A work team was conducting well plug and abandonment activities to decommission a production platform this past April. The activities took place at night, and equipment included a power swivel skid, casing jack and crane. The roustabout worker was acting as a rigger to help control the load of the power swivel as it was being moved from atop the well. When the power swivel was lifted above the well access opening in the deck on the platform, the roustabout either stepped or was dragged by the load into the opening. Night medevac callout was delayed due to confusion in emergency planning, and the worker’s fall into the opening resulted in his death.

A BSEE investigation team indicated several factors contributed to the accident, a few of which are highlighted below:

• The pre-lift meeting did not discuss the existence of the hole beneath the power swivel, which would be exposed once the swivel was lifted off of it. Therefore, no fall protection was provided as required by company policies, BSEE, and USGC.

• The pre-shift JSA meeting also did not address the hole in the main deck beneath the power swivel, and was not attended by all involved parties (including the roustabout).

• No signed, unique JSA document was created.

• The lighting may have been inadequate for a night operation.

• Equipment on the platform was positioned poorly and interfered with the crane operation:

o The power swivel skid was equipped with two “tag lines” that were only three-feet long, requiring riggers to be in close proximity to the load.

o The tag lines were attached to the power swivel in such a way that they would drag across the open hole as the skid was moved.

o A rudimentary, inherently dangerous, “pipe rack area” allowed the box ends of 15 joints to protrude over the skid, requiring riggers to manually maneuver the load to keep from hitting the pipe.

o The temporarily stored casing jack interfered in the crane operator’s vision of the lift.

• There was no clearly designated, direct supervision of the lift because of multiple responsibilities assigned to the only supervisor on duty.

• The supervisor and company man on site did not have an emergency plan with medevac procedure and contact information readily available.

In developing a JSA, it is important to meticulously and thoroughly evaluate each aspect of the job ahead of time. Including input from workers who have performed the task in the past may be of particular value, as they can identify hazards, control measures and job steps a supervisor might not be aware of. The JSA can also be used to designate specific tasks for each person, and enable the supervisor to discern if additional workers or supervisory staff will be necessary, before beginning the job.

It may also be necessary to designate a pre-task JSA to include worksite preparation activities, such as adequate lighting and visibility, clear walkways and lines of travel, moving and stowing of unnecessary equipment, and designated “safe” areas for spotters and supervisors.

In addition to clearly designated supervision, a comprehensive lift plan and fall protection, easily retrievable emergency and medevac plans, standard operating procedures and a work-site risk assessment, a thorough and well prepared JSA covering all risks and hazards associated with the task can aid in safe performance of jobs similar to this. By utilizing a worker sign-in sheet (now available in the JSABuilder individual JSA dashboard), supervisors and health and safety officers can ensure all workers have been briefed on the risks and controls, and are fit to perform their assigned tasks.

Text for this article based off the BSEE Safety Alert. A full report of the accident can be reviewed on the BSEE site.

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Quite often, this evaluation may result in assigning the worker a different set of duties than normal for the day, to ensure no one’s safety is jeopardized. Occasionally, it may mean requiring the worker to take a mandatory rest day and be discharged from the work site for the day.

It is important for each worker to understand the side effects of the drugs he or she takes, whether prescription or over the counter. Those drugs that may have the ability to impair the worker’s safe performance of the job need to be reported to the job supervisor or health and safety officer, for the sake of the worker’s safety, as well as the rest of the job site.

It is also important to ensure employees know and understand the company’s drug policy. Do employees feel safe reporting a change in medication or a new medication, without fear of reprisal? Do employees understand that change in work duties due to impairment is not a disciplinary action, but a necessary precautionary measure? Does the company have a policy in place to accommodate light duty or alternate duty work days? Do employees understand that the company values their safety more than turning a profit?

Finally, other routine prescription and over the counter drugs also have the ability to impair workers, and may be habit forming (in particular, prescription painkillers and anxiety medicines). If you suspect you or someone you know may be becoming addicted, call 1-800-662-HELP.

For information on disposing of prescription and over the counter drugs safely, contact your local waste provider. Many waste collectors off a medical waste drop off day for proper disposal of expired and unused medications.

See also the CDC, CDC Poisoning in the United States: Fact Sheet and the CDC Injury Center Prescription Drug Overdose in the United States blog Q&A.

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Sources quoted by OSHA, including the Liberty Mutual Research Institute and the National Academy of Social Insurance (NASI), estimate that the direct costs to employers for occupational injuries, illnesses and deaths were $53 billion in 2008, and annual workers’ compensation benefits paid for all compensable injuries and illnesses were approximately $58 billion in 2009. NASI further reported that the total costs paid by employers for workers’ compensation increased from $60 billion in 2000 to $74 billion in 2009.

Numerous studies have been conducted that show that implementation of an effective injury and illness prevention program (IIPP) can dramatically reduce workplace injuries, illnesses and deaths, as well as significantly reduce the direct and indirect costs associated with such incidents. The most important features of an effective program, according to the research, include management commitment and leadership, effective employee participation, integration of health and safety with business planning and continuous program evaluation.

To determine the effectiveness of various IIPPs, OSHA evaluated several State-mandated and State-recommended programs. There are 34 states that have established laws or regulations designed to require or encourage such programs, with 15 that have mandatory regulations for all or some employers. States with mandatory programs were found to have the greatest reductions in workplace incidents.

More specifically, OSHA reported that California, Hawaii and Washington, which all have mandatory programs, showed workplace fatality rates as much as 31% below the national average in 2009. Details regarding injury and illness rates were provided for several states, including:

• Alaska: 20-year mandatory requirement; five years after implementation the net decrease in injuries and illnesses (above the national decrease) was 17.4%;

• California: 21-year mandatory requirement; five years after implementation the net decrease in injuries and illnesses (above the national decrease) was 19%;

• Hawaii: 27-year mandatory requirement; net reduction in injury and illnesses was 20.7%.

OSHA also reported dramatic workers’ compensation savings in states that offered incentives to employers who adopted injury and illness programs. For example, in 2009, Colorado reported a cumulative annual reduction in accidents of 23%, and a cumulative reduction in accident costs of 58 – 62%. Even small companies have reported significant savings in workers’ compensation costs following implementation of an effective program.

The Ohio Bureau of Workers’ Compensation analyzed the policies of 16 firms over a 12 year period that had implemented SHARP-certified injury and illness prevention programs (IIPPs), and found that the average number of claims decreased by 52%, the average claim cost decreased by 80%, the average lost time per claim decreased by 87% and claims (per million dollars of payroll) decreased by 88%.

The numbers speak for themselves. Implementation of an effective injury and illness prevention program (IIPP), together with active management and employee engagement, can dramatically reduce workplace injuries, illnesses and deaths, as well as significantly reduce the direct and indirect costs associated with such incidents.

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OSHA believes that IIPPs provide “the foundation for breakthrough changes in the way employers identify and control hazards leading to a significantly improved workplace health and safety environment.” In addition to reducing workplace injuries, companies with effective, actively maintained programs can see a dramatic improvement in regulatory compliance, coupled with the financial benefits of a safer and healthier workplace, including significant reductions in workers’ compensation premiums.

An example of how a successful IPPP can positively affect worker’s performance and the company’s bottom line is the case of Hypotherm, a manufacturer of high-tech plasma and laser-cutting tools and machines based in New Hampshire. The company provides an extensive training program to its 900+ employees that emphasizes health and safety as part of an overall focus on quality. Between 2007 and 2010, the company saw a 25 percent reduction in costly machine crashes and down time, and realized a 90 percent savings in workers’ compensation costs. Hypotherm has consistently been named a “Best Place to Work” in New Hampshire, and having a proactive and effective IPPP has been key to that success.

Although OSHA has not yet mandated development and implementation of injury and illness prevention programs (IIPPs), such regulations are being considered by OSHA. As stated during a June 10, 2010 stakeholders meeting held in Washington, D.C., an OSHA representative stated that, “a mandatory Injury and Illness Prevention Program rule, enforceable by OSHA inspectors, is the plan that is currently being considered.”

Mr. David Wallis of OSHA’s Directorate of Standards and Guidance, further stated that, “there are more than 7.5 million businesses in the United States, and that more than 5 million of these employ 20 or fewer employees. Based on current statistics, injuries are evenly distributed between large and small employers.” Mr. Wallis stated that, “OSHA would like to formulate a rule that is broad enough to capture all workplace hazards, but also be focused enough so that the rule does not lose its effectiveness.”

According to the OSHA white paper, an effective IIPP includes the following core elements:

(1) management duties;

(2) employee participation;

(3) hazard identification and assessment;

(3) hazard control;

(4) education and training; and

(6) program evaluation and improvement.

There are 25 states in the U.S. where development and implementation of worker protection programs is mandatory. Several of the State-level programs are being considered by OSHA in development of a federal standard. Several participants in the June 2010 meeting stated that the California rule successfully led to the creation of numerous effective programs, and they suggested that OSHA should try to borrow some of the components that have made California’s program successful. Title 8 of the California Code of Regulations, Section 3203 requires that “every employer shall establish, implement and maintain an effective Injury and Illness Prevention Program” (IIPP). The text goes on to include the following instructions.

The Program shall be in writing and, shall, at a minimum:

(1) Identify the person or persons with authority and responsibility for implementing the Program.

(2) Include a system for ensuring that employees comply with safe and healthy work practices.

(3) Include a system for communicating with employees in a form readily understandable by all affected employees on matters relating to occupational safety and health, including provisions designed to encourage employees to inform the employer of hazards at the worksite without fear of reprisal.

(4) Include procedures for identifying and evaluating work place hazards including scheduled periodic inspections to identify unsafe conditions and work practices. Inspections shall be made to identify and evaluate hazards.

(5) Include a procedure to investigate occupational injury or occupational illness.

(6) Include methods and/or procedures for correcting unsafe or unhealthy conditions, work practices and work procedures in a timely manner based on the severity of the hazard.

(7) Provide training and instruction.

In addition to the components of the program, OSHA evaluated the “critical success features” associated with superior health and safety performance. Several studies reviewed by OSHA concluded that strong management commitment and active employee involvement were critical to reducing injury risk, and that conversely, “paper programs” are, not surprisingly, ineffective.

An example of how management commitment and active employee participation is critical in developing and maintaining effective programs was provided by OSHA in their review of McConway & Torley’s health and safety program and culture. Pittsburgh-based McConway & Torley has been producing steel castings, rail couplings, and car-connecting systems for the railroad industry since 1868. Although the company had a compliance-based safety program, workers were still getting injured at their two foundries.

Working with OSHA to develop a new injury and illness prevention plan based on OSHA’s Voluntary Protection Program (VPP), managers and workers discovered that the required high level of employee involvement really made a difference in the success of the program and in the reduction of work place injuries. Foundry managers and employees now participate in monthly safety audits, facility-wide inspections, accident investigations and self-assessment, and are actively involved in conducting safety training. Employees submit ideas for safety improvements and then help implement those improvements, providing them with a degree of empowerment that continues to make a difference in injury reduction and creating a safer workplace. The impact of the new program was significant in allowing the company to reduce worker’s compensation cases in its facilities by 79 percent and reduce related direct costs by 90 percent between 2006 and 2010.

Identification and control of workplace hazards is critical to an effective IIPP, but even more important is the commitment from management to provide a safe and healthful workplace, coupled with active employee involvement in the management of identified risks. JSABuilder not only provides the necessary tools to identify hazards and establish control measures, but it sets up a unique system that allows workers and managers to share, analyze and update site-specific information, encouraging participation in the program at all levels. As building blocks of an effective IIPP, JSAs/AHAs can help reduce workplace injuries and illnesses, improve workplace attitudes and reduce company costs as well!

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Incident: An unexpected failure of a pipe fitting resulted in the sudden release of pressure, causing an oxidizing agent to spray into a well technician’s face. Although the technician was wearing safety glasses, the pressure caused the oxidizing agent to spray under the safety glasses and into the technician’s eyes. The technician was immediately helped by others to an eye-wash station where his eyes were flushed with water and he was checked for injuries. As a precautionary measure, the employee was taken to an emergency room.

Fortunately, the incident only resulted in minor discomfort and the physician determined that no medical treatment was necessary. The technician was able to return to work the next day.

Investigation: The investigation revealed that the injection well coupling that failed was not constructed properly and did not use compatible materials. The investigation also concluded that the effect of the failure was compounded by a Job Safety Analysis (JSA) that required safety glasses but not goggles during this stage of the activity. Although goggles had been used in other similar injection projects, this protection had been overlooked.

Corrective Actions: As a result of this incident, revisions were made to engineering specifications to ensure incompatible materials were not used in the future. Also, the JSA for the injection of oxidizing agents was revised. All staff working on chemical oxidation projects are now required to don full splash protection during injection operations.

All accidents are preventable and this one should have been, yet all too often human error results in unintended consequences and injuries. Your JSA process should involve asking the question of what could go wrong and providing controls to prevent injury in the event it does. What caught our eye in this incident was that splash protection had been used before, but that somehow this information was not conveyed to others. JSABuilder captures your knowledge of hazards and controls by storing this information for you and your colleagues to use again and again, making for a more efficient JSA process and a safer workplace.

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1. Cigarette smoke – if you don’t have a non-smoking policy already, consider starting one or designate a confined smoking area.

2. Cockroaches – limit food and trash sitting out unattended, and maintain a sanitary work environment.

3. Dust mites – install bare floors where possible, vacuum offices regularly, and try to keep offices under 50% relative humidity.

4. Mold – ventilate work spaces and keep them cool and dry.

5. Pets & Animals – a contained, clean pet at home means your employees won’t bring dander to work with them!

6. Pollen – familiarize yourself with and monitor your area’s seasonal ragweed, grass and tree pollen. Reduce exposure by allowing employees to adjust their schedules to working in the afternoon, after it rains, or on indoor projects.

For a full reference on the above allergens and preventative strategies, visit the National Institute of Environmental Health Sciences (NIEHS) website.

Make sure you also check out OSHA’s website on Occupational Asthma to learn more!

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• Remove hazardous noise from the workplace whenever possible.
• Engineering controls are the most effective way to limit or prevent hazardous noise.

• When unable to reduce or eliminate noise levels, choose appropriate hearing protection (expandable foam plugs fit all, pre-molded plugs are reusable, canal caps can hang around your neck while it’s quiet, and earmuffs protect the entire outer ear).

• Noise-induced hearing loss is 100% preventable, but permanent once it occurs.
• Approximately 30 million workers are exposed to hazardous noise levels on the job and it is the most common occupation illness.
• The industries with top noise exposures are agriculture, mining, construction, manufacturing, transportation, and military.
• A jackhammer’s noise output is 110 dB (for reference, normal conversation is about 60dB) – unprotected exposure to this level of noise for only 2 minutes is enough to cause damage!

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The Facts: The generator weighs about 100 lbs, has only two wheels, and no ergonomically designed lifting handle. Workers must utilize the frame to lift & move the generator. The generator is stored amongst other equipment in the storage shed, making access difficult. A job safety analysis was not performed in advance.

The Situation: A worker was assigned the task of removing the generator. Due to the storage position and lack of maneuverability of the generator, the worker was required to place himself in an awkward position to move the generator. When the worker lifted and started to push the generator, he immediately felt pain in his lower back. The resulting lumbar sprain meant the worker lost one day of work and was on restricted duties for two weeks.

The Analysis: Had job hazards been analyzed, discussed, and a JSA created before the work began, a few simple controls could have been implemented:

1. Casters would have been installed on the generator to enhance maneuverability (Engineering Control).

2. The generator would have been stored in such a manner to allow for better access, avoiding the risk of injury from an awkward position (Administrative Control).

3. Ergonomically sound techniques would have been used by the worker to maneuver the generator into position for transport. This may have involved another worker’s assistance in moving the generator (Administrative Control).

All too often the hazards associated with routine tasks are not fully analyzed before workers proceed. If a job safety analysis had been performed, the hazards of the task would have been carefully considered, discussed, and controlled. The worker would have avoided a painful injury and the company could have avoided unnecessary costs and losing a valuable employee’s time.

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• Carefully inspect the ladder for defects, cracks and corrosion before use. Tag and remove from service any ladders deemed unsafe.

• Make sure the ladder’s feet have slip-resistant pads.

• Use a fiberglass ladder around electricity.

• When setting up a ladder, look for a location with firm, level footing and a rigid support for the top of the ladder.

• Always use three-point contact when climbing a ladder (this means never carrying a load while ascending or descending the ladder – finding a partner to hand decorations up and down to you while you are working is a great idea, or use a backpack or pulley system to avoid hauling them up yourself while climbing).

• Never stand on the top of a ladder.

• Do not pull, stretch or make sudden movements that could cause a ladder to tip.

• Avoid placing ladders near doorways, pedestrian walkways or vehicular traffic.

Don’t forget that these tips are relevant for ladder safety around the home as well, as you are putting up and taking down your holiday decorations year-round. And remember, using a spotter is always a good idea!

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