Assess IRM

How to Conduct a Hazard Assessment

2013-04-23T11:09:00.000-06:00

Every workplace has hazards. We tend to think of workplace hazards in terms of industrial facilities with heavy machinery, but even if you work at home at your keyboard, your workplace has hazards. This article will walk you through the steps of performing a workplace hazard assessment to try and control the hazards where you work.

Step 1: Anticipating General Hazards

Before you enter a work area, take some time to think about the hazards that could exist in that area. Here are a few of the types of hazards you should think about:

Machine hazards: Are there machines or mobile equipment in your work area? They might present a hazard to you, and if your work involves operating machinery, you might present a hazard to people or other machines in the area.
Personnel hazards: Are there people in the area? Think of what hazards they might present to you, and you to them.
Airborne hazards: Might there be something in the air that presents a hazard, such as dust or fumes? Will your work create an airborne hazard?
Thermal or exposure hazards: Will you be working in an area where there are especially hot or cold objects or machinery? Will you be working outside in potentially hazardous weather?
Ergonomic hazards: Will the job require you to work at an awkward angle? Will you be performing repetitive tasks that will cause strain? Will you be lifting heavy objects?
Other hazards: Every task has specific hazards. What aspects of the task could create a danger to you or others?

Compile a list of all of the hazards that might exist in your work area.

Step 2: Anticipating Task-Specific Hazards

After listing the general hazards of your work area, focus on the task you'll be performing. List all of the steps required to perform that task. Break down the task into discrete steps--each step should include only one action--but don't break it down too far. "Unscrew the back of the chassis" is a discrete step. You don't need to say "Lift the screwdriver; place the end in the slot of screw #1; turn counter-clockwise; stop when the screw falls out..."

After listing the steps, think of the hazards associated with each step and write them beside the corresponding step. For example, when you unscrew the back plate, a fallen screw could be a tripping hazard, or it might fall into a machine and damage it. If there are twenty tight screws in the back plate, using a manual screwdriver could present an ergonomic hazard.

Step 3: Assessing Hazards

When you get to the job site, revisit your hazard assessment. Confirm the hazards you anticipated and look for other hazards. Look at the steps in your task as you do so, thinking about what could happen as you perform each step.

Figure 1: Safety Sphere

A good concept to use when you're assessing hazards is the safety sphere (1). Picture yourself at the center of a sphere that extends ten feet (three meters) in all directions, including up and down. If you're working on a solid concrete floor, chances are there won't be significant hazards below you (unless your task is cutting a hole in the floor), but on a steel catwalk, or near the edge of an elevated area, your task could create hazards to people below you.

Depending on your task, you might have to extend the safety sphere in one direction or another. For example, if you're using a pressure washer, you might spray water thirty feet or more, which could impact people or equipment at that distance.

Go over the hazards on your assessment sheet and confirm that you've listed everything you need to consider.

Step 4: Analyzing Hazards

By now, you've probably listed a lot of hazards. Some may seem hardly worth considering, while others may seem quite serious. How do you decide which hazards you need to control, and which you merely need to be aware of? Some may be obvious, but it helps to have a system to quantify workplace hazards. The standard risk formula is as follows:

R = CEP

Where R = risk, C = Consequence, E = Exposure, and P = Probability.

To calculate risk, you assign numbers to each component. A simple way to do this is as follows:

Consequence: What's the worst that could happen?
1) Minor injury or property damage
2) Serious injury or property damage
3) Fatality or catastrophic damage
Exposure: How often will you or others be exposed to this hazard?
1) Hardly ever
2) Sometimes
3) Every time you perform the task
Probability: What's the chance you could be injured or property could be damaged?
1) Probably will not happen
2) Might or might not happen
3) Probably will happen

The descriptions for each number may seem quite arbitrary; they are. But what's important is to apply them consistently to each hazard.

When you've calculated your risk scores, you'll have a set of numbers from 1 to 27. Any risk higher than 12 should be controlled before performing the task. If you only have low risks, see if it's practical to control the hazards with the highest numbers. If you're coming up with consistent scores of 18 and 27, you have a high hazard work site, and should not proceed with the task until the hazards can be controlled.

Step 5: Controlling Hazards

Once you've identified which hazards are significant, you need to figure out how to control them. There are three types of hazard controls:

Engineering controls: If you build something or otherwise put up some sort of physical barrier that protects you from a hazard, you've created an engineering control. Engineering controls are one of the best ways to eliminate or limit your exposure to a hazard. Examples include guardrails along the edge of an elevated area or partition walls to reduce exposure to flying particles.
Administrative controls: These are rules or procedures that limit your exposure to a hazard. Examples include staying two meters away from the edge of an elevated area or spending only a certain amount of time in a high heat area.
Note: Check your local health and safety codes before deciding between engineering and administrative controls. There are some circumstances when engineering controls must be used.
Personal Protective Equipment (PPE): When engineering and administrative controls can't eliminate or control the hazard sufficiently, you may need to wear some form of PPE. Examples include harnesses and lanyards for fall protection (see How to Prepare a Fall Protection Plan), hearing protection, safety glasses, and of course, safety boots.

The hazard controls above are listed in order of preference. Of course, if you can eliminate a hazard by performing your task when the hazard is not present, that's the best situation, but it's not usually practical. Figure out which combination of controls will reduce your exposure to all of the significant hazards at your workplace. I've created a hazard assessment form that will help you control the hazards at your work site. Feel free to use or modify it as you like; it's based on a pretty standard format.

When to Conduct a Hazard Assessment

If you perform a task frequently, you don't have to conduct a hazard assessment every time you do the job, but you should be aware of the hazards and be alert for new hazards each time.Conduct a hazard assessment whenever you perform a task for the first time, and whenever job conditions change. It only takes a few minutes, but it could save your life.

(1) Safety Sphere concept adapted from Eric Ashby of Domtar as quoted in "Cultural Shift", and article in the March/April 2013 issue of Pulp & Paper Canada (www.pulpandpapercanada.com)

How to Prepare a Fall Protection Plan, Part 4

2013-02-21T13:07:00.002-07:00

In Part 3, I talked about the importance of your rescue plan. Today, we're going to look at an accident that happened on a bridge and analyze what went wrong.

Fall of the Bridge Inspectors

I received the picture at right from a fall protection trainer. The picture shows the aftermath of a boom failure.

Here's what appears to have happened:

Three bridge inspectors were examining the underside of a bridge from a manlift.
They moved the manlift to reach farther under the bridge.
The short arm of the lift impacted against the side of the bridge, hitting a hydraulic line or cylinder.
The long arm of the lift swung downward to a vertical position.
The workers were ejected from the bucket when the arm reached the bottom of its arc.

The second picture shows a closer view of the aftermath of the fall. (I've blurred the workers' faces.) Here are some items to note about the incident:

The worker on the right is higher than the other two because his shock absorber did not deploy. This demonstrates that the workers fell only a short distance.
The second worker's shock absorber deployed partially.
The lowest worker's shock absorber deployed completely. His weight was probably a factor in the deployment of his shock absorber.
Note the position of the dorsal D-ring on the lowest harness. It's normal to have a bit of stretch. The other two D-rings are behind the workers' heads. The lowest worker's D-ring is nearly three feet over his head.
The crossover on the harness is near the bottom of the lowest worker's rib cage. This crossover normally sits below the hips.
Note the position of the lowest worker's left hand. He is apparently holding onto the chest strap of his harness to prevent it from choking him.

It's important to note that this worker is probably not too heavy for his harness. The reason he is much worse for wear than his coworkers is because his harness was loose. Because of his loose harness, he had a significant chance of falling out of it if the fall had been higher. What's more, if he had been knocked unconscious by the fall, it's likely his chest strap would have choked him to death.

But the worst part, from a male perspective, is the extent of the injuries that most likely did happen. The two higher workers will probably be off for a day or two, mainly shaken up, and return to work quickly. It's likely that the low worker will be in the hospital for at least a week with a severe groin injury.

It's possible that lack of training played a part in this incident, but it's just as likely that the low worker's predicament is the result of complacency. He has probably inspected dozens if not hundreds of other bridges without ever needing his fall protection gear, and figured that this day would be no different.

Note: I received these pictures with an analysis of the incident from another person who had received the pictures. I did not read an official report from the company involved. The analysis I give above is my own, based only on the pictures.

The Lesson

The lesson to take back to your workers is always to make sure that they wear their gear properly. If they're not sure they've adjusted it properly, they need to ask. You don't want to find out the problems with your fall protection equipment as a result of an accident.

I hope you've enjoyed reading this series, and I hope it gives you some ideas on how to create or improve your fall protection plan. Make sure you provide sufficient training to your workers, provided by a qualified trainer who will teach all aspects of fall protection, including rescue.

If you found this article to be valuable, please consider making a small donation.

How to Prepare a Fall Protection Plan, Part 3

2013-02-18T20:16:00.000-07:00

In Part 2, I described the equipment that is most commonly used for fall protection. Today I'm going to talk about the most neglected part of most fall protection plans: Rescue.

"Call 911" is Not a Rescue Plan

Most industrial facilities exist in or near cities that have trained fire departments, so why not let them handle things when something goes wrong? There are two main reasons you cannot rely on your local emergency services:

Lack of specialized teams. High-angle rescue is a specialized field. The average emergency responder is not trained to perform high-angle rescue, and will not endanger his team by acting outside their area of competence. Most major cities have at least one high-angle rescue team, but chances are the response time will not be acceptable.
Safe rescue time is limited. A worker hanging in a harness after a fall has approximately four minutes until permanent injury and the risk of death may occur. The leg loops of the harness, even when they have performed exactly as designed, restrict the blood flow to the legs. If the worker is not removed from this position quickly, blood in the legs will begin to clot.

If circulation is not restored, the worker's legs are starved of oxygen. Tissues begin to die. The shock absorber limits the amount of force exerted on the falling worker only so much; the Canadian standard for the maximum force that can be exerted on a worker by a shock absorber is approximately 350 pounds (6000 Newtons).

If the legs are starved of oxygen for too long, amputation may be necessary. Even if a worker is rescued before tissue death has occurred, any blood clots that have formed may become mobile in the blood stream, causing a heart attack, stroke, or an obstruction of blood flow in other parts of the body. Once tissue death has begun, the dying tissues can release toxins into the blood stream once the pressure on the legs is released. For this reason, rescuers must be specially trained.

Planning for Rescue

Your rescue plan will depend largely on the type of fall risks on your site, and of course the heights involved.

The most common rescue strategy is a rescue from below. To rescue a suspended worker from below, you must have clear access to the area below the elevated work area, and you must have a suitable lifting device that will allow your personnel to reach the worker. A manlift device such as an articulated aerial work platform may be suitable. Because of the limited amount of time a fallen worker can remain suspended in the harness, the manlift must be in place from the time a worker begins working in a potential fall arrest situation.

However, having the proper equipment, and having it prepared, is not sufficient. You must train a team of workers in rescue techniques. For this, you need to hire a specialized trainer.

Selecting a Trainer

Many manufacturers of fall protection provide free training to customers when they buy a certain amount of equipment, but be sure to evaluate the quality of the training provided. Instructing workers on how to put on the harness is not enough. According to the Occupational Health and Safety Code of Alberta, employee training must include the following:

(a) a review of current Alberta legislation pertaining to fall protection;
(b) an understanding of what a fall protection plan is;
(c) fall protection methods a worker is required to use at a work site;
(d) identification of fall hazards;
(e) assessment and selection of specific anchors that the worker may use;
(f) instructions for the correct use of connecting hardware;
(g) information about the effect of a fall on the human body, including
(i) maximum arresting force,
(ii) the purpose of shock and energy absorbers,
(iii) swing fall,
(iv) free fall;
(h) pre‐use inspection;
(i) emergency response procedures to be used at the work site, if necessary; and
(j) practice in
(i) inspecting, fitting, adjusting and connecting fall protection systems and components, and
(ii) emergency response procedures.

The legal requirements for training in your province or state will be different, but will probably have some similarities to the list above. Ask to see the trainer's program before you hire them.

A comprehensive fall protection and rescue course will probably involve two days of instruction.

If you live in Canada, a company I highly recommend is New Heights Industries from Winnipeg. They can assist you with all aspects of preparing your fall protection plan, from assessing your risks to training your workers. There are other companies across the country, but I recommend New Heights Industries based on personal experience.

In Part 4, we'll look at a fall arrest situation to see how one company's fall protection plan worked, and how it could have worked better.

How to Prepare a Fall Protection Plan, Part 2

2013-02-09T10:16:00.000-07:00

In Part 1, I described the basic principles of fall protection. In this part, I'm going to talk about the equipment used for fall protection: how to select the right equipment, how to use it, how to maintain and store it.

This article is intended as a starting point, not as a substitute for professional instruction. To ensure your workers' safety in a fall protection situation, hire a professional trainer to instruct your workers.

Fall Protection Harness

The most familiar part of a fall arrest or fall restraint system is the harness. There are many varieties of harness. Some expensive harnesses have many rings and padded leg loops. Others are simple, made of plain synthetic webbing with one ring on the back. The selection of the right harness will depend on the type of work at heights as well as your budget. Make sure the harness you select is appropriate for the job.

Some harnesses have so many buckles and rings, they look like some kind of S&M gear. What are all of the rings for?

Dorsal D-ring. On the back, between the shoulder blades, this is the most important ring on the harness. The dorsal D-ring is the only ring that can be used for fall arrest. Simple harnesses will only have this ring.
Side rings. Located at the hips, side rings are only to be used for work positioning. Work positioning is a certain type of fall restraint in which the worker hangs against the resistance of short lanyards.
Chest ring. Chest rings are also only to be used for work positioning. They are sometimes used with a ladder hook to give a climber a break while climbing a high fixed ladder.
Shoulder rings. Shoulder rings are most often used for rescue. When a worker has fallen, and is hanging in his harness, a rescuer will connect a rescue line to a shoulder ring.

It is very important that the dorsal D-ring be the only ring used for fall arrest. Using any other ring for fall arrest will subject the worker to enough force to cause serious injury or death.

Adjusting the Harness

The harness itself is made of synthetic webbing. It is designed to distribute the force of a fall over the body of the worker. It is not designed to prevent injury to the worker in a fall, merely to limit the extent of injury. If a worker falls into the harness, and everything works perfectly, he will sustain minor injuries. These injuries can be minimized by training workers to adjust the harness properly.

Here are some key points for adjusting a fall protection harness:

The dorsal D-ring should be between the shoulder blades. If the dorsal D-ring is too high, it could hit the worker in the head during a fall. If it's too low, it will not distribute the worker's weight evenly.
The shoulder straps should be vertical over the front of the harness, resting in the middle of the shoulders. The ideal place for the shoulder straps to rest is between the top of the shoulder muscle and the neck muscle. If the shoulder straps are too far apart, the worker can fall out of the harness. If they're too close together, the worker can fall unevenly, causing greater injury.
The chest strap should be at nipple height. The chest strap prevents the shoulder straps from separating in a fall, and helps the harness distribute the force of the fall. It is important that it be in the correct position.
The harness should be snug. A worker can fall out of a loose harness, or at the very least sustain much greater injury than he would if the harness were properly adjusted.
The leg loops must be snug. If a worker falls in a harness with loose leg loops, he will sustain a serious groin injury. This simple statement should be enough to convince workers to tighten their leg loops. If some of them still wear their harnesses with loose leg loops, tell them to do a Google image search for "testicular delamination." I'm not going to link that search here. Often, even showing workers that term is enough to convince them!

Inspecting the Harness

All safety equipment must be inspected before every use. Here are some important considerations for inspecting a fall protection harness:

The tag must be legible. The labels on fall protection equipment are printed in a type of ink that will wear over time. By the time the ink has worn to the point of illegibility, chances are the harness has worn to the point where its strength is reduced. It may still be strong enough to arrest a fall; it may be only the label that has worn. But do you want to find out how strong your harness is when you reach the bottom of a fall? If the label is illegible, cut up the harness and replace it.
The rings must be free from cracks or deep scratches. When inspecting the rings, turn them over to inspect the underside. There was an incident where a disgruntled laid-off worker used a hacksaw to sabotage the D-rings on all of the harnesses he could find. Fortunately, the company had trained workers to inspect their harnesses properly, and no one was killed.
The fall indicator must be intact. Many harnesses have a fall indicator. This is a sewn fold in one of the chest straps that has a label sewn around it. If the harness is in a fall, the fall indicator will deploy, and the label will pop open. If the fall indicator is damaged, throw away the harness.
The webbing must be unfrayed. Run each section of webbing over your finger and look closely for broken fibers. Broken fibers indicate a weakened harness.
The harness must be free of oil stains. The harness is made of synthetic webbing, which can be degraded by oils and solvents. Some oils may not weaken the harness, but is it worth betting your life?
The harness must be unmodified. Under no circumstances may any part of the harness be cut or modified. Nothing may be sewn onto it. If you add stirrups to the harness (for groin relief after a fall), make sure they are made for that particular harness, and are added according to the manufacturer's instructions.
Do not write on the harness. The solvents in felt markers can degrade the webbing. Workers can identify their harnesses by attaching a label with a small zip tie, but the best way of remembering who owns a harness is to hang it in individual workers' lockers.

The most important consideration for harness inspection is "When in doubt, throw it out." Before disposing of a harness, cut it up to make sure it can't be recovered from the trash and used.

If a harness is dirty, it can be cleaned with a mild soap solution. There are companies that will clean and inspect fall protection equipment. Even if you hire one of these companies, workers must still inspect their equipment before each use.

Storing the Harness

The best place to store the harness is in each worker's locker. Make sure people don't simply throw their fall protection equipment in the bottom, or stuff it in the top. Harnesses should be hung neatly from a hook to ensure they remain clean and ready to use.

Lanyards

Standard snap hook

A basic fall arrest lanyard consists of six feet of synthetic webbing with a standard snap hook on each end and a shock absorber near one end.

The snap hook has a double-locking mechanism. You need to actuate two levers to open it. This prevents the hook from opening if it is pressed against a surface. The snap hook is designed to prevent roll-out no matter what position it is in during a fall.

The shock absorber consists of three and a half feet of webbing folded and sewn together. The stitching is designed to let go at a steady rate during a fall, providing a constant resisting force to slow the fall.

Adjustable lanyard

A more useful type of lanyard is an adjustable lanyard, shown at left. When adjusted to its full length, it is six feet long, and suitable for fall arrest. It can be adjusted to a shorter length for use in fall restraint.

When attaching the lanyard to the harness, the end with the shock absorber always attaches to the harness. The end without the shock absorber attaches to the anchor point.

Inspecting the Lanyard

Inspecting the lanyard is much the same as inspecting the harness:

The label must be legible.
The snap hooks must be free from cracks and deep scratches.
The webbing must be unfrayed.
It must be free of oil stains.
The shock absorber must be intact.

Remember the rule: When in doubt, throw it out.

The lanyard should be stored with the harness in the worker's locker.

Other Equipment

The harness and lanyard are the central items in a fall restraint or arrest system. Here are some other types of equipment you may have in your fall protection system:

Retractable lanyard. This device consists of a length of webbing or steel cable coiled inside a casing. The lanyard pulls out of the casing and retracts automatically. The unit contains a clutch that locks the lanyard if it is pulled out too quickly. Retractable lanyards must be professionally inspected after they arrest a fall.
Horizontal lifeline. If workers need to move back and forth near the edge of a fall risk while working, a steel cable may be mounted along the edge. Workers attach their lanyards to the cable, allowing them to work safely along the edge. A horizontal lifeline must be designed by a professional engineer.
Confined space entry mast. Fall protection harnesses are often used for entry into confined spaces below floor level. Some masts can be used for fall arrest within the confined space. Follow the manufacturer's specifications and consult a professional before using any mast for fall arrest.
Ladder hooks. A ladder hook may only be used when climbing certain types of fixed ladders. Consult a professional to determine whether your fall protection system should employ ladder hooks.
Rescue devices. Rescue devices include ascenders, descenders, ropes, rigging devices, and other equipment. Rescue devices should not be employed as part of a fall arrest or fall restraint system. They are intended for use only by qualified personnel in a rescue situation.

In Part 3, we'll look at the rescue component of your fall protection plan.

How to Prepare A Fall Protection Plan, Part 1

2013-01-17T16:07:00.002-07:00

One risk that exists at many workplaces is work at heights. This can be a significant risk, as falling from a height can often result in a serious injury or fatality, but fortunately it's not a difficult risk to mitigate--although it does require an ongoing commitment of resources and a well-thought-out plan.

What this article is NOT

This article is NOT intended to serve as your fall protection plan. This article is a planning tool that will help you develop a plan tailored to your needs. The author assumes no responsibility for accidents that may occur as a result in deficiencies in your fall protection plan.

Once you have developed the framework for your fall protection plan, based on this article, I strongly recommend you consult a fall protection consultant, who will help you close the gaps in your plan, and give your employees the training they need to work at heights.

Assessing your fall risks

The first step in your fall protection plan is assessing your fall risks. Are you creating your plan for an office, where the greatest fall risk is employees falling from a small stepladder? Is it an industrial facility where employees frequently repair equipment at the top of bulk elevators? Or is it somewhere in between?

If your greatest fall risk is employees climbing small ladders, your fall protection plan might consist of ensuring that your employees receive basic instruction on ladder safety. If your site is a large industrial facility, it will be much more complex, and will probably consist of fall protection training delivered by a specialist trainer, maintenance of engineering controls and personal fall protection equipment, formal hazard assessment of all work at heights, and a rescue plan.

The following steps are necessary to assess your fall risks.

Familiarize yourself with local laws regarding work at heights. Your local laws will determine the exact height above which fall protection systems are needed, minimum specifications for guardrails, types of equipment that require fall protection gear, and other important considerations.
Look at every task your employees do with their feet off the ground. Not every such task will need to be mentioned in your fall protection plan, but it's the best way to identify fall risks you might not have considered.
Look at every task your employees do around floor or ground openings. Elevation is relative. You can have both feet on the ground and still have a fall risk if you're beside a hole in the ground.
Compare the list of tasks to your legal obligations. Find out what you have to do legally, and what makes sense from a risk management perspective.

The Fall Protection Hierarchy

Once you've assessed your risks, you're ready to start planning to manage them, but first you need a basic understanding of the principles of fall protection. There are several ways to protect workers from falls from above the height prescribed by your local laws.

Note: In this article, I'm going to use a height of 3 meters (10 feet), which is a common specification for the height above which a fall protection system is needed. Before developing your plan, make sure you confirm the prescribed height in your province or state.

The preferred methods of protecting workers from fall hazards are as follows, in order of preference:

Eliminate the fall hazard.
Enclose the elevated area.
Fall restraint
Fall arrest
Safe work procedure

The next few sections will look at each concept in detail.

Eliminate the Fall Hazard

As I wrote in a previous article, Reducing Your Risks, the most effective way to reduce a hazard is to eliminate the task. If you can rearrange inventory so non-palletized items are always at floor level, or move a control station to floor level, or automate an elevated task, you can completely eliminate the risk posed by the task. It's not always possible to do this, but it should always be your first step in analyzing the risk.

If the fall risk is due to a floor opening, make sure the opening is covered by a sheet of plywood or steel plate that will support twice the weight of the heaviest worker. The cover must be secured against horizontal movement and distinctively marked.

Enclose the Elevated Area

If an elevated task is performed frequently, the best way to reduce the fall risk is to enclose the elevated area. Build catwalks and surround them with guardrails. Provide access with a fixed stairway.

Consult your local laws for the guidelines governing the specification of guardrails. In general, guardrails should be about three and a half feet high with a second horizontal member halfway between the top rail and the floor. The space between rails must be small enough that a worker cannot fall through the guardrail. Vertical posts must be close enough together to ensure the railing will not bend. If the elevated area is above an occupied area, or equipment subject to damage from falling objects, toe boards must be installed along the bottom of the guardrails.

Temporary construction guardrails can usually be made of standard 2 x 4 lumber, but permanent guardrails should be made of welded steel pipe.

A work area on a roof can be enclosed by a less rigid barrier placed six feet from the edge. Consult your local laws for the specifications of such a barrier.

Fall Restraint

If it's not practical to enclose an elevated work area, the next option is fall restraint.

Fall restraint involves the use of a personal fall protection harness and lanyard set up to prevent a worker from falling.

Use an adjustable lanyard (pictured at right), adjusted to be long enough to allow the worker to complete his work, but short enough to prevent him from falling.

Anchor points must be engineered. You cannot use a railing, pipe, roof beam, or anything else that is not purpose-built for fall protection. Anchor points are usually (depending on local laws) designed to withstand a force of 16 kN (3600 lb) per attached worker. Anchors need to be this strong so they can be used to fall arrest (next section). If an anchor is to be used only for fall restraint, it still has a minimum breaking strength governed by local laws, and must be marked as being for restraint only.

Aerial work platforms such as boom lifts and scissor lifts have anchor points built in. Make sure your employees use these anchor points, and not the railing of the lift.

Fall Arrest

If fall restraint is not practical, fall arrest may be used if the height above the floor/ground is sufficient. The anchor point must be 18 1/2 feet above the next horizontal surface.

The OSH Academy has a great training module on fall protection systems. The diagram on tab 5.5 of this page shows why you need nearly 20 feet to employ a fall arrest system. Here are the components of the fall distance:

Length of lanyard from anchorage to worker: 6 feet
Length of fully deployed shock absorber: 3 1/2 feet
Height of worker: 6 feet
Safety factor: 3 feet

If you set up an anchor for fall arrest 12 feet above the ground, the worker's feet will probably hit the ground just as the shock absorber starts to deploy--that is, the worker's feet will strike the ground with the full force of the fall, not arrested by the fall protection system.

If you cannot place an anchorage at least 18 1/2 feet above the nearest horizontal surface (or if there is an unusual risk of injury from a shorter fall, such as falling into operating equipment), you cannot use fall arrest; you must use fall restraint.

Safe Work Procedure

Under certain circumstances, depending on your local laws, you may be allowed to use a safe work procedure where a fall protection system is not practical. This is the least preferred method of fall protection because it does not directly protect the worker from the fall hazard.

The only specified circumstance where this method is normally allowed is the installation or removal of a fall protection system.

Coming Up Next

In Part 2, we'll look at fall protection equipment in detail.

How to Write an Effective Emergency Response Plan, Part 2

2012-12-17T09:55:00.001-07:00

This is the second in a series of articles on writing an effective emergency response plan. No matter how big or small your company is, it is critically important to know how you will respond to an emergency.

In How to Write an Effective Emergency Response Plan, Part 1, I described how to write emergency response procedures. This article tackles the second half of your plan, which describes the considerations that will make your plan work.

This article will cover the following sections:

Emergency response policy
Roles of key personnel
Key locations
Emergency training and drills
Updating the Emergency Response Plan

Emergency Response Policy

A policy statement is a commitment by your company's management to plan for emergencies and allocate adequate resources to preparing for them. Your policy statement should include the following statements:

Company management is committed to ensuring the health and safety of employees in an emergency
The company will maintain emergency response equipment and supplies
The company will provide adequate emergency response training to all personnel
Management will review the policy when its needs change

This is a general overview of what should be included in your policy statement. If you work for a large company, you probably have a policy template that you can adapt for your emergency response policy.

In addition to the above statements, the policy should be signed by senior management.

Roles of Key Personnel

It is important to designate which employees will fulfill specific functions during an emergency. When response time is critical, it's not the time to debate roles. And it can be tragic to discover that a critical function was not filled because another function was being duplicated.

The following is an example of a list of defined roles for an emergency response plan:

Incident Commander. This role must be fulfilled for any emergency. The Incident Commander should be an employee who is always on site, and is intimately familiar with the site, all aspects of the operation, the crew, and emergency response procedures. A crew foreman is a good choice for Incident Commander.
Evacuation Director. Must be filled. The Evacuation Director is responsible for ensuring that all personnel evacuate successfully, and reporting head counts to the Incident Commander. The Evacuation Director should be a reliable employee who knows everyone on the crew.
Emergency Caller. Must be filled. The Emergency Caller (also called Communications Director) is responsible for ensuring that all necessary internal and external contacts are called to deal with the emergency. The Emergency Caller will be expected to delegate responsibility for certain calls, notably calls to emergency responders, where you are expected to remain on the line until the fire truck or ambulance arrives.
Safety Coordinator. If your company is large enough to have its own Safety Coordinator, this employee should be one of your first internal contacts to be brought in for an emergency. During an emergency, the Safety Coordinator's role is to support the Incident Commander, providing assistance in whatever role is required. Outside of an emergency, the Safety Coordinator's role is to maintain the emergency response plan and ensure that all personnel are adequately trained to respond to an emergency.
Plant Manager. While not strictly an emergency role, it is important to have your Plant Manager (or other local senior manager) involved in the emergency response process. The Manager's role during an emergency is to authorize the use of resources beyond what has been committed for emergencies in general. Outside of an emergency, the Manager's role is to allocate adequate resources to the emergency response plan, including equipment, supplies, and training.

It's important to assess which people in your company would be suited to specific roles, and what additional roles you might need based on your situation.

Key Locations

In an emergency, it's important that all personnel know where they need to go, and equally important for your Incident Commander to know where everyone is. Here are a few examples of key locations your employees need to know about:

Incident Command Post. This is the location from which your Incident Commander directs emergency activities. Because an emergency can happen in different parts of your facility, the physical location of the Incident Command Post should be flexible. It should be central enough to direct activities of personnel, but should be away from any significant danger presented by the emergency. One of the first radio communications made by your Incident Commander in an emergency should be something like, "This is John Smith. I've established Incident Command in the main control room."
Primary Muster Point. If your employees need to evacuate, they must all evacuate to one known area to ensure that your Evacuation Director can take a head count. An important part of your new employee orientation is making sure everyone knows the location of the Primary Muster Point. A specific corner of an employee parking lot is a typical muster point, but it should not be immediately beside the building. In a temporary work site, a particular pickup truck could be your muster point. Make sure there is a large, clear sign designating the muster point.
Secondary Muster Point. In a large emergency such as a fire, it's possible that your primary muster point will not remain safe, so it's important to make sure you have a designated Secondary Muster Point before an emergency makes it necessary. If you have an accessible parking lot on the other side of your building from the Primary Muster Point, that is a possible location. Otherwise you can use an off-site location, but make sure it's not too far away. Employees should only proceed to the Secondary Muster Point when directed to do so by the Evacuation Director, who must inform the Incident Commander of the change.
Communications Center. The Communications Center may be located at the Incident Command Center, or it may be located elsewhere if your communications infrastructure makes it more practical to do so. This is the location from which emergency calls to key employees and outside agencies are made.

Emergency Training and Drills

For your employees to be prepared to respond to an emergency, they must be trained to do so. Your Emergency Response Plan must outline what training is to be given to all employees, and to those with specific roles. Here are some examples:

Basic Emergency Response Training. Given to all employees. This training tells all employees what to do in case of an emergency, the identity of key personnel, and the location of key areas. In a small company, most of your employees will have important parts to play in an emergency. In a large company, the role of the majority of your employees is to stay out of the way, proceeding to the muster point as quickly as possible. The size and type of your company will determine the extent of your basic emergency response training.
Incident Command. Given to employees who may be called upon to sever as Incident Commander. Don't send only one person to this course; if your regular Incident Commander is on vacation, or has been incapacitated in an emergency, you need a backup Incident Commander. Incident Command courses generally run from one to five days, depending on the level of the course. Contact your local fire department or your municipality to see what training is available in your city, and what level of training is appropriate for your company.
Firefighter Training. In an industrial operation, it may make sense to have employees trained as firefighters. Often, a small fire can be extinguished by a small fire crew with a hose before the fire department has time to respond, potentially saving you millions of dollars. Talk to your insurance company and your local fire department about whether firefighting training is appropriate for your company.
Extinguisher Training. It is important for all employees to know how to use a fire extinguisher. The most important part of extinguisher training is knowing when to use an extinguisher and when to leave the fire behind. As a general rule, if you can reach an extinguisher without the fire blocking your exit, and you can fight the fire with an exit at your back, use the extinguisher. If there's any possibility that the fire will spread and block your exit, evacuate without fighting the fire. Contact your fire department for information on extinguisher training.
First Aid. Your local regulations will specify how many of your employees must be trained in First Aid, and to what level. Even if your company is too small to be covered by the regulations, it is important to have at least one employee trained in First Aid. That employee could save someone's life! Regulations will also specify how much First Aid equipment and supplies you must have, from a small kit to a fully stocked First Aid room.
Emergency Drills. Most companies across Canada are required to have at least one emergency response drill every year. If one is all you have, make it count! Don't announce the drill to everyone before it happens, or all you've given your employees is a smoke break. If a full-scale evacuation will interrupt your production, you may have to be creative, and you will certainly have to inform certain personnel beforehand, but make the drill as realistic as possible. For example, evacuate your office staff while pulling your fire crew away from production to deploy the fire hose in your warehouse.

Talk to your insurance company, your local fire department, and a Health & Safety consultant to determine what additional training your employees may require to effectively respond to an emergency.

Updating the Emergency Response Plan

You should review your Emergency Response Plan at least once a year to determine whether any external factors have changed the way you must respond to an emergency. Whenever you make operational changes, pull out the plan and see what needs to be changed. And of course, whenever key personnel change, the roles defined in your plan may need to be changed.

Make sure your plan includes enough triggers to determine when it needs to be reviewed an updated.

Summary

This has been a brief overview of how to write an effective Emergency Response plan. From here, you should talk to your employees, your local fire department, your insurance company, and a Health & Safety consultant to make sure you've adequately prepared your employees to respond to an emergency.

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How to Write an Effective Emergency Response Plan, Part 1

2012-12-05T10:43:00.000-07:00

Every company should have an emergency response plan. Emergencies don't happen often (we hope), but when they do, it's critically important that everyone in your organization knows how to react quickly and correctly. "Call 911" is not a sufficient response plan.

If you work for a large company, you probably have a safety department, or at least a safety coordinator, who maintains your emergency response plan. But if you're a small contractor, you either have to hire a health and safety consultant or write your own plan. Consultants know a lot about emergency response in general, but they probably don't have any in-depth knowledge about your particular company, so hiring someone to write a plan for you is a long, expensive process.

That's why I've prepared this guide--not to take work away from consultants, but to give small businesses a framework they can use to put together a plan that addresses their specific needs. After you've put together your plan, a consultant can review it to make sure it takes into account all of the considerations that are involved in emergencies in general.

How to Organize Your ERP

There are two main types of documents that make up your safety management system: policy documents and procedure documents. An emergency response plan must primarily be a procedure document. In an emergency, a supervisor should be able to glance at the ERP, quickly find the relevant section, then quickly find out what to do.

On the other hand, if your company is large enough to have a management structure, your ERP will also need policy statements and other guidelines. These should be contained in a second section, after the procedures.

A sample table of contents follows:

Part A: Emergency Procedures
1 - Accident/Injury
2 - Fire
3 - Natural Disaster
Part B: ERP Guidelines
4 - Emergency Response Policy
5 - Roles of Key Personnel
6 - Training

The procedures should be arranged with more likely emergencies before less likely ones. For example, if you live in Kansas, your Natural Disasters section should list Tornadoes before Earthquakes. But do list unlikely emergencies. The less likely an emergency is, the more likely you'll be unprepared for it when it happens.

Emergency Response Procedures

Common Considerations

In any emergency, your people have to act quickly and correctly. Here are some considerations that are common to all types of emergency:

How many people do you normally have on site? What is the minimum number of people?
Who is the best person to take charge in an emergency? Who takes charge if that person is injured?
What types of communication systems do you use? Which one is the most reliable for specific types of emergency communication? If you have contractors on your site, how do you communicate with them?
How long will it take emergency responders to reach your site?
Do your first aiders have adequate training?

All procedures consist of three general parts:

Responding to the incident
Managing the incident
Resuming operations after the incident

What to Include

In general, include anything that could conceivably happen that would cause significant injury or damage to your people, equipment, and facilities. List the most likely emergencies first, followed by those that are less likely to happen.

Here are some examples of emergency procedures you should have in your plan:

Accident/Injury

No matter what type of business you run, you must have a procedure for dealing with serious injuries at your site. A sample Accident/Injury procedure follows:

A worker who is injured, or witnesses an injury, must immediately contact the Foreman by radio.
The Foreman will assign a First Aider to assess the injury.
If the injury requires emergency response, the Foreman will assign a worker to call 911 and stay on the line until the ambulance arrives.
The Foreman will assign a worker to wait at the gate and direct the ambulance to the scene of the injury.
If the worker must be transported to medical aid, but does not require an ambulance, the foreman will assign a worker to drive the injured worker to the medical center.(1) Even in cases of minor injury, an injured worker must never transport himself.
If the accident requires production to shut down, the Foreman will direct the Lead Hand to supervise the orderly shutdown of the production line.
The Foreman will direct the Maintenance Engineer to call the internal emergency contacts.
The Foreman will document the scene of the accident and begin the accident investigation.
Once all required evidence has been gathered, and a substitute has been brought in to cover the injured worker's position, the Foreman will re-start production.
The Foreman will contact the family of the injured worker and inform them of his condition and location.

Fire

A fire is a possibility at any workplace, but is more likely at some facilities than others. If your company uses flammable materials (including everything from large amounts of paper to dangerous liquids), it is important to have a detailed fire response procedure that includes how your workers are expected to participate in firefighting activities. Here's a sample, based on an industrial situation:

The worker who discovers the fire will immediately call the Foreman by radio.
The worker will alert nearby workers and determine whether a fire extinguisher is close enough to reach before the fire spreads.
If a fire extinguisher is available, the worker will use it to fight the fire, ensuring that the fire does not block his(2) escape route.
The Foreman will activate the fire alarm if the fire has not triggered an automatic alarm.
The Foreman will determine whether external emergency response or evacuation is required.
If external emergency response is not required, the Foreman will direct the fire crew in extinguishing the fire using extinguishers and hoses.
If external emergency response and evacuation are required, the Foreman will designate an Evacuation Director and Emergency Caller, supervise the shutdown of the production line, and evacuate the plant.
The Emergency Caller will call the internal emergency contact by cell phone.
The Evacuation Director will take a head count at the muster station and report any missing personnel to the Foreman.
If it is safe to do so, the Foreman will assign a small crew to search for any personnel who are unaccounted for.
When the fire department arrives on the scene, the Foreman will relinquish incident command to the fire chief.
The Accident/Injury procedure will be followed for any injuries that occur as a result of the fire.
When the fire has been extinguished, the Foreman will assess the damage and determine whether production can be restarted.
The Safety Coordinator will document the scene and begin the incident investigation.
If production can be restarted, the Foreman will do so once the Safety Coordinator has documented the scene.
If damage is too extensive to restart production, the Foreman will supervise the production crew in clearing damaged equipment after the Safety Coordinator has documented the scene.
The Foreman will call in a maintenance crew to perform repairs on damaged equipment.

Natural Disaster

The types of natural disaster you include in your emergency response plan will vary depending on your location. If you're located on the Pacific Rim, an earthquake procedure should be a significant part of your plan. If you're on the Gulf coast, make sure your hurricane response is detailed, with adequate resources allocated.

Your Natural Disaster section should include minor disasters that may affect your operations as well as major disasters. Here are two example procedures:

Severe Summer Storm

If a severe summer storm causes damage to the facility, the Foreman must assess whether the damage requires shutting down production.
If the damage requires shutdown, the Foreman will supervise the orderly shutdown of the production line.
If the damage requires evacuation, the Foreman will designate an Evacuation Director and prepare the crew for evacuation.
If the damage has caused injuries, the Foreman will follow the Accident/Injury procedure.
The Evacuation Director will assess the current weather conditions and determine whether it is safe to evacuate to the primary muster station.
If current weather renders the primary muster station unsafe, the Evacuation Director will advise the Foreman by radio, and supervise evacuation to the Warehouse.(3)
The Evacuation Director will take a head count at the muster station and report any missing personnel to the Foreman.
If it is safe to do so, the Foreman will assign a small crew to search for any personnel who are unaccounted for.
The Evacuation Director will call the internal emergency contacts by cell phone.
After the storm has abated, the Foreman will assess the damage and determine how long it will take to restore production.
The Safety Coordinator will document the scene and begin the incident investigation.
The Foreman will call in a maintenance crew to repair damaged equipment.

Earthquake

When an earthquake occurs, the Foreman must quickly determine whether it is strong enough to require shutdown, and initiate an emergency shutdown of the production line.
If the earthquake has caused structural damage to the building or production equipment, the Foreman will designate an Evacuation Director and Emergency Caller and evacuate the building.
The Evacuation Director will assess the safety of the primary muster station, supervise evacuation to a safe muster area, take a head count, and advise the Foreman of any missing personnel.
If it is safe to do so, the Foreman will assign a small crew to search for any personnel who are unaccounted for.
The Emergency Caller will call internal emergency contacts, but will call 911 only if there are life-threatening injuries.
The first aiders will treat injured workers to the best of their ability. In a widespread disaster, emergency response may be significantly delayed, and first aiders may be called upon to exceed their training.
If the earthquake has caused a fire, the Foreman will lead the fire crew in fighting the fire using extinguishers and hoses. The Maintenance Engineer will shut off the natural gas line at the main distribution shack.
In an extended emergency, the Foreman will designate a Logistics Officer to distribute food and water from the cafeteria if it can be reached safely.
When not on an emergency call, the Emergency Caller will monitor the radio to determine whether nearby medical centers are available for life-threatening injuries.

About These Procedures

The examples given above are not intended to be cut-and-paste procedures for your operation. You must assess the potential dangers to your personnel and your operations and take all reasonable steps to ensure that your plan takes those dangers into account. These procedures are intended to give you examples of what types of dangers might be presented by certain emergencies, and what roles your personnel might have to take on to preserve the health and safety of everyone on your site.

Next Time

How to Write an Effective Emergency Response Plan, Part 2 will address the second part of the plan, which covers how to put everything into place to ensure that you are able to implement your emergency response procedures.

Footnotes:

(1) In Alberta, we have Medicenters and other clinics that are very good at dealing with work-related injuries. Emergency room wait times can be long for non-life-threatening injuries, so it's worthwhile finding out what options are available in your city.
(2) Throughout this article, I use the male pronoun in procedures. In my workplace, all production and maintenance staff are male, so this usage is accurate. Use of certain pronouns in your documents will depend on your view (or company policy) of using gender-neutral language in company documents.
(3) This plan would include additional steps to assess the safety of secondary muster stations. Don't assume that your muster area will be safe; always have a back-up!

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TDG or not TDG? Can one product be both?

2012-10-26T11:21:00.000-06:00

I was driving through the city today when a placard on a truck made me think about this question. It was a small tanker truck from a major petroleum products company.

I've previously written about seeing small companies that display safety marks incorrectly, but a company this huge has no excuse--and I know that this company in particular adheres strictly to standards such as TDG. And I know another situation where this material is shipped with dangerous goods placards.

The material in question is Lube Oil (sample Lube Oil MSDS). Also called Used Oil, Distillation Bottoms, or other names, Lube Oil is a by-product of oil recycling. Used oil recyclers collect used oil products from industrial sites and turn them into recycled oil products using fractional distillation, the same process used to produce many petroleum products from crude oil.

Petroleum molecules consist of chains, rings, and other configurations of carbon-based molecules. Each product has a different boiling point. The oil is heated in a cracking tower, and each fraction is collected in a different condensing unit according to its boiling point. Light products such as gasoline are less common in used oil, whereas heavier products like heating oil are more common.

Finally, after the distillable fractions are boiled off, the heavy, tar-like substance at the bottom is removed. This leftover waste product is useful for various industries as a component in asphalt.

But how dangerous is it? All of the volatile fractions have been boiled off, so there is virtually no inhalation hazard. It's barely flammable; you could aim a propane torch at lube oil all day, and you would probably just soften it.

So why would one company put a dangerous goods placard on this product, but not another?

Class 9 TDG placard

Company A brings Lube Oil to its plant from a long distance by rail. While in transit, the rail car is heated. If it weren't heated (in any season but the middle of summer), Company A would receive a rail car full of useless, solid black tar. So the supplier puts dangerous goods placards on the rail cars identifying the product as Elevated Temperature Liquid, Not Otherwise Specified, which is probably the most benign category of dangerous goods.

Company B ships Lube Oil in smaller batches within the city. The oil is heated before it's poured into the truck, but the truck is not heated because the oil doesn't have time to solidify before arriving at its destination. Company B uses placards that simply say Lube Oil.

There is a bit of a problem with these placards, because they are not proper TDG safety marks. However, in an emergency, they do indicate to emergency responders that the substance in the truck is not dangerous, and the truck may be approached without waiting for a special response team. While not strictly correct, this saves time because emergency responders would tend to wonder if an unlabelled tanker truck from an oil company indeed contains something dangerous.

When you're driving down the road, pay attention to the warning signs on vehicles. Is what you see always consistent? How many misleading safety marks do you see in a week?

How to Display TDG Safety Marks

2012-06-15T11:22:00.002-06:00

While driving around the city, I've noticed a number of vehicles displaying Transportation of Dangerous Goods (TDG) safety marks incorrectly.

Why is this important?

If you display incorrect safety marks, you could put the public and emergency responders in danger if you are involved in a traffic accident.

Here's an example: Bob's Welding uses a van to transport gas cylinders to and from job sites. To warn the public that he has compressed gases on board, Bob permanently displays the following labels on the side of his van:

One day, Bob is on his way home after work. He has dropped off his gas cylinders at the shop, and his van is empty. He is halfway home when a car cuts him off. He can't avoid the car, and he rear-ends it. Unfortunately for Bob, a tanker truck is following him to closely, and he is rear-ended.

When emergency responders arrive, Bob is unconscious. Fire crews see the labels on the side of his van, and are forced to assume that he is carrying at least three gas cylinders, one flammable, one neutral, and one oxidizing--essentially a bomb waiting to go off. The fire crews approach the scene very cautiously, hosing down the van to keep it cool. They wait for special equipment to arrive so they can safely approach the vehicles. The entire Yellowhead highway is closed for half a kilometer in either direction.

Finally, the firemen reach Bob's van and realize that it's empty. In the time it took them to take the extra precautions, thousands of drivers have been delayed and the driver in the car that caused the accident has died from his injuries.

Don't Be Like Bob!

Part 4 of the TDG Regulations describes how to display TDG safety marks. A vehicle carrying dangerous goods is considered to be a large means of containment, and must display placards on all four sides of the vehicle.

TDG placards are 250 mm on a side, and must be removable when used on a vehicle. If you remove dangerous goods from your vehicle, you must remove the placards because the regulations prohibit displaying misleading safety marks.

If you have the three safety marks pictured above permanently attached to your vehicle, your vehicle must contain a flammable gas cylinder, a neutral gas cylinder, and an oxidizing gas cylinder at all times.

If you typically have a few different gas cylinders in your vehicle, you have a choice of displaying all of the placards for the gases your vehicle currently contains or the danger placard plus the placard for the most dangerous gas you're carrying. For example, if you display the following placards...

...you could be carrying cylinders containing chlorine, oxygen, propane, and argon at the same time.

The order of danger for compressed gases is as follows:

Toxic gases such as chlorine
Flammable gases such as propane or acetylene
Oxidizing gases such as compressed oxygen
Other gases such as nitrogen or argon

Small Means of Containment

The gas cylinders themselves must have a label, which is a smaller version of a placard, 100 mm on a side. These labels can be left on the gas cylinders more or less permanently. Even if you use up the gas in a cylinder, it still contains residue, which the TDG regulations define as less than 10% of the fluid capacity of a container.

So if you're transporting empty gas cylinders, you still need to display the correct placards unless the cylinders have been purged.

Jurisdiction

This article applies to dangerous goods transported inside Canada. This includes imports and exports; as soon as you cross the border, your requirements may change. If you're transporting dangerous goods in another country, a safety consultant can help you comply with your local regulations.

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How to Write an Effective MSDS, Part 5

2012-06-13T12:07:00.003-06:00

This is the last part of the series on how to write an effective MSDS. Today, we'll finish outlining what information should be presented in each section.

Section 13: Disposal Considerations

If your product can be disposed of in regular garbage, this should be a short section. Otherwise, clearly explain to your customers how to dispose of used or unused quantities of your product, including the following considerations:

If your product has a very high or low pH, describe how to neutralize it before disposal.
Can your product be disposed of through a standard waste stream, or should the customer contact a specialized contractor?
Does your product need to be diluted or mixed with another substance before disposal?
Should the customer use a specific type of container for disposal?

Section 14: Transport Information

This section should tell your customer how to comply with shipping requirements for your product. If your product is regulated under the Transportation of Dangerous Goods (TDG) Act, or listed under the International Maritime Dangerous Goods (IMDG) Code or the International Air Transport Association's Dangerous Goods Regulation (IATA-DGR), give full classification and labeling information under these regulations.

A good format for this information is a table with the following columns:

Regulation: TDG, IMDG, IATA-DG, etc.
UN Number: A four-digit number preceded by the letters "UN"
Shipping Name: The official shipping name as listed under the relevant dangerous goods legislation. This does not include your product name.
Classes: List the primary class first, then the secondary class, if your product has one
Packing Group: This is especially important for explosive or dangerously reactive substances.
Limited Quantity Index: This indicates the number of liters or kilograms that can be transported without safety marks or TDG documentation.
Special Provisions: Some products cannot be transported on a passenger-carrying ship, for example.
Safety Mark: Show the label or placard that must be displayed on a container or vehicle carrying your product.

Section 15: Regulatory Information

This section should list the regulations that govern the shipping, handling, and use of your product in every country your MSDS is intended to be used.

If you're preparing a specific Canadian MSDS, this section should include complete WHMIS classification information of your product, as well as whether it is TDG regulated (even though this information is given in the previous section), and any lists of toxic or designated substances on which it appears. If your MSDS is to be used in other countries, describe its classification under regulations in other countries, such as HMIS or REACH.

It's also a good idea to show any classification symbols that apply to your product under the various regulations.

Section 16: Other Information

Use this section for any additional safety or environmental information you want to give your customers. For example, if you used a reference guide to prepare your MSDS, you could list that here (a CSA standard, for example).

Also reiterate the date of issue of the MSDS, and give the date of issue of the previous MSDS and the version number. Your legal department will probably want you to include a disclaimer stating that all information has been obtained through sources believed to be reliable (etc. etc.) but your company takes no responsibility for improper use, incorrect information, etc., and all sorts of other legalese. I'm not going to give you a full example of a disclaimer because I don't speak lawyer.

Summary

That wraps up this series. If you're just joining us now, be sure to go back to the beginning and read the whole thing. A Material Safety Data Sheet is an essential part of your service if you sell a controlled product.

Addendum

I've started the long, annual process of updating my MSDS binders, and I'd like to add one more item. Assuming you make your MSDS available online, list your company website somewhere on your MSDS, preferably in Section 1, so it's easy to look for an updated copy.

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How to Write an Effective MSDS, Part 4

2012-05-31T11:10:00.003-06:00

This is a quick post today, continuing to list what should be included in various sections of an effective MSDS.

Part 9: Physical and Chemical Properties

In this section, tell the customer about the product. Properties to list include the following:

Physical state. Is the product a solid, liquid, or gas at room temperature?
What are the melting and boiling points?
Does the product have a distinctive colour and odour? This can be particularly important for gases.
What is its density?
What is the vapour density?
Does it have a critical temperature?
If the product is a pure substance, you might list the molecular formula--but if it's a proprietary formula, you don't have to.

In this section, you can list properties that are listed elsewhere on the MSDS. It may seem redundant, but if someone is looking for a flat list of properties, they may not want to look at several locations in the data sheet.

Part 10: Stability and Reactivity

This section is particularly important for highly reactive substances. Provide the following information:

Stability and reactivity. State whether the substance is unstable or reactive, and provide brief information on storage and handling conditions that will maintain stability.
Incompatibility with various substances. Does your product react with water or air, or with any other substance your customer might use?
Hazardous decomposition products. When your product breaks down, are the resulting products hazardous? For example, perchloroethylene (dry cleaning fluid) degrades into vinyl chloride, which is highly toxic.
Hazardous polymerization. Will your product form hazardous polymer chains under certain circumstances? Describe the circumstances under which polymerization is likely to occur.

Part 11: Toxicological Information

This section describes the potential safety and health effects of your product. It has two main parts: acute effects and chronic effects.

Acute effects. Describe what can happen if the product is inhaled, ingested, or comes into contact with skin or eyes.
Chronic effects. Describe whether the product is carcinogenic (causes cancer), mutagenic (causes genetic mutations), teratogenic (causes fetal mutations), or affects particular internal organs.

Section 12: Ecological Information

This section describes any known effects your product has on the environment. You can list results of lethal concentration studies on fish or any other studies that demonstrate ecological effects.

Summary

Next time I'll finish the last few sections of the MSDS and provide some closing thoughts on the document.

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How to Write an Effective MSDS, Part 3

2012-05-09T09:11:00.000-06:00

Back to Business

It's been a busy month, but it's time to get back to this series. I've spent a bit more time lately writing fiction (some of which you can read on my other blog) and a lot more time working! Meanwhile, I've finished updating all of the MSDS my company has, so this project has been less on my mind. But I've got a new article in mind for this blog, and I want to finish my MSDS series before I start that one, so here goes.

Last time we finished by describing section 4 of a well-written MSDS. To start today...

Section 5: Fire Fighting Measures

First, this section should state whether or not the substance is flammable. If you must provide a distinction between flammable and combustible, please explain it clearly. To keep it simple, just use the term "flammable". We're less interested in a chemistry lesson than we are in knowing whether or not the substance will burn.

If the substance is an oxidizer, state that property clearly. An oxidizing material will not burn by itself, but it can greatly increase the chance of another substance catching fire. After all, diesel fuel is actually not that easy to burn as a liquid, but add ammonium nitrate and it becomes dangerously combustible.

If your product is flammable, be sure to list the following properties:

Auto-ignition temperature. The temperature at which the substance will burn without a spark or other ignition stimulus.
Flash point. This is "the lowest temperature at which a substance can vaporize to form an ignitable mixture in air." (Wikipedia's article on Flash Point gives this concise definition.) This is different from the auto-ignition temperature because an ignition source is used when determining the flash point.
Flammable limits. The lower flammable limit (LFL) is the leanest mixture of the substance that is flammable. The upper flammable limit (UFL) if the richest mixture that is flammable. For example, a mixture containing less than 2.2% propane (the LFL) is not flammable. A mixture containing more than 9.5% propane (the UFL) is also not flammable.
Explosive limits. If your product is explosive, be sure to include these values, which are defined similarly to the flammable limits.
Products of combustion. When your product burns, what chemicals come from its combustion? This property is critically important to emergency responders, who need to know if the smoke they are entering is more dangerous than the substance that is burning. For example, if you burn methane, the primary combustion products are carbon dioxide and water vapor, which are less dangerous than the original substance. Many polymers, however, produce highly toxic combustion by-products.
Fire hazards in the presence of other substances. If your product is more flammable in the presence of certain substances, be sure to note that here. See the oxidizing substance example above.
Fire fighting media and instructions. What should a firefighter use to extinguish a fire involving your product? Will water be safe, or will that spread the fire? Do firefighters need a self-contained breathing apparatus? Is there a danger of accumulation of flammable or explosive gas?

Section 6: Accidental Release Measures

What should your customers do if your product is accidentally released? "Call 911" is not a sufficient answer to this question. Think of the hazards associated with a spill in various situations, outside or inside, ventilated or confined. The phase of your product (solid, liquid, or gas) is an important consideration.

Personal precautions. Do people need to be evacuated from the area of a spill? If so, how far? What personal protective equipment should be worn by people near the spill? If inside, should the area be isolated or ventilated?
Environmental precautions. What tools should be used to prevent the spread of a spill into the environment? Do the authorities need to be advised?
Clean up methods. How should the customer clean up the spill? Once the spill is cleaned up, how should it be disposed of? Can the customer clean up the spill themselves, or do they need a specialized contractor?

Section 7: Handling and Storage

This section can be quite extensive, as it describes any precautions your customers must take when they're using your product. Some questions to ask while completing this section are as follows:

Handling

Do workers need to avoid contact with skin or eyes? Do they need to avoid inhaling fumes?
Does the product become dangerous when agitated, heated, cooled, or exposed to light or sound?
Should the working area be enclosed or ventilated?
Does the humidity in the working area need to be above or below a certain level?
How should the product be loaded or unloaded? Does the transport container need to be grounded during loading or unloading?

Storage

Does the product need to be stored at a certain temperature? A certain level of humidity or barometric pressure? For example, sodium hydroxide crystals require a very dry storage environment.
Does the product have a limited safe shelf life? For example, picric acid becomes highly explosive if left in storage for an extended period of time.
Should your product be stored at a certain distance from certain other substances? For example, oxidizing substances should not be stored near flammable or explosive substances.

Section 8: Exposure Controls/Personal Protection

There are three types of exposure controls:

Limiting exposure
Engineering controls
Personal protective equipment (PPE)

For a product that is a mixture, exposure limits are generally given in a table that lists each hazardous component and the exposure limits defined by the governing body in the customer's jurisdiction. Be sure to specify short- and long-term exposure limits. You do not need to specify the physiological effects of exposure here; that will be given in Section 11.

Important: Your MSDS must show exposure limits in your customer's jurisdiction.

If you supply products outside of your country, you can provide values either by displaying additional columns in your table, or by preparing a separate MSDS for products sold internationally.

Engineering controls are anything that is built that protects workers from exposure. For example, a ventilation system is an engineering control, as is an equipment enclosure.

Personal protective equipment should be specified for every intended use of your product, and for various exposure durations. For example, if your product is used as a parts washer solvent, but it doesn't vaporize at ambient temperatures, rubber gloves and safety glasses may be sufficient protection for that use. If it can also be used as a solvent in a hot application where significant toxic fumes may be produced, PPE for that use should include a specification of the type of respirator required.

Time to Review

Look at the sample MSDS for water and see how each section is organized.

Next time we'll continue with Section 9: Physical and Chemical Properties.

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How to create an Effective MSDS, Part 2

2012-03-28T13:45:00.001-06:00

Section by Section

Last time, I gave an overview of how to create an effective MSDS. Today I'm going to break it down section by section. I've prepared a sample MSDS to show you how the sections should be organized.

Section 1: Product and Company Information

This is the most important section of your MSDS from a first impression point of view. Section 1 must clearly identify the product you're describing, who you are, how to contact you, and who to contact in case of an emergency involving the product--the last item might not be you; there are companies and government organizations that provide 24-hour MSDS information services, such as CANUTEC for Canadian products.

The important fields of Section 1 are as follows:

Product Name
Intended Use
Supplier name and address
24-hour emergency contact number

The phone number listed as a contact for emergencies involving the product must be available 24 hours a day, 365 days a year. When the number is called, the caller must be able to receive complete product information without breaking contact.

Acceptable: "Hold on a sec; I'm passing the phone to Bob."
Unacceptable: "Let me take your number and Bob will call you right back."

If you can't maintain a 24-hour phone contact for emergency information, contact CANUTEC or a similar service provider.

As I stated in Part 1, the product identifier on the MSDS must be the same as the name on the label. This isn't just a tip for your customers' convenience; it's a legal requirement according to Section 28 of the Controlled Products Regulations, which states:

The product identifier that is disclosed on the label of a controlled product or container in which a controlled product is packaged shall be identical to the product identifier that is disclosed on the material safety data sheet for the controlled product.

Section 2: Hazards Identification

This section should explain how the substance might harm people exposed to it. It may also contain brief information on the hazards associated with an environmental release.

The important fields to include are as follows:

Emergency overview: Highlight the most critical hazards to employee health and safety
Routes of entry: How can the substance enter the body?
Acute effects for each route of entry and for external contact
Potential chronic effects

Include all effects that would prompt a visit to a first aid attendant or more significant action.

The most common routes of entry are inhalation, ingestion, and skin contact. If your product is an eye irritant, be sure to address eye hazards specifically.

Section 3: Composition/Information on Ingredients

Your product might be proprietary. You might not want to tell the world exactly what's in it because your competition could duplicate it. Fortunately, you don't have to list the exact composition.

You must list all ingredients that have potential health hazards, but you may give a percentage range for their concentration within the product. But be sensible.

Benzene: 0-100%
Toluene: 0-100%
Xylene: 0-100%

...is not reasonable. And if your product is called "Hydrochloric Acid 50% Solution" and you list hydrochloric acid as "40-60%", you're not fooling anyone. At worst, your customers will have serious doubts about your quality control!

A reasonable ingredient listing for a product containing BTEX hydrocarbons, but no other hazardous ingredients, would be something like this:

Benzene: 0.1-0.5%
Toluene: 5-10%
Ethylbenzene: 4-8%
Xylene: 10-15%
No other ingredients classified under the Controlled Products Regulations

Section 4: First Aid Measures

In this section, list the steps that a first aid attendant or a regular worker should take in order to render basic first aid. You don't need to list medical procedures. If medical attention beyond first aid is required, simply state "Seek medical attention" followed by an adverb or phrase that describes the ugency: at soonest convenience, within 24 hours, immediately, etc. Advise if the patient is not to be moved, and if emergency medical assistance must be called.

List specific first aid steps for various routes of entry, such as inhalation, ingestion, or skin contact. If first aid varies according to conditions such as temperature or whether the product is combined with another substance, specify these steps as well.

Time to Review

Look at the sample MSDS for water and see how each section is organized.

Next time we'll continue with Section 5: Fire Fighting Measures.

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How to Create an Effective MSDS

2012-03-22T14:16:00.002-06:00

I haven't been updating this blog in a while because I've become steadily employed as an Environment Health and Safety Specialist for a manufacturing company in Edmonton. However, in my job I've found the need to continue educating people in the field about various aspects of Integrated Risk Management, especially documentation.

Today's post is aimed at industrial suppliers who produce products that are classified as hazardous, and are sold in Canada. General aspects of this article will apply to any supplier of hazardous products, but if you distribute controlled products in Canada, this article is very important.

If you sell controlled (hazardous) products in Canada, you must prepare a Material Safety Data Sheet (MSDS) for your products. This article covers the general aspects of creating an effective MSDS. Next time I'll look at filling out each section.

General MSDS Requirements

The current standards for Material Safety Data Sheets can be found on Health Canada's website

An up to date Canadian MSDS contains 16 sections. The old nine-section format is still acceptable according to the legal standard, but most suppliers have adopted the 16 section format to conform with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). If you sell products outside of North America, you will probably be required to supply data sheets in GHS format.

Availability

You must make your MSDS available to every customer who purchases a controlled product. The more easily your customers can access your MSDS, the more satisfied your customers will be. Here are some DOs and DON'Ts:

DO publish your MSDS on your company website in PDF format.
DO put a link to your MSDS page on the home page of your website.
DON'T put your MSDS behind a password wall, or ask for contact information to send to your marketing department in order to access your MSDS.

Clarity

The purpose of your MSDS is to provide important information to your customers. Aside from the legal requirement, your customers need MSDS to handle your products safely. If a customer experiences an emergency involving your product, they want to find critical information immediately. To make your MSDS clear, follow these guidelines:

***Make sure the product name on the MSDS is the same as it appears on the product label. This is critical. If an employee is injured from exposure to Modified Asphalt, the first aid attendant will not be looking for an MSDS for ACME Laminating Adhesive. I have seen products with names that vary this much between label and MSDS!
Don't use one MSDS for multiple products. Your customers will see this practice as the pinnacle of laziness, and have serious doubts about the validity of the information. An exception would be different colors of the same type of paint where the pigments are not hazardous.
Write the product name in large, bold type at the top of the first page. In an emergency, your customers do not want to spend time searching for the name of the product.
Keep the product name brief and simple, and avoid using your company name or product number in the product name. "Super Silicone Sealant" is much easier to find in an MSDS binder than "ACME 42863 Super Silicone Sealant 250 mL Squeezable Tube C/W Applicator For Tight Spaces"
Write the date of preparation at the top of the first page. An MSDS must be replaced after three years. Your customers will appreciate it if you make it easy for them to see when your MSDS needs replacing.
Write the page number and number of pages on every page. Your word processor has intelligent fields that will do this for you. It makes a printed MSDS so much easier to keep track of.
Use clear headings and white space. There is no need to squeeze the entire MSDS onto one sheet of paper!

Keeping Current

As mentioned before, MSDS are valid for three years. However, there is no standard for the time of year to publish your MSDS, and most customers do not review their WHMIS program more than once a year. As a result, it can be difficult for your customers with large MSDS binders (containing hundreds of datasheets) to keep them up to date. There are two ways that you help:

Offer an email subscription through your website. Have your IT department set this up so every time you publish a new MSDS, it is automatically emailed to customers who have signed up for the service. But--only use this service for MSDS, not for marketing!
Update your MSDS every two years instead of three. This will ensure that customers who update their binders once a year will not miss any MSDS that expire later in the year.

Hall of Fame, Wall of Shame

In my quest to update the MSDS binders at my company, I've encountered companies that stand out for providing clear, complete MSDS that are easy to find and download, and I've encountered others that serve as a model of how to prevent your customers from getting the information they need.

Some of the Best

Air Liquide - Air Liquide has a link to their MSDS section on their home page. Their MSDS are presented as a list rather than a searchable database, but a selection of categories and a limited number of products make it navigable. The sheets themselves are excellent. The product name is repeated at the top of every page, the headings are large and clear, and they make great use of color for hazard symbols.
Imperial Oil/ESSO/EXXON-Mobil - The company may have too many names for itself, but they provide a convenient database of clear, complete MSDS. The only quirk of ESSO MSDS is that they download in Word format instead of PDF.
Zep Inc. - MSDS are available for a huge volume of their cleaning products. They're very clearly written and easy to use.
Petro Canada - Petro Can makes great use of color and hazard symbols in their MSDS, including Canadian WHMIS symbols as well as American NFPA symbols.

Some of the Worst

Cloverdale Paint - Coverdale Paint stands out as the worst provider of online MSDS I have seen. The only way to find an MSDS on their site is by product number; if you only have the product name, you're out of luck. When you finally find the MSDS you're looking for, you wonder if they've gotten the memo that typewriters are obsolete. The tiny Courier typeface is extremely difficult to read, and the MSDS might actually be missing sections!
Crafco - Instead of a convenient search, this company gives you a flat list to sort through. When you find the MSDS, you're not sure it's the right one because there can be four or so product names on one MSDS.
Devcon - Like Cloverdale, you have to look them up by stock number. The MSDS comes up as an HTML web page that you can convert to PDF using a free online PDF creator, which makes me wonder if the company is run out of somebody's mom's basement. It's 2012! Get with the times! If you're too cheap to buy Acrobat, you can create PDFs using Open Office.
Gregg Distributors - The MSDS for the products I've looked up are scanned copies of paper documents that look like they've been through a fax, with the distributor's document number scrawled at the top. What's more, the MSDS comes direct from the manufacturer. The distributor has not prepared a new MSDS even though they have re-labeled and re-named the product.

Summary

I've outlined the basics of creating an effective MSDS. Make it clear, and make it accessible. If your customers have to guess about anything on your data sheet, it could delay an emergency response.

My next article will outline how to fill in each section of your MSDS.

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A Tale of Two Brothers and their Environmental Risks

2011-09-02T12:50:00.000-06:00

This is a tale of two brothers, Gary and Dave.

When Gary and Dave left high school, they both knew that they didn't want to go through years of school and end up working for someone else. They wanted to be independent and own their own businesses. After looking at where there were opportunities in Vancouver, where they grew up, Gary decided to open an independent gas station, and Dave decided to start a dry-cleaning business.

As they finalized their plans, Dave warned Gary, "You know how dangerous gasoline is. One spark and your entire investment could be gone."

Gary replied, "I know, but I'm doing a thorough risk assessment, and this can be done safely if every employee has the right training, and I put in all the required safeguards. And I'll make a lot more money than you will as a dry cleaner."

"Maybe so," said Dave, "but I still think my shop will be safer than yours."

Over the next few years, Gary and Dave built their businesses, attracting and maintaining customer relationships, and slowly building up money for their dreams. They each bought a car and a house, got married, and raised their families.

Gary's Retirement

After 25 years of successful business, they started thinking about early retirement. The business climate was good, so it wasn't long before they found people interested in buying their businesses.

Gary sat down with his lawyer, Lou to plan for the sale.

"Everything looks good, Gary," Lou said. You've run your business efficiently, kept clear and accurate books, and have a great safety record. The only potential hurdle I see is the environmental assessment. Are your tanks double-walled with interstitial monitoring?"

Gary looked blankly at Lou. "They were there when I bought the property. I know they're steel, and I never noticed any gas missing, so they couldn't have leaked much."

Gary's Assessment

The following week, an environmental contractor visited Gary's Gas Bar. He examined the property, and told Gary that he'd be conducting a historical assessment of the property. A week after that, Lou informed Gary that a more detailed assessment was needed if he wanted to sell the property. Gary didn't want to be a landlord to whoever took over the gas bar, so he told Lou to go ahead.

The following week, the environmental consultant brought a drilling truck to the property. The truck drilled a series of holes around the lot, and in the street on both sides of the property. The consultant explained that these monitoring wells would allow him to determine the extent of the plume of gasoline that was probably spreading out from his old, leaking tank. Even if the leak was tiny, over the years it could release a lot of gasoline, which could contaminate a lot of soil as it slowly biodegraded.

A week later, the consultant returned to check the soil contamination levels in the monitoring wells. A week after that, Gary sat down with Lou, the buyer, and the consultant. Lou let the consultant explain his results.

The Results

"Good news!" he said. "The strata underneath your property form a natural bowl structure, which has contained the leaking gasoline. You have high BTEX levels right underneath your gas bar, but outside your property there's nothing that can't be left to monitored bioremediation."

The others around the table looked at the consultant, waiting for him to speak a language they understood.

"Basically," he said, re-tuning his brain to the frequency of people without an Environmental Engineering degree, "The layers of soil and rock under your property are like a bowl, and that has kept the gasoline from spreading to your neighbors. Gasoline is lighter than water, so it floats on the layer of water underground. It also contaminates that water, but there aren't any fish-bearing streams in the vicinity, and the contamination is largely contained. The contamination we worry about is in the form of four hazardous chemicals found in gasoline, which are highly concentrated right under your gas bar, but outside your property, we can let nature do the job for us."

Gary took this in for a minute. "So how do we clean up the contamination under my gas bar?"

"Excavation," said the consultant. "It will mean demolishing your building and removing your tanks and pump islands. We'll take the soil to the hazardous waste landfill in Delta, where it can slowly degrade, and replace it with clean fill. This looks like an easy job; shouldn't run you more than $40,000."

"Forty thousand!" exclaimed Gary. "That will take a bite out of my retirement savings."

"Could be worse," the consultant said. "If contamination spreads to neighboring properties, or gets into waterways, cleanup costs could be as high as a million or two."

The Cleanup

Gary spent the next couple of months supervising the demolition of his gas bar and the excavation of his property. The buyer coordinated with Gary during the backfilling to install a set of brand-new double-walled composite tanks with interstitial monitoring that would instantly sense any leak, then took over the site to build his new gas bar and convenience store.

Dave's Retirement

The next day, Gary sat down with Dave. "Well, brother, it looks like you were right all those years ago. My business did have more risk than yours. But we never counted on the risk of polluting our environment."

"No, Gary," Dave replied. "Your business turned out to be much less of a risk than mine. I'm going to be a landlord for the rest of my life. It's a good thing I saved up over the years, because I have absolutely zero sales income from my property."

"What happened?" Gary asked.

The Problem with 'Perc'

"While you were dealing with your assessment, I went to see my lawyer about selling my property. He looked at the age and type of business, and asked me if I used 'perc'. When I figured out what that was, and confirmed that my dry-cleaning fluid is perchloroethylene, which I've stored in a small metal tank under my store for the last 25 years, he told me that I could never, ever sell my property or it would bankrupt me completely."

"But that little tank of yours has, what, 20 gallons of fluid in it? How could that possibly be worse than my thousands of gallons of gas?"

"The environmental consultant explained that perchloroethylene is a DNAPL, a dense non-aqueous-phase liquid. Unlike gasoline, it sinks below the water table until it hits a layer of rock or clay. It pools there, slowly sinking into the clay layer, and polluting the groundwater that flows slowly above it. Unlike your property, mine is on a slope that leads all the way down to False Creek."

"Ouch," Gary said. "That doesn't sound good."

"That's actually the good part. False Creek is so polluted from a century of industrial activity, a little extra pollution isn't that noticeable. But if I sell the property, that triggers a Site Profile, which will lead to a full assessment like you had. The consultant says the clay layer under my part of the city is pretty far down. Cleanup costs for similar jobs have started at $3 million, and they have never been completely successful because you can't get the residual pollution out of the clay."

"So what do they do about the remaining contamination?"

"They sink a deep well downhill from the property, pump out the groundwater, and treat it. The theory is that eventually all of the contamination will be pumped out, but according to the consultant, of all the pump-and-treat wells installed since the 1970s, not a single one has ever been removed."

"So who would pay for that pump system?"

"You're looking at him, Gary."

"So you're going to find a tenant?"

"I had a young family that was interested, but the guy set the condition that I had to replace the tank with a modern one, with two walls and electronic monitoring. Trouble is, no one will touch that job for fear of being involved in a future environmental lawsuit."

Dave sighed. "I never wanted to get involved in any kind of cover-up, but if anything causes any kind of assessment, I'm going to lose everything. I'm going to have to pour concrete over that tank and forget it exists. After a few years, maybe someone will rent it without needing to know there was a dry cleaner there before."

Conclusion

So the two brothers retired, both with a little less than they had planned. Neither one of them set out to pollute their environment, but both were caught by an environmental risk that is almost universal in their types of business. When they started their businesses, there were no environmental laws or standard practices that would have prevented this type of pollution, but by the time they retired, the laws had changed.

Your business may not have an underground storage tank, but it certainly impacts the environment in some way. Are you ready for the legal environment that might exist when you're ready to retire?

Reducing Your Risks

2011-08-17T09:44:00.000-06:00

Once you've prioritized your risks, it's time to mitigate your high risks.

Sometimes, mitigation measures are obvious and immediately effective. Continuing with the example from last time, if Willy is using an old wooden stepladder that sits unevenly on the floor, replacing the ladder will significantly reduce the risk of falling.

In most cases, a systematic approach to risk mitigation will provide the most effective results. On your risk matrix, look at the risk of falling. The CEP numbers break down as follows:

Consequence: 3
Exposure: 4
Probability: 3

...for a total Risk value of 36. In this case, all three numbers are high, so we'll look at all three aspects when evaluating mitigation strategies.

Reducing the Consequence would mean reducing the severity of injuries Willy could sustain as a result of falling off the ladder. At first, this seems like an impractical strategy. The warehouse floor is concrete, and the upper shelf is six feet above the floor. Lowering the shelf is not practical because taller items would not fit underneath. And it would not be practical to have Willy carry a crash mat with him to place under the ladder twenty times a day.

There may, however, be a way to mitigate this aspect of the risk. Acme called in a safety consultant, who watched Willy climb the ladder. The consultant observed that Willy always climbed to the top of the ladder, then bent over to pick up the item he was to carry. As a result, Willy's feet were usually five or six feet above floor level. The safety consultant retrained Willy to climb only to the point where his waist was level with the upper shelf, then retrieve the stock item without bending over. As a result, Willy's feet were only three feet above the ground, reducing his potential fall distance, thereby significantly reducing the potential severity of an injury as a result of falling.

As a result of this step, Willy's consequence score was reduced to 2, resulting in a new risk score:

2 x 4 x 3 = 24.

The consultant also trained Willy on the proper way to climb and descend a ladder while holding a load, maintaining three points of contact whenever possible, and recognizing when a load was too heavy or awkward to carry up or down the ladder safely. For such cases, the consultant recommended using a custom-made pallet with a solid surface and small enough openings to prevent it from shifting on the forklift. Willy would raise the new pallet to the height of the upper shelf, climb the ladder and move the load at waist height onto the pallet, center it as well as he could, then descend the ladder and lower the load using the forklift.

This step reduced the probability or serious injury to a score of 2, resulting in a new overall score:

2 x 4 x 2 = 16

At that point, the company decided the score was reduced to an acceptable level, and thanked the consultant for his services, because consultants tend to be expensive now, whereas the risk was only potentially expensive in the future.

However, the company's purchasing clerk started thinking about the issue. She had been working to streamline the purchasing process to make the flow of inventory more predictable. Due to her actions, she designed a simple workflow pattern for the warehouse that would allow them to ensure that all loose inventory was placed on the floor in one aisle, close to the shipping doors.

The company adopted her proposal, and as a result, Willy never had to climb the ladder to retrieve inventory again. His new risk score for this activity was as follows:

2 x 0 x 2 = 0

If the consultant had looked at the problem a little more holistically, he might asked whether it was necessary for Willy to climb the ladder at all. This brings up an important principle in risk management:

Before expending a lot of effort adjusting a risky activity, determine whether the activity can be eliminated.

As it happens, the elimination of climbing the ladder also significantly reduced or eliminated the other two risks on the matrix. But as an exercise, assuming that Willy continued to use the ladder, see if you can figure out other ways to mitigate the remaining risks.

In the next article, we'll look at another type of risk.

Entering The Matrix

2011-08-05T22:39:00.000-06:00

With all of the aspects faced by a company (or even an individual's personal life), it can be difficult to determine which risks should be addressed immediately, and which can wait. A risk matrix helps you quantify the degree of risk posed by each activity, and gives you an overview of which risks you should manage quickly, and which can be put off. In today's article, we'll learn to put together a risk matrix.

"My common sense hurts."
"You've never used it."

A complete risk matrix will take considerable time to put together, but each step is fairly simple. We'll examine a simple matrix that evaluates the risks faced by one employee at a fictional company.

Acme Wholesale sells a wide variety of products to hardware stores, department stores, and other retailers. Products are stocked on two levels of shelves in the warehouse. Many products are wrapped on skids. Others are stacked on the shelves in boxes or containers, which can weigh up to 100 pounds (45 kg). Liquid products in the containers include hazardous chemicals.

Willy K. Oates is a warehouse employee. When a customer order appears on his computer screen, he retrieves the requested products and takes them to the loading dock where another employee prepares them for shipping. He operates a forklift to move skids. He uses a stepladder to retrieve boxes and containers from the upper shelf. The warehouse is usually very full, so products are placed wherever there is space. Willy is often the only stock person on duty, but the shipper/receiver helps him with heavy products when he is able.

It should be apparent that Willy's job involves a high degree of safety risk. I've built a risk matrix to quantify them. Click the link to open the matrix in Google Documents. You can access the document if you don't have a Google account, but I recommend getting one for the ease of online collaboration.

The first column of the risk matrix contains the activity to be evaluated. In this example, we're evaluating Willy's frequent trips up and down the ladder. The most obvious risk of ladder use is falling. If Willy falls from the ladder from a height of six feet, it's likely that he will be seriously injured. That's the first consequence (C) we'll evaluate for this activity. A serious injury would result in Willy missing work, requiring someone to take his place. It's serious for the employee and the company, though not catastrophic for either, so we'll assign a consequence value of 3 out of a possible 4.

Exposure (E) is based on how present the risk is. This is a measure of how often Willy is in danger of the consequence, as well as how protected he is from the consequence. Willy climbs his ladder about 20 times a day. It's a simple stepladder, so there are no handrails. He is very exposed, so we'll assign an E value of 4 out of 4.

Probability describes how likely the consequence is. Willy is relatively new to the job, and has not taken a ladder safety course. The ladder has been with the company since the warehouse opened, and has been bent a number of times when someone backed the forklift into it. Willy has not fallen yet, but the probability of a fall is pretty high, 3 out of 4.

Putting the numbers together, 3 x 4 x 3 gives us a risk score of 36. This number doesn't mean much by itself, so we'll evaluate a couple of other risks from this activity.

The warehouse carries a small number of extremely hazardous chemicals, exposure to which could be lethal. About twice a month, Willy has to carry one of these containers up or down the ladder. He is extremely careful with them, and usually gets the shipper to help him, but he's had one or two close calls.

In this situation, the consequence of death warrants the highest C value: 4. Exposure is limited due to the infrequency of carrying the items, so E = 1. Willy's extra care helps make up for the unsteady ladder, so the probability P = 2, giving us a risk score of 4 x 1 x 2 = 8.

The last consequence we'll look at results from Willy's handling of the ladder. Quite often, he bumps a box or a skid while moving the ladder. This doesn't usually damage the product, but occasionally an item is written off. In this case, C = 2 because the financial losses are not very high. E = 4 because Willy handles the ladder very frequently. P = 2 because it happens once in a while. The risk score is 2 x 4 x 2 = 16.

Comparing the risks, the chance of Willy being injured is the most serious with a value of 36, and should be addressed first. Product loss (16) should be addressed next, and Willy's possible demise (8) can be put on the back burner because of the low exposure and probability scores.

Note: A detailed risk assessment by Access IRM would take a more in-depth look at any risk that could result in a fatality. Our proprietary risk management calculations ensure any potentially fatal risk is given a proper score.

After the risks are calculated, it's time to look at mitigation strategies. That's the topic of our next article.

What is Risk?

2011-07-31T10:28:00.000-06:00

We all have a general understanding of the word "risk", but for the purpose of IRM we're going to define it very specifically. In fact, we're going to us an equation to define risk:

Risk = Consequence x Exposure x Probability

or more simply,

R = CEP

Of course, now we need to define the three other terms in the formula.

Consequence - This is the event that could happen as a result of a certain activity or situation. An employee falls off a ladder. You get a flat tire on the way home from work. An earthquake traps you at work.

Exposure - This is a measure of how present the risk is. Does an employee spend all day up and down a ladder? How old are your tires, and what kind of roads do you drive on? What is the earthquake frequency in your area?

Probability - What's the chance that this is going to happen? Do you expect your employees will fall off ladders every day? Do you think you'll get a flat tire once a month? How often do you experience strong earthquakes?

It is important to determine which risks should be addressed, and which ones can wait. To do this, you assign a numerical value to each of the factors above, then multiply them to get your overall risk value. The numbers are somewhat arbitrary, but they give you a starting point.

At Assess IRM, we use a proprietary risk calculation model to obtain a meaningful risk value, resulting in a risk matrix that allows you to target the risks that have the most potential to affect your life or business. Contact us to find out how we can help you prepare for the unexpected.

In our next article, you will learn how to create a risk matrix that will give you an overview of everything that might happen, and help you target which risks you need to address first.

Welcome to Assess IRM

2011-07-31T07:53:00.000-06:00

"What if?" is the central theme of Integrated Risk Management. Whatever you do, there are various factors that can potentially impact your daily routine. One of your employees could fall off a ladder. An unauthorized person could enter your warehouse and start opening boxes. A storage tank from a neighboring business could spill chemicals onto your property. A tornado could destroy your entire operation.

Even in your personal life, risk factors can cause unforeseen consequences. You get a flat tire while driving home. A tree falls on your roof. Your wallet goes missing from your home. A close relative dies.

All of these incidents require some type of response. Some responses are simple, while other require significant advance planning. Integrated Risk Management helps you plan for any incident to minimize the impact on your life, or on the operation of your business.

Every week, Assess IRM will present a new article that will help you manage your risks, whether they be safety, security, environmental, or emergency response risk factors. You will learn to rank your risks according to their severity, target the risks that need management most urgently, and create effective plans for every risk that could impact your life.

You have insurance to manage your financial risks. For everything else, there's IRM.