EM-385 Archives - Work Comp Roundup

For roofers and safety professionals, I am about to touch that third rail of safety. Is there such a thing as too much safety? As a 20 year plus safety professional I never thought I would answer this with a resounding YES! But here goes.

Increasing compliance

I have been watching as OSHA has incrementally increased requirements, with an eye on the changes and how they affect daily operations. Up to now I have been able to live with the changes in our workplace and the added paperwork and responsibility and so have workers. [WCx]

Thoughtful preparation

I have no problem with the added OSHA requirements as they have proven to my watchful eye to have merit. With thoughtful preparation and combining of the standard morning briefing and with minimal documentation, we have managed to meet and even exceed the individual site pre-task planning and hazard analysis.

Documentation

In conjunction with a larger roofing contractor, we have come up with a single form (two pages) that covers all the requirements. Some creative additions to this form to have the added benefit of a 5 day term which in turn lowers annual paperwork.

We have a brief meeting of the minds each morning where we cover the day’s work to come and any new hazards. Add to this a forward looking checklist of potential hazards with a check off list, and we have a compliant situation.

It sounds like we have it all covered, right? Well, not so fast.

The roofing company I have just mentioned has been faced with two cases lately that ask for more, WAY MORE! How can this be?

Added requirements

First, I will relate one new contract with a large national general contractor. The requirements this company has added are, in my experience, nothing short of make work. They have added a requirement for a dedicated safety professional with at least an OSHA 500 card to be on site at any time work is under way. This for a crew of 6-10 that already has a supervisor with a 30 hour card and most team members hold 10 hour cards. As well, we are required to follow and document additional steps that I will not detail here to avoid “outing” the GC. These steps each require several daily forms.

Over tasked supervisors

We have an excellent team with an excellent safety attitude and culture. However all this added paperwork and over supervision is causing hard feelings among our supervisors. I fear that this will affect our existing safety culture and team sprit as it seems any real input from the team is no longer necessary or wanted, just the forms! Additionally, the negative attitude growing among our crew is palatable.

Team Spirit trouble

My greatest fear is that this perception has trickled down through the ranks and has eroded a safety culture many years in the making. The barrage of forms and make work have my supervisors grumbling, and it comes off to the crew as being negative about safety in general. I ask, will this apathy lead to a team member not doing some basic safety requirement that will get them hurt? I say it is likely and fear the end result.

EM-385

The next situation is very similar yet involves work on a military base. This brings in a new set of requirements that is also troubling. If anyone out there has dealt with EM-385, then this concern is understood I do not need to detail here all of the steps and requirements past the daily JHA (job hazard analysis) of each work step every day. This of course requires a dedicated safety professional following the workers through the day completing mountains of paperwork. Not only will this add the risk of another person on the roof, it can create a distraction negative to our goals and contrary to our existing safety culture.

Over commitment

Is this trend a result of an over commitment to safety? Is this possible? In a world where we have finally started to see some positive safety cultures develop across the roofing trades, are some clients asking more than is sensible? Should well meaning general contractors add on steps and require them as part of the contract? I say no. We should use the OSHA guidelines as a measure and add what works is needed to develop individual safety cultures that fit with our tasks. A safe workplace is not a factor of the amount of paperwork generated, but by the compliance, attitude, and culture a good team develops and lives by.

Possible Solutions

Be sure to do all that is needed to have the safest possible workplace. If that includes recognizing and dealing with unnecessary safety protocols added on by well meaning General Contractors or clients, do not stay silent. If this is the case, I suggest bringing it up before the start date. If there are not agreeable terms, ask for a review by an outside and unbiased professional. Having a proper balance of safety and compliance and documentation is an important and fragile thing that can be overdone if the entire process is not understood. At times, a new view from above may be the best course of action.

In Summary

Is this actually over commitment or is it our old nemesis—communication? I say the latter. No one intends to overwhelm with minutia or mountains of paperwork. The GC is doing all the right things; they may not be aware of the current status of all subcontractors programs. When they see a compliant situation many of these duplications may just fall away. [WCx]

Brian Hill is owner of OshaSure in Birmingham Alabama and has over 20 years as a workplace safety and risk consultant. Brian was previously a pilot for a major US airline and member of the company’s interdepartmental safety committee. He found his new career in safety after the closing of the airline in 1991. Brian has found the same passion he had for flying in assisting companies with safety, heath and risk issues. oshasurebh@aol.com

For more information click on www.oshasure.com or call 205-296-0601

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Do not use this information without independent verification. All state laws vary. You should consult with your insurance broker or agent about workers comp issues.

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