Maintenance Technology September 2016 - 22

SAFETY STRATEGIES and an equally effective over-thecounter medication, though, can be the difference between a recordable and a non-recordable injury. Plant and facility staffs should include personnel with some degree of medical background or training and a strong grasp of injury-reporting requirements. These types of individuals should always accompany injured workers to off-site clinics, doctor offices, and/or hospital emergency rooms to assure prompt and effective treatment and correct reporting. Strategic plans must address safety. Safety should be an inherent part of strategic plans-corporate, site, and department. Compliance with safety procedures must be mandatory, and failure to follow or enforce them will result in non-compliant behavior. To be sure, safety policies and procedures must be realistic. Procedures should address specific regulations and/or hazards. Procedure compliance (especially critical procedures) should be verified through audits (see below). Any procedural exceptions need to be identified up front and formally approved. Sites, however, should be judicious in granting any exceptions. Recognize that willful deviations in safety procedures increase risk and liability. Therefore, effective safety policies, procedures, and programs must be easily understood. Include the following: ■ Procedures should be written in layman's terms (avoiding legal or technical jargon). Include helpful references for those seeking additional information, such as applicable OSHA regulations. ■ Make procedures readily available to anyone who needs them. Key word search-ability helps workers find the appropriate procedure for their application. ■ Review and update safety procedures through an appropriate frequency based on criticality, regulatory changes, and other parameters. 22 | MAINTENANCE TECHNOLOGY Contractor Safety Matters due dates and overdue notifications. Although a simple spreadsheet will suffice, there are inexpensive software programs that track every action item through completion. They include an interface to the plant email system and send out notices and reminders of the status of corrective actions, especially those that are overdue. It's also important for inspectors to employ a structured root-cause analysis process or methodology that helps them identify root causes and contributing factors, along with specific corrective actions for each root cause and contributing factor. Based on that information, corrective actions can be implemented and, where practical, hazards can be engineered out. Internal safety auditors/ inspectors need to stay informed about pertinent industry incidents, evaluate internal application of that information, and confirm compliance and mitigation. Doing so involves participating in near-miss reporting activities, including investigation, if warranted. They should also analyze near-miss data to identify recurring problems and initiate preventive action(s). In doing this work, it may be helpful for inspection-team members to leverage advanced statistical methods with safety data to discern trends that may not be obvious to the untrained observer. Keep in mind that a job safety analysis (JSA) should be performed prior to commencing any maintenance work. Risk assessments should be a part of the JSA process. Measuring and monitoring is key. You can't manage what you don't measure. Accordingly, sites must measure and monitor safety to manage and sustain injury-free performance. That means tracking and reporting such The use of maintenance contractors is inevitable. Thus, their selection and management is critical to support and sustain an injury-free workplace. Consider the following best practices: ■ Select contractors based on safety performance (OSHA 1910.119). ■ Base contractor selection on actual safety performance, not the contractor's reported safety programs. Establish contractor safety-selection criteria, e.g., better half performers using Bureau of Labor Statistics data (current chemical industry TRIR is 2.3 and refining is 1.7). ■ Include a cancellation clause in contracts to the effect that if poor safety performance warrants, the contractor can be expelled from the site. ■ Set a high bar for exceptions, such as sole-source contractors. Require leadership approval for any exceptions. Make exception mitigation rigorous. ■ Use dedicated contractor supervisors for contractor management and oversight. ■ Establish a contractor steering team to set policy. ■ Maintain an active contractor safety council with company and contractor participation. ■ Designate a mentor for each primary contractor and hold him or her accountable for the performance of their respective contractor(s). Safety audits are essential. This means conducting announced and unannounced audits with internal and external auditors. Sites should also implement a plant manager's safetyinspection program. The plant manager's safety-inspection team should conduct an unannounced inspection at least once a month. Members of the inspection team should be assigned specific safety policies, procedures, and/or regulations to audit and re-inspect units or work areas to ensure that previously identified deficiencies have been addressed. Note that this type of team demonstrates that management is actively and visibly engaged in safety. Members should be trained (see safety-training sidebar) and thoroughly familiar with the policies and procedures they're auditing. The inspection team should use a corrective-action tracking system for non-compliance that includes SEPTEMBER 2016

Table of Contents for the Digital Edition of Maintenance Technology September 2016