You've tried everything you can think of to abate a hazardous situation, but the hazard remains. Maybe it's time to think "outside the box."
Brainstorming and looking beyond traditional problem-solving concepts may provide the answer you need to abate that hazard. In the fourth printing of his book, "OSHA Inspections: Preparation and Response" (McGraw-Hill), safety consultant Rick Kaletsky of Bethany, Conn., offers several suggestions on how to creatively approach abatement.
One is to talk to those affected by the hazardous situation. It could be as simple as asking them what they would suggest to involving workers in team-based, problem-solving settings. Sometimes, the best ideas may start as "seemingly wild or strange notions" and should not be dismissed with mocking, sarcasm or insulting criticism, Kaletsky writes.
"If you're going to get to creative solutions, you've got to look at the hazards and talk to the workers affected," said Kaletsky, who worked for OSHA for 20 years as a compliance officer and assistant area director.
Throughout the book, enhanced and updated for 2000, Kaletsky writes about how employee involvement can help with hazard abatement,especially when preparing for an OSHA inspection. Beyond that, the author lists other examples to creatively abate a pesky hazard:
- When machine hazards noted during inspections appear to be very difficult to abate, it may be feasible to simply eliminate the machine. Can the work be done on another kind of in-house machine?
- If several tasks are performed on each of several machines and it is difficult to abate the task-specific hazard, perhaps each machine can be dedicated to only one or two tasks.
- When dealing with process safety management of highly hazardous chemicals, decrease the amount of chemical to less than the threshold quantity that triggers the regulation.
- Try substituting a flammable chemical with a water-based, nonflammable solution to avoid costly and necessary elimination of in vapor-ignition hazards.
- Where possible, eliminate a highly hazardous operation from the facility by contracting the work. A contractor may be more adept at controlling a hazard because of his expertise. Examples of contracted tasks are permit-required confined spaces, hazardous waste operations, emergency response and electrical safety-related work practices. On top of that, the facility might be able to "max out" of certain OSHA standards that no longer apply to the work situation, Kaletsky writes.
"Understand that there are other avenues open to hazard abatement," he said. "You don't always have to deal with just what's in front of you."
Open minds can flourish on safety teams, Kaletsky writes. Forget the expression, "It has always been done that way." Ask why it was always done that way and how it should be done now.
"The bottom line," Kaletsky says, "is that it is good business practice to avoid being locked into the confines of conventional, cookie-cutter approaches to risk reduction. Innovation and alternative ("out of the box") thinking falls right into this philosophy."
Other subjects with updated material in the latest edition of Kaletsky's book include respiratory protection, workplace violence, late-shift work, personal protective equipment, OSHA inspection scheduling and ergonomics. The book is divided into two sections: Part 1 prepares the work site for an OSHA inspection; Part 2 deals with responding to OSHA after the inspection.