More thoughts on Fitness for Duty.
As an employer, how well do you determine employee fitness for duty? Fit for duty means are they healthy enough to do their job without adding risk to themselves or others. Are they physically and mentally prepared for their assigned job and tasks? There are both regulatory requirements as well as legal limitations that dictate how much information and of what sort you as an employer may ask of a prospective employee. However, certain occupations – especially those regulated by the government such as CDL vehicle driver – require health and medical history assessment. For example, for a prospective or current CDL driver, failure to meet medical screening acceptance criteria usually results in restriction or even prohibition from commercial driving. In other occupations, pre-existing medical conditions can be problematic too. Fitness for duty is also a daily consideration; if an employee is not capable of functioning at necessary physical and metal levels to do a job safely, they shouldn’t until such time that they are deemed fit.
Complying with environmental regulations can be a daunting task even for the trained professional. Besides the US EPA, the government has another website that provides a wealth of information about environmental regulations and compliance guidance. The site contains links to information for every major environmental regulation and program promulgated by the Feds. There is even a section on compliance auditing and enforcement, and another on training and presentations. Visit the site to learn more: https://www.fedcenter.gov/programs/compliance/.
Accidents happen, sometimes despite thoughtful planning. But planning is not enough and does not complete the formula. Maintain on-going consequential thinking as part of the process. That means to repeatedly reassess conditions, the environment, as well as your actions and those of others. A safety plan such as a daily work plan to site safety plan will have gaps if it is seen as a static go-to answer-all plan. Each person must use consequential thinking as they work; asking themselves what has changed and if their actions will have a negative impact at a future point.
Here’s a case in point: an industrial construction project, an ironworker was excited to demonstrate how he was wearing all the required safety equipment and was keeping his work area free of tripping hazards and clutter. He had in his possession a thoughtfully completed site-required task analysis form. Was he then working safely? Well, no he wasn’t. He was tightening bolts on an I beam with a large box-end wrench. They have been known to slip or even break. He was pushing or pulling against the torque which made him lean into or away from his work. A couple of feet away were a number of long bolts protruding from new concrete and ready for the next standing I beam. If he had slipped or fallen in the direction of the bolts, he could have been badly injured or even impaled. The solution was to cap the bolts and to use a wider stance when torquing the nuts on the bolts he was working on to steady himself. So it pays to plan ahead and assess; what could occur in seconds or minutes ahead?
Spill Prevention, Control, and Countermeasure Plans (SPCC’s) are required by the EPA when certain threshold amounts of stored oils are reached. See: 40 CFR, Subchapter D, Part 112.7. We find that there are often flaws or omissions in SPCC plans. They include:
- Failing to include oils stored in stationary equipment such as hydraulic systems and/or crankcases.
- The SPCC Plan did not have a signature of approval by management (40 CFR 112.7)
- The SPCC Plan was not certified by a PE (40 CFR 112.3(d))
- No spill history was included in the FRP (40 CFR 112.20(f)(2(i)(F))
- No self-determination criteria form was included in the SPCC Plan (40 CFR 112.20)
- The Plan lacks written procedures for inspections and for maintaining inspection records for 3 years (40 CFR 112.7(e))
- Personnel are not properly instructed in spill prevention procedures (40 CFR 112.7(f))
- Spill prevention briefings are not conducted for operating personnel (40 CFR 112.7(f)(3))
- Inspections are not conducted as required (40 CFR 112.7(e))
- Facility security measures, including fencing, gates, and/or security guards, are not mentioned in the SPCC Plan (40 CFR 112.7(g)(1))
These are but a few common gaps. We’ll discuss SPCC’s in more detail in an upcoming post.