin- paper or in practice. This is especially evident when contrac-
gle client. Such is the energy generation tors isolate energized systems, where the
sector, whether oil and gas, renewables, Essentially, contractors exist in breadth and depth of mitigations must
or nuclear, where a glut of contractors competing states simultaneously, both match the complexity of the system’s
(e.g., drillers, civil engineering, crane independent of and dependent on the hazards. The inadequate application of
services, well logging, balance of plant, client. Look no further than control lockout/tagout (LOTO) resulting in inci-
waste management, maintenance ser- of work procedures or lift planning, dents such as high-pressure releases, live
vices) greatly outnumber the companies where differences in process can result circuit contact or unplanned equipment
that actually comprise the industry itself. in confusion and work stoppages in the activation is all too common. One of the
Furthermore, as companies embrace the field. Much like ill-fitting puzzle pieces, most disastrous and well-known exam-
latest technologies (e.g., data analytics, gaps form where communication breaks ples involving contractor LOTO is the
cloud-based databases, drone inspec- down, expectations are ill-defined or 1988 Piper Alpha disaster, in which the
tions) to further extract every ounce unmet, and standards dramatically removal of a single pressure relief valve
of organizational efficiency and reduce differ, all at the expense of the safety of led to the death of 167 offshore workers
overall costs, they promote an accel- those performing the work. (Tombs, 1990). In the author’s recent
erated dependence on the specialized experience, one contractor’s haphazard
competencies of contractors, thus further Regardless of the level of contractor substation LOTO downstream of a fa-
cementing an organization’s reliance on involvement in an organization, the cility resulted in a total site outage that
its external business partners. contractor management process is a subsequently caused the activation of an
unique improvement opportunity that asset’s emergency mode. Unfortunately,
The ubiquity of contractors able to is often mistakenly viewed, outside of another contractor group was simultane-
perform work at every level of an orga- an OSH context, as an onerous for- ously working inside the asset and failed
nization, coupled with the inevitable mality that can be sidestepped. In part to fully apply LOTO, resulting in thou-
necessity for a company to operate due to the difficulty of managing the sands of dollars of equipment damage.
competitively, demands some measure contractor paradox, this perception is
of contractor management. In an oper- short-sighted at best and negligent at Even a slight deviation in LOTO
ational context, and more specifically worst. Within the OSH context, con- procedures will result in near-hits, se-
from an OSH perspective, contractor tractor management is perceived as vere injuries or worse. The classic risks
management is a requirement and has one of the least glamorous and overly associated with contractor work are
been for some time. However, it still monotonous aspects of an OSH man- well known: discrete spending, resource

JUNPINZON/ISTOCK/GETTY IMAGES PLUS Much like ill-fitting puzzle
pieces, gaps form where
communication breaks
down, expectations are
ill-defined or unmet, and
standards dramatically
differ, all at the expense
of the safety of those
performing the work.

assp.org MAY 2019 PROFESSIONAL SAFETY PSJ 27

BEST PRACTICES

allocation, subcontractors, tempo- Whether an artifact of previous client structured, as a haphazard appearance
rary workers, technical competency, demands or out of a fear of legal liability, is difficult to understand and calls into
training, procedural compatibility and most contractors regardless of size now question the competency of a compa-
more. However, beyond the reality that have something resembling an OSH ny’s OSH department. Avoid grouping
contractor management systems are management system, at least on paper. unlike questions, which can break the
necessary for protecting against the Templated safety manuals covering flow of data input and create confusion.
aforementioned risks, OSH departments every OSHA element can easily be pur- Questions should be direct, objective and
often fail to proactively manage these chased or obtained from online sources. explicitly target the data requested in
risks relative to the contractor’s scope of Although contractors are most likely quantifiable terms. One should not leave
work. Managing contractors and their well-intentioned and there is no require- any ambiguity or omit specificity for fear
subcontractors is an active process that ment for every OSH manual to be an of overreach or pushback from contrac-
demands a full cycle approach (i.e., plan, original masterpiece, these manuals hold tors; transparency and accuracy benefit
do, check, act), where there is constant little value for either party when devel- all aspects of OSH.
communication and feedback at every oped solely for bureaucratic purposes.
step of the process, not only when things 3) If historic areas of concern exist,
go off script. This article aims to explore Skimming through hundreds of con- pose multiple questions about the topic.
the common avoidable mistakes OSH de- tractor management system documents, For example, instead of asking whether
partments regularly commit in relation often identical, will inevitably lead to subcontractors or temporary workers
to the contractor management paradox complacency and missed deficiencies. At will be used on site, the questions should
and proposes solutions to address their some point, this method of review be- be which ones, how many and for what
underlying causes. comes unsustainable and contractor ver- specific job task? More importantly,
ification becomes a mindless chore rather one should avoid too many binary,
Pushing Paper than a tool for risk assessment, thus closed-ended questions such as “does
Spending an inordinate number of calling into question the usefulness of your company have a safety program?”
the entire process. Ironically, this burden or “do you know of any previous inci-
work hours perpetually developing may be shifted to online third-party con- dents working with our company?” These
and revising an organization’s OSH tractor management databases at an ad- questions dissuade objectivity because
management system while accepting a ditional cost (i.e., a contractor to manage they elicit a point of view and also pro-
contractor’s system without proper due contractors’ data). Notwithstanding the vide limited actionable information.
diligence is an irony often lost on indus- data streamlining and resource deferral If open-ended questions prove to be
try professionals. Often, these reviews provided by such services, the core prob- problematic or unmanageable, multiple
are performed once during the initial lem of gauging procedural implemen- response questions can be used.
contractor qualification process and nev- tation and field performance remains.
er again. Frequently the review consists Although third-party databases provide 4) Supporting documentation is a ne-
of the client attesting to the contractor’s a deeper dive into content and statistics, cessity. A total recordable incident rate
OSH system comprehensiveness and the true picture of a contractor’s actual is only as good as the OSHA 300 form
performance with limited information as quality can remain obscured from view. signed by the contractor. This applies to
to the actual scope of work. The elements all other supporting documentation that
of the contractor’s management system While the insights that desktop analyses can provide a more complete representa-
(e.g., working at height, LOTO, manage- provide are a critical first step and point tion of contractor performance. There is
ment of change) are hurriedly evaluated of reference, they also provide a standard- no reason that documents such as OSHA
against client standards, while OSH sta- ized and objective initial approach. The forms, EMR letters, training certificates,
tistics (e.g., total recordable incident rate, following examines common missteps and OSH procedures, incident reports and
days away restricted or transferred rate, potential areas for improvement in the regulatory citations should be omitted
rate, near-hits) are compared against desktop analysis methodology. from a contractor’s record, especially
somewhat nebulous criteria [e.g., Bureau when the objective is to mitigate future
of Labor Statistics rates, experience mod- 1) Avoid paper-based forms entirely. operational risk. No other department
ification rate (EMR), internal key perfor- The contractor’s initial encounter with would assume such risk without proper
mance indicators]. Beyond recognizing an organization’s OSH management due diligence, so why would OSH be
obvious data discrepancies, the result can system is the contractor OSH question- excluded? It would be professionally irre-
be an ill-defined process with limited in- naire. In the age of digitization, a pa- sponsible to accept incomplete documen-
formation that can, and often does, easily per-based form, whether a stand-alone tation that conspicuously falls below an
devolve into a pencil-whipping exercise. document or part of a larger contractor organization’s standard.
qualification package, is subject to
Given the broad range of potential greater analytical error. Third-party 5) The contractor must be specific
work scopes for a multitude of contrac- contractor databases are quickly be- about a work scope on the questionnaire.
tors working on a single project, mean- coming the preferred data management Neither consulting nor crane work is a
ingful evaluation of every contractor’s method, although internal spreadsheets work scope, rather, they are generic job
management system and performance are equally reliable in collecting and descriptors. When a contractor is op-
is near impossible. Contractor submit- analyzing large volumes of data for dis- erating under the purview of a client,
tals are often an amalgamation of every crepancies and redress. the anticipated level of risk is inversely
possible OSH topic that could potential- proportional to the specificity of the pro-
ly touch on their expertise and can be 2) Develop a questionnaire that cap- posed work scope, regardless of the type
unnecessarily hundreds of pages long. tures all pertinent OSH data in a suc- of work to be performed. A specific work
cinct, specific and logical format. The scope along with supporting technical
questionnaire should be meticulously

28 PSJ PROFESSIONAL SAFETY MAY 2019 assp.org

documentation will allow for the appro- GORODENKOFF/ISTOCK/GETTY IMAGES PLUS Successful
priate risk mitigations to be put in place,
not excluding the selection of a different be specifically tailored to the contractors contemporary
contractor if needed. on site. The client must have high visibil-
ity in the field. Managing from a distance contractor
Process Meets Practice is not a suitable option if contractors and
The greatest disservice an organization employees alike are to recognize the im- management
portance of procedural discipline.
can render regarding contractor safety requires a strategic
is to ignore or circumvent any part of Regularly completing this task is easier
the contractor management process. said than done, given that most OSH approach to
This practice ultimately negates the need professionals must manage large swaths
for having a process and dramatically of contractors in multiple locations per- the contractor
erodes organizational integrity. The root forming a broad range of work scopes. In
causes of this negligence may vary (e.g., such cases, an organization must make paradox, where
operational conflicts, internal metrics, contractor management a core responsi-
poor scheduling, unskilled labor pool, bility for both line managers and site per- contractors are
unplanned events, competing depart- sonnel. Many of the same auditing tools
mental interests). However, the long-term are needed for site management to doc- both temporary
negative consequences of such action ument contractor performance. Indeed,
(e.g., personal injury, loss of reputation, the most effective method is to formally and permanent,
protracted lawsuits) will far outlive any share ownership of contractor manage-
expected short-term gains of getting the ment and empower site staff to ensure integral and
job done. that contractors perform to expectations.
To start, feedback from weekly contrac- separate, trusted
While documented systems and prior tor meetings and direct lines of commu-
performance data are valuable to any nication to corporate OSH are critical but verified,
contractor management program, they to addressing contractor safety issues as
are only part of a much larger process. they occur. Beyond this, direct involve- subordinate and
Desktop analyses are often given dis- ment throughout the entire contractor
proportionate value in comparison to management process, from selection equal.
the actual competency and quality they to commercial operation, is absolutely
attempt to describe. This is mainly be- essential to identify opportunities for barriers (e.g., procurement, supply chain)
cause of the resource-intensive nature improvement that would be otherwise has created greater contractor account-
of actively evaluating contractors in the missed by corporate management. This ability and site responsibility.
field versus analyzing contractor data in author has observed that shrinking the
the office. The latter is inherently easier. hierarchy and shifting organizational Completing the management cycle
Nonetheless, the contractor management (i.e., plan, do, check, act) is crucial to op-
process extends well beyond the initial erational sustainability and will further
stamp of approval. A common error is drive opportunities to identify contractor
the failure to follow through the entire deficiencies before they materialize in
process past the desktop phase. the field. The level of process fidelity and
consistent contractor review executed
Contractors must be assessed on a by an organization is directly tied to an
continual basis, independent of prior organization’s overall OSH performance.
performance. Whether a contractor has Without verification beyond the initial
two, 20 or 200 workers on site, the same vetting phase, the process cannot impact
assessment process must be consistently on workplace safety. Only when the con-
applied, albeit with varying levels of tractor management cycle is followed in
scrutiny relative to risk. Passing muster its entirety will true gains in safety per-
on paper does not equate to acceptable formance be realized and in turn raise
contractor performance in the field. minimum performance standards across
the board.
This reality becomes apparent when
a contractor’s work habits are observed Set Up for Failure
firsthand. If this part of the contractor The preceding guidance is the mini-
management process is not respected,
the door to risk is left wide open. There- mum that any contractor management
fore, constant communication of OSH system should accomplish. However, a
expectations and verification of expecta- question remains: how can something so
tions in the form of frequent site audits, well-known and inextricably linked to
regular site visits, fact-based evaluations, risk management be consistently over-
contractor interactions, daily/weekly looked? Is the process inherently flawed?
reporting, post-job reviews or any other Let’s examine the reality of applying the
means of assessment, whether formal or management process and its difficulties.
informal, become obligatory. All should
A contractor’s OSH procedures are
only a framework to enforce, they do
not always represent actual practice.

assp.org MAY 2019 PROFESSIONAL SAFETY PSJ 29

BEST PRACTICES

Merely checking a box that a contrac- this should be documented for future risk only compound their own failures in
tor’s energy isolation program exists is projects as a proactive measure. Doing the contractor management process.
not enough. So, what is the appropri- so obligates contractors to reevaluate
ate level of review? The answer lies in their protocols to avoid repeat events and Regardless of organizational priorities,
knowing the basic best practices of OSH allows clients to more efficiently forecast time constraints, resource availability
and creatively auditing against these resource allocation. Rather than only re- or even a spurious sense of security,
practices in the office and in the field. sponding to outcomes with written rep- contractors should not be expected to
What distinguishes a functional con- rimands, repetitive change orders, verbal assume any operational risk. Contractors
tractor management program from one warnings or, worse yet, near-hit reports, are by definition an extension of compa-
on autopilot is the ability to ask ques- documented nonconformance can feed ny risk and as such must be managed be-
tions that address the underpinnings of back into the procurement process and yond their impact on project quality. An
a contractor’s programs and gauge the preemptively shift operational risk away actively engaged contractor management
depth of their competency. For example, from the project before any contractors system presents numerous potential
ask for an energy isolation program, as arrive on site. Documented nonconfor- gains in safety for a reasonable invest-
well as completed LOTO forms, train- mance breaks the familiar cycle of repeat ment relative to potential risk. As noted,
ing documentation, PPE requirements mistakes and promises to improve. At the slightest improvement such as refor-
and a specific list of equipment that the some point, no matter how convenient or mulating questions, changing medium
contractor is qualified to work on. The cozy a business relationship is, without or consistent exchanges with contractors
contractor should be able to describe some measure of OSH accountability, will start paying dividends almost im-
in detail the specific types of hazard- repeat errors can and will metastasize, mediately. Alternatively, failing to make
ous energy present and their isolation skewing expectations and normalizing sustained investments in contractor
methods. Follow up with a field visit and deviations within the process. There- management can lead to pronounced
verify that these conditions are actually fore, organizations should actively track losses in overall contractor quality and
followed. If any part is unsatisfactory or nonconformance as a means to protect performance, furthering the degradation
lacks specificity, it is time to reassess. system integrity and transfer risk to the of the contractor base.
forefront of a project.
One should ask for clarification, Successful contemporary contractor
not change. Clients often engage in Erasing the Status Quo management requires a strategic ap-
self-deception when it comes to asking Any OSH process performed passively proach to the contractor paradox, where
contractors to modify or differently contractors are both temporary and
interpret their management systems to is destined to produce failures at nearly permanent, integral and separate, trusted
satisfy the client’s standard. Any deter- every step; contractor management is no but verified, subordinate and equal. Ad-
mined contractor can modify a policy exception. The process does not seek to equately assessing risk from the perspec-
to meet a client’s requests, especially remove contractors from an ever-grow- tive of these multiple states demands a
when a major project is on the line. The ing pool of potential partners but rather system reflective of the level of their in-
idea should not be to subjugate contrac- aims to build up a reliable contractor terconnection. As a result of this inherent
tors to the client’s management system; group that exemplifies an organization’s inseparable risk, regardless of the client’s
doing so will inevitably lead to lip ser- commitment to OSH principles. Opti- intent, any action on a contractor man-
vice and deteriorating relationships. mally, the OSH standards by which a agement system will yield either positive
Contractors are business partners, not contractor operates should be no differ- or negative synergistic and compounding
subordinates. Most require and wel- ent from those used by the organization effects on contractor quality. Simply put,
come guidance to successfully accom- that hired it. Contractor risk is not a contractor’s quality is a function of the
plish a work scope without incident. separate from company risk. Hence, a client’s capacity to align competing para-
Expectations and obligations should be company’s expectations of itself cannot doxical states in the same direction. One
clearly defined from the beginning. If differ from the expectations it has for its must remember that paradoxes cannot
a contractor’s procedure does not meet contractors. These expectations must be be solved, they always exist in some form
a minimum standard, one should doc- applied consistently and equitably across or another. What counts is how they are
ument the discrepancy and bridge the all scopes of work. This creates an atmo- managed. PSJ
gap. Often a bridging document or man- sphere in which accountability is viewed
agement of change will suffice to clarify as a two-way street and forces companies References
any perceived deficiencies and create a to broaden their scope of OSH respon-
sense of collaboration rather than de- sibilities. Doing so advances the core Beale, C.J. (2003). Factors influencing the
pendence. objective of developing a high-perform- safe management of contractors on major haz-
ing contractor base and creates a cycle of ard installations. Proceedings of the Institution
Documenting contractor noncon- positive reinforcement. Conversely, com- of Chemical Engineers Symposium, Manchester,
formance is a necessity and should be panies that treat contractor liability as U.K.
used as often as the situation arises. diminutive and severable from their own
Often nonconformance is followed by Tombs, S. (1990). A case study in distorted
disciplinary or negative action against communication. Proceedings of the Institution
a contractor. However, in practice, of Chemical Engineers Symposium, London,
documented nonconformance is a tool U.K.
for overall process improvement, not
punishment. If a contractor is unable to Stefan Malhotra, M.P.H., CSP, ASP, CHMM, REM, is an OSH professional in the energy indus-
meet its OSH obligations for any reason, try, specializing in management system development, emergency response and incident investigations.
Malhotra has a master’s degree in Environmental and Occupational Health from University of Texas,
School of Public Health in Houston and an undergraduate degree from University of Texas at Austin. He
is a professional member of ASSP’s Gulf Coast Chapter, and a member of the Society’s Environmental
Practice Specialty.

30 PSJ PROFESSIONAL SAFETY MAY 2019 assp.org

LEADING THOUGHTS

Four Ways to Effectively Attract

A DIVERSE WORKFORCE

By Jeremy Eskenazi

Is your team diverse? Do you invest to ensure that your team reflects the needs and
attitudes of your customers and clients? They should reflect the communities your
employees live in, work in and provide services to.

FATCAMERA/E+/GETTY IMAGES When people think about diversity, they typically rooms facing the correct direction? Do your gyms have Jeremy
focus on gender, ethnicity and age. These are important areas that are exclusive for women? How is your pay Eskenazi
aspects to focus on, but another kind of diversity is often equity based on gender? These are things that can help
overlooked: diversity of thoughts, background and experi- attract top talent and show that the organization will Jeremy Eskenazi is
ences. If elements of this are missing in your organization, welcome people as equal employees without singling founder of Riviera
it is likely that people mostly think the same way, and new them out or making them feel that they will not find a Advisors, (www.riviera
ideas and ways to problem solve and innovate may be sense of belonging at your company. advisors.com) a bou-
stunted. When you have employees who only follow the tique recruitment
boss, the only ideas you have are from that one source. In addition to finding the right candidates, diversity and talent acquisition
brings several important benefits to your organization. management and
While there is no one-size-fits-all playbook for at- Imagine if those who applied for your job postings came optimization consult-
tracting diversity, it is important to make your organi- in for an interview and did not see anyone who looked ing firm, an interna-
zation attractive for diverse talent. To effectively attract like them, or if all those who interviewed them asked the tionally recognized
diverse candidates, four success practices have been same questions in the same way. They likely would not be speaker and author
effective: referral programs, early careers/university interested in continuing the discussion. Your employer of RecruitCONSULT!
strategy, cultural awareness training for hiring manag- brand is only as good as what employees and candidates Leadership: The Cor-
ers and workplace preparedness. will say about the company when you are not in the porate Talent. He is a
room. If you take the opportunity to show that it is a pro- specialized training
Referral Programs gressive company that is visibly investing in many areas and consulting profes-
If you have individuals on your team who are highly of diversity, it will be obvious from their first encounter. sional, helping global
human resources
engaged and doing a great job, they likely have similar While it is generally true that almost everyone values di- leaders transform how
friends. Consider offering incentives with shorter payout versity, people in younger generations are often vocal about they attract top talent
times and getting immediate impact to ensure that your their values. Moreover, many expect diversity and can be at some of the world’s
team is helping to attract people who are a good fit for outspoken about how much it matters to them in a work- most recognized com-
the company. They can also act as ambassadors in alum- place. By bringing in a diverse group of people to the orga- panies.
ni groups, associations or clubs to which they belong. nization, you will have access to broader networks, which
will spur further diversity opportunities and all the benefits This article was
Early Careers/University Strategy that brings. Think of how much more likely it is that diverse originally published
Attracting talent right out of school is often a strategy people who enjoy working at your organization will intro- in Article Weekly.
duce the company and advocate for it in their circles. Reprinted with
for helping shape the career of younger people but it is permission.
also a great way to find diversity. A strong university re- While the business reasons for diversity are compelling
cruiting strategy is a terrific way to help create a diverse on their own, many jurisdictions also have regulatory
team because you can more easily target diversity on a requirements that must be considered as well. It is not just
university campus through student clubs and organiza- laws for the jurisdiction the company operates in; it could
tions. Setting up early career development programs and be laws necessary to sell to your customers. For example,
considering individuals in majors that you would not tra- if your company sells to the U.S. government, laws require
ditionally seek out are also good for the employer brand the company to submit an affirmative action plan to im-
and ensures that talent can develop with the business. prove diversity at the organization and provide updates
during the term of the contract. There is also an audit pro-
Cultural Awareness Training for Hiring Managers cess to ensure that organizations are adhering to their plans.
We know that hiring managers sometimes need help
Most importantly, the organization should invest
to build relationships. While it is unwise to force training in diversity not only because it is the right thing to do,
on managers (which often backfires), integrating train- but because the company will get much better business
ing that helps them identify unconscious bias is an area results. Do not let regulations drive diversity efforts. The
of learning and development that has taken off in recent best way to improve diversity is to be truthful. No matter
years and has been effective in many organizations. how many smiling, ethnically diverse models you may
hire to represent the brand or false testimonials you may
Workplace Preparedness want to post, it is easy to spot a workplace that does not
It is one thing to say you want diversity; setting up value diversity. The truth always comes out. Give your
organization the best competitive advantage you can by
your physical space and your benefits program to ac- welcoming diversity into your team and celebrating it in
commodate it is another. Does your office have a space real ways. All types of diversity bring something new to
for nursing mothers? Does the company offer extended the table, and every organization needs fresh ideas. PSJ
parental leave and are your human resources policies
inclusive for LGBT individuals? Do you have prayer

assp.org MAY 2019 PROFESSIONAL SAFETY PSJ 31

WORTH READING

Book Review

PHYSICAL HAZARDS OF THE WORKPLACE
By Barry Spurlock, 2018, Boca Raton, FL: CRC Press—Taylor and Francis Group

A review by Chad McDonald, M.S., CSP, CHST

Physical Hazards of the Workplace the appendixes. As a safety professional,
delivers a well-organized reference I would not use the appendixes but rath-
for safety professionals. Spurlock’s er reference the current Code of Federal
book is an excellent resource for a Regulations. That said, every standard
broad overview on identifying and cited in the book is current. The author
controlling physical hazards. As the also provides a useful toolbox of check-
author suggests, injury rates can im- lists, guidelines, and safety and health
prove through mere luck, but the risk program examples. Whenever tasked
is only reduced through purposeful, with the fundamental OSH functions
quality efforts in identifying and con- noted, I am always searching for best
trolling hazards. The publication is practice examples as a starting point
intended to be a reference for safety for my programs and the book is a great
practitioners. Spurlock suggests using place to find such examples.
it as a textbook.
Overall, this book is a useful reference
The book does a great job of giving for both new or experienced OSH pro-
guidance on four fundamental OSH fessionals. It provides a quick overview
profession tasks: anticipating, identify- of how to identify and control the most
ing, analyzing and controlling hazards common workplace hazards that safety
in the workplace. I believe the book’s professionals encounter. As a safety and
overall strength is that Spurlock focuses health trainer, I plan to reference the
on the need-to-know information of book when I’m designing a new course
each physical hazard addressed. The or revising existing ones for insights on
book references many general industry identifying and controlling physical haz-
and construction standards located in ards in the workplace.

Industrial Ventilation What Everyone Must Know
About OSHA: General Industry
By ACGIH, 2019, Cincinnati, OH: Author
By John Teeples, 2019, Davenport, IA: Mancomm
This two-volume set describes
the elements of designing and What Everyone Must Know About OSHA: General Industry, 2019
effectively maintaining an in- edition, is a comprehensive volume that introduces readers to
dustrial ventilation system. The OSHA and leads them through each component of the agency’s
set is intended for management general industry standards in easy-to-understand language.
and those who work with indus-
trial ventilation systems. First published in 2004, the new edition of this book features
24 updated chapters, pretests, updated OSH data, improved
The first book in the set, In- sample forms and documents, and synopses of current regu-
dustrial Ventilation: A Manual latory requirement to ensure that the reader has the tools and
of Recommended Practice for knowledge needed to provide employees with a safe workplace.
Operation and Maintenance,
includes guidance and training informa- The book outlines the necessary steps for complying with
tion for personnel, and discussion about OSHA regulations in an easy-to-use format that presents topics
effective industrial ventilation system op-
eration and maintenance. It also discusses in a clear how-to approach.
tools that allow management to deliver the The book is designed for
desired employee protection. Topics include air system testing,
balancing, construction and commissioning, system modifica- use by OSHA Training Insti-
tions, and operator skills and training. tute education centers when
teaching OSHA 10- and 30-
The second book in the set, Industrial Ventilation: A Manual of hour training, and OSHA
Recommended Practice for Design, 30th Edition, is used by engi- 6000-type courses for federal
neers, regulators and industrial hygienists to design and evaluate agencies and safety commit-
industrial ventilation systems. Updates to this edition include con- tees, and can be a curriculum
ceptual figures that incorporate computational fluid dynamics and component for the OSHA 500
a new control concept for vacuum extraction on welded guns. train-the-trainer program.

Learn more at https://bit.ly/2DqTdtV. Find the book at https://
mancomm.com/what-every
one-must-know-about-os
ha-gi.

32 PSJ PROFESSIONAL SAFETY MAY 2019 assp.org

Book Review

THE SAFETY TRAINING NINJA
By Regina McMichael, 2019, Park Ridge, IL: ASSP

A review by Anna M. Aragon, D.H.Ed., M.S.I.R., M.A.Ed., CSP, CHES, REHS/RS

The intended audience of The Safety Training Ninja is a useful while other feedback can
human resources, safety or similar professional tasked with be discarded. Experience and
delivering safety training. However, the book parts from the education help identify the con-
notion that none have received formal training or education structiveness and feasibility of
on andragogy or adult learning topics. The book is aimed at such comments.
individuals tasked with delivering safety training without prior
knowledge on how to become an effective trainer. OSH professionals who
might find this book useful are
McMichael devotes 10 chapters to becoming an effective individuals who, without any
safety trainer with the following topics: change; systems prior knowledge of adult edu-
approach; audience and business; design; development; im- cation principles, andragogy or
plementation; evaluation; collaboration; e-learning; and training find themselves in a
PowerPoint. The book is organized by common headers such position of needing to educate
as acknowledgements, introduction, chapters, conclusion, and train others. Instead of
further reading, index and author information. The index is buying a variety of books or references on the topic, this is a
a useful element when looking for specific information. Ninja great starter resource.
tips scattered throughout the book bring attention to specific
factors. The information is clearly presented as I did not have Overall strengths of the book include elemental factors such
to re-read any sentence. References are included at the end of as knowing your audience, planning for success and evaluating
each chaper. While some of the references would not be ade- past experiences. One weakness, or perhaps just a characteris-
quate for scholarly purposes, they may provide useful infor- tic, of the book is that it is not a scholarly publication. The book
mation to a safety training ninja in development. reads as a series of elements to consider, accompanied by Mc-
Michael’s personal experiences.
McMichael discusses how to manage trainer feedback and
address comments of a personal nature. I enjoyed reading The uniqueness of this book rests on the personal experienc-
her perspective on feedback because I have often found that es of its author. McMichael’s safety voyage started with a per-
managing feedback is not commonly taught. Some feedback is sonal tragedy. Since then, her involvement in the safety field has
spanned nearly three decades and counting.

#StandUpForHealth Total Worker Health

By COBA Europe, 2019, Fleckney, England: Author Edited by Heidi Hudson, Jeannie
Nigam, Steven Sauter, et al., 2019,
COBA Europe’s e-book #StandUpFor- floor matting. Over a 7-week period, Washington, DC: American Psycholog-
Health examines the potential health ef- researchers collected data from 30 body ical Association
fects of static work positions by presenting areas using a body discomfort diagram.
facts and statistics associated with pro- Participants reported considerable dis- Total Worker Health brings togeth-
longed sitting or standing and the detri- comfort 5.2 more times when matting er knowledge and viewpoints from
mental effects they can have on a person. was not used. thought leaders on integrative preven-
tion strategies that safeguard and ensure
Designed to educate people about The book also discusses workplace fatigue, the health and well-being of workers.
musculoskeletal disorder prevention, lost productivity due to sickness or injury, This book is based on the NIOSH pro-
this book incorporates the latest muscu- and overall well-being in the workplace. gram of the same name that targets pol-
loskeletal disorder statistics and recent icies, programs and practices to address
results from COBA’s Standing at Work Download the e-book at www.coba worker safety and health in both the
survey. The e-book includes europe.com/standupforhealth. physical and organizational work envi-
a section from a diabetes and ronment, and outside the workplace.
high-risk specialist podiatrist
who discusses the effects of Intended for OSH professionals,
prolonged standing as well as human resources managers and policy-
what preventive steps workers makers, the book includes organizational
can take, such as standing on a approaches for program implementation;
cushioned floor, continuously examples of applications for diverse
moving to keep circulation worker populations; and evidence of pro-
flowing to avoid swelling and gram effectiveness for addressing work
using cushioned insoles. conditions that impact mental health,
fatigue, sleep and work-life conflict.
The book also outlines a
study commissioned by COBA Find the book at www.apa.org/pubs/
Europe in which reserachers books/4316192?tab=1.
compared standing on con-
crete with using anti-fatigue

assp.org MAY 2019 PROFESSIONAL SAFETY PSJ 33

RISK MANAGEMENT
Peer-Reviewed

RISK TREATMEN

Harmonizing the Hiera
& Inherently Safer Des

By Bruce K. Lyon and Georgi Popov health and industrial hygiene beginning in the late JAMESTEOHART/ISTOCK/GETTY IMAGES PLUS
1940s. In Advanced Safety Management, Manuele
TTHE PRIMARY GOAL FOR AN OSH PROFESSIONAL is to (2008) cites the third edition of National Safety
reduce operational risk to a level that is considered as Council’s 1955 Accident Prevention Manual as an
low as reasonably practicable (ALARP). ANSI/ASSP early source of a hierarchy of controls.
Z590.3-2011 (R2106), Prevention Through Design, de-
fines ALARP as “that level of risk which can be further The concept of ranking risk reduction strategies has
lowered only by an increase in resource expenditure developed over the years. Originally, the principle of the
that is disproportionate in relation to the resulting hierarchy of controls was to control the hazard as close
decrease in risk.” Achieving and maintaining ALARP to the source as possible, with 1) engineering as the top
should be the goal, the state of being in all workplaces. control measure and 2) PPE as the second option.
One concept OSH professionals use to achieve the state
of ALARP is the application of risk reduction strate- Using engineering solutions to control
gies according to the hierarchy of controls. hazards at their source or in the pathway
of transmission is more reliable and less
Origins of the Hierarchy of Controls Concept burdensome to the worker than personal
OSH professionals have traditionally ranked con- protective equipment. Once installed, these
controls work day after day with minimum
trol measures according to their effectiveness and routine intervention beyond maintenance
reliability in removing or controlling hazards. This and monitoring. (U.S. Congress, OTA, 1985)
concept has become known as the hierarchy of con-
trols. It is thought to have its origins in occupational

KEY TAKEAWAYS

•The primary goal of safety and

risk management is to achieve
and maintain a level of risk that
is as low as reasonably practi-
cable while accomplishing the
organization’s objectives. This is
achieved by selecting and apply-
ing appropriate risk treatments
using a hierarchy approach.

•A fundamental concept within

operational risk management is
the ranking of hazard controls and
risk treatment strategies known as
the hierarchy of controls.

•Various hierarchy of controls

models exist, each having slight
differences in control options
and applications, presenting
some confusion to the user. A new
risk reduction hierarchy model
is presented that incorporates
inherently safer design strategies
in a more comprehensive format
accompanied by a decision tree.

34 PSJ PROFESSIONAL SAFETY MAY 2019 assp.org

NT STRATEGIES

archy of Controls
sign Concepts

The concept was further advanced with the writ- The Treatment of Risk
ings of William Haddon and his concepts of energy Risk treatment involves the selection and appli-
control. Haddon (1970) proposed 10 strategies for
reducing and avoiding harm or damage based on cation of risk reduction measures for a risk that is
a model of potentially harmful energy transfer. judged to be unacceptable. The output of the risk
His strategies, which include preventing, reducing, assessment is a valuable input to the risk treatment
modifying, separating, detecting and strengthening process. The risk assessment results should be used
against energy transfer risk, have had a major influ- to make important decisions on how to control
ence on the thinking about safety and risk, and the anticipated and identified hazards, and reduce
concepts of risk treatment ranking and hierarchy. their risk. Without acting on the risk assessment’s
findings and treating risk, a risk assessment is of no
In the present day, the hierarchy of controls concept value, and in fact may lead to negligence of the orga-
provides a systematic way of thinking, considering steps nization (Popov, Lyon & Hollcroft, 2016).
in a ranked and sequential order, to choose the most
effective means of eliminating or reducing hazards and ISO Guide 73 (ANSI/ASSE Z690.1-2011) defines
their associated risks. Acknowledging that premise (that risk treatment as the “process to modify risk.” For
risk reduction measures should be considered and taken operational and hazard risks, the process to modify
in a prescribed order) represents an important step in risk involves the selection and application of one or
the evolution of the practice of safety (Manuele, 2008). more treatment options to reduce risks to a level that
is as low as reasonably practicable and acceptable

assp.org MAY 2019 PROFESSIONAL SAFETY PSJ 35

FIGURE 1

BOW TIE ANALYSIS DIAGRAM

Hazards Causes Preventive Scenario Mitigative controls Resulting
controls consequences

Escalation factor

Escalation factors

FIGURE 2 Prevention: Risk prevention is the act

SAFER TECHNOLOGY & ALTERNATIVES ANALYSIS of keeping something from occurring
that would otherwise cause risk or harm.

For example, a pressure relief valve on an

enclosed tank or vessel prevents over-pres-

surization and explosion. Preventive action

is defined as “an action taken to reduce

or eliminate the probability of specific

undesirable events from happening” and

is described as generally less costly than

mitigating the effects of negative events

after they occur (BusinessDictionary.com,

2018). ANSI Z590.3 reinforces this in Sec-

tion 9, Hierarchy of Controls, which states

that the first four control levels of the hier-

archy are more effective because they are

preventive actions that eliminate or reduce

risk by design, elimination, substitution

and engineering measures.

Mitigation: This term has become more

popular recently by some governmental

agencies, organizations and groups. The

term mitigation is generally defined as the

action of reducing the severity or serious-

ness of something, thus making a condi-

tion or consequence less severe. Federal

Emergency Management Agency (FEMA,

2017) defines mitigation as “the effort to

to the organization. ISO Guide 73 provides several reduce loss of life and property by lessen-

notes that further describe risk treatment options: ing the impact of disasters.” Rather than a preven-

•avoid the risk by deciding not to start or continue tive measure, mitigation is a reactionary measure

with the activity that gives rise to the risk; used to reduce severity. An emergency action plan

•take or increase risk in order to pursue an opportunity; is a mitigation plan that is designed to limit damage

•remove the risk source; and harm in response to an emergency-type event.

•change the likelihood; Protection: Similar to mitigation, protection is the

•change the consequences; act of shielding, covering or keeping an asset from

•share the risk with another party or parties, in- harm. It is designed to limit the severity of harm or

cluding contracts and risk financing; impact rather than prevent the event from occurring.

•retain the risk by informed decision. Examples of risk protection include automatic fire sup-

For the OSH professional, common terms used in pression systems in buildings; cathodic protection for

association with operational risk treatment include an underground storage tank; and PPE. Insurance (or

control, reduction, mitigation, protection and preven- risk transfer) could also be considered a form of pro-

tion. These terms are often used interchangeably; how- tection measure for the insured parties or properties.

ever, there are some subtle, yet important distinctions Control: Risk control is a more encompassing

to consider regarding these risk treatment terms. term meaning to manage risk by reducing likelihood

36 PSJ PROFESSIONAL SAFETY MAY 2019 assp.org

FIGURE 3

NIOSH PTD HIERARCHY OF CONTROLS MODEL

and severity of an exposure. ISO Guide 73 Most Elimination Physically remove
(ANSI/ASSE Z690.1-2011) defines control effective the hazard
as a measure that modifies risk and may
include processes, policies, devices, prac- Substitution Replace the hazard
tices or other actions. As indicated in the
ISO standard, controls may not always Engineering Isolate people
exert the intended or assumed modifying controls from the hazard
effect. Some in the profession use the term
loss control; however, management of risk Administrative Change the way
involves controlling the risk rather than controls people work
just controlling the resulting loss.
Least PPE Protect the
Reduction: Risk reduction, like risk con- effective worker with PPE
trol, seeks to minimize or reduce the like-
lihood and severity of an unwanted risk.
Reduction is defined as making something
smaller in size, amount or number. Note. Adapted from “Hierarchy of Controls,” by NIOSH, 2015, www.cdc.gov/niosh/topics/hierarchy.

A comprehensive approach to reducing FIGURE 4
risk to an acceptable level often requires
layers of controls or defenses, or a combi- ANSI/ASSP Z10 HIERARCHY OF CONTROLS MODEL
nation of preventive, protective, mitiga-
tive and control measures (Lyon & Popov, Most Controls Examples
2016). For example, Figure 1 shows a bow effective 1) Elimination •Design to eliminate hazards, such as falls,
tie analysis diagram, which identifies 2) Substitution hazardous materials, noise, confined
preventive measures on the left side of the Least 3) Engineering spaces and manual material handling.
bow tie (barriers positioned between the effective controls •Substitute for less hazardous material.
hazard-causes and the event) and the mit- •Reduce energy. For example, lower speed,
igation measures on the right side of the 4) Warnings force, amperage, pressure, temperature
bow tie (reactive measures between the and noise.
hazardous event and the consequences). 5) Administrative •Ventilation systems
Both preventive and mitigative measures controls •Machine guarding
are risk reduction treatment strategies. •Sound enclosures
6) PPE •Circuit breakers
OSH professionals should understand •Platforms and guard railing
these differences and make use of all the •Interlocks
available risk reduction strategies to prop- •Lift tables, conveyors and balancers
erly manage operational risk. •Signs
•Backup alarms
Risk Treatment Plans •Beepers
Risk treatment plans can involve a single •Horns
•Labels
control or multiple risk reduction measures Procedures
to accomplish the risk reduction desired. •Safe job procedures
Concepts such as inherently safer design, •Rotation of workers
layers of protection, recognized and gener- •Safety equipment inspections
ally accepted good engineering practices, •Changing work schedule
and safer technology and alternatives,
along with the hierarchy of controls should Training
be incorporated into the risk treatment •Hazard communication training
plan. Risk treatment options can include •Confined space entry
the decision to 1) avoid the risk by choosing •Safety glasses
to not engage in the activity or exposure; •Hearing protection
2) eliminate the risk by removing the risk •Safety harnesses and lanyards
source; 3) reduce the likelihood or reduce •Gloves
the severity; 4) share the risk among other •Respirators
parties such as contracts and risk financ-
ing; and 5) retain the risk such as self-fund- Note. Adapted from Occupational Health and Safety Management Systems [ANSI/ASSP Z10-2012
ing or other risk-based decisions. (R2017)], by ANSI/ASSP, 2017, Park Ridge, IL: ASSP.

Risk treatment is a continuous process
that involves the formulation, selection
and implementation of treatment plans,
evaluating the residual risk levels after
treatment to determine acceptability, and
for those that remain unacceptable, fur-
ther treatment is required. For treatments

assp.org MAY 2019 PROFESSIONAL SAFETY PSJ 37

FIGURE 5

ANSI B11 SAFETY OF MACHINERY HAZARD CONTROL HIERARCHY

Risk reduction Examples Influence on risk factors Classification
measures •Impact on overall risk Design out
Most •Eliminate pinch points (increase (elimination) by affecting
preferred clearance) severity and probability of harm Engineering
•Intrinsically safe (energy •May affect severity of harm, controls
Elimination or containment) frequency of exposure to the
substitution •Automated material handling hazard under consideration, and Administrative
(robots, conveyors) the possibility of avoiding or controls
Guards, •Redesign the process to eliminate or limiting harm depending on
safeguarding reduce human interaction which method of substitution is
devices and •Reduced energy applied.
complementary •Substitute less hazardous chemicals •Greatest impact on the
•Barriers probability of harm (occurrence
measures •Interlocks of hazardous events under
•Presence sensing devices (light certain circumstances)
Awareness curtains, safety mats, area scanners) •Minimal, if any, impact on
devices •Two-hand control and two-hand trip severity of harm
devices
Training and •Enabling devices •Potential impact on the
procedures •Lights, beacons and strobes probability of harm (avoidance)
•Computer warnings •No impact on severity of harm
Least PPE •Signs and labels
preferred •Beepers, horns and sirens •Potential impact on the
•Safe work procedures probability of harm (avoidance
•Safety equipment inspections or exposure)
•Training •No impact on severity of harm
•Lockout/tagout/verify •Potential impact on the
probability of harm (avoidance)
•Safety glasses and face shields •No impact on severity of harm
•Earplugs
•Gloves
•Protective footwear
•Respirators

Note. Adapted from Safety of Machinery (ANSI B11.0-2015), by ANSI/B11, 2015, Houston, TX: B11 Standards.

FIGURE 6 FIGURE 7

TWO STAGE ITERATIVE APPROACH TO THE ANSI/ASSP Z590.3 PTD RISK
HIERARCHY OF CONTROLS & RISK REDUCTION REDUCTION HIERARCHY OF
CONTROLS MODEL
Action steps Goal Result
Controls
Stage 1 •Change task, function, location Hazards Most Risk avoidance: Prevent entry of hazards
Eliminate eliminated preferred into a workplace by selecting and

•Substitution of materials incorporating appropriate technology and
work methods criteria during the design
Stage 2 •Engineering controls Balance/ Reduce risks to processes.
optimize a safe and Eliminate: Eliminate workplace and work
•Awareness (e.g., warnings, signs acceptable methods risks that have been discovered.
and devices, placards) level (culture Substitution: Reduce risks by substituting
drives the mix) less hazardous methods or materials.
•Safe operating procedures Engineering controls: Incorporate
engineering controls/safety devices.
•Training (e.g., operator main- Warning: Provide warning systems.
tenance) Administrative controls: Apply
administrative controls (e.g., the
•PPE organization of work, training, scheduling,
Least supervision).
Note. Adapted from Safety of Machinery (ANSI B11.0-2015), by ANSI/B11, 2015, preferred PPE: Provide PPE.
Houston, TX: B11 Standards.
Note. Adapted from Prevention Through Design: Guide-
lines for Addressing Occupational Hazards and Risks in
Design and Redesign Processes [ANSI/ASSP Z590.3-2011
(R2016)], by ANSI/ASSP, 2016, Park Ridge, IL: ASSP.

38 PSJ PROFESSIONAL SAFETY MAY 2019 assp.org

or controls that have been implemented, assessment 2) Reduce severity. Second-order inherent safety
of their effectiveness and reliability are required. measures; measures that treat the hazard by reduc-
This may require testing and verification of some ing the hazard’s intensity or severity.
degree to ensure that controls are working as ex-
pected. Also, it is important to determine that the 3) Reduce likelihood. Second-order inherent safe-
implemented control measures have not created any ty measures; measures that reduce the likelihood of
unintended consequences or introduced new risks. the event or exposure.

RAGAGEP 4) Passive safeguards. Layers of protection; mea-
The term recognized and generally accepted good sures that reduce the frequency or impact of the
hazard without the need for external input or activa-
engineering practices (RAGAGEP) was introduced tion of the control. Examples include fixed guards,
in 1992 by OSHA in the process safety management barriers, dikes and containment buildings.
(PSM) standard (29 CFR 1910.119). RAGAGEP in-
volves the selection and application of appropriate 5) Active safeguards. Layers of protection; mea-
engineering, operating and maintenance knowledge sures that detect and respond to process deviations
when designing, operating and maintaining chemi- that require external input and activation of the
cal facilities with the purpose of ensuring safety and control to provide safety.
preventing process safety incidents. This concept is in
alignment with the prevention through design (PTD) 6) Procedural safeguards. Layers of protection;
concept of designing in such measures and managing measures such as operating procedures, management
risk throughout a system’s life cycle. The use of appli- system procedures and administrative measures that
cable RAGAGEP as well as regulatory requirements rely on the human element to respond or perform.
should be one of the first considerations made when
selecting available risk treatments. Following the use of inherent safety measures,
the remaining hazards and their residual risk are
STAA & Inherent Safety minimized through the use of layers of protection
Another risk reduction approach referenced in the including passive, active and procedural safeguards
to a level that is acceptable to the organization.
OSHA PSM standard and U.S. EPA’s risk management
plan standard is the safer technology and alternatives The Hierarchy of Risk Treatment Strategies
analysis (STAA) concept. STAA (Figure 2, p. 36) is the Risk treatment selection should always be linked
concept of integrating various risk reduction strategies
that work toward making a facility and its chemical to the concept of the hierarchy of controls to reduce
processes as safe as possible (EPA, 2015; OSHA, 2017). risk to an acceptable level. Hazard and risk control
measures vary in their degree of risk reduction, effec-
STAA follows a hierarchy of risk treatment op- tiveness and reliability. The hierarchy of controls con-
tions beginning with the use of inherently safer cept is structured with the most effective and reliable
technology or inherently safer design applied at the risk reduction options at the top, descending to the
process design stage (CCPS, 2008b; EPA, 2015). The least preferred option. The hierarchy model generally
concept of inherently safer design and inherent safe- starts with avoidance of risk (excluded in some mod-
ty focuses on eliminating or reducing the hazards els), followed by elimination of risk, then substitution
associated with a set of conditions and is closely of risk. From there, residual risk is controlled using
aligned with the PTD concept. The concept of inher- engineering controls, warning systems (also excluded
ent safety requires designers to attempt to eliminate in some models), administrative controls and PPE.
or reduce hazards that are identified at each stage in
the system’s life cycle, and design safety systems to Various models exist. Unfortunately, OSH text-
control hazards rather than accept them. The theory books and others continue to refer to engineering
is that a process is inherently safer if it reduces or controls as the highest level of control. It is import-
eliminates the hazards associated with materials ant to recognize and understand the differences
and operations used in the process. Such elimina- among the various hierarchy of controls models.
tions and reductions of risk are permanent in the
system. It may not always be feasible to eliminate or Jensen (2007) provides a unique review of several
minimize hazards, but the inherent safety concept hazard control strategies. He lists nine strategies and
requires that this first be attempted. An inherently shows their relationships with 1) Haddon’s (1980) 10
safer process should not, however, be considered strategies for reducing damage of all kinds original-
inherently safe or absolutely safe. There will always ly based on his energy control theory; 2) Johnson’s
be some residual risk. While implementing inherent (1975) “The Management Oversight and Risk Tree”;
safety concepts will move a process in the direction 3) Asfahl’s (2004) list from Industrial Safety and
of reduced risk, it will not remove all risks. Health Management; and 4) Manuele’s (2003) list of
nine strategies from On the Practice of Safety. Jen-
The hierarchical steps for managing chemical and sen’s proposed strategies, which closely align with
process hazards and risk in the STAA approach are: Haddon’s list, are well explained in his article and
presented in the following order:
1) Avoid hazard. First-order inherent safety mea-
sures; measures that would avoid or eliminate the 1) Eliminate the hazard.
hazard altogether. 2) Moderate the hazard.
3) Avoid releasing the hazard.
4) Modify release of the hazard.
5) Separate the hazard from that which
needs to be protected.

assp.org MAY 2019 PROFESSIONAL SAFETY PSJ 39

FIGURE 8

HIERARCHY OF ERGONOMIC RISK CONTROLS

Control method Stage/application Control examples Effectiveness
Avoidance Conceptual stage High
New design Prevent entry of hazard into
Elimination workplace by design, selection of High
Operational stage technologies, equipment and work Moderately
Substitution Existing processes methods.
Redesign Eliminate existing hazard by high
Engineering Conceptual stage changes in design, technologies,
controls Operational stage equipment and methods. Moderate
Existing processes Substitute materials, sizes, weights
Administrative Conceptual stage and other aspects to a lower Moderately
controls Operational stage hazard severity or likelihood. low
Existing workstations Reduce hazard by changes to
PPE Redesign workplace, tools, equipment, Low
Operational stage fixtures, adjustability, layout,
Practices and procedures lighting or work environment.
Reduce exposure to hazard by
Operational stage changes in work practices, training,
Workers job enlargement, job rotation, rest
breaks or work pace.
Reduce impact of hazard to
employee by use of protective
equipment and materials such as
vibration attenuation gloves.

Note. Adapted from “Improving Ergo IQ: A Practical Risk Assessment Model,” by B.K. Lyon, G. Popov and K. Hanes, 2013,
Professional Safety, 58(12), pp. 26-34.

6) Help people perform safely. reduce the likelihood of its occurrence. A risk treat-
7) Use PPE. ment plan should include options and alternatives
8) Improve the resistance of that which that eliminate the hazard or reduce its risk.
needs to be protected.
9) Expedite recovery. To provide OSH professionals a broader range
of risk reduction strategies that include inherently
Variations of control hierarchies exist, including safer design concepts, the authors have proposed a
those from NIOSH and ANSI standards, which are hierarchy of risk treatment (HORT) strategies hier-
presented in Figures 3 through 7 (pp. 37-38). The B11 archy model (Figure 9).
annex presents a unique and well-reasoned two-step
approach to applying controls (Figure 6, p. 38). The The model includes 10 risk treatment strategies, or
theory is that risk treatment should first attempt to tiers, which are divided into three categories: 1) de-
eliminate or substitute the hazard, then consider, in sign/redesign; 2) engineering; and 3) administrative
descending order, engineering controls, awareness controls. Design/redesign risk treatments, the first
devices, safe operating procedures, training and PPE category, are the only risk treatments that are long
(lower level controls) to reduce residual risk. lasting and typically do not degrade over time. Haz-
ards avoided, eliminated or substituted through design
Among the established models, the ANSI/ASSP will not change unless the design feature is changed.
Z590.3 Prevention Through Design model (Figure 7, However, the second and third categories of risk treat-
p. 38) is considered the most complete hierarchy of ments are less resilient. Engineering controls can be
controls model since it includes risk avoidance and circumvented and, over time, tend to degrade, wear
warning systems. out or lose effectiveness. Such controls also require
ongoing inspection, testing, maintenance and repair.
For risks associated with ergonomics, the authors Administrative controls are the least effective and de-
have developed a hierarchy of ergonomic risk con- grade more quickly due to variations in the quality of
trols model based on the PTD hierarchy identifying training, application and management, as well as orga-
application phases and control examples to aid the nizational influences and human fallibility. For these
user (Figure 8). reasons, administrative controls are considered the last
resort in the hierarchy. Following are brief descriptions
A Hierarchy of Risk Treatment Model and examples of each risk treatment strategy:
The objective of operational risk management is
1) Avoid. New hazards/risks are intentionally
to implement appropriate risk reduction plans to avoided in new designs, as well as in redesigns, ad-
reduce risks associated with each decision made to ditions and modifications to existing systems and
achieve an acceptable risk level. OSH professionals workplaces. Example: In a new facility, design all
should be able to effectively lead risk assessments, walking and working surfaces at the same level to
develop appropriate risk reduction strategies and avoid falls from heights.
advise decision-makers in making appropriate
decisions. Risk treatments (i.e., risk controls) are 2) Eliminate. Existing hazards/risks are elimi-
designed to reduce the risk of a hazard’s effects or nated or removed from systems/workplaces through

40 PSJ PROFESSIONAL SAFETY MAY 2019 assp.org

FIGURE 9

A HIERARCHY OF RISK TREATMENT INCORPORATING
INHERENTLY SAFER DESIGN CONCEPTS

redesign. Example: Eliminate a hazardous Avoid

chemical process from the workplace by re- Eliminate
designing the process or remove it from the

workplace and isolate it away from workers. Substitute
3) Substitute. New or existing hazards/

risks are intentionally replaced with less Minimize

hazardous materials that meet the needs of Simplify
the system or workplace. Example: Replace

a highly hazardous chemical such as pure Passive control
sulfur dioxide with a less hazardous chem-

ical such as potassium meta-bisulfite. Active control

4) Minimize. The amount or quantity

of a particular hazard is minimized to a Warn

level that presents a lower severity risk.

Examples: Minimize the size and weight of Adminstrative

materials to a level that workers can easily

handle; use the smallest quantity of hazard- PPE
ous materials feasible for a process; use the

lowest voltage or energy required; reduce

operating temperatures and pressures.

5) Simplify. The likelihood of error or

occurrence is reduced through simplify- Note. Adapted from “Risk Management Tools for Safety Professionals” [Webinar], by B.K. Lyon
ing the systems or workplace processes and G. Popov, Sept. 6, 2018, Park Ridge, IL: ASSP.
and controls. Examples: Eliminate un-

necessary complexity in controls and evaluate and consider which models and risk reduc-

displays; reduce the number of steps to
complete a critical task; incorporate human factors tion strategies best serve the needs of their organiza-
tions and applications to achieve ALARP.
engineering design into systems to reduce human

error potential. Risk Reduction Strategies Decision Tree
6) Engineer with passive controls. Hazards are Risks should be prioritized to allow decision-mak-

controlled or contained by passive engineering ers to act on the most important risk first so that
controls that protect/function without activation. appropriate resource allocations can be made for
Examples: Install a containment dike around a risk avoidance, elimination, reduction or control.
hazardous material storage tank; install a fixed/per- For more complex situations, a risk treatment or
manent guard on a machine; use hard/fixed barriers. implementation plan may be required to document
the reasons for selecting control options, their ex-
7) Engineer with active controls. Hazards are pected benefits and the methods of implementing the
controlled by active engineering controls that require controls. Such a plan should identify who is respon-
activation to protect or function. Examples: Presence sible for implementing controls, the timeframe and
sensing devices on machines; process controls and resources necessary, and the key performance mea-
safety instrumented systems (SIS); automatic fire sup- sures, reporting and monitoring requirements of the
pression systems and sprinkler systems. implementation.

8) Warn. Awareness device that informs or Selection of the most appropriate risk reduction
warns of residual risks by sight, sound or touch. strategies to achieve ALARP can be achieved by using
Examples: Forklift backup alarms; perimeter warn- a decision tree. Figure 10 (p. 42) illustrates such a risk
ing tape and signage; highway rumble strips to reduction strategies decision tree (Lyon & Popov, 2018b)
indicate drifting off road. that can be used in the risk treatment planning process.

9) Administrative. Hazards are managed by ap- A case example for applying risk reduction strate-
plying work procedures and worker training for safe gies follows:
operation of the system or workplace. Examples:
Written standard operating procedures and pro-

tocols; employee orientation and training; behav- A manufacturing organization plans to

ior-based safety efforts. expand operations by doubling the size of

10) PPE. Hazards are managed by donning and the main facility. As part of the planning

wearing protective clothing and equipment to pre- process, a design and build team that

vent or reduce contact, exposure, and impact or includes OSH professionals is assembled.

harm from hazards. Examples: Respiratory protec- Upon the scoping and development of the

tion; flame-resistant clothing; fall protection harness conceptual designs, the OSH professionals

and lanyard. lay out safety specifications that support

Table 1 (p. 42) compares five hierarchy of controls the organization’s acceptable risk levels

models and their listed risk treatment strategies dis- and business objectives. The design team

cussed in this article. The models range from five to develops and uses a design safety specifica-

10 strategy levels or tiers. OSH professionals should tions checklist.

assp.org MAY 2019 PROFESSIONAL SAFETY PSJ 41

TABLE 1

HIERARCHY OF CONTROLS MODELS: STRATEGY TIERS

Hierarchy of controls models

Risk treatment NIOSH ANSI/ASSP ANSI/ASSP HORT
strategies Z590.3 model
Avoid PTD Z10 ANSI B11
Eliminate 1 1
Most Substitute -- -- -- 2 2
effective Minimize 3 3
Simplify 111 -- 4
Least Engineer: Passive -- 5
effective Engineer 222 -- 6
Engineer: Active 4 --
Warn -- -- -- -- 7
Administrative 5 8
PPE -- -- -- 6 9
7 10
-- -- --

333

-- -- --

-- 4 4

455

566

FIGURE 10

RISK REDUCTION STRATEGIES DECISION TREE

Yes No
Yes

No
Yes
Yes

No
Yes

No

No

No

For each hazard identified or anticipated, od. The team reviews alternative mate-
the team, led by the OSH professionals, rials, chemicals or methods for their risk
determines its risk level and whether it is levels, perceived benefits, costs, ability to
acceptable to the organization, or if it re- satisfy operational objectives, and makes
quires further treatment. For risks that are a determination whether ALARP can be
unacceptable, the following process using achieved.
the risk reduction decision tree is used.
If further risk reduction is required, the
Beginning with highest level risk reduc- team looks at the next strategy of minimiz-
tion strategy, avoidance/elimination, the ing the “quantity” of the hazard. Certain
team tests its feasibility. The team consid- materials, weights, sizes, chemicals or ener-
ers the risk level, what is possible, the antic- gy forms (e.g., voltage, pressure, tempera-
ipated costs and potential trade-offs. ture) can be reduced to ALARP.

If avoidance/elimination is not possible, For risks that can be reduced through
the team formally considers substitution simplified designs, controls or methods, the
with a less hazardous material or meth- team identifies acceptable solutions.

42 PSJ PROFESSIONAL SAFETY MAY 2019 assp.org

Bruce K. Lyon, P.E., CSP,

ARM, CHMM, is vice president

with Hays Companies. He holds a

B.S. in Industrial Safety and an M.S.

in Occupational Safety Management

from University of Central Missouri

The team selects engineering controls Center for Chemical Process Safety (CCPS). (UCM). He is a board member of
based on their effectiveness as well as their (2008a). Guidelines for hazard evaluation proce- Board of Certified Safety Profession-
reliability beginning with passive devices dures (3rd ed.). Hoboken, NJ: Wiley. als (BCSP), advisory board chair to
followed by active-type controls. The risk UCM’s safety sciences program and
reduction strategies at this stage are con- CCPS. (2008b). Inherently safer chemical pro- vice chair of ISO 31000 U.S. Technical
sidered higher level controls. However, the cesses: A life cycle approach (2nd ed.). Hoboken, Advisory Group. Lyon is coauthor of
team is unable to reduce all risks to an ac- NJ: Wiley. Risk Assessment: A Practical Guide
ceptable level. to Assessing Operational Risk and
Federal Emergency Management Agency Risk Management Tools for Safety
The team incorporates warning devices (FEMA). (2017). What is mitigation? Retrieved Professionals. In 2018, he received
and administrative measures such as job from www.fema.gov/what-mitigation the BCSP Award of Excellence. Lyon
hazard analyses, inspections, work proce- is a professional member of ASSP’s
dures, training and PPE into the risk reduc- Haddon, W., Jr. (1970). On the escape of Heart of America Chapter, and a
tion plan. tigers: An ecologic note. (Strategy options in member of the Society’s Ergonomics
reducing losses in energy-damaged people and and Risk Management/Insurance
The plan is presented and discussed with property). MIT Technology Review, 72, 44-53. practice specialties.
management decision-makers for approval,
modification and implementation. Haddon, W., Jr. (1980). The basic strategies
for reducing damage from hazards of all kinds.
Conclusion Hazard Prevention, 16(5), 8-12.
A large part of the OSH professional’s role is to
Jensen, R.C. (2007, Jan.). Risk reduction Georgi Popov, Ph.D., QEP,
advise and influence the organization in operational
risk issues. In the event of serious-injury-or-fatal- strategies: Past, present and future. Professional SMS, ARM, CMC, is a professor
ity-level risks, the OSH professional should make Safety, 52(1), 24-30.
clear to decision-makers the importance of imme- in the School of Geoscience, Physics
diate risk treatment and reduction. Cost-benefit Johnson, W.G. (1975). The management over- and Safety (GPS) Sciences at UCM.
analysis and other justification tools may be needed sight and risk tree. Journal of Safety Research, He holds a Ph.D. from the National
to help make the proper case, as well as an alternate 7(1), 4-15.
plan to present to decision-makers in the event that Scientific Board, an M.S. in Nuclear
the primary plan is declined. Any such plans should Lyon, B.K. & Hollcroft, B. (2012, Dec.). Risk Physics from Defense University
be integrated into the organization’s management assessments: Top 10 pitfalls and tips for im-
processes and discussed with stakeholders. Deci- in Bulgaria, and a post-graduate
sion-makers and stakeholders must understand the provement. Professional Safety, 57(12), 28-34. certification in environmental air
residual risk levels resulting from the risk treatment Lyon, B.K. & Popov, G. (2016, March). The quality. In 2001, he graduated from
plan, and its level of acceptability. Residual risk art of assessing risk: Selecting, modifying and the Command and General Staff
levels should be documented and monitored for any combining risk assessment methods to assess College at Fort Leavenworth, KS.
further treatment and continual improvement as risk. Professional Safety, 61(3), 40-51.
part of the safety management system. He is coauthor of Risk Assessment:
Lyon, B.K. & Popov, G. (2017, Nov.). Com- A Practical Guide for Assessing
The use of the hierarchy of controls models, such municating and managing risk: The key result Operational Risk and Risk Manage-
as those discussed in this article, should be standard of risk assessment. Professional Safety, 62(11), ment Tools for Safety Professionals.
practice for OSH professionals when developing risk 35-44.
reduction strategies to achieve ALARP. Considering Popov is a professional member of
expanded models such as those that include addi- Lyon, B.K. & Popov, G. (2018a). Risk manage- ASSP’s Heart of America Chapter,
tional higher-level risk reduction options such as ment tools for safety professionals. Park Ridge, a member of the Society’s Risk
simplification, minimization, and other inherently IL: ASSP.
safer design concepts can prove beneficial to OSH Management/Insurance Practice
professionals and their organizations in their quest Lyon, B.K. & Popov, G. (2018b, Sept. 6). Risk Specialty, and serves on ASSP’s Risk
to achieve and maintain ALARP. PSJ management tools for safety professionals [We- Assessment Committee. He received
binar]. Park Ridge, IL: ASSP.
References the Heart of America Chapter’s
Lyon, B.K., Popov, G. & Hanes, K. (2013,
ANSI/ASSP. (2011). Vocabulary for risk management Safety Professional of the Year (SPY)
(National adoption of ISO Guide 73:2009; ANSI/ASSP Z690.1- Dec.). Improving ergo IQ: A practical risk
2011). Park Ridge, IL: ASSP. Award in 2015, the ASSP Region V
assessment model. Professional Safety, 58(12), SPY Award in 2016, and ASSP’s Out-
ANSI/ASSP. (2016). Prevention through design: Guide- 26-34.
lines for addressing occupational hazards and risks in standing Safety Educator of the Year
design and redesign processes [ANSI/ASSP Z590.3-2011 Manuele, F.A. (2003). On the practice of safe- Award in 2017.
(R2016)]. Park Ridge, IL: ASSP. ty. Hoboken, NJ: John Wiley & Sons.

ANSI/ASSP. (2017). Occupational health and safety Manuele, F.A. (2008). Advanced safety man-
management systems [ANSI/ASSP Z10-2012 (R2017)]. Park
Ridge, IL: ASSP. agement: Focusing on Z10 and serious injury prevention.

ANSI/B11. (2015). Safety of machinery (ANSI B11.0- Hoboken, NJ: John Wiley & Sons.
2015). Houston, TX: B11 Standards.
NIOSH. (2015). Hierarchy of controls. Retrieved from
Asfahl, C.R. (2004). Industrial safety and health manage-
ment. Upper Saddle River, NJ: Pearson Prentice Hall. www.cdc.gov/niosh/topics/hierarchy

BusinessDictionary. (2018). Prevention. Retrieved from OSHA. (2017). Process safety management for petroleum
www.businessdictionary.com/definition/prevention.html
refineries: Lessons learned from the petroleum refinery

process safety management national emphasis program

(OSHA 3918-08 2017). Retrieved from www.osha.gov/Pub

lications/OSHA3918.pdf

Popov, G., Lyon, B.K. & Hollcroft, B. (2016). Risk assess-

ment: A practical guide to assessing operational risks. Hobo-

ken, NJ: John Wiley & Sons.

U.S. Congress, Office of Technology Assessment (OTA).

(1985, April). Preventing illness and injury in the work-

place (OTA-H-256). Retrieved from https://ota.fas.org/

reports/8519.pdf

U.S. Environmental Protection Agency (EPA). (2015,

June). Chemical safety alert: Safer technology and alterna-

tives (EPA 550-F-15-003). Retrieved from www.epa.gov/

sites/production/files/2015-06/documents/alert_safer

_tech_alts.pdf

assp.org MAY 2019 PROFESSIONAL SAFETY PSJ 43

VANTAGE POINT
Peer-Reviewed

REMODELING
HEINRICH

An Application
for Modern Safety

Management

By E. Scott Dunlap, Bryan Basford and Michelle Smith

HHERBERT WILLIAM HEINRICH was an employee of the engi- ment (Krause, 2011). Figure 1 presents incident rate data from
neering and inspection division of Travelers Insurance Co. 2003, the year in which the Standard Industrial Classification
He collected data from insurance claims and analyzed it to (SIC) changed to the North American Industry Classification
form a theory that he outlined in the first edition of Industrial System (NAICS), through 2014, the most recent year for which
Accident Prevention: A Scientific Approach, which was first BLS data are available.
published in 1931. His findings have served as the foundation of
much of the teachings in modern safety management. He was The BLS data could present a potential issue with Heinrich’s
a pioneer in his era of occupational safety in that he sought to theory. Other recordable, restricted-work and lost-time rates
establish a model that would predict incidents and the ratios in have decreased over time with no year-to-year increase. However,
which they would occur based on the data he examined. the fatality rate did increase between 2003 and 2004; 2005 and
As presented in the literature review, Heinrich’s theory has 2006; 2009 and 2010; and 2013 and 2014. This cursory analysis
become the object of much recent criticism. Heinrich used data could support criticism of Heinrich’s theory, but a deeper analy-
based on a spectrum of industries insured by his employer. sis is needed through an exploration of various industrial sectors.
Some critics have indicated through research that his model Of note, prior to a deeper analysis and considering the year-to-
is inaccurate and that not enough information is available year fluctuations in fatality rates, the following percentages of
through his methodology to replicate his research. Critics al- improvement exist over the period presented in Figure 1:
lege that minor incidents cannot be used to predict the volume
of serious injuries and fatalities (SIFs), which has given rise •other recordable rate, 33%;
to a body of literature on SIFs. The criticism is also based on •restricted-work rate, 34%;
macro-level Bureau of Labor Statistic (BLS) data that indicate a •lost-time rate, 27%;
reduction in other recordable, restricted-work and lost-time in- •fatality rate, 15%.
juries, while fatalities have not experienced the same improve- The research presented in this article is not intended to be
an exact comparison to Heinrich’s model. Instead, BLS data
KEY TAKEAWAYS were analyzed to determine whether the spirit of Heinrich’s
model has a space in contemporary safety management by
•This article presents the authors’ analysis of current Bureau of evaluating the degree to which minor incidents (i.e., record-
able injury rates) can predict the occurrence of more severe
Labor Statistics data at the national and industry sector levels to incidents (i.e., restricted-work, lost-time and fatality rates).
determine whether simple revisions to Heinrich’s theory are in The authors did not include near-hits in the current research
order rather than dispensing with it entirely, as has been recently due to lack of available data within the context of the BLS
suggested. data, although near-hits were a component of Heinrich’s
model. Due to BLS data being utilized at the industry sec-
•The authors determine that Heinrich’s theory has merit in con- tor level, the authors acknowledge that they did not analyze
unique variables within each industry sector and organiza-
temporary safety management through an analysis of recordable, tions contained in each sector that can influence incident oc-
restricted work, lost-time and fatality data at the national and currence. Such variables affecting safety culture could include
industry sector levels. organizational policies, management philosophies, number
of workers in the organization, level of diversity, tasks per-
•The authors determine that instead of a singular model, multiple

models are in order as evidenced by the “house” models presented
in the research findings.

44 PSJ PROFESSIONAL SAFETY MAY 2019 assp.org

formed, exposure to risks, condition and type of equipment
and tools available, and pay scales.

Literature Review

Research related to Heinrich’s theory has been mixed. Seward

and Kestle (2014) performed a study on the relevance of Heinrich’s

theory in modern reconstruction projects by reviewing incident

data from rebuilding projects in Christchurch, New Zealand.

Seward and Kestle felt that Heinrich’s safety pyramid was still rel-

evant to the safety practices on construction sites, as they found a The research presented in this article is
ratio of 20-5-1, which is at least in the spirit of Heinrich’s model. intended to extend the dialogue and

Radvanska (2010) states that the focus must be a more bal-

anced approach and that focusing too heavily on major incidents present potential modifications that can
is also cause for concern when there are many more significant

opportunities to provide a better basis and better control of ma- be made to the foundation that
jor incidents at the bottom of the pyramid. They say collected Heinrich established.
data reveal that the triangle model presented by Heinrich may

not actually be an equilateral triangle, depending on the safety

culture of the individual company in which it is used. Dislodging the long-held beliefs that Heinrich’s theory is
Johnson (2011) states that still under debate is whether the law is a daunting challenge for modern safety professionals.
Heinrich’s work should serve as a guideline for planning safety
influence of Heinrich is good or bad. She says that many safety initiatives, but should not be the sole focus, as it leaves out an
professionals are calling for the debunking of Heinrich’s theory entire realm of possible hazards, including system design and
and for its removal from all safety language and training, cit- overall culture. The belief that the majority of incidents are the
ing its age and the continual question of whether his research fault of the worker enables upper-level management to simply
would hold up to modern methods and peer review. She cites insure against major losses as a result of an inevitable incident,
Manuele, who notes that Heinrich revisited his 300-29-1 ratio and further keeps the safety profession from better ensuring
in subsequent editions of his work but failed to explain it out- the safety of the worker. Because of this, many professionals
side of his 1931 first edition. call for the complete removal of Heinrich’s ideas. Some pro-
fessionals, however, feel that more research is needed, using
Johnson (2011) says that critics of Heinrich’s work note that Heinrich as a litmus test but striving to advance the profession
focusing on “man-failure,” as is supposed by Heinrich (1931) through professional research (Johnson, 2011).
suggesting that 88% of accidents occur due to the unsafe acts of
man, lead safety professionals to focus too heavily on workers Executives often rely solely on OSHA injury rates or large
rather than on the systems in which they operate. Accidents penalties to assess their overall safety performance. When
often have multiple causes, Johnson notes, not solely the failure something catastrophic occurs, especially at a location with a
of one person or piece of equipment, and should be investigated low overall injury rate, many executives are caught off-guard
more diligently by safety professionals.

FIGURE 1 and chalk it up to chance (Krause, 2011).
Companies often cite that they were op-
U.S. BLS RATE DATA, 2002-2014 erating under the premise of Heinrich’s

theory, that by reducing the number of

4.5 4 4.1 4 4.2 4 minor incidents the company would be
able to eliminate or at least drastically
4 3.7 3.5 3.6 3.5 3.4 3.3 3.4 reduce the occurrence of major incidents.
3.5
Krause (2011) states the root cause for
major incidents lies not in Heinrich’s

3 theory that frequency breeds severity, but

2.5 2.4 2.3 2.2 2.1 2.1 2.1 2 1.9 1.9 1.8 1.7 1.6 rather in the entire metric by which safety
2 1.5 1.4 1.4 1.3 1.2 1.2 1.2 1.2 1.2 1.1 1.1 1.1 is measured as a whole. Heinrich’s theo-
ries have been debunked by current BLS
1.5 data, which has shown a decrease in the
number of minor incidents, but the more

PHOTODISC/PHOTODISC/GETTY IMAGES 1 1 1 0.9 0.8 0.8 0.8 0.7 0.7 0.7 0.7 serious injuries and fatality rates have re-
1.1 1.1 mained constant, even showing increases
in some cases (Krause).
0.5

0 Krause (2011) also notes that proper

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 identification of factors leading to SIFs

Other recordable Restricted work Lost time Fatality must be a priority. He says that many SIFs
have identifiable precursors and assuming

Note. Data from “Injuries, Illnesses and Fatalities,” by Bureau of Labor Statistics (BLS), 2015, the conditions that led to the SIF have
retrieved from www.bls.gov/iif/oshsum.htm; and “Census of Fatal Occupational Injuries (CFOI): never previously occurred is a fatal flaw
Current and Revised Data,” by BLS, 2016, retrieved from www.bls.gov/iif/oshcfoi1.htm#rates. in safety professionals’ thought processes.

According to Krause, safety professionals

assp.org MAY 2019 PROFESSIONAL SAFETY PSJ 45

TABLE 1

RESULTS USING RECORDABLE CASES TO PREDICT FATALITY CASES

Simple linear regression model results using recordable cases to predict fatality cases for each industry sector.

95% CI for average

fatalities for 1

recordable case per 100

Estimated Slope Lower Upper
P-value
Sector n regression line R2 limit limit
0.10
Agriculture, forestry, fishing 41 = 63.59 - 9.75 x 0.07 35.28 72.4

and hunting (11)

Mining (21) 22 = 11.04 + 6.65 x 0.16 0.07 15.53 19.84
0.08 7.89 10.14
Construction (23) 8† = 8.0 + 0.98 x 0.45 0.00 0.88 3.57
0.11 4.80 6.36
Manufacturing (31-33) 85 = 0.94 + 1.28 x 0.10 0.18 3.30 5.91
0.80 8.90 14.80
Wholesale trade (42) 19 = 6.9 - 1.3 x 0.14

Retail trade (44-45) 56 = 5.48 - 0.88 x 0.02

Transportation and 63 = 12.31 - 0.46 x 0.00

warehousing (48-49)

Utilities (22) 10† = -2.0 + 3.7 x 0.66 0.00 0.55 2.90
0.33 1.24 2.37
Information (51) 8† = 0.89 + 0.92 x 0.16 0.08 0.38 1.32
0.00 0.09 3.19
Finance and insurance (52) 10† = -0.0 + 0.9 x 0.34

Real estate, and rental and 14 = -3.8 + 5.5 x 0.52

leasing (53)

Professional, scientific and 10† = 0.5 + 0.6 x 0.19 0.20 0.71* 1.36*

technical services (54)

Management of companies 0 -- -- -- -- --

and enterprises (55)

Administrative and support, 10† = 3.68 + 2.03 x 0.32 0.09 4.98 6.44

and waste management and

remediation services (56)

Educational services (61) 10† = 0.6 + 0.3 x 0.03 0.64 0.42 1.28
0.00 0.89 1.19
Healthcare and social 33 = 1.18 - 0.14 x 0.34
< .0001 -1.16 2.06
assistance (62)
0.09 0.21 2.19
Arts, entertainment and 17 = -1.6 + 2.07 x 0.66
0.01 0.90 2.71
recreation (71)

Accommodation and food 18 = 0.6 + 0.58 x 0.17

services (72)

Other services, except public 27 = -1.25 + 3.05 x 0.24

administration (81)

Note. *Extrapolation of the model; † Level 2 analysis.

should look beyond the numbers, realize that Heinrich was Manuele (2011) says Heinrich’s original sources have been
wrong, and work to develop new and better methods of preven- lost to time and only the first four editions of his book remain;
tion. Process safety must be better understood, and the organi- there is no way to determine how Heinrich gathered his data,
zation’s culture should reflect the desire for top leadership to do the quality of the data he obtained, or how effective his data
more to prevent SIFs (Krause). analytics were. Manuele says that Heinrich’s work would not
stand up to modern peer review and that much of the terminol-
Nash (2008) communicates a similar message regarding BLS ogy he used would be considered sexist by today’s standards.
data, stating that those who are skeptical of the validity of Hein- Manuele notes that Heinrich’s work is focused heavily on
rich’s theory may believe that the data shown by BLS refutes it. applied psychology and that many safety practitioners could
He notes that BLS data show an increase in the number of fatal not effectively apply the psychological emphasis of Heinrich in
work injuries between 2005 and 2006 but show a fatality rate their daily incident prevention efforts.
that remained constant for the same period. Based on Heinrich’s
model, one would expect the rate to increase along with the Heinrich attributes 88% of the causes of accidents to
number of fatalities (Nash). Because of this discrepancy, it is im- “man-failure,” and believed that psychology was an important
portant for safety professionals to change their view on incident element in remedying those problems. Heinrich advocated for
investigations and subsequent corrective actions, employee be- prevention of the first proximate cause of an incident, which
havior and risk management, and engineering controls. was generally the easiest to correct. Manuele (2011) states this

46 PSJ PROFESSIONAL SAFETY MAY 2019 assp.org

TABLE 2

RESULTS USING RECORDABLE CASES TO PREDICT LOST-TIME CASES

Simple linear regression model results using recordable cases to predict lost-time cases for each industry sector.

95% CI for average lost

time for 1 recordable

case per 100

Estimated Slope Lower Upper

Sector n regression line R2 P-value limit limit

Agriculture, forestry, fishing 46 = 1.24 + 0.29 x 0.22 0.00 1.28 1.78
and hunting (11)

Mining (21) 30 = -0.02 + 1.19 x 0.59 0.00 1.04 1.30

Construction (23) 29 = 0.27 + 0.67 x 0.80 0.00 0.81 1.06

Manufacturing (31-33) 210 = 0.14 + 0.51 x 0.71 0.00 0.59 0.70

Wholesale trade (42) 26 = 0.13 + 0.80 x 0.48 0.00 0.77 1.07

Retail trade (44-45) 117 = 0.26 + 0.46 x 0.33 0.00 0.61 0.83

Transportation and 98 = 0.45 + 1.06 x 0.35 0.00 1.29 1.75
warehousing (48-49)

Utilities (22) 10 = 0.09 + 0.59 x 0.85 0.00 0.57 0.78

Information (51) 55 = 0.46 + 0.10 x 0.02 0.29 0.47 0.66

Finance and insurance (52) 43 = 0.06 + 0.38 x 0.21 0.00 0.32* 0.56*

Real estate, and rental and 29 = 0.01 + 0.76 x 0.71 0.00 0.67 0.87
leasing (53)

Professional, scientific and 10 = 0.08 + 0.28 x 0.24 0.15 0.22* 0.51*
technical services (54)

Management of companies 10† = 0.11 + 0.38 x 0.81 0.00 0.44 0.54
and enterprises (55)

Administrative and support,

and waste management and 20 = -0.05 + 1.02 x 0.65 0.00 0.71 1.24

remediation services (56)

Educational services (61) 10 = 0.34 + 0.22 x 0.42 0.04 0.49 0.63

Healthcare and social 40 = 0.45 + 0.37 x 0.39 0.00 0.52 1.13
assistance (62)

Arts, entertainment and 29 = 0.57 + 0.29 x 0.48 0.00 0.64* 1.07*
recreation (71)

Accommodation and food 20 = 0.25 + 0.39 x 0.14 0.11 -0.04 1.32
services (72)

Other services, except public 30 = 0.24 + 0.48 x 0.36 0.00 0.60 0.84
administration (81)

Note. *Extrapolation of the model; † Level 2 analysis.

focus does not account for the dynamic, complex environment a comprehensive incident investigation is the only way to uncov-
in which incidents occur, and that focusing only on the first er all of these causes, not just “man-failures” (Manuele, 2011).
cause does a disservice to those affected by the incident, citing
the complex natures of both the 2003 Space Shuttle Columbia Due to the varying perspectives regarding the relevancy
disaster and the 2010 Deepwater Horizon explosion. of Heinrich’s theory in contemporary safety management,
additional research is needed. The research presented in this
According to Manuele (2011), when the focus is placed too article is intended to extend the dialogue and present potential
heavily on the failures of workers as a root cause of an incident, modifications that can be made to the foundation Heinrich
management is often excused as a causal factor, as blaming the established.
workers is the path of least resistance. There are often several
causal factors of an incident, he says, including cultural factors Methodology
within the organization that are not often accounted for by a Building on information presented in the literature review,
superficial investigation. While human error at the worker level
accounts for a large portion of the incident causes, what is not of- the authors used a 9-year history of BLS data to analyze trends
ten considered are the failures of management that have allowed related to other recordable injuries, restricted-work injuries,
both unsafe environments and unsafe practices to continue. lost-time injuries and fatalities. To present a more accurate un-
Maintenance and design factors also must be accounted for, and derstanding of trends accounting for hours worked, the authors
used rates rather than volume of cases.

assp.org MAY 2019 PROFESSIONAL SAFETY PSJ 47

TABLE 3

RESULTS USING RECORDABLE CASES TO PREDICT RESTRICTED-WORK CASES

Simple linear regression model results using recordable cases to predict restricted-work cases for each industry sector.

95% CI for average

restricted work for 1

recordable case per 100

Estimated Slope Lower Upper
P-value
Sector n regression line R2 limit limit

Agriculture, forestry, fishing 41 = 0.369 + 0.31 x 0.14 0.01 0.31 1.02
and hunting (11)

Mining (21) 30 = -0.03 + 0.53 0.63 0.00 0.45 0.56
0.00 0.40 0.61
Construction (23) 29 = 0.27 + 0.24 x 0.41 0.00 0.70 0.88
0.00 0.55 0.96
Manufacturing (31-33) 211 = 0.19 + 0.60 x 0.56 0.00 0.25 0.56

Wholesale trade (42) 24 = -0.01 + 0.76 x 0.35

Retail trade (44-45) 114 = -0.20 + 0.61 x 0.30

Transportation and 98 = -0.47 + 1.02 x 0.51 0.00 0.38 0.70
warehousing (48-49)

Utilities (22) 10 = 0.03 + 0.49 x 0.89 0.00 0.44 0.59
0.35 0.22 0.31
Information (51) 49 = 0.23 + 0.04 x 0.02 0.29 0.09* 0.42*

Finance and insurance (52) 28 = 0.06 + 0.19 x 0.04

Real estate, and rental and 21 = -0.13 + 0.60 x 0.55 0.00 0.34 0.60
leasing (53)

Professional, scientific and 10 = -0.03 + 0.25 x 0.17 0.24 0.07* 0.38*
technical services (54)

Management of companies 10† = -0.05 + 0.44 x 0.79 0.00 0.34 0.45
and enterprises (55)

Administrative and support,

and waste management and 20 = -0.35 + 0.78 x 0.66 0.00 0.23 0.63
1.00 0.16 0.36
remediation services (56) 0.00 -0.05 0.78
0.76 0.70* 1.14*
Educational services (61) 10 = 0.26 + 0.00 x 0.00 0.14 -1.04* 1.14*
0.46 0.37 0.51
Healthcare and social 40 = -0.08 + 0.45 x 0.34
assistance (62)

Arts, entertainment and 27 = 0.90 + 0.02 x 0.00
recreation (71)

Accommodation and food 20 = -0.51 + 0.56 x 0.12
services (72)

Other services, except public 30 = 0.50 - 0.05 x 0.02
administration (81)

Note. *Extrapolation of the model; † Level 2 analysis.

This study departs somewhat from the context of Hein- from SIC to NAICS, thus allowing continuity of industry sector
rich’s theory in that it excludes near-hit and first-aid cases, comparison between years, uniform specific categorization of
which do not appear in BLS data. Using BLS data provides a the NAICS natural resources and mining sector, and the trade,
degree of reliability, although it is open to critique due to the transportation and utilities sector first appeared within the
system through which information is reported for inclusion. fatality data tables in 2006. The creation of these two data cate-
BLS data provide an opportunity to remain within the spirit gories in the 2006 fatality data established a starting point from
of Heinrich’s theory by evaluating cases that are minor (other which fatality data could be analyzed, along with the precise
recordable cases) and that are severe (lost time and fatalities). list of industry sector categories presented in the BLS injury
BLS data also support extending the research-based dialogue and illness tables. The final year of analysis was 2014 because
regarding Heinrich’s contribution to occupational safety man- it was the most recent year of data provided at the time the
agement in that this data has been used to refute Heinrich’s research was conducted. In addition to national data, the au-
theory (Krause, 2011; Nash, 2008). thors also analyzed data at the primary industrial sector level,
advancing one step beyond national level data. These industry
BLS injury data (BLS, 2015) and fatality data (BLS, 2016) were sectors included:
analyzed for the 9-year period from 2006 through 2014. Al-
though 2003 could have served as the initial year for evaluation •agriculture, forestry, fishing and hunting (NAICS 11)
because that was when industrial classification codes changed •mining (NAICS 21);

48 PSJ PROFESSIONAL SAFETY MAY 2019 assp.org