Workers’ health and safety is among many things to account for when making changes to manufacturing processes and equipment. Failure to fully consider health, safety, and other operational aspects at the concept and design phases of a project can result in costly setbacks during construction and operationalization. Achieve safety and productivity dividends over the long term by employing the following strategies and tactics to make safe design, safe construction, and safe operations a reality where you work.
Know applicable standards
If you were to hear, “I’m from the government and I’m here to help you,” you wouldn’t be alone if your response were, “Thanks, but no thanks; I’ve got this.” People don’t want to be forced into action. Most of us would rather be guided into choices by benefits. There are benefits to standards (even the mandatory ones).
Government regulations and consensus standards are rich sources of good practices and pain-free lessons learned. People like you from companies like yours provided the insight upon which standards were written. The adage that safety standards are “written in blood” isn’t far from the truth. Why in the world would anyone want to learn their own hard lessons? It’s much easier to learn from others’ experiences. You’ll want to figure out which standards apply to your projects and to do this during early phases of the project, ideally before putting a project out for bid, writing internal work orders, or taking other initial steps.
Contracts should require compliance with applicable standards and regulations. Outcomes will be predictable if applicable standards and regulations (your expectations) are not specified during the work scoping and bidding process: 1) Vendors will bid low and perform minimally to preserve profit margins, or 2) You’ll incur numerous delays and change orders for out-of-scope requests.
One thing that standards and regulations require for some systems in some regions (and is a best practice for all systems in all areas) is a risk assessment. In a risk assessment, the vendor documents the expected as-installed hazard and grades the risk for operation and maintenance in the presence of these hazards, and then uses the process to quantify risk mitigation possible through recommended controls/precautions. Even when risk assessments are not formally required to meet minimum government expectations, it is always wise to ask vendors to provide this documentation. It almost goes without saying that companies should do their own assessments and see if things match up.
Another frequently included contract requirement is that the vendor must have a “safety-competent person” on-site during the work’s construction/integration phase. The role of the safety-competent person is to ensure that health and safety considerations are accounted for (so your organization will not be affected by contractor safety mistakes). The vendor’s competent person is a point of contact from whom to receive site-specific information about hazardous energy control, confined space entry, hazardous chemicals, and egress/evacuation protocol. In an ideal world, the foreman or site superintendent (the overly busy person whom you see carrying blueprints and project schedules) can serve double-duty as the safety-competent person. Dedicated safety resources are recommended for complex and large-scale jobs.
Most progressive health and safety management systems contain provisions for contractor/vendor approval. The health and safety department or purchasing agent will typically furnish vendors with expectations prior to bidding. Vendors in turn furnish necessary documentation regarding historical health and safety performance and mechanisms in place to ensure site safety. Typically, contractors will also furnish policies for prehire and random substance and alcohol testing, insurance coverage, and other documents. Less-safe vendors will be screened out prior to bidding work.
Clear contract language goes a long way toward preventing confusion, costly change orders, and delays. Companies that receive vendor work products will want to follow through and ensure contract compliance actually happens.
Understanding applicable standards
Standards and regulations can be difficult to read and apply properly. Simply handing a safety regulation or standard to maintenance, operations, and other (nonsafety) support personnel probably won’t lead to a deep understanding or correct application of the subject matter. Support specialists such as health and safety professionals should be part of the project team. These specialists can help decode and interpret tricky regulatory language.
Even if there is a health and safety professional on the project team, you may still want to consider briefing/training the entire project team on applicable standards. A common language and understanding is needed so project team members can communicate around common goals of the project. When training, emphasize the reasons for standards. To aid in clear understanding, project leads should request project team participation in end-user and vendor visits for a more complete as-used representation of processes and equipment. Remember, people would rather choose to comply because of benefits, not because the government or “corporate” says so. Train early in the process for full project lifecycle benefits. Expect coordination and communication difficulties if the health and safety specialist is the only person who understands the standards.
A parting note about nongovernmental industry consensus standards: Consensus standards aren’t always as optional as they may seem. Adopting practices that exceed regulatory minimums helps prevent incidents and can provide ongoing protection from “general duty” penalties and civil liability. Think of consensus standards as a way to do more and get more in return.
Involve stakeholders
Stakeholder needs must be met for project success. Groups potentially affected need to have a voice in project decisions (how else can companies validate that project plans will address stakeholder needs?). Involving affected groups fosters a sense of ownership and ensures foundational knowledge needed for procedure development and ongoing support of implemented systems.
Production and maintenance groups are frequent project initiators, and as such their voices are commonly heard. Other affected groups may be unfortunate afterthoughts to novice project leads. Think big when soliciting project input. Get multiple perspectives: Talk with other sites using similar processes and equipment, and hear from operators, maintenance employees, supervisors, managers, and support personnel. Seek third-party perspectives from equipment manufacturers and process integrators. Third parties have insight, an interest in project success, and a network of end users (so ask for introductions).
Intended changes can give rise to unintended side effects. After stakeholders have been identified, gather the group and apply “if/then” logic to brainstorm secondary effects attributable to the intended project deliverables. Consider all angles – upstream, downstream, and forward into the future – in an attempt to anticipate these often-overlooked impacts.
One project I supported introduced pallet picking automation. Material configuration on incoming pallets became a concern. Suppliers were made aware of pallet configuration changes. Suppliers were asked to furnish test pallets for preacceptance picking reliability validation. The supplier missed an opportunity to correct stressful new configuration stacking practices (force and posture risk factors were present during test pallet stacking). The supplier experienced an outbreak of soft tissue injuries directly correlated with the increased demand for pallets in the new configuration. The window to act on force and posture risk factors closed with operationalization of new picking automation.
In this case, the ergonomic benefits of automated pallet picking were offset by the increased ergonomic burden on suppliers. Secondary effects can be expected, need to be watched for, and should be identified and acted upon early so controls can be implemented before adverse consequences occur.
Safe construction and integration
Construction and integration will vary depending on the project, so we’ll be purposefully brief in addressing this topic. The strongest enabler of safe construction/integration performance has already been mentioned – namely, making sure expectations for the project are well-understood, clearly specified, and scoped/priced into bids. Again, this is likely to involve including provisions for a safety-competent person and/or a dedicated safety resource.
You can expect that the safety resource or competent person will handle safety activities such as making sure workers coming on site are properly trained and drug-free; making sure equipment is properly inspected prior to use; conducting daily site inspections; investigating incidents for root causes; weighing in on potential conflicts related to the day’s work (e.g., it might be a bad idea to use flammable PVC pipe cement near welding, cutting, and grinding activities; conversely, it may be a great idea to perform welding, cutting, and grinding activities away from operational areas).
The vendor safety resource will be one point of contact for the project team. Project team members will have occasion to observe vendor work activities. Any unsafe acts and conditions observed need to be brought to the attention of the vendor’s safety resource. In most cases, it is appropriate for the vendor safety resource to directly address safety issues. Along these lines, the project team should usually stop short of directing vendor employees, as this is the vendor’s responsibility.
Operationalizing processes and equipment
Most companies cannot afford having much nonproductive time pass after the conclusion of construction and equipment integration activities. Companies want to begin realizing a return on project investment as soon as productive use of equipment and processes is possible.
Immediate productivity is a risky proposition unless the project team has made operational readiness a priority well in advance of construction/integration completion. Project schedules should include milestones for the completion of safe operating procedures, hazardous energy control procedures, confined space entry procedures, job hazard analysis (if required), and the like. Machine safety interlocks and other safety controls identified through risk assessments need to be thoroughly tested. It may be discovered that risk that seemed well-controlled in theory (and two-dimensionally on prints) is not quite so safe up close and personal with as-installed processes and equipment. Time also needs to be allocated for workers to receive training and become proficient in new operations. Similarly, coaching and reinforcement, too, will be especially important, so factor in time for these.
Jonathan Jacobi is a senior EHS adviser in UL’s EHS Sustainability Advisory Services practice. He has more than 20 years of health and safety leadership experience in the nuclear, automotive, semiconductor, paper, and tobacco industries and has served the U.S. DOE and companies such as Intel Corp., Altria Corp., Kimberly-Clark, and Honda. Jacobi s a certified safety professional (CSP) and OSHA Authorized Outreach Trainer.
Early procedures are written without much actual experience using the equipment. Companies invariably find that procedural revisions are needed according to this new understanding. Ask people to talk it up. Spend time on the floor asking people for feedback. Convey the message that it’s OK to find things wrong and that you want to learn from fresh perspectives of workers experiencing equipment and processes for the first time.
As much as the project team hopes to anticipate effects, some small ripple may still be missed. It’s better to face this reality than to run from it. This is why many successful project leads develop a punch list for items identified by operational owners of installed systems.
New manufacturing processes and processes can bring many benefits, but they can also introduce risk into the business. Time spent considering perspectives, wants, and needs of all stakeholders helps keep projects on track and on budget. Successful project integration requires a team effort, and a team effort takes planning, legwork, and reinforcement. Putting the effort in before the project starts will save time and money and ultimately will help keep your employees healthy, safe, and on the job.
