by: Safety Scrooge
About this time every year I find it more and more difficult to get into the “Holiday Spirit”. Maybe, like you, I work too hard, too long, and commute too far. Maybe we’ve all become hardened by the never ending flow of disturbing local and world news. Did I leave out the daily exciting stock market roller coaster ride? That usually gets my heart pumping. I finally get home, kick off my shoes and settle down in my favorite chair only to be bombarded by commercials. Talking heads trying to sell me something I don’t need. Maybe “they” think if I see the commercial often enough I’ll change my mind and buy that all-purpose adjustable ladder that everyone wants. Ever hear the guy at the end of a commercial that reads the disclaimer. How does he do that? He talks so fast it doesn’t even sound like he’s using words.
Holiday Spirit? Maybe I’m just getting old. Whatever the reason, even though the world around us is up-side down, we need to remain focused on effectively assessing hazards associated with our construction projects. Construction is a dangerous business and confined spaces can be deadly places. Let me explain where I’m going with this. Recently, I was delivering a confined space safety training course to fairly large class. As a safety professional, my particular goal was to introduce the new OSHA Construction Confined Space Standard (29 CFR 1926 Subpart AA). The room was filled with a majority of younger foremen and superintendents. The rest of the attendees were owners of small to mid-sized construction companies, a few safety professionals, and assortment of designers and engineers.
My purpose in writing this article is not to discuss the new OSHA Confined Space standard (29CFR 1926.1200). I look forward to discussing that with you in a future article. My purpose now is to blow off a little steam and possibly share an experience with those of you that have ever given, or will give, a safety class or a five-minute safety talk.
My class started in the usual way. My materials and hand-outs were in order. I greeted everyone with a smile. Attendance was taken. Evacuation procedures were reviewed and I outlined the objectives of the class. After all, I’ve been doing this for over 30 years and I’ve become very familiar with the routine. Just when I was about to get started, one of the participants, seated in the back row, had set the tone for the class. In a loud voice he announced that he owned his own construction company. He then told me that “We all know this is a waste of time, so let’s get it over with.”
Rather than get upset and eject him from the course for his poor attitude I decided to introduce him to the equivalent of Safety past, Safety present, and Safety future. In other words, I was going to be his nightmare. It would be totally up to him if he finished the class and hugged Tiny Tim or left dragging the unsafe chain he forged in life.
It so happened that his comment proved to be a good training tool. I used it to my advantage to explain the importance of complying with the new standard and compliance with safety regulations in general. After he spoke, the rest of the class turned to look at him and then waited for my reaction. Every once in a while someone like this pops up in a class. I’ll admit I was annoyed. After all, this is an important topic and OSHA predicts that approximately 800 lives will be saved because of this new standard.
I stood at the front of the class, casually leaning against the podium. I took a deep breath and in a non-threatening way made eye contact. I told him I was curious about why he thought this training was a waste of time. He didn’t hesitate. He replied, “I’m too busy trying to make a living and I haven’t got time to waste on this safety stuff”. There had to be some reason why he was here, so I asked him why. He said he was the subcontractor on a project and he was told by the general contractor that he would be the “competent person” on the job.
At this point I really became concerned. The term “Competent Person” is used in many OSHA standards and documents. An OSHA “competent person” is defined as “one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them” (29 CFR 1926.32(f)). By way of training and/or experience, a competent person is knowledgeable of applicable standards, is capable of identifying workplace hazards relating to the specific operation, and has the authority to correct them.
I asked him and the rest of the class if they ever witnessed or have been directly responsible for an employee’s work related death or injury? I asked if anyone has ever taken part in an accident investigation involving a confined space? Silence. I had everyone’s attention and I noticed my star pupil slump and squirm in his seat. I could tell by the look on the faces of the other participants that they were disappointed with him and his comments. This was encouraging. I had only one “Bah Humbug” in my class.
I asked my final question. I asked him directly if he was one of those contractors who bids low to be awarded the project and then cuts corners on safety to make a profit while gambling on the life and health of his employees? He was speechless. He was embarrassed. He left the class. The rest of the class had gone smoothly. There were some great conversations and I was reminded that there are those that can use an attitude adjustment and there are those take confined space safety seriously.
Here is my Confined Space Holiday Safety Wish for him and others who feel the safety of their employees does not contribute to their “bottom line”; May you realize before it’s too late that the chances you take with safety can permanently impact your life and the lives of others and their families. I hope he decides to review and understand the new confined space standard. I hope he trains his workers. I hope he puts his heart and soul into that training and sets a good example for his employees to follow. Most of all, I hope he improves his attitude toward confined space safety and becomes pro-active when it comes to improving the safety of the workplace. In construction, we design, we build and rebuild spaces that may fit the definition of a confined space. Confined space means a space that: 1) Is large enough and so configured that an employee can bodily enter it; 2) Has limited or restricted means for entry and exit; and 3) Is not designed for continuous employee occupancy. It’s our responsibility as an employer or employee to ensure job safety. Construction can be a dangerous business and there’s no room for dangerous attitudes. I wish you and yours a happy and safe holiday.
