We recently blogged about some best practices for OSHA inspections, but we thought we would add to that with some comments on Process Safety Management. In terms of Environment, Health and Safety concerns, a process can be any given activity (or perhaps a combination of various activities). It can include the use of any substance that the Environmental Protection Agency (EPA) deems hazardous, whether the substance is manufactured on site or merely handled or moved from site to site. And so, process safety management (PSM) refers to the regulation of various activities that are viewed as potentially hazardous – regulation that is propagated by OSHA.
Process safety management makes use of a set of interrelated approaches for managing various hazards. Its goal is to reduce the frequency (and, ideally, to completely eliminate the occurrence) of incidents that result in harm to the individuals in the workforce or to the environment. This goal is accomplished, in part, by providing structured guidance for production design, organizational skills, operational procedures, audit programs, and other helpful tools.
A 14-Point PSM Program
OSHA has designated the following 14 elements to work together as a process safety management program:
• Process Safety Information
• Pre-startup Safety Review
• Operating Procedures
• Process Hazard Analysis
• Mechanical Integrity
• Trade Secrets
• Employee Participation
• Management of Change
• Hot Work
• Emergency Planning and Response
• Incident Investigation
• Compliance Audits
Each element in the OSHA PSM program is designed to work hand-in-hand with the other thirteen. In spite of the fact that they may seem tedious and overwhelming, they are in place, of course, to guarantee the safety of employees and the environment. They can only accomplish this often-daunting task, however, if they are built on the foundation of a dedicated, involved management team and controlled access to information.
Information is Vital to Successful PSM
Without controlled and accurate information, process safety management simply cannot work properly. A company cannot be in compliance with OSHA standards if the standards are not clearly known or understood. What kind of information is needed? It is information that relates to the following three key areas (as a minimum):
• The technology of the process- All employees and members of the management team should have an overall knowledge of the basic flow of the entire process, including the standard inventory as well as the upper and lower safety limits on variables such as pressures, temperatures and compositions. The entire team should have a clear understanding of the effect that deviating from set safety procedures and regulations will bring.
• The equipment used in the process- All members of the company should be familiar with the tools, machines, and all equipment used on the job. Workers should understand how to maintain the equipment in safe, working order and should understand the rules for safe usage of each piece of equipment. A company should provide visual charts, diagrams and such to help employees understand the way the process makes use of the various pieces of machinery. Specific instruction should be given to teach employees about precautionary steps involving the equipment’s ventilation, electrical system, emergency shut-offs, and other safety features.
• The hazards of chemicals that may be used in the process- It is crucial that the company’s work force have knowledge and understanding of the chemicals used on the job, including their: toxicity, reactivity, corrosive ability, thermal stability (for example, the effect that storage temperature has on the chemical), the permissible exposure limits and the hazards involved when mixed with other substances.
As few as one major, negative incident regarding health and safety in a given company can impact the company’s future for years to come. Information is powerful, and the company CEO who desires the assurance that plant processes are functioning on a safe, hazard-free level needs a way to access crucial information about the company processes and to get that information into the hands of the entire staff. That information is key in maintaining efficient process safety management.
The Nimonik company includes a team of process safety management experts who can assist companies with the overwhelming task of ensuring that their processes are operating within OSHA compliance levels and are hazard-free. If you would like to have the peace of mind that information and compliance can bring to your company in the safety management area, give us a call for a FREE consultation about our PSM tools that can help keep your company in the compliance mode. You can reach us on the web or by calling toll free: 1-888-608-7511. Our customer service experts are waiting to talk with you.
Management of cleaning services can be a moving target. With high staff turnover, roving teams and varying standards, ensuring you deliver a clean facility, hotel room, or building to your clients is a challenge. Nimonik Audit for iPad and Android are essential tools to helping you complete Quality Assurance and Quality Control on your cleaning service delivery. Below are some free checklists that you can use on our platform. For a personal tour of the system to discuss your requirements, simply send us an email to firstname.lastname@example.org
A big thanks to Mel Manuel Rosas of Pin Point Safety for his comments and input into the following post.
Workplace safety 101: Lessons Learned in Safety Management
Ensuring a safe workplace is a challenge that is made more difficult by staff turnover and constrained resources. In this post, I hope to help pinpoint some of the key items that will help your organization ensure that it is prepared for OSHA inspection. This post will be the basis of my HR.com presentation next week on May 12th. Register here!
The short answer to ‘What you need to do to be ready for an OSHA Audit’ is to follow the full Federal Code and any differences your state might have. Twenty-three states have standards above and beyond what the Federal government requires. Of course, that strategy is not terribly helpful. In reality, your company should start with written safety policies that are approved by management. However, far too many companies stop there – leading to problems with OSHA inspectors.
Not only must you have policies, but they must also be implemented and staff must be up- to- date on their requirements. Each employee must demonstrate to an OSHA inspector that they are aware of what they must to do remain safe based on their role at the company. This includes everything from materials handling and personal protective equipment to confined space permits and lockout tagout procedures. The key for ensuring this level of knowledge is twofold: education and verification.
Education comes in the form of regular training and retraining sessions. These training sessions need to take place for both new and long-term employees and contractors. It is essential that you keep records of who participated in the training, who gave it and when it too place. You can use an online system such as Nimonik to manage this or you can keep the records on your own with Word and Excel files.
When an OSHA inspector does come to your site, you want to ensure that your staff is ready. An OSHA inspector will typically follow your production line, from materials receiving to the shipping of the final product. They will attempt to ensure that all staff and all processes are up-to-speed on their requirements. The only way to ensure that level of knowledge is regular inspections of your location and its staff. Of course, you can use our Audit tool from Nimonik, but this can also be done with pen and paper. The essential part is that you actually use checklists and other tools to keep your staff on their toes.
In terms of testing material, you can use off-the-shelf checklists such as the ones offered by Nimonik. But, a far better solution is to use your own internally-developed checklist. This will force your staff to be involved in the process and invest their knowledge in the company for use by other staff and even for themselves. Your Safety Manager should take time with each person at your location to have them put down on paper all of their knowledge about the safety procedures related to their work tasks. They should indicate the risks involved and list items that they themselves watch out for and that other employees should know about, too. The persons transmitting their knowledge should pretend that someone else needs to replace them tomorrow due to a staff change. Ultimately, this is a Job Hazard Analysis, but since that term can be scary, the best way to frame it is often as a simple explanation of what a job entails and what it requires to stay safe.
When you use these checklists in the field and you find an issue that is amiss , it is essential that you take action. Not only should the direct person at fault be offered assistance to improve the work – through training or another activity – but the staff member’s superiors also need to be informed and made responsible. Demonstration of responsibility is a key element for OSHA inspectors. Your management is as responsible for any safety violations as is the lowest person on the totem-pole, ultimately it is the CEO’s responsibility that all staff members are working in a safe and compliant manner; and management cannot offload that responsibility down the ladder.
The Federal government has a VPP program that companies can adopt to demonstrate proactive safety programs. It is not rocket science. A safe company is one that has fully involved employees and a safety culture that are constantly transmitting the best practices and improving the work environment. Again, using safety tools to signal opportunities for improvement can be done with Nimonik or with a simple Excel and Email system. The key is information gathering and then information transmission.
We hope these tips help you prepare for your next OSHA Inspection and you stay off the below average DART list which currently contains has over 9,000 locations in the United States. Do not hesitate to contact Nimonik for more information, and please come to our Webinar on May 12th to learn more!
Nimonik is thrilled to announce a new report: Problematic Audit Items (see your own report here)
This new report is designed to help you pinpoint items that repeatedly have problematic findings. The items are identified across your Audit Templates and your Facilities, helping you identify issues that need to be placed at the top of your priority list. According to many management systems, such as Kaizen of 5S, you should start with the biggest issues and work towards the rarer problems. This Problematic Audit Items report helps you identify the big issues that should be tackled as soon as possible.
You can see the number of times a specific item has been audited and what percentage of the time it has been problematic. The severity column allows you to quickly see your high risk items. The score is calculated by taking the weight of the item and the value to generate a score, it is then added across all the times it was audited. The Severity is in essence summing the cumulative scores. We hope this new report helps you further identify problematic items with potentially large organizational risks.
Today’s management teams face unprecedented challenges in the area of maintaining a safe work environment. In addition to the obvious need for creating an environment of health, safety and wellness, OSHA requirements and possible repercussions for neglecting them are more stringent than ever.
Management teams are handling this heightened challenge in a variety of ways. Some companies employ strict measures for safety violations, hoping that the austere environment will coerce employees into compliance. However, from a psychological perspective, this authoritarian approach does little to promote a pleasant, cooperative aura in the workplace. Instead, it tends to keep personnel on edge and fosters a suspicious, critical mentality among co-workers.
For example, one well-known company in the food production industry upholds the motto “Accidents don’t just happen: people cause them.” This company immediately terminates the employee who is responsible for any “accident” on the job site. While such a policy may effectively alleviate on-the-job mishaps, it also may have a tendency to incite the qualities of fear and reluctance, which are generally not conducive to productivity.
What can a management team do, then, to reduce injuries, illnesses and the resulting employee down time? Some companies raise awareness by using safety quotes to promote a more secure work environment. A well-constructed safety quote can speak volumes and help change your corporate culture. Perhaps the following guidelines can be used to create effective safety quotes that will bring about a positive response from the company’s work force:
Keep them simple. Just as with roadside billboard advertising, passers-by have only a few seconds to view and to grasp the message. Zero in on a specific “call to action” that needs to be accomplished. A brief statement such as “Hardhats Only Zone” can be much more effective than posting a lengthy quotation of the law code which requires such safety measures. The bottom line is this: if it isn’t read, it isn’t noted.
Brevity also helps eliminate the feeling of being lectured (which invariably generates an adverse response from an audience). Using the simple message “Hardhats Only Zone” is psychologically acceptable whereas a lengthy explanation of the types of injuries that can be sustained when the hardhat is neglected can be patronizing. Try some of these simple quotes that can be found online on various sites:
- “Head injuries are brutal: protect your noodle.”
- “Accidents don’t keep business hours.”
- “A confined space is a dangerous space.”
- “Don’t live on the edge.”
- “What you don’t know CAN hurt you.”
- “A spill + a slip = an emergency room trip.”
- “Put safety first because accidents last.”
Use one, simple, colorful graphic with each safety post. A bright yellow hardhat and a pair of goggles with the words “Get in Fashion” makes an understandable, effective statement while appealing to the basic need for conformity.
Appeal to a basic human need such as survival, security, belonging, and self-esteem. A simple silhouette of a family next to the words “Don’t make the Emergency Room your hangout after work today” may cause an employee to think twice before circumventing a protective measure.
Use humor rather than a didactic approach. For example, a simple graphic of a person’s head with hair standing on end and the words “Electrocution is a shocking way to go!” or “Missing fingers will seriously hinder your golf swing!” get the point across in a memorable way.
The use of safety quotes, when handled effectively, can mean lower DART ratings for your company. Devoting time and money to create a safe work environment is not a cost: it is an investment. If you would like more ideas for promoting EHS standards within your team, you can contact the Nimonik Company online or call toll free at 1-888-608-7511. A highly-skilled member of the Nimonik team is standing by waiting to speak with you about your EHS needs.
At Nimonik we love to hear about companies who strive for environmental, social and safety excellence. When our clients make these lists, we are even more thrilled!
Each year, corporations all over the world compete for the 2015 Global 100 Most Sustainable Corporations in the World index: a ranking system of the “most sustainable” companies in the world published in the Toronto based Corporate Knights magazine. An especially high honor goes to those companies who rank in the top 25% of the top 100. We are thrilled to work with a number of the identified leaders, such as L’Oréal and Atlas Copco.
The Global 100 has been ranking companies against clear sustainability metrics since 2005 and is one of the most respected rankings for companies at the forefront of best management practices. For the ranking, companies must pass a four-step screening process to gain placement on the Global 100 Shortlist and then a further round of scoring determines which companies will obtain a position on the final Global 100. Solactive, the German index provider, has also created an investment index out of the identified Corporate Knights Global 100 to track their financial performance as they strive for environmental sustainability.
How Nimonik Helps Build a Foundation for Sustainability
Any company that aims to be environmentally sustainable must first master regulatory compliance. Nimonik’s team of experts employ the latest technology to help corporations build their sustainability strategies on top of our compliance tool for EHS legislation, industry standards, OSHA requirements, process auditing and more. Nimonik builds the local and international legal research and maintains accurate inspection checklists so its clients can concentrate their efforts on the operationalization of their requirements. Using our solution, Atlas Copco and L’Oréal have reduced their time tracking EHS laws and inspecting their locations, freeing up resources to pursue higher value sustainability tasks.
For example, Nimonik’s EHS Audit App can help an organization conduct every type of inspection – from environmental regulatory requirements to internal corporate sustainability standards. To sample the auditing app and see what it can do move your organization towards the Global 100 Sustainable companies, please visit the Nimonik web site and view one of the auditing checklists.
One last note on the link between inspections and sustainability. A key component of sustainability is your supply chain. Nimonik’s auditing apps can help a management team determine if its current or potential suppliers are meeting the company’s standards of excellence – one of the key factors in sustainability. After all, if the parts to the whole are not meeting standards for sustainability, then the whole is affected. Therefore, an effective analysis of suppliers is crucial to the operation of the company.
Again, a big congratulations to all the organizations that made the Global 100 Most Sustainable Companies and we look forward to helping companies pursue a more efficient and more sustainable business model!
Nimonik is thrilled to announce an Android version of its award winning iPad and iPhone software, EHS Audit. Now available for free on the Google Play Store, this app lets you use over 1500 free audit checklists to conduct an environmental, health, safety or quality audit.
This initial version allows you to synchronize all of your data with NimonikApp.com, collaborate on audits and inspections and generate signed reports.
In the next few weeks we will be adding Corrective Actions (CARS), Photo, Audio and Other attachments to your audit questions. We will follow up with Tasks, Incidents, and other great features this summer. We look forward to keeping this app at the forefront of inspection software around the world. To stay tuned or receive a personal demonstration of the system, give us a call at 1-888-608-7511
Nimonik is presenting its state of the art technology and amazing content in a number of presentations over the next two months. Here are some of our upcoming presentations:
- How to Prepare for an OSHA Inspection – HR.com – May 12, 11 AM EST
- How to Conduct EHS Compliance Audits on iPad and Android – BLR.com – May 20, 2 PM EST
- Upcoming changes to ISO 14001 – June 5, 2 PM EST
- General Nimonik Demonstration of Audit Module – May 14th, 2 PM EST
- General Nimonik Demonstration of EHS Legal Management Module - May 27, 2 PM EST
- General Nimonik Demonstration of Permit Management Module – June 10, 2 PM EST
Over the past three years, Nimonik has worked hard to deliver the best and easiest to use audit tools. Today, we are thrilled to announce Version 3 of our Auditing interface. It is completely redesigned and rebuilt for 2015 with powerful and easy to use navigation. Some of the key features you will see on Beta.NimonikApp.com :
- View your entire audit at once;
- Easily see which items have outstanding corrective actions;
- Loads 300% faster than previous version;
- Quickly drag and drop media and files into your items;
- Add a signature and secure your audit data; and
- Quickly load more audit questions.
We really hope you enjoy this beta version of our auditing interface, we expect it to be rolled out to all users in July 2015. Here is a GIF animation to help you see what our tool can do for you!
The carbon market is making an impressive entrance in North America. Ontario announced this week that the province will join the Quebec and California carbon market. Quebec and California aligned their emissions regulations in 2014 to create a joint carbon market, the largest in North America and the only one in the world operated at the subnational level. The current Quebec and California harmonized provincial and state regulations apply to more than 80 large companies and concern over 400 million metric tonnes of carbon emissions (source available here) and this will grow with the addition of Ontario. The next couple of years will see Ontario bring its emissions regulations into mutual alignment in order to join this developing market, while other states and provinces consider following suit.
California’s and Quebec’s cap-and-trade system can be summed up as a market where participants buy and sell permits to emit carbon, called “emissions allowances.” One emissions allowance equals one metric tonne (kt) of carbon (CO2) released into the atmosphere. Every company producing more than 25,000 kt CO2 must possess enough allowances to match its emissions. Most companies are issued emissions allowances free of charge by the government, but only up to a certain emissions amount – called the emissions limit or “cap.” If a company wants to emit CO2 beyond the cap, the company must purchase the necessary emissions allowances at auction. Conversely, companies who have reduced their emissions to a level below the cap may sell their excess allowances at auction. Every year the cap lowers between 1% and 2%, thus reducing the supply of free allowances and possibly increasing the auction price.
One of the most appealing aspects of the California-Quebec joint cap-and-trade system is its potential to add other government jurisdictions, thus expanding the carbon market. Developed as part of the Western Climate Initiative, the system was envisioned as connecting multiple states and provinces. Emission allowance interchangeability is the link between jurisdictions. Although California and Quebec have very different economies and distinct carbon reduction goals, emissions allowances at auction are fully interchangeable. An emission allowance from Quebec equals one from California, and vice versa. Quebec and California hope that, in this way, businesses and governments will benefit from an emissions framework tailored to their region but part of a larger, more competitive carbon market.
This expansion and cohesion is made possible through harmonized regulatory systems. California’s cap-and-trade system was implemented under the aegis of Assembly Bill 32: Global Warming Solutions Act, passed in 2006 (Act available here). The Quebec National Assembly passed a similar bill in 2009 with Bill 42: An Act to Amend the Environment Quality Act and Other Legislative Provisions in Relation to Climate Change (Act available here). Regulations allowing linkage with other jurisdictions followed in 2011 with the California Cap on Greenhouse Gas Emissions and Market-Based Compliance Mechanisms Regulation and the Quebec Regulation respecting a cap-and-trade system for greenhouse gas emission allowances, and were finalized in 2012 with Quebec’s Regulation respecting the delegation of management of certain parts of a cap-and-trade system for greenhouse gas emission allowances.
In the coming years, Ontario is expected to pass similar legislation. Environmentalists and businesses alike will have their eye on this developing regulatory framework. The results of continuing joint auction will also affect Ontario’s regulatory choices. At present, the carbon market is bearish but respectable. The second joint auction in February 2015 resulted in all emissions allowances being sold, yet only a mere dime above the price floor. How the entry of Ontario affects the auctions will likely influence whether or not other jurisdictions join. If Ontario smoothly joins the established market, cap-and-trade may have the potential to expand across North America.
A recent report by the Ecofiscal Commission, available here, lauded the joint cap-and-trade model. The report argued that the model is a flexible market mechanism that can be successfully adopted by other governments. The report has academic and political clout – the Ecofiscal Commission’s advisory board features one former Prime Minister and three former provincial Premiers. So, it is unsurprising that the report has already had a political impact. Glen Murray, Ontario Minister of the Environment and Climate Change, tweeted here that “Quebec’s leadership on climate change is recognized & celebrated.” This comment came just days before Ontario signed on to cap-and-trade.
The hoped-for result of the cap-and-trade system is a price on carbon that encourages environmental innovation, does not overly penalize heavy emitters, creates new business opportunities and brings in revenue for the government. Whether cap-and-trade can accomplish all this remains to be seen. Nevertheless, the debut of the carbon market has been impressive. Less than two years old, it already encompasses California, one of the largest economies in the world. California and Quebec have been able to overcome differences of language, legal systems, economic profiles, and geography to form a promising level of regulatory cohesion. For the rest, the market will be the test.