Вы находитесь на странице: 1из 30

Advisor

THE
VOLUME 10 NUMBER 3

A TECHNICAL PUBLICATION OF ASSES CONSULTANTS PRACTICE SPECIALTY

PAGE 6 COMPLIANCE Lockout/ Tagout & Machine Guarding PAGE 12 SAFETY & HEALTH Multigenerational Workplace PAGE 16 MANAGEMENT Business Relationships

How Big is a Confined Space?


BY BARBARA JO RUBLE

PAGE 18 CONSULTANT SERVICES BLS Data

uring the course of a recent audit, I discovered that many of my colleagues and I had been taught to apply OSHAs confined space standard (29 CFR 1910.146) incorrectly. The question that came up was related to identifying a confined space, which I find to be one of the more frequently debated questions among safety professionals. And because this discussion took us beyond the basic standard and into the compliance

A space that cannot be entered is not confined; therefore, it does not pose hazards related to the difficulty of exiting the space.

directive and the preamble to the standard, I thought it would be worthwhile to share the details with others who may face similar situations. The confusion comes up in reading the definitions in the standards. A confined space is defined as one that (among other things) is large enough and so configured that an employee can bodily enter. This is followed by the definition of entry, continued on page 28

For a complete Table of Contents, see page 3

1 The Advisor www.asse.org 2011

ADMINISTRATORS MESSAGE

Advisor
THE

ThankYou
s ASSEs Safety 2011 approaches, be sure to register, get organized and plan your itinerary to make the most of this great event. Not only will there be several special events surrounding ASSEs 100th anniversary, but vast educational and networking opportunities will also be available, all in one place. Here are some good links to help you prepare: Best Conference Tips 10 Conference Networking Tips 10 Tips for Successful Business Networking I hope to meet you at this years conference. I would love to hear your feedback on how you think the Consultants Practice Specialty (CPS) is doing and what we can do to improve. Although my term as Administrator is up at the end of June, I would like to pass some ideas along to my successor, Pam Walaski. I know Pam will do a great job as Administrator since she has been so helpful in her role as Assistant Administrator, but please step up and contribute to advance CPS to its full potential. With a new term approaching, I want to challenge CPS memWILLIAM R. BOB COFFEY bers to get involved. The saying you get what you put in is especially true for association memberships. A limited number of advisory committee positions are available, but we are always looking to form subcommittees and project taskforces. For more information on volunteer opportunities, click here. As I depart, I would like to thank all of you for your continued loyalty and support. I also would like to thank the volunteer advisory committee for their tireless efforts to keep CPS moving forward. Thank you all and hope to see you at Safety 2011!

CONSULTANTS PRACTICE SPECIALTY

OFFICERS
Administrator WILLIAM R. BOB COFFEY (717) 428-1357
wrcoffey@wrcsafety.com

Assistant Administrator PAM FERRANTE (412) 414-4769


pam@jcsafety.com

Publication Editor DEBBY SHEWITZ (216) 862-5077


dshewitz@ix.netcom.com

COMMITTEES
Awards & Honors DAVID F. COBLE
davidcoblecsp@aol.com

Body of Knowledge WILLIAM R. BOB COFFEY


wrcoffey@wrcsafety.com

Conferences & Seminars KATHY HART


kathy@clearvisionconsult.com

Membership Development CLIFF PETRIELLA


safequest@ameritech.net

Nominations LINDA M. TAPP


ltapp@crownsafety.com

Website Development BRIAN HITT


hitt2010@att.net

ASSE STAFF
Staff Liaison KRISTA SONNESON (847) 768-3436
ksonneson@asse.org

Publication Design SUSAN CARLSON


scarlson@asse.org
The Advisor is a publication of ASSEs Consultants Practice Specialty, 1800 East Oakton St., Des Plaines, IL 60018, and is distributed free of charge to members of the Consultants Practice Specialty. The opinions expressed in articles herein are those of the author(s) and are not necessarily those of ASSE. Technical accuracy is the responsibility of the author(s). Send address changes to the address above; fax to (847) 768-3434; or send via e-mail to customerservice@asse.org.

2 The Advisor www.asse.org 2011

C O N T E N T S
VOLUME 10 NUMBER 3

PAGE

1 HOW BIG

IS A

CONFINED SPACE

By Barbara Jo Ruble The author defines confined space and clarifies how OSHAs confined space standard should be applied in the workplace.

PAGE

16

PAGE

LOCKOUT/TAGOUT & MACHINE GUARDING


By Randy Roig OSHAs control of hazardous energy (lockout/tagout) standard is one of the more complex federal safety regulations. Compliance with the standard is further complicated by its interrelation with two other significant standardsa connection that many people fail to make.

FIVE STEPS TO DEVELOPING IMPENETRABLE BUSINESS RELATIONSHIPS


By Michael Rega & Anne-Marie Lenton One thing that separates top consultants from the ordinary is their client management skills, which include the ability to penetrate and forge a genuine bond with key players within the client organization.

PAGE

18

BLS DATA ON THE CONSULTING INDUSTRY


PAGE

8 LOCKOUT/ENERGY CONTROL:
HELPING
TO

An overview of the consulting industry based on Bureau of Labor Statistics data.

FILL

THE

GAPS

By Andrew W. Johnson It is important for safety consultants to make their clients aware of any gaps or deficiencies in lockout programs.

PAGE

12 SAFETY & HEALTH


By Michael W. Thompson

PREVENTION IN THE MULTIGENERATIONAL WORKPLACE


Todays multigenerational workforce requires management, safety and health professionals and disability management specialists to be creative in planning and implementing prevention activities with regard to injury and illness.

CONNECTION KEY
Click on these icons for immediate access or bonus information

Video

Website

PDF

Hot Link

AD

Ad Link

Direct Link

3 The Advisor www.asse.org 2011

NEW MEMBERS

Welcome New Members


W
e want to thank everyone who remained a loyal member of the Consultants Practice Specialty and welcome the following members who recently joined. Joseph McHugh Lewis McIlroy Gilbert Meneses, Tennessee Valley Authority Shawnna Mettlen, EHS Assist LLC Sam Mickey, SSC William Miller Robert Mullins John Nain, Nain & Associates LLC Michael Nichols Jude Ofulue, Nigerian Institute of Safety Professionals Melissa Panter Daniel Pivin Andrew Pozun Michael Prejean, Advanced Safety Training Management Robert Ramirez, Advance Safety Inc. Jordan Reagan, Imperial Risk Pamela Reich David Ritchie Dominique Robinson Gary Rossi George Saunders, Chesapeake Engineering & Design Inc. Thomas Schmidt, Advanced Earthworks Inc. Cindy Schneider, North Valley Compliance Inc. Philip Shipp, Professional Forklift Engineering Services Charles Short, Division One Management J. Stack Katherine Stevens, Business Health Solutions PC Lisa Swapp Luis Tarrats, LAT Safety Solutions Scott Tengan Dhruti Thaker, Actavis Carl Thurnau Andrew Troccoli Thomas Turansky Crystal Turner Mark Vaillancourt Margaret Wan, EOH Consulting John Wilhite Mark Williams, Willis Corroon Corp. Makki Al Awami, Saudi Aramco Husam Eddin Al Khaldi, ADCO Saleh Alharbi, Saudi Aramco Florante Andrion, Team Sual Corp. Team Energy Phils Andrew Arena, Arena Construction Co. Inc. Stacey Arnold Keith Badey, Bermac Risk Management LLC Rickie Baker Steven Belanger Roger Blank, Pacificorp Jeffrey Brown, Brown Services LLC Tyler Buckingham James Burke Robert Cavalier, Raytheon Sharon Childress Terese Churchill, EverGreen Environmental Health & Safety Inc. Shawn Cline, Forensic Analytical Consulting Services Inc. Steven Crooks, People Property & Environmental Protection Inc. Patricia Cushman Ronny Daigle Malcolm Dimiceli Matthew Eckstine Drake Evans Henry Franklin, Tesoro Edwin Granberry Rick Grobart Marlon Harding Henry Hedges Steven Hoke Jasen Holton, ATC Associates Samuel Hoskin, Kinder Morgan Heather Humphries, Ryt-Way Industries, LLC Robert Jackson, Jackson Management Services LLC Taryn Johnson, New World Engineering Inc. Jeremy Jones, Health and Safety Sciences LLC Alexsis Kassebeer Brandon Lackland Donald Little Maureen McElroy

4 The Advisor www.asse.org 2011

DONT GET HAMMERED BY COSTLY CLAIMS DUE TO INADEQUATE INSURANCE COVERAGE

You ensure that your clients are safe, let Complete Equity Markets, Inc. insure that you are.
Go to www.cemins.com/asse.html or call us at: (800) 323-6234
Complete Equity Markets, Inc. in CA dba Complete Equity Markets Insurance Agency, Inc. CASL#0D44077 1190 Flex Court Lake Zurich IL 60047

HAZARDOUS ENERGY

BY RANDY ROIG, PH.D.

Lockout/Tagout & Machine Guarding


The Minor Servicing Exception
SHAs control of hazardous energy (lockout/ tagout) (LOTO) standard (29 CFR 1910.147) is one of the more complex federal safety regulations. Compliance with the standard is further complicated by its interrelation with two other significant standardsa connection that many people fail to make. The first of these is the electrical safety standard (29 CFR Subpart S), which requires that activities, such as electrical circuit testing, trouTaking advantage bleshooting and diagnosis, that require live equipment and are not of the minor service covered by the requirement to lock be performed by a qualified perexemption to LOTO out son.(Editors Note: See the article is much more Lockout/Energy Control: Helping Fill the Gaps in this issue of The complicated than to Advisor for an additional discussion it first appears. of the relationship between LOTO and electrical safety regulations.) The second standard is machinery and machine guarding (29 CFR Subpart O). Following is the regulatory framework that pulls these two standards together. Many operators will attempt to take advantage of the exception for minor servicing activities without having thoroughly evaluated each requirement that must be met in order to truly qualify for it. First, the definition of such activities must be properly understood. In addition to the language in the actual standard, the compliance directive for LOTO (CPL 0200-147) lists lubricating, draining sumps, servicing filters, making simple adjustments and inspecting for leaks and/or malfunction as examples of routine activities that can frequently be done with effective production-mode protections, such as machine guarding. Second, the need for equivalent protection must be understood. What is often overlooked in evaluating that protection is that machine guarding evaluations are typically conducted only with normal operations in mind. Guards that are perfectly acceptable during normal operations may or may not provide adequate protection during servicing-type activities when employees will intentionally place their hands or other parts of their bodies into hazardous areas of the machine. Typical guards include: interlocks; e-stops; REGULATORY FRAMEWORK The application section of the LOTO standard presence sensors; (20 CFR 1910.147(a)(2)(ii)) states: light curtains; Normal production operations are not covered by this 2-hand-activated push buttons. standard (see Subpart O of this Part). Servicing and/or CPL 02-00-147 discusses how OSHA views these maintenance, which takes place during normal production various types of guarding systems, keeping in mind that operations, is covered by this standard only if: the key requirement for qualifying for the minor servic1910.147(a)(2)(ii)(A)An employee is required to ing exemption is that the guarding must be equivalently remove or bypass a guard or other safety device; or effective to locking out the machine. 1910.147(a)(2)(ii)(B)An employee is required to Pages 2 to 24 of the CPL states, Safeguarding devices place any part of his or her body into an area on a (e.g., presence-sensing safeguarding devices) that rely on machine or piece of equipment where work is actually control circuitry and are used for employee protection purperformed upon the material processed (point of operaposes may not be used in lieu of LOTO during machine tion) or where an associated danger zone exists during a servicing/maintenance activities because control circuit devices are not, by definition, energy-isolating devices. machine operating cycle. Further definition of devices that may not be used in lieu Note: Exception to Paragraph (a)(2)(ii): Minor tool of LOTO is found on pages 1 through 5, as follows: changes and adjustments and other minor servicing Push-buttons, selector switches, safety interlocks and activities, which take place during normal production other control circuit-type devices are not energy-isolating operations, are not covered by this standard if they are devices. Programmable logic controllers are used in many routine, repetitive and integral to the use of the equipment for production, provided that the work is performed machine applications, and these control circuit devices are not considered energy-isolating devices for purposes of the using alternative measures which provide effective proLOTO standard. Safety functions, such as stopping or pretection (see Subpart O of this Part).

6 The Advisor www.asse.org 2011

STANDARDS
Z244 Standard

W
venting hazardous energy (motion), can fail due to component failure, program errors, magnetic field interference, electrical surges, improper use or maintenance, etc. QUALIFYING DEVICES What devices will qualify as providing equivalent protection? In the CPL, OSHA states that approaches taken in accordance with ANSI standard B11.19 1990 or 2003, Performance Criteria for Safeguarding, will be considered to have met the requirement for providing effective alternative protection by the use of special tools or guarding (safeguarding) techniques that effectively prevent employee exposure to hazardous energy (a detailed discussion of these approaches with industry-specific examples can be found on pages 3-27 through 3-32). It also states that these guard devices must be under the exclusive control of the employee performing the minor servicing. Note that this can be complicated if more than one person is working on the minor servicing, and lockout may then be required. How can you tell fairly easily whether a guard device will meet ANSI B11.19? If it was installed by anyone other than the machines manufacturer, there is a good chance it will not. If it was manufactured prior to 2004, it probably will not. Check the device manufacturers literature for certifications, and in the case of emergency stops (e-stops), check specifically for certification as a fail-safe device. While reviewing the manufacturers information, it is also critical to determine what sort of routine inspection, maintenance and servicing they recommend for the device. Failure to follow those recommendations can mean that the device would no longer be reliable, which could lead to an OSHA violation for not providing equivalent protection or to an injury. How often do clients test their interlocks? If you cannot find any documentation related to whether or not a guard meets ANSI B11.19, what other steps can the employer take to determine if it provides the equivalent protection that allows them to take advantage of the minor servicing exemption? The first thing would be to verify what, if any, hazard an employee could be exposed to during the specific activity performed (note that the use of a tool to reach into the hazard zone can change this part of the analysis). Then conduct some type of documented failure analysis of the control system that is relied on to protect the employee from that hazard. Techniques could include a failure modes and effects analysis (FMEA), fault-tree analysis or what-if analysis. There also needs to be an evaluation of whether procedures exist to test if the deactivation that is relied on has worked and whether the guard device is properly tested and maintained. If the employer is relying on an e-stop, consider the following: How does it really work, and what does it actually shut off? Only electrical power or other potential sources of hazardous energy? If the e-stop button is released, is the machine back in full operational mode, or are additional steps needed to restart it? Is there still exposure to energized electrical circuits after the e-stop has been activated? Is the e-stop certified as fail-safe? Is an e-stop button truly under the exclusive control of the operator performing the minor servicing activity? If the employer is relying on an interlock, consider the following: Is the interlock certified? Does it include a high-reliability interlock switch? Is the interlock properly tested and maintained? Will there be exposed power points? Will there be stored energy/other types of energy? CONCLUSION Taking advantage of the minor service exemption to LOTO is much more complicated than it first appears. The reliability and performance of a guarding system need to be evaluated separately it will be used to provide an alternative to locking out equipment during minor servicing the requirements are likely to be much stricter than they would be for normal operation. Consultants who have a thorough understanding of these subtleties can provide valuable assistance to their clients in avoiding serious injuries and possible OSHA citations.
Randy Roig, Ph.D., former principal and co-founder of Specialty Technical Consultants, is recognized nationally and internationally as a leader in the fields of environmental health and safety (EHS) auditing and management systems development. He has 31 years experience in EHS management for the aerospace, food, manufacturing, medical, pharmaceutical, semiconductor, transportation and utility industries. Roig pioneered implementation of root cause analysis in environmental auditing and developed new processes to implement ISO 14000 at reduced costs. His present concentration is on strategic compliance evaluation and management, with an emphasis on efficient and effective implementation. He is a lean/six sigma master black belt, having led numerous teams to improvements in EHS performance and risk reduction. He may be reached at rroig@stcenv.com.

7 The Advisor www.asse.org 2011

COMPLIANCE

BY ANDREW W. JOHNSON, CSP

Lockout/Energy Control: Helping to Fill the Gaps


any workplaces must comply with the lockout energy control (OSHA Subpart J 1910.147) standard because they have machines that personnel need to access to perform service and/or maintenance. Many of these companies have had lockout programs in place for many years. However, as a safety consultant that is called on to review and provide safety programs, procedures and training, I see many defiAs safety consult- ciencies as well as a consistent misunderstanding of what exactly is ants, it is important required to achieve an effective overlockout program. that we do our best all The basic elements that must be in to ensure that we place to achieve compliance with the standard are: do not let our lockout energy control procedures; clients fall into protective materials and hardware; these common gaps periodic inspections; that exist in many training and communication.

lockout programs.

ENERGY CONTROL PROCEDURES Machine-specific energy control procedures must be developed for just about every piece of equipment at a facility in which the unexpected energization or startup of the machines or equipment or release of stored energy could cause injury to employees while servicing and/or maintenance is performed, unless that machine or equipment meets the following criteria: cord and plug-connected equipment (handheld tools, computers, printers, etc.), provided exclusive control is maintained; other equipment when all of the following are true of a particular piece of equipment: 1) the machine or equipment has no potential for stored or residual energy or reaccumulation of stored energy after shutdown, which could endanger employees; 2) the machine or equipment has a single energy source that can be readily identified and isolated; 3) the isolation and locking out of that energy source will completely deenergize and deactivate the machine or equipment; 4) the machine or equipment is isolated from that energy source and locked out during servicing or maintenance; 5) a single lockout device will achieve a locked-out condition; 6) the lockout device is under the exclusive control of

the authorized employee performing the servicing or maintenance; 7) The servicing or maintenance does not create hazards for other employees; and 8) The employer, in using this exception, has had no accidents involving the unexpected activation or reenergization of the machine or equipment during servicing or maintenance. These energy control procedures must be developed to include these fundamental areas: a specific statement of the procedures intended use; specific procedural steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy; specific procedural steps for the placement, removal and transfer of lockout devices or tagout devices and the responsibility for them; and specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices and other energy control measures. In my experience, the major elements missing from most lockout procedures are the transfer of lockout provision as well as good methodologies to properly verify the effectiveness of lockout and to verify that no residual energy (steam pressure remaining in lines, rotational energy, gravity, air pressure) still remains in the system. Information within the procedures must tell the maintenance person how to ensure that all energy has been released, removed, bled off, secured or otherwise rendered safe. Additionally, many times when we review programs that are already in place or are called on to develop procedures for a client, the facilities equipment is forgotten. Rooftop units, air handlers, air compressors and similar equipment are also required to have procedure coverage under this standard. Machine-specific lockout procedures are often not developed for single-energy-source pieces of equipment, but some single-source equipment has the potential to still have stored or residual energy that could harm someone. Under the eight criteria for lockout procedures, Item 1 states that if a potential exists for stored or residual energy after locking out the disconnect, then a lockout procedure is required. A prime example of this would be an exhaust fan unit, which would have a local disconnect and therefore single-source, exclusive control but would still have the potential of the fan blades rotating long after the system

8 The Advisor www.asse.org 2011

was shut off, which could cause an injury if the hazard was not properly identified. We were recently called out to review a companys program that had such an injury. On a rooftop exhaust fan unit for an oven, a maintenance worker shut off and locked out the electrical disconnect but forgot to wait for the fan unit inside to stop rotating before checking the tension on the belt. The individual stated that he quickly looked inside and the fan blades were rotating at such a speed that it looked like they were stopped. Common lockout procedures can be developed for like equipment. In other words, if a facility had 30 exhaust fan units that were similar in design, function and isolation methodology (i.e., same disconnect types), then one procedure could be developed for all 30 of these units. This is important to consider when developing an effective lockout program, and it is of the utmost importance to ensure that this common lockout procedure idea is not misapplied. The equipment covered by a common lockout procedure needs to be similar in every way when it comes to how it is locked out.

start, it still requires personnel to go to these lockout stations and to find the correct lockout hardware that would be required for their specific machine. It would be a better practice to set up lockout hardware kits by machine types. By having these kits, the maintenance personnel could obtain a complete set of lockout hardware for the particular machine or system on which work is to be performed. Minimizing the guess work and making it as easy as possible for personnel to comply with the program must be the objective. Additionally, companies that have proper lockout hardware onsite sometimes provide little or no training on how to properly use the lockout devices. Some lockout hardware devices can be cumbersome to use, especially certain ball valve lockout devices. If not properly put on, the valve handles on these lockout devices serve no more than as a potential head injury to people working underneath when they slide off the handle due to improper use. Proper training on how to use the lockout hardware must be part of the program.

PERIODIC INSPECTIONS OSHA requires that: PROTECTIVE MATERIALS & HARDWARE The employer shall conduct a periodic inspection of Protective materials and hardware required would the energy control procedure at least annually to ensure include items, such as the lockout locks in addition to the that the procedure and the requiretags, chains, ball valve lockout covers, wheel valve lockCompanies should ments of this standard are followed. out covers, breaker lockout devices or other hardware These inspections shall be perrequired for the isolation of the equipment from their have a fairly rouformed by an authorized employee hazardous energy sources. The employer must provide other than the ones(s) using the ener- tine methodology these devices. gy control procedure inspected. Too often, companies purchase boxes of lockout hardin place of inspectThe employer shall certify that ware without looking at their facility to determine the periodic inspections have been ing the lockouts on proper size, quantity and types of lockout devices performed. required. We recently helped a warehouse facility get The point of these periodic inspec- a routine basis so their lockout program together, and one engineer took us tions is to find and correct any deviato their storeroom so that we could see what lockout there is no mad tions or inadequacies identified. To hardware they had on hand. We went through boxes of do this, the periodic inspection shall dash at the end of lockout hardware that had never been opened, and for include a review, between the inspector the most part, they contained about 100 wheel valve cov- and each authorized employee, of that the year to comers for 14 wheel valves. This facility has numerous employees responsibilities under the plete all of the roller conveyors, wrappers, labelers, baggers and other energy control procedure inspected. equipment that is primarily fed by electrical and flexible Ideally, a lockout inspection form inspections. tube 30 psi compressed air. The only valves at this facili- should have a series of yes/no questy that were this large were the valves for the sprinkler tions on it that the inspector could fill out and add comrisers, and there were only ten of those. ments. This would allow the safety committee, safety We mainly work at much more complex manufactur- manager or other person(s) responsible for the lockout proing facilities that have different sizes and types of valves gram to ensure that the training, lockout procedures and and energy-isolation devices for their equipment, and the overall program are updated and modified as needed to while providing centralized lockout stations is a good ensure that any problems identified are corrected. These inspections are required to be performed at least annually for each procedure and for each authorEditors Note: See the article in this issue titled ized employee who is permitted to lock/tag equipment Lockout/Tagout & Machine Guarding: The for servicing or maintenance. Companies should have a Minor Servicing Exception for a related discusfairly routine methodology in place of inspecting the sion on the relationship between LOTO and lockouts on a routine basis so there is no mad dash at the machine guarding standards. end of the year to complete all of the inspections. The intention of this requirement is to find problems in the
9 The Advisor www.asse.org 2011

Additional retraining shall also be conducted whenever a periodic inspection reveals, or whenever the employer has reason to believe, that there are deviations from or inadequacies in the employees knowledge or use of the energy control procedures. The retraining shall reestablish employee proficiency and introduce new or revised control methods and procedures, as necessary. The trainings focus must be to look for the gaps, deficiencies and changes in the program, procedures or work practices and train to these items. ELECTRICAL LOCKOUT Another important item to consider as part of an effective lockout program is not contained within the 1910.147 regulation but within the Subpart S regulations. The Subpart S regulations contain specific training requirements for persons who are permitted to work near energized parts. These persons are known as qualiThe Subpart S regulations fied persons. Many times when we talk to companies about their contain specific training energized work safety requirements, they tell us that they requirements for persons work on everything deenergized and never open a panel without first shutting off the power. In most cases, who are permitted to work door this is not reality; troubleshooting, voltage testing, taking near energized parts. These amp draws, diagnostics on control boards and other tasks be done, and the system must be energized. persons are known as must Even if the company were to argue that it does not do qualified persons. these tasks, an electrical system is not considered electrically safe (meaning no electrical hazard is present) until it has been minimally shut off, locked out and veriprogram, procedures or persons understanding of these items and to make the necessary corrections. Companies fied to be deenergized (voltage test). Until all three of often look at this as a tattletale-type task and therefore if these items (up to and including the first voltage test to they do the inspections, the inspectors check all boxes as verify a deenergized condition) are completed, the system is to be treated as energized and therefore a qualified yes so they do not get their co-workers in trouble. person (one who has received special training on electriWhen we are called upon to do a third-party audit, we find a completely different picture. We must strive to get cal hazards) is the only person who can enter these areas the message across that this is not to find fault with a and perform that work and only while wearing the propparticular person(s), but to find deficiencies or opportuni- er arc flash and shock PPE. ties for improvement within the overall program. If work is to be performed on the electrical circuits, a qualified person must be the one to perform the lockout TRAINING & COMMUNICATION for these tasks. Training is an essential part of any safety program. However, we often see that annual lockout training is CONCLUSION required as part of a companys lockout program. While As safety consultants, it is important that we do our I never discourage annual training, the problem we see is best to ensure that we do not let our clients fall into these that it is a rehashing of the OSHA standard and does not common gaps that exist in many lockout programs. We meet the true nature of what is required. need to make them aware of where deficiencies exist and The 1910.147 regulation does not contain an annual of opportunities for improvement. requirement for training. The annual requirement is for periodic inspections. The requirement for retraining is as Andrew W. Johnson, CSP, is a partner in Sotaris, LLP a safety compliance assistance company in Beachwood, OH. Areas of follows: experience include compliance assistance in the areas of lockout, Retraining shall be provided for all authorized and electrical safety, fall protection, confined spaces and emergency affected employees whenever there is a change in job preparedness. Johnson has been a safety consultant for 15 years assignments, machines, equipment or processes that and has been with Sotaris, LLP for the past seven years. He is present a new hazard or when there is a change in energy past president of ASSEs Northern Ohio Chapter and has served in various roles within the chapter for the past 6 years. control procedures.
10 The Advisor www.asse.org 2011

ASSE and the Consultants Practice Specialty thank

Complete Equity Markets, Inc.


for Its sponsorship

Complete Equity Markets, Inc.

SAFETY & HEALTH

BY MICHAEL W. THOMPSON, CSP

Safety & Health


Prevention in the Multigenerational Workplace
odays multigenerational workforce requires management, safety and health professionals and disability management specialists to be creative in planning and implementing prevention activities with regard to injury and illness. People in their 70s are working alongside those in their teens, and it follows that workplace safety and health management systems cannot be one size fits all and must answer the age-old question asked by all employees, What is in it for me? This broad cross-section of people requires the workplace to be viewed in a new way: through a multigenerational lens. The starting place is to underEmployers would stand the workplace, which is comprised of at least five demographic agree that safety groups. The first is the Silent born 1927 to 1945, education is a key Generation, the youngest of whom are in part of orientation their late 60s and 70s, who have retirement or returned to and training for delayed the workforce. new employees. Next is the largest demographic, the Baby Boomers, which is typically split into two subgroups. The True Boomers, born 1946 to 1955, tend to be very hard workers with a whatever it takes attitude, while the Younger Boomers, born 1956 to 1964, often view that they did not have the same opportunities as those who came before them. Generation X, born 1965 to 1980, is described as wanting to work to live and may be juggling work/life balance. Generation Y (sometimes referred to as Millennials), born 1981 to 1994, typically prefers a flexible arrangement for working, believing that it should not matter where or when the work gets done as long as it is accomplished. Such a mix of ages and experience further enriches the ethnic and cultural diversity of the workplace. The multigenerational workplace brings together valuable institutional knowledge as well as new ideas, determination and great adaptability. From a safety and health perspective, risk assessment and prevention activities require novel and flexible approaches in multigenerational workplaces. The national debate over increasing the retirement age suggests that the average and median ages of workers will increase. Statistics in the aggregate indicate that older workers have a lower injury rate than their younger counterparts. However, when older workers are injured,

they generally take longer to heal or may not recover, leading to a higher probability of becoming disabled. In some cases, because of the nature of the illness or injury, it may be difficult to determine if it is work-related or lifestyle-related. Therefore, having robust rehabilitation, disability management and return-to-work programs for the multigenerational workforce is imperative. Increasingly, lifestyle factors, such as smoking and obesity, may lead to occupational health issues. It is estimated that more than 61% of adults in the U.S. and 50% of those in Europe are overweight or obese. In response, employers must examine their health, safety and environment (HSE) equation in terms of culture, leadership, liability and expenses. H may be viewed as less important than S and E, even though more workers become disabled or even lose their lives due to health issues than to safety and environmental incidents. Thus, HSE factors must be taken together, emphasizing health and wellness to reduce risks of occupational and nonoccupational illness and injury, while also examining the risks posed by safety and environment factors. UNDERSTANDING HOW GENERATIONS VIEW RISK & SAFETY When dealing with generational issues, some common attitudes are encountered. These are generalities that, if allowed to influence ones thinking too much, become stereotypes. Thus, it is important to recognize that every group is comprised of individuals who have unique abilities, attitudes and experiences. That said, however, commonalities illustrate how perception impacts risk and safety. Consider a forklift operator, whom we will call Frank. In his mid-50s with decades of work experience, Frank is well aware of OSHA standards. However, his attitude is that he has been driving a forklift for most of his adult life. His view of risk and prevention is built on his confidence to get the job done with whatever it takes. Therefore, he believes he can skirt certain rules, such as not setting the brake every time or not putting on his seatbelt just to travel a short distance. The job has become so routine that Frank views it as low-risk. His work habits and practices, however, have actually increased the risks posed to Frank and others in the workplace. Now consider what happens if Frank, as a senior forklift operator, should mentor or help train a new employee. What are the chances that he could, even inadvertently, model or teach and pass on to the younger generation these unsafe behaviors and practices? As this example shows, risks and hazards in the work-

12 The Advisor www.asse.org 2011

place do not change, but perceptions of them vary from person to person and from group to group. In other words, they are viewed differently through multigenerational lenses. For younger workers, for whom the biggest cause of unscheduled workplace absence (excluding pregnancy) is injuries, the need to understand how this group assesses risk is paramount. Employers need to take a comprehensive view of their occupational health, wellness and safety programs to ensure that the language used and the way in which messages are disseminated allow them to reach the widest cross-section of employees, says Debbie Cromwell, chair of the Certification of Disability Management Specialists Commission. Just as programs need to be tailored to specific health risks present in the workplace population, so should wellness, prevention and safety initiatives appeal to the maximum number of employees across multiple generations. SAFETY & HEALTH FROM DAY ONE The challenge for many employers is to help workers embrace safety and health when they are new on the job and to retain that mindset throughout their careers. Typically, this process starts with new job orientation, education and training for employees to ensure that safe work habits and behaviors are taught from day one. E.ON U.S., which owns and operates three regulated utilities in Kentucky and Virginia, emphasizes workplace safety in training for all workers, particularly those who are younger and lack experience with certain hazards. As part of their orientation, they learn that safety is the number one priority for our company and that embracing that priority is essential to their success as an employee, explains Ed Staton, director of transmission for E.ON U.S. Safety is everyones job, and employees are responsible and accountable for their own and their co-workers safety. Employers would agree that safety education is a key part of orientation and training for new employees. However, as safety professionals, we might also challenge ourselves to engage future employees as well. As ASSE has demonstrated in its initiatives, safety should be taught to young children in school (see Safety Suitcase designed to educate 4th- through 6th-grade students about safety) and to teens entering the workforce for the first time with a summer job (see What Teens Need to Know Before Going to Work). All of us need to support efforts to teach children what safety means and what safety professionals do to make the workplace safer. When these young people embrace safety during the learning phase, they will carry this attitude with them into their adult years. The result may very well be healthier and more prevention-conscious future employees. MEETING THE NEEDS OF MATURE WORKERS Given the large demographic of Baby Boomers, one major consideration in the multigenerational workplace is

how the aging of the workforce impacts risk and safety. Our discussion here is not meant to be a comprehensive discussion of all the hazards; rather the intention is to provide a few examples that illustrate the need to assess risks that are lifestyle-, workplace- and age-related. Consider workplace signage. We know that federal Department of Transportation requirements have changed and require states and municipalities to evaluate and change the font size of street signs to accommodate the visual capabilities of older drivers. The same approach should be taken in the workplace to evaluate the readability of signs, warnings and instructions. If mill workers need to remove their nonprescription safety glasses to put on reading glasses to read instructions or a sign, they increase their risk of an eye injury from workplace activities. Increasing font size on signs is a simple and low-cost solution that keeps safety glasses in place. Another safety consideration is lighting, general workplace and task-specific illumination. Older workers typically need more light to perform tasks safely and efficiently. In addition to conducting ergonomic assessments at work stations, lighting should also be assessed. In open-concept offices or cubicles, mature workers may be distracted by ambient noise and background conversations because the ability to concentrate typically decreases with age. One accommodation is to allow employees to work from home. However, employees need to understand best practices that encourage and support safe and healthy work at home. Another consideration is when mature workers begin to age out of physically demanding jobs. Although we may associate this issue with manufacturing, one of the

13 The Advisor www.asse.org 2011

biggest areas of concern is in healthcare. For example, nurses are expected to be able to lift and move patients. For nurses who are over the age of 45, and with the increased prevalence of obesity among patients, the emphasis increasingly is placed on injury prevention through safe work habits and use of devices, such as patient lifts. In addition, hospitals are looking at ways to reassign nurses to less physically demanding jobs in order to retain their knowledge and expertise while protecting these professionals from risk of injury. At OhioHealth, registered nurses are educated about ways in which they can continue their careers after they are no longer able to handle their physical job demands, such as with tuition assistance and education vouchers to learn new skills. We wanted them to be more proactive before they could no longer do their jobs, says Chris Moranda, MA, LSW, CDMS, CCM, manager, disability services, at OhioHealth. Through the combined expertise of professionals in the fields of safety, occupational health and disability management, employers can find ways in which to allow valued employees to stay on the job in productive, but less physically demanding jobs. SAFETY & HEALTH: MULTIGENERATIONAL COMMON DENOMINATORS Despite the generational differences observed and

studied, workers will generally agree that safety and health attitudes and behaviors represent lifestyle choices that govern every task, behavior and interaction. In the workplace, safety and health systems can only be effective if the generations know and accept the common belief that it is risk-free to speak up and take ownership. If a risk of hazard exists, employees need to know that raising this with their supervisor or manager is not only acceptableit is expected. Safety is about people first. When a company has the right people in place and they have been properly educated and trained, are competent and know their rights, safety becomes the cultural norm for all generations. It has been stated that the only good jobs are safe jobs. Safety and health are the common denominators impacting how people work and live in a prosperous and dynamic society.
Michael W. Thompson, CSP, is a public member commissioner of the Certification of Disability Management Specialists Com mission, the only nationally accredited organization that certifies disability management specialists. He is the global HSE advisor for BP Exploration and Production Information Technology and Services in Houston, TX. Thompson is a professional member of ASSE, a past ASSE president (2007-08) and ASSEs 2010 Safety Professional of the Year.

Now Accepting Safety 2012 Speaker Proposals

ll submissions should be sent to ksonneson@asse.org by July 1, 2011. Honoraria: Individual speakers (one to two speakers per session) receive a full complimentary conference registration. Group/panel presenters receive a complimentary registration for the day on which they speak and a reduced rate for the balance of the conference. Travel, lodging and meal expenses are the speakers responsibility. Submissions: The subject line should read ASSE 2012-[Sponsoring Practice Specialty and Topic Area]. Receiving sponsorship from your practice specialty for submissions is a great membership benefit so please take advantage of it. Presentation Description: Describe your presentation and specify expected learning outcomes for attendees. Indicate the session level. Levels are evaluated as follows: Basic: 2 to 5 years of experience. Intermediate: 6 to 10 years of experience. Advanced: 10+ years of experience. Executive: Executive level for senior management.

Maximum length is three pages. Biographical Data & References: For each speaker, include name, address, education, current position, certifications, designations, qualifications and relevant speaking experience. List phone numbers for three references. List noteworthy publications from the past 3 years. Maximum length is three pages. Brochure Description: Provide a brief description (less than 50 words) of the presentation for inclusion in marketing materials. Length of Presentation: 1 or 1 hour (to include 15 minutes for questions). Multiple Submissions: Two proposals maximum per speaker. Complete a separate application form for each submission. Acceptance: Notification of acceptance will be mailed by the end of November. Proceedings Paper: Speakers must submit a paper based on their presentation for the proceedings, which are provided to conference attendees. Details on preparing the proceedings paper are provided upon selection.

14 The Advisor www.asse.org 2011

MANAGEMENT SKILLS

BY MICHAEL REGA & ANNE-MARIE LENTON

Five Steps to Developing Impenetrable Business Relationships


ne thing that separates top consultants from the ordinary is their client management skills, which include the ability to penetrate and forge a genuine bond with key players within the client organization. Whether it is their planning, their sheer determination, the strength of their personalities, their hard work or an infinite number of other possible combinations, the result is that the client feels the consultant is a vital and important element of their organization. Let us call this type of consultant the key client manager. The two attitude requirements for a key client manager are: 1) Commitment. The client must feel the key client manager truly understands his or her unique situation and problems. This could range from The key to sustain- a major technical problem or organiproblem to a political probing your relation- zational lem within the company. The key is ship is ongoing responsiveness. It is an attitude of and commitmentjumping contact at all points concern in and being totally committed to in the organization. helping the client without hesitating or making the client feel obligated. 2) Expertise. Key client managers must understand the clients business as well as their own. For consultants to develop the sort of relationship that results in repeat business, rather than just one-off projects, they must possess an attitude of expertise. This requires you to stay current with a certain amount of technology, market trends and client issues along with SH&E expertise. If you are willing to accept these prerequisites for truly bonding with your clients, following these next five critical steps will open up all sorts of opportunities and will afford entry into the clients inner circle of influence. 1) Counselor Approach. Your clients perception of you is in direct proportion to your own approach. If you view the client totally as a source of revenue, then your job is to negotiate orders. In turn, the client will perceive you and classify you as a supplier. The measure of your worth will be in the price/performance ratio of your bid or services as compared to your competitors. On the other hand, if you view your mission as a problem-finder, problem-solver and profit-improver for the client, you will in turn be viewed as a welcomed

member of their team. They will feel in need of your expertise, and your worth will be in direct relation to your value and profit improvement to their organization, not in relation to the lowest bidder in the market. 2) Exposure. Very seldom do key client managers get to the clients inner circle without some help along the way. Most often, in the early stages of their research, they perform an excellent organizational analysis. During this process, they seek to identify certain people of significance in the organization who would stand to benefit from their recommendations. These people are potential champions for your cause and must be sold on the ideas you recommend and on the need to help you get the proper exposure at all levels of their organization. The development and nurturing of the proper champions may be vital to your success. It is much easier to get an appointment when the subordinates position you as someone with whom the executive must meet. 3) Collective Problem-Solving and Implementation. Most successful key client managers position themselves early in the relationship as resources. They work with the client to develop the financial analysis and proper solutions, as well as implementation plans to meet their needs. They then assist the client through the implementation phase of the sale or service contract after the order or commitment for professional services has been received. In doing this, a bonding takes place at

16 The Advisor www.asse.org 2011

all levels of the organization. In effect, the key client manager stays close with the customer through all phases of the relationship, including the implementation phase. By doing this, the key client manager capitalizes on the opportunity to bond at all levels of the client organization. 4) Confidentiality. Being welcomed into the inner circle conveys a special level of trust. For someone outside the company to be elevated to this position indicates they must have demonstrated that they can be trusted. Many times they will be given confidential data, marketing plans, business strategies or other pieces of important information. The client must feel that this information will be held in strict confidence. Much like the doctor/patient relationship, if the trust is not there, no relationship exists. 5) Advisory. The last rung on the ladder is when the client comes to you for advice. The best problem to solve for the key client manager is the one s/he has identified, brought to managements attention and proceeded to solve. This is achieved through introducing a new service, product or idea for the organization or by suggesting a change in their processes.

These five steps will take you inside the clients inner circle, but sustaining that relationship is your new goal. We live in a business environment where individuals move in their careers frequently, so having a relationship with only one person at the client organization can leave you vulnerable. The key to sustaining your relationship is ongoing contact at all points in the organization. You must stay in touch with all levels and continue to look for problems to solve. The more you solve, the stronger the bond. As a result, the more valuable you become to the organization, the longer you will keep the key account.
Michael E. Rega is executive vice president of the Ecliptic Consulting Group Inc., a multiindustry sales and management adult education and skills development company. A certified speaking professional, he may be reached at (727) 692-1911. Anne-Marie Lenton is a consultant/speaker at Ecliptic Consulting Group Inc. She specializes in sustainable plan development and corporate social responsibility. She holds a B.A. with honors from Warwick University and an M.S. in Management from the University of South Florida. She may be reached at (727) 692-1911.

OSHA Revisions Strengthen Outreach Training Program

SHA has revised its voluntary outreach training program requirements and procedures to improve the quality of outreach classes and to ensure the integrity of its authorized trainers. Formerly known as program guidelines, the new program requirements will apply to all outreach training programs, with separate procedures for each specific program. The new requirements include a trainer code of conduct and a statement of compliance, which requires trainers to verify that the training they conduct will be in accordance with the outreach training program requirements and procedures. Other program enhancements involve limiting classroom size to a maximum of 40 students, limiting the use of translators to those with safety and health experience and limiting the amount of time spent on videos during the training. Also, OSHA has imposed limits on outreach training conducted outside of the agencys jurisdiction and is allowing military members returning from overseas an additional 90 days from their return date to renew their trainer authorization. OSHA is also requiring that trainers issue OSHA course completion cards to students within 90 days of class completion. Furthermore, trainers are now required to provide the card directly to the student, allowing students to have proof of training completion to display at any jobsite and to help prevent organizations from withholding the card from a worker. OSHA has also added record requirements, imposed tougher

advertising restrictions and revised the rules for using guest trainers. These revisions will serve to tighten the program controls to ensure that the best training is provided to the worker participants, says Assistant Secretary of Labor David Michaels. Trainer reliability will be enhanced, and classes will focus more on fulfilling students needs for safety and health training. The content of the training classes has also been changed. All construction classes are required to include four hours on Focus Four Hazards. All 30-hour classes must include 2 hours on Managing Safety and Health. The new requirements and procedures also integrate recent requirements, which require training classes to last a maximum of 7.5 hours per day and include a new 2-hour Introduction to OSHA training module. The outreach training program, a voluntary participation information resource, is part of OSHAs Directorate of Training and Education. The program comprises a national network of more than 17,000 independent trainers who teach workers and employers about OSHA, workers rights and how to identify, avoid and prevent workplace hazards. Ten- and 30hour outreach classes are available for construction, general industry and maritime, and 15-hour classes are available for disaster site workers. Students who successfully complete classes receive completion cards.

17 The Advisor www.asse.org 2011

CONSULTANT SERVICES

BLS Data on the Consulting Industry


ccording to the Bureau of Labor Statistics (BLS), the consulting industry is projected to be the fastest-growing, with employment increasing 83% over the 2008-18 period, and is one of the highest-paying. Job competition will remain keen; the most educated and experienced workers will have the best job prospects. About 73% of workers have a bachelors or higher degree.

environmental pollutants, cleaning up contaminated sites, establishing a recycling program and complying with government environmental laws and regulations. For example, a real estate developer might hire an environmental consulting firm to help design and develop property without damaging natural habitats, such as wetNATURE OF THE INDUSTRY lands. A manufacturFirms that offer consulting services influence how ing or utilities firm businesses, governments and institutions make decisions. might hire environOften working behind the scenes, these firms offer tech- mental consultants to nical expertise, information, contacts and tools that assess whether the clients cannot provide themselves. They then work with firm is meeting govtheir clients to provide a service or to solve a problem. ernment emissions standards in order to GOODS & SERVICES avoid penalties Usually, one of the resources that consulting firms before government provide to clients is expertise in the form of knowledge, regulators inspect the experience, special skills or creativity; another resource property in question. is time or personnel that the client cannot spare. Clients Finally, many govinclude large and small companies in the private sector; ernment agencies federal, state and local government agencies; institutions, contract work out to such as hospitals, universities, unions and nonprofit environmental conorganizations; and foreign governments or businesses. sulting firms to assess environmental contamination in a The management, scientific and technical consulting particular geographic area or to evaluate the costs and services industry is diverse. Almost anyone with expert- benefits of new regulations. ise in a given area can enter consulting. Scientific and Occupational safety consulting services firms provide technical consulting firms provide technical advice relat- services similar to those offered by other private busiing to almost all non-management organizational activi- nesses and some government agencies, identifying workties, including compliance with environmental and place safety hazards and ensuring that employers are in workplace safety and health regulations, the application compliance with government worker safety regulations. Safety consulting firms might help plan a safe and of technology and the application of sciences, such as healthy environment for workers, identify hazardous biology, chemistry and physics. materials or systems that may cause illness or injury, assess safety risks associated with machinery, investigate INDUSTRY ORGANIZATION Larger consulting firms usually provide expertise in a accidents and assess the likelihood of lawsuits resulting variety of areas, whereas smaller consulting firms gener- from safety code violations. For example, a manufacturing firm building a new ally specialize in one area of consulting. One of the largest specialties in scientific and techni- plant may seek the advice of a safety consulting firm cal consulting services is environmental consulting serv- about how to build equipment and design the building layout to increase workplace safety and reduce human ices. Environmental consulting firms identify and error. Or a restaurant may look to a safety consultant to evaluate environmental problems, such as the presence develop occupational safety and health systems for of water contaminants, and offer solutions, often after employees, such as slip-resistant floors and shoes. Some inspecting the sites. Some firms in this segment of the industry advise clients about controlling the emissions of safety consulting firms might specialize in a particular
18 The Advisor www.asse.org 2011

type of hazardous material, while others might specialize in a particular industry, such as construction, mining, manufacturing, healthcare or food processing. As with environmental consulting firms, many government agencies contract out work to safety consulting firms for help with safety engineering, technical projects and various kinds of assessment. Security consulting, by contrast, seeks to ensure the safety and security of an organizations physical and human assets that may be threatened by natural or human-made disasters. Clients might hire security consulting firms to assess a buildings security needs. The firms then may recommend protecting the building against theft and vandalism by installing security cameras, hiring security guards and providing employee background checks. Other security consultants study a buildings design and recommend measures to protect it from damage from fires, tornadoes, floods, earthquakes or acts of terrorism. Security consultants may also recommend emergency evacuation procedures in the event that such disasters occur. Increasingly, clients are hiring security consulting firms to protect their confidential computer records against hackers and viruses. Recently, government agencies have hired security consulting firms to advise them on how to protect national monuments and the national transportation, utility and defense infrastructureairports, bridges, nuclear reactor plants, water treatment plants and military barracksagainst terrorism. Scientific and technical consulting firms also advise on a diverse range of issues relating to the physical and social sciencesissues having to do with agriculture, biology, chemistry, economics, energy and physics. Agricultural consulting firms might advise on different farming techniques or machinery that increases agricultural production. Economic consultants might develop forecasting models and advise clients about the potential for a recession or an increase in interest rates that could affect business decisions. Energy consultants might advise clients on how to reduce costs by implementing energy-saving machinery. Finally, biological, chemical and physics consultants might give theoretical or applied expertise in those fields.

RECENT DEVELOPMENTS Management, scientific and technical consulting has grown rapidly over the past several decades, with businesses increasingly using consulting services. Hiring consultants is advantageous because these experts are experienced and well trained, and they keep abreast of the latest technologies, government regulations and management and production techniques. In addition, consultants are cost-effective because they can be hired temporarily and can perform their duties objectively, free of the influence of company politics. WORKING CONDITIONS Hours In 2008, nonsupervisory workers in the industry averaged 35.0 hours per week, slightly higher than the national average of 33.6. However, many consultants must meet hurried deadlines, a requirement that frequently entails working long hours in stressful environments. Consultants whose services are billed hourly often are under pressure to manage their time carefully. Occasionally, weekend work also is necessary, depending on the job performed. WORK ENVIRONMENT Working conditions in management, scientific and technical consulting services are generally similar to those of most office workers operating in a team environment. The work is rarely hazardous, with a few exceptionsfor example, for environmental or safety consultants who inspect sites for contamination from hazardous materials. In addition, some projects might require many executives and consultants to travel extensively or to live away from home for extended periods. However, new technologysuch as laptop computers, with remote access to the firms computer server, and videoconferencing machinesallow some consultants to work from home or to conduct meetings with clients in different locations, reducing some of the need for business travel. Most firms encourage employees to attend employerpaid time management classes. The classes teach participants to reduce the stress sometimes associated with working under strict time constraints. Also, with todays hectic lifestyle, many firms in this industry offer or provide health facilities or clubs that employees may use to maintain good health. EMPLOYMENT The management, scientific and technical consulting services industry had about one million wage and salary workers in 2008. Table 1, p. 20, depicts how employment is distributed among the different segments of the industry. The vast majority of establishments in the industry were fairly small, employing fewer than five workers. Selfemployed individuals operated many of these small firms. Despite the prevalence of small firms and self-employed workers, large firms tend to dominate the industry.

19 The Advisor www.asse.org 2011

Table 1 % Distribution of Employment & Establishments in Management, Scientific & Technical Consulting Services By Detailed Industry Sector, 2008

of the country, many workers are concentrated near large urban centers. OCCUPATIONS IN THE INDUSTRY Most management, scientific and technical consulting services are fairly specialized; still, the industry comprises a variety of occupations (Table 3). Compared with other industries, the management, scientific and technical consulting services industry has a relatively high proportion of highly educated workers. About 73% have a bachelors degree, compared with 32% of workers throughout the economy. Around 32% have a masters or higher degree, compared with 11% of workers throughout the economy. Certain jobs may have stringent entry requirements. Other positions can be attained only after many years of related experience. In management, scientific and technical consulting services, 62% of employment consists of workers in management, business and financial operations occupations and in professional and related occupations. These same occupational groups account for about 31% of workers across the entire economy. These groups of workers comprise a disproportionate share of jobs in the industry because workers with education and experience in business management and workers with scientific, engineering and other technical backgrounds conduct most of the consulting work in this industry.

Table 2 % Distribution of Employment By Age Group, 2008

PROFESSIONAL & RELATED OCCUPATIONS Workers in professional and related occupations are employed mainly in the scientific and technical consulting portion of the industry. Many of these workers are engineers and scientists who use their expertise in consulting. For example, environmental engineers and environmental scientists and geoscientists are employed by environmental consulting firms to evaluate environmental damage or to assess compliance with environmental laws and regulations. Other engineers, such as agricultural, biomedical, chemical, mining and geological, nuclear and petroleum engineers; and physical and life scientists, such as agricultural and food scientists, biological scientists, chemists, materials scientists, physicists and astronomers, are employed by consulting firms specializing in their scientific disciApproximately 41% of jobs are found in establishplines. Architects and civil and industrial engineers are ments with 50 or more employees, and some of the sometimes employed by safety and security consulting largest firms in the industry employ several thousand firms to assess the construction of structures, such as people. buildings and bridges, and to make recommendations Many individuals move into consulting after gaining regarding reinforcing these structures against damage. experience in their field by working in an industry in that Other professional and related workers include econofield. As a result, the average age in the consulting indusmists, market and survey researchers, lawyers and engitry is higher than in all industries. Table 2 shows that the neering technicians. Engineering technicians aid consulting industry has higher proportions of older engineers in research and development. Like engineers, workers and lower proportions of younger workers than these workers are found primarily in the business and are present across all industries. Although employees in this industry work in all parts management consulting segments of the industry.
20 The Advisor www.asse.org 2011

OTHER OCCUPATIONS Management, scientific and technical consulting services firms do not produce any goods. As a result, they employ relatively few services, sales and production workers, who, together with the remaining occupational groups, make up only about 14% of industry employment.

within management, scientific and technical consulting services firms, but most jobs in the industry are similar in three respects. First, clients usually hire consulting firms on the basis of the expertise of their staffs, so proper training of employees is vital to the success of the firms. Second, although employers generally prefer a bachelors or higher degree, most jobs also require extensive on-the-job training or related experience. Third, TRAINING & ADVANCEMENT advancement opportunities are best for workers with the Training and advancement opportunities vary widely highest levels of education. Most consulting specialties Table 3 provide a variety of different Employment of Wage and ways to enter the profession. Whereas very few universities Salary Workers in Management, or colleges offer formal programs of study in manageScientific & Technical Consulting ment consulting, many fields Services By Occupation, 2008 provide a suitable background. These fields include most & Projected Change, 2008-18 areas of business and manage(employment in thousands) ment, such as marketing and accounting, as well as computer and information sciences, economics and engineering. Also, many business schools have consulting clubs that offer exposure to consulting firms or opportunities to provide consulting services to businesses. Some schools offer programs in logistics and safety that relate directly to consulting jobs in those areas. Some college graduates with a bachelors or masters degree and no previous work experience are hired right out of school by consulting firms and go through extensive onthe-job training. The method and extent of training can vary with the type of consulting involved and the nature of the firm. Some college students might have an advantage over other candidates if they complete an internship with a consulting firm during their studies. Other workers with related experience are hired as consultants later in their careers. For example, former military or law enforcement workers often work for security consulting firms.
21 The Advisor www.asse.org 2011

Similarly, some government workers with experience in enforcing regulations might join an environmental or safety consulting firm. Consultants in scientific fields often have a masters or doctoral degree, and some previously have taught at colleges and universities. Most consulting firms require their employees to possess a variety of skills in addition to technical skills or industry knowledge. To a large extent, a college degree is only one desired qualification; workers must also possess proven analytical and problem-solving abilities, excellent written and verbal communications skills, experience in a particular specialty, assertiveness and motivation, strong attention to detail and a willingness to work long hours if necessary. Many consultants undergo training to learn these and related skills, such as project management and building relationships with clients. Consultants must also possess high ethical standards, because most consulting firms and clients will contact references and former clients to ensure that the quality of their work was of the highest standard. Management and leadership classes and seminars are available throughout the U.S. Some classes and seminars are hosted by volunteer senior executives and management experts representing a variety of businesses and industries. Many large firms invest much time and money in training programs, educating new hires in formal classroom settings over several weeks or months, and some even have separate training facilities. Small firms often combine formal and on-the-job training. The Institute of Management Consultants USA, Inc. (IMC USA) offers a wide range of professional development programs and resources, such as meetings, workshops, interest groups and national conferences, that can

be helpful for management consultants. IMC USA also offers the certified management consultant (CMC) designation to those who meet education and experience requirements, as well as pass an interview and oral and written examinations. Management consultants with a CMC designation must be recertified every 3 years. Other areas of specialization, such as logistics and safety, also offer certification programs for professionals, but these programs are not necessarily designed for consultants. Still, consultants might find it beneficial to receive designations from such programs as well. Although certification is not mandatory for management consultants, it may give a jobseeker a competitive advantage. Without consulting experience, it can be difficult to sustain a business as an independent management consultant firm. As a result, most entry-level positions are in relatively large firms and often involve little responsibility at the beginning. Striving for and displaying quality work results in more responsibility. Most management consulting firms have two entry-level positions: workers who hold bachelors degrees usually start as research associates; those with graduate degrees generally begin as consultants. Successful workers progress through the ranks from research associate to consultant, management consultant, senior consultant, junior partner and, after many years, senior partner. However, in some firms, it is difficult for research associates to progress to the next level without further education or certification. As a result, many management consulting firms offer tuition assistance, grants or reimbursement plans so that workers can attain an M.B.A. or other degree. Almost all workers in management consulting services receive on-the-job training; some have prior work experience in a related field. Most managerial and supervisory workers gain experience informally, overseeing a few workers or part of a project under the close supervision of a senior manager. Workers who advance to highlevel managerial or supervisory jobs in management services firms usually have an extensive educational background. Less commonly, some large firms offer formal management training. The management, scientific and technical consulting services industry offers excellent opportunities for selfemployment. Because capital requirements are low, highly experienced workers can start their own businesses fairly easily and cheaply; indeed, every year, thousands of workers in this industry go into business for themselves. Some of these workers come from established management, scientific and technical consulting services firms, whereas others leave industry, government or academic jobs to start their own businesses. Still others remain employed in their primary organizations but have their own consulting jobs on the side. OUTLOOK Management, scientific and technical consulting serv-

22 The Advisor www.asse.org 2011

nities in human resources consulting for firms that manage their clients payroll systems and benefits programs. At the same time, increasing competition has led to more business mergers, providing opportunities for consulting firms to assist in the process. Also, as increasing numEMPLOYMENT CHANGE bers of older business owners retire, consultants will be Wage and salary employment in the management, sci- used to assist in the liquidation, acquisition or restructuring of those businesses. entific and technical consulting services industry is Globalization will continue to provide numerous opporexpected to grow by 83% between 2008 and 2018. All tunities for consulting firms wishing to expand their servicareas of consulting should experience strong growth. Projected job growth can be attributed primarily to eco- es or to help their clients expand into foreign markets. Consulting firms can advise clients on strategy, as well as nomic growth and to the continuing complexity of busiforeign laws, regarding taxes, employment, worker safety ness. A growing number of businesses means increased demand for advice in all areas of business planning. Firms and the environment. The growth of international businesses will create numerous opportunities will look to management consultants to draft business for logistics consulting firms as busiplans and budgets, develop strategy and determine approThe increasing use of nesses seek to improve coordination in priate salaries and benefits for employees. new technology and the expanding network of suppliers The expansion of franchised restaurants and retail and consumers. stores will spur demand for marketing consultants to An increasing emphasis on protect- computer software determine the best locations and develop marketing plans. The expansion of business will also create oppor- ing a firms employees, facilities and is another major factunities for logistics consulting firms in order to link new information against deliberate acts of tor contributing to suppliers with producers and to get the finished goods to sabotage will continue to create numerous opportunities for security consumers. growth in all areas consultants. These consultants provide Finally, businesses will continue to need advice on compliance with government workplace safety and envi- assistance on every aspect of security, of consulting. from protecting against computer ronmental laws. Clients need consultants to keep them viruses to reinforcing buildings against bomb blasts. up to date on the latest changes in legislation affecting Logistics consulting firms are finding opportunities in their businesses, including changes to tax laws, to environmental regulations and to policies affecting employee helping clients secure their supply chain against interruptions that might arise from terrorist acts, such as the disbenefits, healthcare and workplace safety. As a result, ruption of shipping or railroad facilities. Growing security firms specializing in human resources, environmental concerns, rising insurance costs and the increasing threat and safety consulting should be in strong demand. of lawsuits provide added incentives for businesses to proThe increasing use of new technology and computer tect their employees welfare. software is another major factor contributing to growth Growth in management, scientific and technical in all areas of consulting. Management consulting firms consulting services might be hampered by increasing help clients implement new accounting and payroll softcompetition from nontraditional consulting firms, such ware, whereas environmental and safety consulting firms as investment banks, accounting firms, technology advise clients on the use of computer technology in firms and law firms. As consulting firms continue to monitoring harmful substances in the environment or expand their services, they will be forced to compete workplace. Consulting firms might also help design new with a more diverse group of firms that provide similar computer systems or online distribution systems. One of services. the biggest areas upon which technology has had an Economic downturns can also have an adverse effect impact is logistics consulting. The Internet has greatly on employment growth in consulting. As businesses are increased the ability of businesses to link to and commuforced to cut costs, consultants may be among the first nicate with their suppliers and customers, increasing proexpenses that businesses eliminate. Furthermore, growth ductivity and decreasing costs. Technology-related in some consulting specialties, such as executive search consulting projects have become so important that many consulting, is directly tied to the health of the industries traditional consulting firms are now merging with or setting up joint ventures with technology companies so that in which they operate. However, some consulting firms each firm has access to the others resources to serve might experience growth during recessions: as firms look clients better. to cut costs and remain competitive, they might seek the The trend toward outsourcing and mergers will also advice of consultants on the best way to do so. create opportunities for consulting firms. To cut costs, many firms are outsourcing administrative and human JOB PROSPECTS resources functions to consultants specializing in these Despite the projected growth in the industry, there will services. This business strategy should provide opportu- be keen competition for jobs because the prestigious and ices is projected to be the fastest growing industry over the next decade. However, because of the number of people looking to work in this industry, competition for jobs is expected to remain keen.
23 The Advisor www.asse.org 2011

Table 4 Median Hourly Wages of the Largest Occupations in Management, Scientific & Technical Consulting Services, May 2008

independent nature of the work and the generous salary and benefits generally attract more jobseekers than openings every year. Individuals with the most education and job experience will likely have the best job prospects. EARNINGS INDUSTRY EARNINGS Management, scientific and technical consulting services are one of the highest-paying industries. Nonsupervisory wage and salary workers in the industry averaged $913 a week in 2008, compared with $608 for workers throughout private industry. Median hourly wages in the largest occupations in management, scientific and technical consulting are shown in Table 4. The data in the table do not reflect earnings for self-employed workers, which often are high. BENEFITS & UNION MEMBERSHIP Besides earning a straight salary, many workers receive additional compensation, such as profit sharing, stock ownership or performance-based bonuses. In some firms, bonuses can constitute one-third or more of annual pay. Only about 1% of workers in management, scientific and technical consulting services belong to unions or are covered by union contracts, compared with 14% of workers in all industries combined.

Ask ASSE
Z358.1 states that eyewash stations should be tested, Q: ANSI including flushed for 3 minutes, every week. OSHA applies this standard and issues citations based on this criteria. However, Cal-OSHA requires, by regulation, inspections only once a month. Can you confirm that the requirement for state programs to be at least as stringent as OSHA standards applies only to regulations, not to application of established safety standards, such as ANSI Z358.1? rule of thumb is that a state-plan state must be equal or A: The greater than the federal rule. However, this is a legal question of citation by reference of a national voluntary consensus standard and how it impacts a state-plan state. State programs need not be exactly the same as OSHA. When the state of California received its designation as a stateplan state, the eyewash regulation was as it is today. Assuming that a gap analysis was made between the federal regulations and the California regulations, one would assume that no one saw at the time a significant difference between the two. The spirit and intent of the eyewash requirements (that they be tested to ensure that they work) was all that was compared. As federal enforcement has evolved, the inclusion of the ANSI standard may have merged into the OSHA enforcement model. California has been given exclusive jurisdiction to enforce its requirements. Stringent does not mean exactly like or the same. Anyone could file a complaint to the OSHA oversight organization and allege that dissimilarity exists between the two standards, but s/he would need to show/demonstrate a material difference that would not protect a California worker and that California workers would be subjected to grievous injury as a result of the testing protocols. Less testing most likely would not be recognized as less safe. OSHAs rule is short. 1910.151(c) states: Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use. Only one citation was issued for the testing criteria by a state plan; none for the feds. OSHA citations were generally on 15-minute flush and access/time/distance.

SAMPLE CITATION LANGUAGE


The personal eyewash unit was neither inspected nor maintained since 2004, which could expose employees, using the eyewash, to bacterial infection, and eye injury from contaminated flushing fluid. Among other methods of abatement, one feasible and acceptable method to correct this hazard is to inspect the eyewash periodically and flush, drain and refill the eyewash every 90 days in accordance with the manufacturers instructions as specified in ANSI Z 358.11990.62.1. Abatement documentation (photographs, receipts,

copies of programs, training certification, etc.) is required for this item.

24 The Advisor www.asse.org 2011

CHEMICAL HAZARDS

LinkedIn Discussion: ADA


(that does not mean that a claim cannot or would not be filed, in which case lawyers need to be consulted). The chemical. The company produces the chemical in quesother considerations mentioned are workers compensation. Does the company need to find a position for him tion case management and employee relations factors where he will not be exposed to the chemical? that also come into play. I believe the worker must declare his disability my experience, asthma and allergies that are A1: as soon as possible and make a request for reaA8: In severe or persistent come under the . . . limits sonable accommodation. one or more major life activities . . ., in this case, perhaps breathing or a single employees inability to funcFirst, I would be suspicious of an allergic reacA2: tion in that work environment (if so determined). This tion that only manifested during a spill, espesounds like an allergy stemming from a contactant cially if the employee has been around for awhile. This (chemical, dyes, etc.), but, the question does not mention could be anything from an olfactory response to a highdose reaction. A doctor is rarely in a position to connect what the chemical is. For example, over time, some adhesives can induce the dots from a single event. If it should be an old estabsensitivity and reaction. The question is was it a contaclished allergy to known agents, reasonable solutions are tant or an outgassing exposure (breathing)? Under ADA available for any employee, from local controls to improved containment and much more. On the surface, it and Section 504 of the Rehabilitation Act, this can be appears that the Americans with Disabilities Act (ADA) covered assuming this person cannot otherwise perform the essential tasks of the job while others remain unafaccommodation should not be rushed into. I suggest a fected. In this case, we would need more details. I do not deeper investigation and history workup. think accommodation would necessarily mean finding seems the employer should provide reasonA3: It the engineer another position, as several more options able accommodations while the investigation may be available if details were known. A chemical spill continues. The claim should be investigated not only to is an abnormal occurrence. Did the engineer get sick determine if the employee is trying to get away with a false claim, but also to determine what may have caused before the spill? Is spill response part of his essential this reaction. A licensed healthcare provider may be able tasking, and did he take part in cleanup or containment? an employer learns an applicant or to connect the dots, but it may take a few tries. In the A9: Once employee is allergic and in need of an accommeantime, to protect the employee, reasonable accommodation, the employer may be required by ADA to promodations should be provided while the investigation vide the needed accommodation. The allergic worker continues. may be able to respond to low levels of exposure, levels Several things would have occurred in parallel A4: which may be lower than the relevant occupational expoas the spill was addressed and the investigation sure limits set by OSHA or recommended by NIOSH began. Measures would be taken to eliminate a repeat incident, and employees would be involved in the gather- or ACGIH. Accommodating the allergic employee would genering of data, including additional accommodation if there ally involve reducing exposure further by providing spewere signs of employee concerns or allergic reactions. Possible actions might include inspecting the process cific protection for the sensitive individual, such as before putting it back on line or adding ventilation, additional protective equipment, which the average (nonscrubbers, isolation measures or PPE in the short and allergic) worker probably would not need. Protective long run. equipment could involve the use of respirators for respiThe state of employment is important. Some ratory protection, protective clothing (such as gloves) or A5: states require that if employees can work, the barrier creams for skin protection. state must provide them with a job while they go through The use of respirators would involve employer comrehabilitation. More importantly, where were the precau- pliance with OSHAs respiratory protection standard tions that should have protected the worker in the first (29 CFR 1910.134), including the use of a physical to place? Per OSHA, there should have been adequate PPE determine whether a worker could wear a respirator. to protect the workers as well as a fresh air exchange. Battery-powered respirators may enable those with pulAre they properly trained per the HAZWOPER monary or cardiovascular problems to still use a respiraA6: or hazmat regulations pertaining to them? tor. Respirators made of silicone may enable someone to If the question is specifically about ADA comwear a respirator who has a rubber allergy (such as an A7: pliance, then an allergy is unlikely to meet the allergy to mercaptobenzothiazole). definition of a disability that requires accommodation Exposure could be reduced by the use of engineering engineer became sick at work after a chemiQ: calAn spill. The doctor told him he is allergic to that
25 The Advisor www.asse.org 2011

controls, such as better or more efficient use of ventilation to dilute or remove exposure; improved equipment design to reduce the production of vapors, mists and splashes; or enclosures of equipment or processes to contain or collect any emissions. Air cleaning equipment could be used to reduce the air concentration of a potential allergen in the sensitive individuals work area. Exposure may be reduced by scheduling changes that do not place the sensitive worker in a work area at the same time that a potential allergen is used (for example, avoiding the use of products, such as cleaning chemicals, pesticides or paints in the sensitive persons office or work area). Personnel should be aware of what to do or who to call (such as emergency telephone numbers) if the allergic person experiences an adverse reaction, such as an asthmatic attack or anaphylactic shock. The allergic persons physician should be consulted as to what such measures should include (such as having antihistamines or brochodilators available for emergency use). However, other alternatives to consider that could reduce or remove the potential for exposure to an allergen include product substitution, the use of an alternative formulation for the chemical or material used and eliminating containment of use of the potential allergen. For example, to avoid inhalation of persulfate boosters in hair bleaches, a hairdresser could use a bleach with a nonpersulfate booster, such as sodium perborate, sodium percarbonate or magnesium carbonate. Process substitution reduces or eliminates exposure to an allergen by the use of an alternative method for doing a job. For example, to avoid skin or respiratory allergies from the use of cold sterilization with formaldehyde solutions, sterilization using steam or ultraviolet light could be considered. Both product and process substitution may be well worth investigating because they may have advantages to the employer in the areas of cost savings on hazardous waste disposal, less potential liability

for handling or storage of hazardous materials, reduced need for extra or special ventilation or protective materials/equipment/clothing, reduced need for fire or other types of insurance, reduced workers compensation costs for injuries or illnesses, etc. may have the added advantage of A10: Substitutions reducing exposure for other workers who have not yet shown any adverse health effects. For some chemical exposures, it may be possible to conduct medical testing to determine if an individual is likely to have an allergic reaction to an exposure or to diagnose hyperreactive respiratory airways. Such testing should be performed post-job offer or by a physician who reports to the employer only whether the employee can perform the requirements of the job and what accommodations might be necessary so that privacy can be protected and the potential for discrimination reduced. For more information on ADA and accommodations, contact: ADA Regional Disability and Business Technical Assistance Center Hotline, (800) 949-4232 (voice/TTY) Job Accommodation Network, 918 Chestnut Ridge Road, Suite 1, Morgantown, WV 26506-6080, (800) ADA-WORK (voice/TDD) U.S. Equal Employment Opportunity Commission, 1801 L Street, NW, Washington, DC 20507, (800) 6694000 (voice), (800) 800-3302 (TDD) or (800) 666EEOC (publications) Chemical Hazard Information Program, New York State School of Industrial and Labor Relations, Cornell University, 110 Pearl Street, 8th Floor, Buffalo, New York 14202-4111, (716) 842-1124 safety professionals, offering or guiding A11: As management to multiple solutions (that will work), while no-action or inadequate responses are kept off the table, is truly effective. Solutions that benefit all are best.

Free Legal Services Branch

he Consultants Practice Specialty (CPS) has nearly 1,700 members. In early 2010, CPS decided to sponsor the new Legal Services Branch. The Legal Services Branch was started to give SH&E professionals the expertise to proactively avoid and mitigate legal liability for themselves and their organizations. This branch also provides technical content and updates to aid expert witnesses, consultants, legal professionals and forensic specialists. The Legal Services Branch has more than 50 members and is growing every day. As a CPS member, this branch is free to join. Send an e-mail to customer service (customerservice@asse.org) asking to add you to the Legal Services Branch.

Several volunteer positions are open within the Legal Services Branch. The branch currently seeks an Executive Secretary, Newsletter Coordinator and Website Development Chair. To read more on volunteer opportunities, click here.

26 The Advisor www.asse.org 2011

Safety 2011
S
afety 2011 is the premiere professional development conference that helps professionals learn from the successes of other individuals and organizations, network with peers and earn CEUs.
The annual conference also provides an opportunity for Consultants Practice Specialty (CPS) members to meet face to face. This year, CPS will meet at a restaurant near the convention center for food, fun and networking opportunities on Sunday, June 12, 2011. Please keep an eye out for an e-mail with more details on the location. Meeting information will also be posted on our LinkedIn page. Also be sure to stop by the CPS kiosk in the exhibit hall and at the practice specialties booth to get more information about group activities and projects. Below are the CPS-sponsored sessions for Safety 2011. Go online to view all of the sessions, read about the special events and register today.

MONDAY, JUNE 13, 2011


525 Key Issue Roundtable #1: Using the Internet for Marketing (Sponsored by Complete Equity Markets, Inc.) 561 Lessons from China: ASSEs 2010 Delegation to Shanghai and Beijing Tuesday, June 14, 2011 643 Communicating During a Crisis: A Case Study of the BP Oil Spill Wednesday, June 15, 2011 701 Pipelines and Grids: Tools from Executive Coaching for Safety Leaders

705 Responding to Emergencies, First Considerations 758 Neuroleadership: Transforming Safety By Improving Thinking 768 Identifying Confined Spaces 771 Hands-on Training: There is Time, Even if Operations Does Not Know It 7070 Food at Rest is Food at Risk 7080 Engagement: Does it Really Matter? 7190 Electrical Safety on MultiEmployer Worksites

Volunteer Opportunities

olunteer opportunities within the Consultants Practice Specialty (CPS) will help you sharpen your existing skills, develop new skills in a risk-free environment, expand your horizons, become more motivated and energized about safety, increase your visibility within the

profession, boost self-satisfaction and demonstrate workplace and leadership skills that can be documented on your resume. Please contribute in any capacity that fits into your life and set of demands. If you are interested in volunteering, please contact CPS.

27 The Advisor www.asse.org 2011

COVER STORY
How Big is a Confined Space? continued from cover page 1 which says in part that entry is considered to have occurred as soon as any part of the entrants body breaks the plane of an opening into the space. This has led safety professionals to the interpretation that any space into which a worker might extend his or her head or arms should be considered a confined space (if it meets the rest of the definition about not being designed for continuous occupancy and having limited or restricted means of entry/exit) even if the space is too small to accommodate the employees entire body. However, further investigation shows that OSHA never intended to apply the confined space standard in this way, and the proof is clearly laid out in the preamble to the 1993 final rule. The preamble notes that several commenters on the original proposed rule said the definitions of confined space and entry were confusing, and some commenters suggested that small spaces could be just as hazardous and should be subject to the rule. OSHA responded, The agency has not adopted this suggestion. While OSHA is concerned that spaces that are too small for complete bodily entry may pose hazards for employees, the agency did not intend to cover such spaces under the permit space standard. OSHA believes that the notice of proposed rulemaking preamble discussion of permit space incidents and of proposed provisions clearly indicates that the proposed rule was intended to cover only spaces that were large enough for the entire body of an employee to enter. As commenters have correctly noted, the proposed definition of permit-required confined space did not cover the small spaces. Such spaces do not meet the definition of confined space nor do they pose hazards comparable to those associated with confined spaces. Since an employee cannot totally enter such spaces, s/he should not have difficulty withdrawing from the space. For a space to be considered a permit-required confined space, it must first be a confined space. A space that cannot be entered is not confined; therefore, it does not pose hazards related to the difficulty of exiting the space. More recent agency interpretations are consistent with this position. The 2008 letter of interpretation on determining whether an aircraft fuel tank is considered a confined space makes clear that if an employee cannot fit his or her entire body into the space, then it is not a confined space. However, some employees may fit into spaces that others do not. I recommend that if a small adult (4 ft 11 in. and 90 lbs) fits into the space, the space should be managed as a confined space. The capacity and configuration of the space, not the actual entry practices, determine whether a space is subject to the rule. If an employee fits inside the space and it meets the other elements of the confined space definition, it must be managed as a confined space even if written procedures call for employees only to reach inside with their hands. Finally, keep in mind that other sections of the OSHA rules require you to protect employees from the types of hazards that may be encountered when working in spaces that are too small to be considered confined spaces. These may include exposures to toxic substances and air contaminants, machine guarding issues or control of hazardous energy. The compliance directive for the confined space standard (CPL 02-00-100) has a question-and-answer section in Appendix E that includes the following. How will OSHA address a space that does not satisfy the criteria for a confined space but that potentially contains a hazardous atmosphere? Employers must comply with the permissible exposure limits and other requirements contained in standards addressing specific toxic substances and air contaminants, to the extent applicable, in all spaces in which employees may be present. In addition, the respiratory protection standard, 29 CFR 1910.134, applies where an employee must enter a space in which a hazardous atmosphere may be present and no other specific standard applies. The respiratory protection standard contains special precautions for working in atmospheres that are oxygen-deficient or immediately dangerous to life or health. I hope this information will help clarify what has been a confusing standard and will assist you in easing the burden of confined space management for your clients.
Barbara Jo Ruble, QEP, CPEA, is president of Specialty Technical Consultants. She has more than 30 years experience helping corporations develop, assess and improve their environmental health and safety management systems and compliance programs. She is s the primary author of OHSAS 18001/OSHA VPP Occupational Health & Safety Management Systems: A Complete Implementation Guide published by Specialty Technical Publishers of Vancouver, Canada. She may be reached at bruble@stcenv.com or at (410) 625-1952.

ASSE 2011 Scholarship & Grant Recipients

he ASSE Foundation (ASSEF) is pleased to announce the 2011 scholarship and professional development grant recipients. In April 2011, ASSEF awarded nearly $172,000 to 102 individuals. Seventy-one students representing 34 universities

will receive scholarships, and 31 ASSE members will receive professional development grants. To view the recipients or to read more about ASSEF, click here.

28 The Advisor www.asse.org 2011

ANNOUNCEMENTS

ASSE to Launch New Center for Safety & Health Sustainability

new Center for Safety and Health in Sustainability (CSHS) will be launched at ASSEs Professional Development Conference (PDC) and Exposition, Safety 2011, in Chicago. The Center, a 501 (c) 3 tax exempt organization, will aim to provide a voice for occupational SH&E professionals in the shaping of sustainability policies. It will provide new insights into the measurement, management and impact of safety and health sustainability, with the goal of being a recognized thought leader for sustainability and corporate social responsibility. It will seek to educate the business community on the importance of safety in good corporate governance and corporate social responsibility. The CSHS is a collaborative effort among ASSE, the American Industrial Hygiene Association (AIHA), whose members serve the needs of occupational and environ-

mental health and safety professionals practicing industrial hygiene, and the Institution of Occupational Safety and Health (IOSH), a U.K.-based safety and health practitioner organization. Collectively, the three organizations represent approximately 80,000 safety and health professionals located worldwide. CSHS is an organizational stakeholder of the Global Reporting Initiative (GRI), a network-based organization that pioneered the worlds widely-used sustainability reporting framework. Mike Wallace, the director of GRIs Focal Point USA, will be attending the CSHS launch and presenting at Safety 2011. The Center was developed out of a growing perception among ASSE members of the need for safety and health professionals to have a voice in shaping sustainability policies both in business and public policy.

ASSE Expands Professional Membership to Those With OHST, CHST Credentials

SSE recently voted to accept two new credentials for professional membership, the top membership category in ASSE. Recently approved credentials by the ASSE Board of Directors for ASSE professional membership are the Construction Health and Safety Technician (CHST) and the Occupational Health and Safety Technologist (OHST). Professional membership is the highest membership category in ASSE. Other membership categories include: member, international member, associate, student, honorary and emeritus. In addition, ASSE professional members can be or have a Professional Engineer (P.E.) registration, Certified Safety Professional (CSP),

Certified Industrial Hygienist (CIH), Certified Health Physicist (CHP), Certified Hazardous Materials Manager (CHMM), Certified Professional Environmental Auditor (CPEA), Certified Fire Protection Specialist (CFPS), Canadian Registered Safety Professional (CRSP), Chartered Fellow of the Institution of Occupational Safety and Health (CFIOSH), Chartered Member of the Institution of Occupational Safety and Health (CMIOSH) credentials, Certified Occupational Health Nurse Specialist (COHN-S) and Certified Occupational Health Nurse (COHN). Along with these, one must have 5 years of safety experience and a bachelors degree from an accredited college or university.

Consultants Practice Specialty Resources


Mentoring Services: Visit the Members Only section of ASSEs website and click Mentor Contacts or contact ASSE staff. Job Search Assistance: Visit Nexsteps, ASSEs Career Resources LinkedIn site or your local chapter site to view SH&E job postings. Career Resources: Use the Career Resource Center. Networking: Join our LinkedIn and Facebook groups or view all of ASSEs social media sites. Technical Advice: Use our 24/7 online question submission form or contact the Consultants Practice Specialtys (CPS) volunteer Advisory Committee with any technical questions. Publication Opportunities: We welcome article submissions (earn COCs and win a cash prize if you are the top article), topic suggestions and interview requests. Educational Resources: CPS Practice Specialty website; SH&E Standards Digest; Special Issues and Best of the Best publication; Key Issues publication; interviews; Business of Safety Committee; Nanotechnology Support Site; webinars.

29 The Advisor www.asse.org 2011

WAIT!
You provide the safety net for your clients; let us provide one for YOU. Make SURE you have the proper insurance coverage.

Go to www.cemins.com/asse.html or call us at: (800) 323-6234


Complete Equity Markets, Inc. in CA dba Complete Equity Markets Insurance Agency, Inc. CASL#0D44077 1190 Flex Court Lake Zurich IL 60047

Вам также может понравиться