Workplace Safety Awareness Council Blog

The Workplace Safety Awareness Council is a 501(c)(3) not for profit organization dedicated to keeping America's workforce safe. We invite you to join our blog and comment. We also invite you to our next series of Free OSHA update training and OSHA Bootcamps.

Tuesday, September 29, 2009

Can Safety Goals Really Reduce Workers Comp Costs?

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Why Should You Create Safety Goals?
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Last week I was in Phoenix to present at the PAHCOM Conference and what a great event! The general feeling we're getting out there is that safety managers are more interested in the return on investment of safety than ever before.

And it makes great sense! A recent study by Liberty Mutual found that for every dollar spent on safety you can expect a $3 - $4 return on the $1 investment! That's pretty powerful stuff, in any economy.

Think it doesn't work? While working with a group of municipal power companies in Florida, one risk manager was able to reduce his company's
workers comp and liability insurance costs from $1 million dollars to just above $275,000 in a three year period. That's not a one time savings
of $625,000 - its an annual savings of $625,000 based on smart safety goals - $625,000 each and every year!

Imagine what a similar savings would do for your company. better yet, imagine what a similar savings would do for you personally. Think job
security, a healthy raise, new doors opened, the ability upgrade your position and salary. Pretty good options, especially in this economy!

To find out how to achieve similar savings in your organization, join us for a webinar entitled:

"Establishing Safety Goals That Reduce Workers Comp Costs and Keep Employees Safe"

This webinar may just be the jump start you need to make some serious changes in your organization and career:

http://tinyurl.com/Safety-Goal

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Is your company a safe place to work? How do you know?
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Did you know that OSHA has established benchmarks for each industry? These benchmarks allow OSHA to measure your organizations safety record against the national average for your industry. If you exceed that national average, expect a visit from your local OSHA office!

The good news is that you can proactively measure your safety record and take steps to improve it as necessary!

By attending this webinar you will learn:

* Get management "buy-in" by communicating your safety programs "ROI"
* How your workers comp costs can be reduced by a establishing your safety program
* How OSHA established your injury benchmark
* How to set realistic and attainable safety goals that encourage compliance
* Using a safety committee to keep your injury goals on track
* The dangers of implementing a safety incentive program
* How to measure your company's injury rate

Reducing costs, improving morale, avoiding fines, increase productivity - these are just a few of the benefits of safety benchmarking and effective goal setting.

By attending this webinar, you'll learn how to easily establish safety related goals that will save your company money and most importantly - keep your employees safe!

Seating is limited to reserve your spot now: http://tinyurl.com/Safety-Goal

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Tuesday, September 15, 2009

The ABC's of OSHA Compliance - Its Not as Difficult as You Might Think

I just arrived back from a presentation in Fort Lauderdale Florida for a group of Facility and Maintenance Managers. My presentation was entitled "Top 10 OSHA Violations in a Built Environment" and I'm happy to say it was a rousing success!

I had the opportunity to speak with a number of building managers and chief engineer types and one of the common issues was "cryptic nature" of the OSHA regulations. . .

I hear this a lot. In fact it seems that this perception is what keeps most organizations from developing a sustainable safety program.

The good news is that OSHA compliance does not need to be difficult, time consuming or expensive. In fact we've just announced a new webinar which will provide you with a roadmap for OSHA compliance in 6 easy steps.

http://tinyurl.com/ABC-OF-OSHA

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OK, so Where do I Start and are There Only 6 Steps?
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Like any big project, you have to break it down into bite-sized steps. . .
We can breakdown OSHA compliance into 6 major steps:

(1) Conduct "Job Hazard Analysis" of potentially dangerous tasks

(2) Develop written safety programs that address these hazards

(3) Train employees on proper safety procedures when working around these hazards

(4) Conduct regular safety inspections so dangerous items can be corrected

(5) Be sure to remember the "Administrative Requirements" like OSHA recordkeeping and posters

(6) Get familiar with the OSHA regulations that speak to your hazards

Once we examine each of these six steps and develop a system for completing each, the goal of OSHA compliance gets easier.

How many of these steps has your organization completed?
Do you understand and have you mastered each of these steps?

If you're finding OSHA compliance to be difficult of time-consuming, why not join our webinar on the ABC's of OSHA Compliance. . .

http://tinyurl.com/ABC-OF-OSHA

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The 5 Reasons we Are Not OSHA Compliant and Our Rebuttal
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(1) This responsibility was dumped in our lap with no warning, much less any training

Rebuttal: Deal with it! If your name is going to be attached to it, you better protect yourself (and your job) and figure this out.

(2) I'm too busy with my "real job" to spend time on safety

Rebuttal: You need to organize your safety program so its on "auto-pilot". That way you're not taking too much time from your "real-job". See also rebuttal #1.

(3) The regulations are too complicated and I'm lost

Rebuttal: This is true until you learn how to look up the OSHA regulations.
Remember the first you went to the library to check out a book?
I do - I was in first grade and was utterly lost - until I learned the Dewey Decimal System.
Learn OSHA's system and this become a non-issue.

(4) My employer doesn't care about safety and compliance issues

Rebuttal: Your employer doesn't understand the potential return on investment a safety program can bring. Typically for every $1 spent on safety programs, organizations get a $3 - $4 return. That's pretty good right? Wouldn't it be nice to turn your safety program into a "profit center"?

(5) OSHA won't bother us so why worry about being compliant

Rebuttal: You've been lucky! The fact is under our new Administration OSHA has been given
more authority and is better funded. In fact they are in the process of hiring additional compliance officers. Beware of complacency. . .

http://tinyurl.com/ABC-OF-OSHA

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You're Invited to the "ABC's of OSHA Compliance" Webinar
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Are you responsible for OSHA compliance in your organization?
If so you’ve probably realized its not always easy to understand the often confusing OSHA standards. Many people in this scenario simply give up resulting in unsafe work practices and non-compliance.

Learning Objectives:

By attending this webinar you will learn:
  • 6 easy steps to a safe and compliant worksite
  • Administrative requirements (paperwork) that is often overlooked
  • Lean how to look up OSHA regulations (it’s not as hard as you think)
  • A 5 step process for answering any OSHA question
  • Understand what training you are required to provide employees
  • The MBWE formula for safety inspections – this is critical!
  • How to quickly create the written safety plans that OSHA requires
This webinar is a must for organizations who want to be proactive in their safety programs. By attending you’ll learn how to quickly and easily become OSHA compliant while protecting your most valuable resource - your employees!

http://tinyurl.com/ABC-OF-OSHA

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Monday, September 7, 2009

Why is OSHA Recordkeeping Such a Hot Topic?

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Why is OSHA Recordkeeping Such a Hot Topic?
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This month, OSHA will begin a National Emphasis Program (NEP) on injury and illness record keeping. OSHA plans to review the record keeping practices of employers with low incidence rates in typically high-injury industries.
The inspections will evaluate the following areas, according to a report from Constangy, Brooks and Smith LLP.

* Medical files for 2007 and 2008 occupational and non-occupational cases. Those may include 301 forms, workers’ compensation records, absentee records and audiograms.

* Employee and management interviews to determine effectiveness of the employer’s record keeping system.

* Record keeper interviews to determine knowledge and level of training, as well as any employer interference in proper record keeping.

* An inspection of the facility to confirm that hazards present match those on the record keeping forms.

This program is the result of Congressional hearings last year that questioned the effectiveness of OSHA’s injury and illness reporting.

http://www.wpsac.org/webinars.php?page=recordkeeping

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What Can You do to Prepare?
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To prepare for these OSHA inspections, we recommend that employers:

(1) Ensure that the employees responsibly for recordkeeping have been properly trained and training is documented;

(2) Make sure there is an OSHA 301 or its equivalent for every recordable case;

(3) Review all injury & illness cases from 2007 and 2008 to determine if they are accurately reflected in the OSHA 300 Logs

(4) Review the procedures for reporting injuries and illnesses within your company. Also, ensure that employee privacy is maintained as required by OSHA and HIPAA.

(5) If your company uses a safety incentive program, evaluate whether the incentive program discourages the reporting of work-related injuries or illnesses.

(6) Determine if superviosrs within your organization discourage employees from reporting workplace injuries and illnesses.

http://www.wpsac.org/webinars.php?page=recordkeeping

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You Can Also Attend the Essential OSHA Recordkeeping Webinar Next Week!
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Don't let another year go by wondering if you are following OSHA's rules for Injury and Illness Recordkeeping. Sign up now for this information and easy to follow webinar:

http://www.wpsac.org/webinars.php?page=recordkeeping

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Tuesday, September 1, 2009

You're Invited: Essential OSHA Injury & Illness Recordkeeping Webinar

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You're Invited: Essential OSHA Injury & Illness Recordkeeping Webinar
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Last week we mentioned the "Essential OSHA Injury & Illness Recordkeeping Webinar"
scheduled on Tuesday September 15, 2009 at 2:00pm - 3:30pm and we wanted to make sure
you received the invitation.

http://www.wpsac.org/webinars.php?page=recordkeeping

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OSHA Injury & Illness Recordkeeping Changes
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We'll the kids are back in school, Labor Day is right around the corner and Football season is about to kick off. Which of course got me thinking about how quickly this year has flown by. Only four months until the New Year!

Before long we'll be putting together our annual OSHA reports and posting them for three months (if you're not aware of this requirement - READ THIS BLOG ENTRY)!

I mention the OSHA Injury & Illness Logs because some very interesting things are taking place behind the scenes with OSHA.

Let me start with some background from last year. . .

On April 22, 2008 U.S. Senators Patty Murray (D-WA), Chairman of the Senate HELP Subcommittee on Employment and Workplace Safety and U.S. Senator Edward Kennedy (D-WA), Chairman of the Senate Health, Education, Labor and Pensions Committee asked the U.S. Government Accountability Office (GAO) to investigate whether OSHA is effectively working to ensure that employers are accurately reporting injuries and illnesses in the workplace.

Senators Murray and Kennedy referenced academic studies that employers OSHA logs CAPTURED ONLY 31% of illnesses and 33% of injuries that are reported in other databases.

They also found that the BLS Survey of Occupational Injuries and Illnesses did not account for up to 68% of work-related injuries and illnesses occurring annually in Michigan from 1999 to 2001. [http://www.nycosh.org/reference_library/Rosenman.pdf].

Another academic study found that the actual number of work-related injuries and illnesses is 40% higher than the BLS Survey of Occupational Injuries and Illnesses estimate.

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What Does OSHA say About Injury & Illness Reporting?
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On July 15, 2009 OSHA held a meeting of the National Advisory Committee on Occupational Safety and Health (NACOSH). One of the topics discussed was OSHA's recordkeeping initiative, in particular the forthcoming Injury and Illness Recordkeeping National Emphasis Program (NEP).

At this NACOSH meeting Dave Schmidt, Director - OSHA Office of Statistical Analysis referenced the academic studies noted above and also mentioned OSHA’s own recordkeeping audits have shown that between 10% and 20% of the workplace injuries and illnesses are under-recorded. So even by OSHA's own admission, employers were not accurately reporting the true nature and frequency of work related injuries and illnesses.

In August 2008, the GAO Study initiated by Senators Murray and Kennedy, one of the stated objectives was to “assess OSHA's efforts to ensure that employers are properly recording injuries and illnesses.”

Further OSHA has been provided funding in FY 2009 Budget to “enhance enforcement and oversight of injury and illness recordkeeping to ensure complete and accurate recording and reporting by employers”.

In other words - OSHA's on the "Hot Seat". They have to prove that they are ensuring accurate recordkeeping. How can they prove that?

They could be more diligent in looking at employer recordkeeing logs when they visit.
They could perform more random audits.
They might decide to target certain industries where recordkeeping violations are probable. They could even target organizations with low injury rates, thinking that the low injury rates are a result of under-reporting. . .

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Employer Related Concerns
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From an employer standpoint one of the OSHA recordkeeping challenges we've heard repeated many times is how difficult it is to know if an injury is an OSHA recordable or not. Employers often feel that there is too much "gray area" and the rules are difficult to follow. Because of this typically one of two things happens:

1. Employers record every injury no matter how minor for fear of breaking the law.
2. Employers under record injuries and illnesses since they are unsure what is required.

Either of these scenarios is counterproductive as it potentially hides problems within an organization and discourages positive corrective action. It also provides the Bureau of Labor Statistics and OSHA with faulty data. Of course purposely under reporting to hide workplace injuries and illnesses does happen but surprisingly we have found that many employers are inaccurately recording workplace injuries and illnesses due to a lack of familiarity with the 1904 regulations.

Don't put off your injury & illness recordkeeping concerns. Join us for this excellent webinar on September 15, 2009 at 2:00pm.

Its our best attended webinar each year for good reason!


http://www.wpsac.org/webinars.php?page=recordkeeping

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Here are just a few of the areas we will cover during the webinar:
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  • The #1 OSHA recordkeeping violation - and how to make sure your company doesn't get nailed for it
  • What injuries and illnesses must be recorded and why its critical to avoid"over-reporting"
  • How the OSHA 300 Log trips up many managers, and what you can do so you don’t get saddled with a costly citation
  • A valuable 4-step action plan that you can use to determine when an injury needs to be documented
  • CAUTION! If you are exempt from OSHA Form 300, you are not exempt from the BLS Survey Form. Find out why
  • How to show "good faith" in your OSHA records so you'll never get slapped with an expensive "willful" violation
  • How your documentation techniques should change between your OSHA 300 Log and the 301 Incident Report
  • How HIPAA views OSHA recordkeeping and what privacy mechanisms are required
  • Which OSHA injury & illness documents must be made available to employees and which are off-limits
Here's what is included with this webinar:
  • One full hour of instruction
  • Thirty minutes of live call answering
  • Latest required OSHA forms emailed to participants
  • Entire 29 CFR 1904 Recordkeeping regulations emailed to participants
  • Presentation and handouts emailed to participants - over 65 pages!
  • Participants can email their questions to instructor prior to the tele-seminar
  • Special webpage dedicated for participants - includes forms, DART rate calculator, Industry benchmarks and more!
BONUS: Can't attend the live webinar? Listen to the recorded version anytime - anyplace!

We have limited space available so get signed up today:
http://www.wpsac.org/webinars.php?page=recordkeeping

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Monday, August 17, 2009

OSHA Begins to Refocus on Enforcement Activities

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OSHA Begins to Refocus on Enforcement Activities

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We mentioned this a few months ago but its worth repeating and providing an update or two. . .

President Obama put together a report on the upcoming budget and it had some very interesting things to say about the OSHA budget. In particular here is what the report says:

"For the past eight years, the Department's labor law enforcement agencies have struggled with growing workloads and shrinking staff. The President's Budget seeks to reverse this trend. The Budget will increase funding for the Occupational Safety and Health Administration, enabling it to vigorously enforce workplace safety laws and ensure the safety and health of American workers"

On February 17, 2009 the American Recovery and Reinvestment Act of 2009 was signed into law by President Obama. The Act is an extraordinary response to a crisis unlike any since the Great Depression, and includes measures to modernize our nation's infrastructure, enhance energy independence, expand educational opportunities, preserve and improve affordable health care, provide tax relief, and protect those in greatest need.

Well what does this have to do with OSHA?
OSHA role is to ensure that worker protection laws are enforced as recovery infrastructure investments are carried out.

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What This Means For Employers and Their Recordkeeping Responsibilities
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How will OSHA carry out these responsibilities - after all this will cost more money right?

Well thanks to new budgets OSHA is looking at a $27 million increase over previous years budgets and requires OSHA to improve its tracking of workplace injuries and illnesses.

This last sentence is interesting - "requires OSHA to improve its tracking of workplace injuries and illnesses".

The funding increase also contains a $52 million increase for the Bureau of Labor Statistics (BLS), which is aimed at improving the reporting of workplace injury statistics.

Look for OSHA to shortly announce a National Emphasis Program (NEP) on OSHA Injury & Illness Recordkeeping. This NEP is the result of heat OSHA's been taking from a number of corners including a GAO report initiated by Senator Kennedy.

We'll be talking more about this on our blog in September so stay tuned. . .

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Bad Performers Beware: Severe Violators Inspection Program (SVIP)
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Acting Assistant Secretary of Labor for OSHA Jordan Barab announced a new program named the Severe Violators Inspection Program (SVIP) at a recent House Subcommittee in April.

"Some changes under consideration for the program include mandatory -- not recommended -- follow-up inspections, more inspections of other establishments of an identified company, and additional enhanced settlement provisions," Barab continued "The new program will include a more intensive examination of an employer's history for systemic problems that would trigger additional mandatory inspections".

He also told the House subcommittee that he's suspended the practice of setting goals for new VPP sites and Alliances to direct OSHA's resources instead to enforcement.

This new program is a welcome additional to OSHA's arsenal directed to the bad performers -

The question is:

Are you on the list (or will you land on it in the future) and what will you do to stay off the list?

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Monday, August 3, 2009

Heat Stress & Employers Responsibilities

Earlier this year I was conducting training in Dubai and what I remember as I got off the plane and waited for my taxi was the intense heat - at midnight! I'm from Florida and quite used to hot weather but this was different, Dubai after all is a little slice of concrete paradise carved into the desert and the temps reach 120 degrees without a blink.

Because of these unbearable temperatures, Dubai passed laws that outside work may not be performed between 11:00am and 2:00pm. This was to serve as a protection from the heat. Not a bad idea, but what about your business. Shutting down work may be a bit extreme, so what other precautions can you take - and how does OSHA view your responsibility to protect workers from heat?

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First - what are symptoms of of a heat exposure problem?
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Symptoms of Heat Exhaustion

* Headaches, dizziness, lightheadedness or fainting.
* Weakness and moist skin.
* Mood changes such as irritability or confusion.
* Upset stomach or vomiting.

Symptoms of Heat Stroke

* Dry, hot skin with no sweating.
* Mental confusion or losing consciousness.
* Seizures or convulsions.

Preventing Heat Stress

* Know signs/symptoms of heat-related illnesses; monitor yourself and coworkers.
* Block out direct sun or other heat sources.
* Use cooling fans/air-conditioning; rest regularly.
* Drink lots of water; about 1 cup every 15 minutes.
* Wear lightweight, light colored, loose-fitting clothes.
* Avoid alcohol, caffeinated drinks, or heavy meals.

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Next - what could you do to protect workers?
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Using the recommended process of Engineering Controls, then Work Practices (Administrative Controls) and then PPE, here are a few ideas:

1. A variety of engineering controls including general ventilation and spot cooling by local exhaust ventilation at points of high heat production may be helpful. Shielding is required as protection from radiant heat sources. Evaporative cooling and mechanical refrigeration are other ways to reduce heat. Cooling fans can also reduce heat in hot conditions. Eliminating steam leaks will also help. Equipment modifications, the use of power tools to reduce manual labor and personal cooling devices or protective clothing are other ways to reduce the hazards of heat exposure for workers.

2. Work practices such as providing plenty of drinking water -- as much as a quart per worker per hour -- at the workplace can help reduce the risk of heat disorders. Training first aid workers to recognize and treat heat stress disorders and making the names of trained staff known to all workers is essential. Employers should also consider an individual worker's physical condition when determining his or her fitness for working in hot environments. Older workers, obese workers and personnel on some types of medication are at greater risk.

3. Alternating work and rest periods with longer rest periods in a cool area can help workers avoid heat stress. If possible, heavy work should be scheduled during the cooler parts of the day and appropriate protective clothing provided. Supervisors should be trained to detect early signs of heat stress and should permit workers to interrupt their work if they are extremely uncomfortable.

4. Acclimatization to the heat through short exposures followed by longer periods of work in the hot environment can reduce heat stress. New employees and workers returning from an absence of two weeks or more should have 5-day period of acclimatization. This period should begin with 50 percent of the normal workload and time exposure the first day and gradually building up to 100 percent on the fifth day.

5. Employee education is vital so that workers are aware of the need to replace fluids and salt lost through sweat and can recognize dehydration, exhaustion, fainting, heat cramps, salt deficiency, heat exhaustion, and heat stroke as heat disorders. Workers should also be informed of the importance of daily weighing before and after work to avoid dehydration.

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OK, but does OSHA require you to protect workers from heat and sun exposure?
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An April 16, 1998 Interpretation Letter from OSHA says that worker exposure to the sun's radiation is discussed indirectly under 29 Code of Federal Regulations 1910.132(a) pertaining to personal protective equipment. Employers are to use effective forms of protection such as wide-brim hats and long sleeve clothing. In situations where the only effective means of protection is sun screen, then it too may be used.

If OSHA can prove over exposure to the sun and an employer did not move to protect the worker, a general duty clause citation may be issued.

For further information, OSHA has provided some great information in the OSHA Technical Manual: http://osha.gov/dts/osta/otm/otm_iii/otm_iii_4.html

Another great idea is to print out the Heat Stress Quick cards and provide them to all employees as a reminder of precautions they can take
OSHA Quick Card http://osha.gov/Publications/osha3154.pdf

Give these ideas some serious thought and see if your company can implement these ideas.

Its a brutal summer out there, but remember - winter is right around the corner and then we'll discuss freezing temperatures!

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Thursday, July 2, 2009

The Ten Commandments for Todays Reliability Pros

In the past I've quoted or mentioned my good friend Joel Leonard over at SkillTV (www.SkillTV.net). He's known in certain circles as the "Maintenance Evangelist" and he really does get out there and "preach the good word" about maintenance and reliability.

Well Joel has created a new article entitled: The Ten Commandments for Todays Reliability Pros, and since we have so many plant maintenance folks onboard and maintenance and reliability have a direct impact of a safe workplace, I'd thought I'd share his article in ten commandments style! Good stuff Mr. Leonard - good stuff indeed. . .


With the rash of recent headline disasters traced back to maintenance and operational functions, don’t we need to elevate our reliability performance standards? From rail track sensors sending faulty signals in DC causing two trains to collide, killing and injuring several passengers; to an explosion at a meat processing plant traced to contractors venting natural gas, killing 3 and injuring dozens; and even an ammonia leak burning a workers lungs inside out at a chicken processing plant, shouldn’t we respond?

As companies are cutting corners to save money short-term, as we transition to new workers while baby boomer generation retires, and as we implement more and more sophisticated equipment, our challenges are steep and perhaps are at biblical proportions.

These results are purposely not etched in stone to provide flexibility to adjust to the continual changes in advanced technology and new strategies. However these should serve as a guide to help current and future reliability pros garner more support and understanding from executive and operational leaders.

  • Thou shalt make Maintenance & Reliability a profit contributor for the collective good of the entire company.
  • Thou shalt know the critical equipment whose products delight customers while keeping the land, air and water clean and pure.
  • Thou shalt schedule moments of rest and repair for the critical equipment.
  • Thou shalt maintain the critical equipment to appease the spirits of Quality and Operations.
  • Thou shall not falsely worship reactive maintenance or implement fix it when it breaks mentalities.
  • Thou shall not covet maintenance that serves no useful purpose.
  • Thou shall not steal uptime away from production in times of upheaval and crisis.
  • Thou shall not take the life of equipment with poor practices.
  • Thou shall not place false equipment history in the asset bible (CMMS).
  • Thou shallt convince top execs that reliability and maintenance is to be supported not just managed.
  • Thou shalt not wait until tomorrow to document your work, for it shall never get done
  • Thou shalt not assume anything when investigating a failure, lest you overlook important details
  • Thou shalt not allow emotions to determine the focus of your work, instead sort by criticality
  • Thou shall not allow anyone to misuse the good name of Maintenance in vain and blame it for the shortcomings of the organization as a whole. Respect maintenance, it is critical to the success of any organization and should not be seen as just an overhead or cost center.
  • The stores are a holy sanctity, thou shall respect them and keep them full, use suppliers to consign the stock where possible to reduce cost and Develop relationships with key suppliers, treat them as your partners.
  • Thou shall respect thy skilled tradesmen, do not allow your trades to die, train well the young and develop the old in modern techniques.
  • Thou shall not covet another’s processes, take time to review and benchmark then adopt the best bits. Remember the basics, sometimes good people and good tools are all you really need.
Oh, you may have noticed that there are actually 18 listed above. The responses were so good that could not shrink to ten. And after-all, since I don’t have to lug huge stone carved tablets down a mountain, why not have more?

Your success largely is dependent on your ability to create solutions, manage performance and develop miracles to achieve profits in a down economy, meanwhile keeping your business environment safe. Since you have god-like responsibilities, you choose which commandments to follow. Now it is your turn to add, change or delete to advance your organization.

P.S. If you like the article, give Joel a shout at Joel@SkillTV.net - tell him we sent you!

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