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Promoting Safety on the Job: An Approach for Today

| By Clare Epstein, Vector Solutions

By providing comprehensive ongoing training solutions, promoting emergency preparedness and implementing proactive safety guidelines on a day-to-day basis, employers can set their staff up for success

In 2023, the Occupational Safety and Health Administration (OSHA; Washington, D.C.; www.osha.gov) reported a total of 29,747 workplace violations — a nearly 35% increase from the year before [1]. This should be a major cause for concern among employers in the chemical process industries (CPI), as violations like insufficient fall protections and hazard communications can lead to employee injury — and even fatalities in some cases (Figure 1).

FIGURE 1. Diligent fall protection and hazard communication are crucial to avoid workplace safety incidents and non-compliance

While OSHA’s full analysis of workplace safety in 2023 has yet to be released, what we do know is there were 5,486 fatal work injuries in 2022 [2]. This was a marginal increase (5.7%) from 2021, but any uptick in workplace fatalities — no matter how seemingly minor on paper — means an uptick in families and friends mourning the often preventable loss of a loved one.

With OSHA violations and workplace injuries on a steady incline, chemical manufacturing employers have an urgent responsibility to ensure that their workers are properly trained and adequately prepared for the hazards they may encounter on the job. This can be accomplished via the implementation of comprehensive, up-to-date and ongoing safety training.

This article explores the role of training and preparedness, how these practices are poised to prevent the most common OSHA violations and the tools and tactics employers have at their disposal to keep their workers confident and protected.

 

Dynamic, ongoing training

Knowledge is an employee’s greatest asset when it comes to avoiding hazards and navigating emergencies on the job. However, standards and regulations are constantly changing, as are the risks an organization might face. Chemical manufacturing employees in particular face specific risks — namely, chemical spills, leaks and releases that can severely impact both individual staff members and the public at large. Everything from changing climate conditions to fluctuating employee headcounts to opening a new facility has the potential to introduce new risks to employees. Multipronged and ongoing safety training is therefore imperative.

But it is critical to note that safety training should never be static and is a required element of OSHA’s Process Safety Management (PSM) standard [3]. Workers need access to the latest information so they can implement new technologies and remain compliant with emergent regulations. OSHA’s PSM standard requires the proactive identification, evaluation, mitigation or prevention of highly hazardous chemical releases. Chemical engineers need to be focused on any additional modifications and updates to the PSM standards, as well as continued compliance with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) [4]. For more information on the GHS, see The Globally Harmonized System, Chem. Eng., December 2013, pp. 42–44.

Learning-management technology can provide platforms that offer a wide variety of online training options, including interactive education geared specifically to the needs of the CPI. For example, employers looking to train their chemical engineers and chemical processing employees on the GHS standard, PSM, industrial maintenance and skills, or instrumentation and controls can offer valuable content through a digital learning-management platform.

In addition to training workers during the onboarding process, organizations must offer ongoing and refresher training so that staff can refamiliarize themselves with important concepts and procedures as necessary. Otherwise, they run the risk of forgetting vital information, which could lead to negligent onsite behavior.

 

Emergency preparedness

OSHA requires all employers to develop, implement and train all employees on an Emergency Action Plan (EAP) [5]. Organizations that manufacture, process and utilize chemicals must ensure that their EAP includes scenarios for handling chemical releases. This is another area where ongoing education is required — OSHA mandates that employees be trained on the EAP upon hiring and when their responsibilities under the plan change due to promotion or transfer. Most employers choose to train their staff on an annual basis to keep the EAP fresh and top-of-mind. The following are a few tips for employers to strengthen their emergency preparedness posture.

Provide leaders with emergency training. OSHA requires employers to designate and train emergency evacuation leaders. These individuals need to be trained on communication procedures, evacuation routes and their facility’s emergency alarm systems to confirm they are able to coordinate an employee evacuation when necessary. Education on soft skills is also incredibly important. Leaders should be educated on topics like stress management, interpersonal leadership skills and diversity, equity and inclusion. This will make navigating an emergency as seamless as possible.

Train employees on multiple scenarios. There is a vast array of emergency scenarios for which modern workers need to be prepared. Fires, extreme weather conditions, active shooter and workplace violence, chemical spills and cybersecurity attacks all fall under this umbrella. Employers must identify which of these scenarios are the most relevant to their organization (for example, a facility in Kansas may benefit more from a tornado-based EAP than a hurricane-based one) and train every level of the business on the proper procedures to follow should such a scenario occur.

Leverage technology to supplement preparedness training. Digital e-learning tools are a cost-effective and efficient option for organizations looking to train a large number of employees on a broad range of emergency scenarios. Interactive modules walk the staff member through a hypothetical emergency, enabling them to witness different outcomes based on the choices they make. Such platforms may also offer 3-D modeling so that employees can visualize the impacts of hazards like fires or floods on their facility.

 

Avoid frequently cited standards

The safety of workers should always be employers’ top priority, especially in particularly hazardous environments. But improper practices are not just a safety risk; they have financial implications, too. Notably, the price of negligence is only increasing — the maximum penalties for serious and other-than-serious violations increased from $14,502 to $15,625 in 2023 [6]. What’s more, the maximum penalty for willful or repeated violations has now reached $156,259 per violation.

As such, employers need to be keenly aware of how to prevent violations from occurring. The following sections outline how proper training can help prevent the top ten most frequently cited OSHA violations of 2023. See Table 1 for associated relevant OSHA standards.

1. Fall-protection general requirements. Employees need to be familiarized with the correct use of equipment, how to conduct inspections, and helpful techniques to minimize the risk of falling.

2. Hazard communication.Workers must know how to identify hazardous chemicals, substances and materials. Understanding what substances are present in their workplace and knowing exactly how to respond when a potentially hazardous material spills or is mishandled will keep them informed of and ready to tackle potential risks.

3. Ladders. Employees must be trained on best practices for using, storing and maintaining ladders in the workplace.

4. Scaffolding. The right training will educate workers on the various scaffolding types they will be dealing with, as well as proper assembly procedures and the potential dangers associated with scaffolding. Safety measures for erecting, inspecting and dismantling scaffolding must be strictly adhered to.

5. Powered industrial trucks. Keep employees apprised of forklifts’ common safety features and working dimensions and ensure they understand the correct procedures for operating these vehicles.

6. Lockout/tagout (LOTO). Dangerous machines must be completely shut off during maintenance or servicing work. Employees need to know the specific measures required to shut down these machines so they can perform maintenance without risk of injury.

7. Respiratory protection. Employees must be familiar with the different types of respirators available and when and how to use them.

8. Fall-protection training requirements. The right training solution will enable workers to walk through interactive scenarios involving fall hazards. Such tools will guide them through choosing the right fall-protection equipment and techniques while still covering related legal standards.

9. Personal protective and lifesaving equipment (PPE). In addition to respiratory protection, employees need to be familiar with the correct selection, fitting and usage of PPE for the protection of their face and eyes. Comprehensive training solutions will provide examples of incidents where proper PPE usage prevented workers from getting injured on the job to illustrate its importance and encourage compliance (Figure 2).

10. Machine guarding. To ensure physical barriers and safety devices are adequately preventing hazardous machine components from injuring workers, employers should implement training solutions that provide tools, such as interactive checklists for inspecting and maintaining their machine guards.

FIGURE 2. Employees should not only be trained in PPE best practices, but should also be empowered to help other employees ensure they are wearing their PPE properly

Clear and apparent SOPs

In addition to implementing the right training solution, employers can prioritize employee safety by establishing and training on standard operating procedures (SOPs). Transparent communication between employees, their peers and their supervisors is a surefire way to keep everyone on top of potential risks. If an employee becomes aware of a potential hazard, like a chemical spill, they need to know exactly who to inform and how to do so.

Employers must also establish standards and provide appropriate training for employees on the proper usage of PPE. OSHA has a number of requirements surrounding the usage of PPE [7]. Employers must make these requirements crystal clear to their staff and encourage workers to speak up when equipment is damaged, missing or if they notice a peer wearing their PPE incorrectly.

If employees or contractors work directly with hazardous materials, like most chemical manufacturers, employers need instructions in place to control and manage those materials. Procedures and standards on cleaning and maintaining work-area mats, using separate cleaning tools for various spills to prevent cross-contamination, and changing out of clothes that have been exposed to toxic materials, are required. These practices will both keep employees safe from hazardous materials at work and minimize the risk of exposing others once they leave the facility.

Beyond these standards, there are a number of additional efforts employers must make to prioritize day-to-day safety. Keeping pathways to work areas and emergency exits clear and identifying and removing fire hazards are just a few examples of further precautions mandated by OSHA.

 

A safety-first culture

Prioritizing employee safety has a number of positive implications for your organization. The most obvious of these is that with the proper training solutions and guidelines in place, workers are less likely to become injured while completing their daily tasks.

Proper training can also support retention efforts. According to the American Chemistry Council (ACC; Washington, D.C.; www.americanchemistry.com), employment in the chemical industry surged in 2022 but is expected to fall from this high [ 8]. Giving employees the tools they need to safely do their jobs will nurture confidence in their abilities and trust in you as an employer. When workers feel holistically supported by their organization, they are less likely to seek out other opportunities. By following such rigorous training and preparedness strategies, employers can set their staff up for success in any scenario. ■

 

References

1. National Safety Council (NSC), OSHA Reveals Top 10 Safety Violations at NSC Congress & Expo, October 2023.

2. U.S. Bureau of Labor Statistics (BLS), National Census of Fatal Occupational Injuries in 2022, December 2023.

3. OSHA 29 CFR 1910.119, subpart H, Process safety management of highly hazardous chemicals; www.osha.gov/process-safety-management.

4. United National Economic Commission for Europe (UNECE), Globally Harmonized System of Classification and Labelling of Chemicals (GHS), Rev. 2, 2007, www.unece.org/ghs-rev2-2007.

5. OSHA 29 CFR 1910.38, subpart E, Exit Routes and Emergency Planning.

6. OSHA Trade Release, U.S. Dept. of Labor announces annual adjustments to OSHA civil penalties, January 2023.

7. OHSA 29 CFR 1910, General Industry Standards, www.osha.gov/personal-protective-equipment.

8. ACC, Industry Outlook: Chemical Production Slows as Recession and Regulatory Challenges Loom, June 2023.

 

Author

Clare Epstein is the general manager, commercial for Vector Solutions (4890 W. Kennedy Blvd., Suite 300, Tampa, FL 33609; Website: www.vectorsolutions.com). Epstein brings more than 20 years of leadership experience working with safety training and technology. As general manager, Epstein is responsible for driving strategy, execution and growth for Vector’s commercial market segment, which serves customers across manufacturing, oil-and-gas, property management, engineering and construction. She first came to Vector after the company’s acquisition of IndustrySafe, a leading provider of environmental, health and safety (EHS) software, where she was the chief operating officer. Her experience also includes leadership roles at Civis Analytics and theEMPLOYEEapp. Clare holds a M.S. degree in city planning from the Massachusetts Institute of Technology and a B.S. degree in urban studies from the University of Pennsylvania.