In Part 1 of this feature, we discussed what employers can do to prepare for emergencies like the one in West, Texas. Today, we’ll examine the role of accident prevention strategies and talk about how implementing proactive, multifaceted safety programs can prevent disasters and benefit everyone.
Accident prevention: Move beyond compliance
There’s been a lot of debate about the West Fertilizer Company’s regulatory history, but the answers aren’t straightforward. The materials at the facility in West, Texas, are regulated by a patchwork of different agencies, including OSHA, the Environmental Protection Agency (EPA), the Department of Transportation (DOT), the Department of Homeland Security (DHS), and several state-level agencies, including the Texas Commission on Environmental Quality (TCEQ).
While compliance with safety regulations is undeniably important, each of these regulatory agencies looks at just a piece of the chemical safety puzzle. The EPA is primarily concerned with risk to the community; OSHA worries about employee safety; the Pipeline and Hazardous Materials Security Administration (PHMSA), a division of the DOT, regulates the transportation of hazardous materials; and the DHS is primarily concerned with security for terrorism prevention purposes. The lesson here is that employers can’t assume that compliance alone will address safety from a broad, multifaceted perspective. If each regulatory agency is concerned with a particular aspect of safety, it’s up to the employer to see the big picture and be proactive in managing risks.
The bottom line is that compliance is just the first step. When designing a safety system, employers should ask themselves: What are the ultimate goals of the regulations that apply to me? How does compliance keep my employees safe—and are there additional measures I should take to protect them? With that in mind, here are some steps every employer can take to help prevent accidents and manage risk:
Job hazard analysis
What is it? Job hazard analysis is the process of breaking down a job or task into basic steps. Each step is then analyzed to determine the hazards involved. Hazards uncovered could include being struck by an object, back injuries from repeated lifting, or lacerations from a piece of machinery.
How does it prevent accidents? By taking a detailed look at the interaction between the worker, the environment, and the tools used at each step of a task, employers who conduct job hazard analysis can pinpoint hazards that may not be obvious and take steps to make a job safer before an injury or accident occurs.
Process safety management
What is it? Process safety management is an OSHA requirement that involves taking a comprehensive look at each process at a jobsite that uses or emits certain highly hazardous chemicals. The key to effective process safety management is a careful review of what could go wrong and the dangers that would result. Steps must be taken to address these hazards, and the employer must develop and implement operating procedures consistent with these findings.
How does it prevent accidents? While process safety management is a legal requirement for certain facilities, it’s helpful to look beyond the language of the regulation and consider its underlying goals: anticipating and preventing the worst-case scenario through careful planning. This kind of thinking is helpful for any employer that wants to be proactive about accident prevention, not just those that store hazardous chemicals.
Injury and Illness Prevention Plan
What is it? As its name implies, an Injury and Illness Prevention Plan (IIPP) is a written plan with a comprehensive strategy for preventing injury and illness in a workplace, including details like who is responsible for enforcing the plan, a system for ensuring compliance, communication procedures, hazard assessment, procedures to investigate incidents and correct hazards, employee training protocols, and recordkeeping standards.
More resources from Safety.BLR.com:
How does it prevent accidents? The key to accident prevention with an IIPP is its comprehensive nature. An effective IIPP addresses all aspects of workplace safety, from the physical environment to the tools to the employees, and uses this information to create a multifaceted strategy for accident prevention. IIPPs aren’t a federal OSHA requirement, but they’re encouraged—and some states, including California, do require them.
Proactive accident prevention is good for businesses, too
Going beyond compliance isn’t just about creating a safe workplace for employees; it makes business sense, too. The General Duty Clause of the Occupational Safety and Health Act requires employers to furnish a workplace “free from recognized hazards that are causing or are likely to cause death or serious physical harm.”
What this means for employers is that even those who comply with the specifics of all applicable regulations aren’t immune from citations in the event of an accident. If OSHA finds that a hazard that caused an accident was foreseeable and preventable—even if it wasn’t governed by an existing regulation—companies may find themselves slapped with violations and costly fines.
On the flip side, employers who adopt best practices may see a decrease in their workers’ compensation premiums. For example, even though IIPPs aren’t currently a federal requirement, workers’ compensation insurers may reduce their rates for companies that have these plans in place.
The bottom line
Regulatory compliance is necessary, but it’s just a starting point. To prevent disasters like the one in West, Texas, from happening again, employers need to take responsibility for implementing comprehensive safety systems that plan for the worst. Even if that worst-case scenario never happens, a proactive accident prevention and emergency response strategy will improve everyday safety and benefit everyone.