OSHA’s Fall Prevention Campaign: Ladders

In previous posts, we have discussed the importance of Fall Prevention and the national focus on providing training, guides, and resources in support of this fall protection safety risk management. Falls are the leading cause of death in construction and a frequent safety issue in many other industries. Even falls at minimal height can result in broken bones, lost worker time, and worker’s comp injury claims.  Nearly a third of fall fatalities in construction are falls from ladders.

Recently OSHA has produced several resources to provide guidance to safety managers with respect to ladders. Specific guidelines include:

  • Use the right ladder for the job
  • When using a ladder to access another level, secure and extend the ladder at least 3 feet above the landing point
  • Wear proper footwear
  • Place the ladder on stable and level ground
  • Ensure that the ladder is fully extended before accessing
  • Prevent passersby from walking under or near ladders while in use
  • Do not work on the top rung of the ladder
  • Maintain three points of contact at all times
  • Do not carry tools or materials while using a ladder
  • Do not lean on the ladder while working and keep your weight centered
  • Do not use ladders near accessible doorways
  • Check, maintain and safely store ladders
  • Do not use faulty ladders: bent, missing a step, or unable to be locked open

In addition, the California Department of Industrial Relations provides additional resources for specific ladder requirements, including design and construction (complete with ANSI regulations); ladder types and proper ladder selection; care, use, and maintenance; and employee training.

ANSI: Follow the Proper Guidelines

The number of variations between ladder designs, applications, and composition is nearly as unique as the people that use them.  It can be difficult to determine the applicable ANSI standard and rating that applies to each ladder at a workplace.  As an example, the ANSI category for portable metal ladders (ANSI-ASC A14.2-2007) covers a wide range of ladders, and excludes others that may seem to fit the category:

Ladder styles include ladder type step stools, portable extension, step, trestle, sectional, combination, single, platform, and articulating ladders, but excluding ladders in and on mines, the fire services, mobile equipment, hoisting equipment, work platforms, antenna communications towers, transmission towers, utility poles, and chimneys. It does not cover special-purpose ladders that do not meet the general requirements of this standard, nor does it cover ladder accessories, including, but not limited to, ladder levelers, ladder stabilizers or stand-off devices, ladder jacks, or ladder straps or hooks, that may be installed on or used in conjunction with ladders.

The importance of being informed to prevent falls from ladders and conform to trending OSHA regulations is clear.  For details about requirements for your workplace access equipment, visit the ANSI website or contact a safety professional.

Work Hazard Analysis

Identifying Workplace Hazards is an integral component of an effective work safety program.  As a required element of OSHA VPP Program participation, following an organized hazard assessment process can be the backbone of a company’s safety policy. Identifying hazards provides the ability to mitigate risk and evaluate safety effectiveness.

The work hazard assessment process consists of five main components:

  1. Identify Hazardous Condition
    Hazards that can lead to injury or illness range from physical injury risk to chemicals, temperature, radiation, noise, and electrical.  Employees need to be involved in hazard analysis from the beginning to assist with acceptance and recognition of benefit.
  2. Determine Root Cause
    Potential root causes can include lack of knowledge, lack of physical ability, improper training, or unidentified hazards.  Managers should reassess hazards when new equipment is installed or new work processes developed.
  3. Eliminate Hazards
    Mitigate risks via controls based on level of injury risk, frequency of exposure, and potential harm.  Evaluate the level of overall risk to prioritize controls and implement.  Identify PPE (Personal Protective Equipment) such as gloves, safety glasses, etc.
  4. Control Measures
    Risk management efforts can include engineering controls to manage exposure, layout, and access; administrative controls to to manage employees, tasks, and training; and  work practices for safety, hygiene, and work area cleanliness.
  5. Evaluation of Effectiveness
    Hazard assessment programs should be evealuated on injury prevention effectiveness.  Evaluation tactics include routine inspections; documentation for injury reports and near misses; requesting, researching and responding to employee feedback.

Source: Marine Corp Community Services

Initiating a Work Hazard Analysis

When commencing hazard assessment, plan to document responsible team members, tasks, and step sequence for processes with injury risk.  A Hazard Assessment checklist similar to this sample provided by the California Department of Industrial Relations may be helpful.  Next, determine and document preventative measures, equipment, and Personal Protective Equipment, and train employees accordingly.  Finally, consider residual risk – any risk that remains after controls have been implemented – for future evaluation and improvement.

Creating Safety Incentives

Incentivizing safety is a controversial topic for management professionals. While the results of incentive programs are generally effective, it is important to create safety incentives that provide the proper focus.  The method, motivational factors, and objectives must be properly structured to avoid undermining the desired effect. In fact, businesses that create safety incentives which discourage employees from reporting injuries are at risk of OSHA violations.  Fear not, safety professionals, by following a few guidelines you can create incentives that build safety culture across the organization.

Safety Incentive Guidelines

  • Make sure you have a safety program in place before creating incentives. Use incentives to enhance the organizational buy-in of a safety program.
  • Plan incentives around the objectives you set for the program.  Reiterate focus and goals at every opportunity.  Reward and promote performance.
  • Avoid incentives that may lead employees to fear the consequences of reporting incidents.  Remember that incentives are to promote safety, not just meet goals.
  • Capitalize on data management technology trends to track and reward long term safety program metrics as well as short term or more focused objectives.

Safety Incentive Program Ideas

  • Safety Slogans: Many incentive programs center around the creation of slogans submitted by members of the organization.  The advantage of slogan incentives lies in culture building and organizational involvement.
  • Safety Quiz: These programs help to ensure employees understand shifting safety initiatives and can also test employee response to real world applications.
  • Housekeeping: The cleanliness and organization of work areas often has a direct effect on safety and can be easily incentivized.

Safety incentives can be a means of establishing a sustainable safety culture while reducing the burden on employees.  Programs such as number of days without injury or lost time can be effective, but should be structured carefully to ensure employees report injuries.  The most effective programs are part of a larger injury risk management safety program, providing support in a way that employees want to participate in.

The Cost of Work Injuries: Direct, Indirect, and Hidden

A worker injury comes packaged with costs far beyond worker’s compensation claims and potential litigation expenses.  Direct costs are significant;  In 2009, worker’s compensation benefits paid totaled $58 billion, a 150% increase from only 6 years prior.  Yet, considering direct costs alone when factoring a return on safety investment or justifying safety and health initiatives is painfully incomplete.  Companies that have dealt with even minor worker injuries have experienced the hidden costs and indirect bottom line factors that can lead to catastrophic side effects or unanticipated benefits.  Studies have shown that work injury prevention programs are effective both on a bureaucratic and a business level.  Considering the complete picture of a work injury can be the most effective motivator for investing in safety risk management programs.

Hidden Costs of Work Injuries

The worst case scenario for a work injury, a death or debilitating injury, carries the most hidden costs for a business organization.  Large workers’ comp claims hike up premiums and can even lead to inability to change or acquire insurance.  From here, consider the effect on the co-worker when an employee suffers an injury on the job.  In the worst case, counseling may be required for co-workers, as the work facility becomes a haunting reminder of the incident.  Lack of sensitivity to this scenario can lead to worker absenteeism and forge foundational cracks in the management-employee bond.  Injuries don’t have to be major to carry hidden costs, however.  Companies with a reputation for aloofness to safety, experience a large number of worker injuries, or fail to support national and economic safety initiatives can have a hard time retaining and hiring employee at competitive salary levels.

Indirect Costs of Work Injuries

The indirect costs of a work injury are more easily foreseeable but still difficult to factor in monetary terms. It is important to realize their reach to fully anticipate the event of a work injury, even if the variability of the costs makes them difficult to forecast. Indirect costs can include training and compensating replacement workers, damaged property, production delays, administrative expense, and morale and reputation factors.  These side effects and reactionary costs can add up to total up to 20 times the direct costs and are usually considered as a multiple factor in projections.

Indirect Safety Benefit & Opportunity Cost

Remember the hidden costs of a work injury?  Hidden benefits are just as closely tied to safety initiatives.  Safety programs are beneficial for the business, the worker, and the economy as a whole.  A 2001 Liberty Mutual report on Safety Investment ROI shows that 61% of executives see a 3-1 return for safety investments, likely due to improved morale, productivity, industry reputation, community support, and HR advantages.  Safety can be a core business value and produce competitive advantage as a positive safety reputation becomes recognized by customers, vendors, and staff.  It doesn’t have to be though.  An attentive and effective safety program can economically support strategies ranging from quality to customer service, while still producing indirect benefit.  Ignoring this agenda for lower return investments is often an opportunity cost for businesses.

When a complete picture of work injuries and safety benefit is considered, it’s easier to see the wisdom in investing in injury prevention and championing proactive safety programs.

OSHA Top Five: Industrial Truck Citations by Industry

Powered industrial trucks are common across industries for transporting, storing, and staging materials, as well as many other practical uses.  Considering the wide range of applications and utility for trucks and trailers, it is not surprising that they are commonly cited for OSHA safety citations.  The sheer size and power of the truck combined with the variety of transported materials are the focus of regulations for OSHA standard 1910.178.

The Top Five industries cited for Powered Industrial Truck violations sheds light on the importance of truck safety risk management in the workplace.

  1. Manufacturing (665 Citations)
  2. Wholesale Trade (165)
  3. Transportation, Communications, Electric, Gas, and Sanitary Services (145)
  4. Construction (105)
  5. Retail Trade (70)

Powered Truck Safety in Industry

OSHA has structured Industry Standard 1910.178 to ensure businesses focus on operating properly equipped trucks, consider the safety factors of transported materials and operating environments, and generally to protect against the power and size of industrial truck equipment. Fire hazards, chemical considerations, and proper labeling are the focus of the standard.

Trucks are common in many industries, particularly those with material transport needs and at construction job sites.  Not surprisingly, each of the top 5 industries cited regularly conduct these activities.  The standard does not apply to “compressed air or nonflammable compressed gas-operated industrial trucks, nor to farm vehicles, nor to vehicles intended primarily for earth moving or over-the-road hauling.”

Fall Protection for Truck Trailers

In addition to standards related to Powered Industrial Trucks, truck trailers provide safety risks to consider when loading, unloading, staging, and performing related work requirements.  Providing safe access to trailers as well as an adequate work area for loading dock employees is a vital element to complete trucking protection.  Trailer access products such as Trucker safety ladders and portable work platforms will trucking fall protection on the road, loading dock, and job site.

Work Injury Prevention Programs

Injury prevention programs have led to a significant reduction in workplace injuries while contributing to improved productivity, reduced turnover, improved OSHA compliance, reduced worker’s compensation claims and premium rates, and higher employee satisfaction.  The costs of a worker injury can be devastating to individuals families and affect businesses on multiple fronts.  In 2009, worker’s compensation benefits paid totaled $58 billion, and indirect costs have been estimated at 1.1 to 4.5 times the direct cost.

Indirect Costs of Worker Injury

  • Wages paid to absent, injured workers
  • Time lost due to work stoppage following injury
  • Administrative time processing injury-related tasks
  • Employee training and replacement following an injury
  • Productivity loss due to new employee training
  • Replacement cost for damaged material and equipment

Source: OSHA Injury and Illness Prevention Programs

Injury Prevention Programs: Effective and Scalable

As of 2012, 34 states, and countries around the world, have instituted required or incentivized injury prevention programs.  The results of state programs are remarkable; work injury rates have been reduced by as much as 60 percent.  Participating businesses have reported additional benefits and some have even encountered more sales opportunities due to their commitment to safety.

 Despite the evidence, many businesses are slow to adopt injury prevention programs.  The perception that implementation will be costly and burdensome, particularly for small businesses, can be difficult to overcome.  The reality has been quite the opposite.  Injury prevention programs are scalable when business owners focus on basic tenets: leadership, participation, hazard identification and prevention, training, and continuing improvement.  The effect on the bottom line is also a positive, due not only to reduced workers compensation premiums and payouts, but also indirect morale, productivity, company image, and process improvements.

Mandatory Policy or Incentivized Benefit?

In a 2012 OSHA white paper, the effect of state programs was reviewed and the results are of interest to businesses considering an injury prevention program.  Incentivized programs in Colorado, Massachusetts and North Dakota resulted in noticeably higher effectiveness compared to mandatory programs in other states.  By providing a worker’s compensation premium reduction incentive,  states reduced work injury by at least 20%, compared to mandatory programs with  10-20% reductions.

In addition to the basic principals of injury prevention and company-wide safety commitment, these results may be a factor to consider for businesses seeking to maximize the effect of injury prevention programs.  Employees who believe their management team cares about safety risks are more motivated, aware, and productive, leading to advantages above and beyond cost benefit.  Anyone who has held a management position knows that while blunt force may get the job done, it often comes with costs ranging from employee resentment to undermining the system.

Incentivize to Promote Safety Culture Investment

Incentivized programs may help to avoid unintended indirect costs while still reaping the benefits.  By incentivizing safety initiatives, employees are more likely to perceive safety as a culture as opposed to a business owner’s cost saving agenda.  Further, incentives will help to communicate safety as a company value with a higher purpose than simply complying to policy. Providing incentives for safety could be based on Key Performance Indicators constructed from hazard assessment initiatives and include cost savings sharing.  Employees that are motivated by incentives will perceive safety not as a management priority but as a mutually beneficial investment.