Rock Products

NOV 2012

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FOCUS ON HEALTH & SAFETY A Higher Plane of Safety By Randy Logsdon I think we've all heard the phrase, and most likely passed it on to others – a bit of wisdom from one to another. It makes the best impression when one holds aloft a copy of 30 CFR and proclaims, "Each rule in this book was written in blood!" (Well, figuratively they're written in blood.) The figurative meaning is that each rule was carefully promul‐ gated as a direct result of one or more fatal or seriously dis‐ abling injuries. And, to be sure, there are a number of solid rules in 30 CFR that specifically address those legacy issues. Among them are rules for locking out electrically powered equipment (56/57.12016); moving machine parts (56/57.14107); shunting electric detonators (56/67.6401); and smoking and open flames (56/57.4100) just to name a few. There are hundreds more. There is, however, a risk of diminished safety resulting from overemphasis on compliance. Recently, I was driving a main thoroughfare through town around 8:30 in the morning. Ahead was a yellow warning sign with amber flashing lights – a school zone; speed limit 15 mph. Being familiar with the area, I knew that the local police department typically moni‐ tored it closely and so I prepared to adjust my speed from the normal 35‐40 mph range. In retrospect, I found that the ABC behavior model drove my actions in this scenario. The Antecedent (activator) was the flashing light that identified the school zone as active. The at‐ tached speed limit sign defined the prescribed behavior. I ad‐ justed my Behavior to comply with the 15 mph speed, thereby avoiding the negative Consequence – a moving viola‐ tion citation. The ABC model worked to perfection in modifying my behav‐ ior to comply with the revised speed limit. But, did it really enhance the safety of school children that might potentially be exposed to the traffic? I've made this same adjustment hun‐ dreds of times, but this time, after exiting the school zone and resuming normal speed, I realized that my focus through that school zone was on my speedometer and not on the side‐ walks and crossings within the zone. Give me an A for compli‐ ance and an F for safety. So there is an assumed correlation between the slower traffic speed and the safety of school children. Such a correlation is likely based on reliable data. But is it not also reasonable to assume that there is a correlation (perhaps a stronger corre‐ 40 ROCKproducts • NOVEMBER 2012 lation) to observant driving behavior and the safety of school children? I offer the above example to illustrate a crucial point. Focus on compliance only, does not necessarily yield optimal safety. Our focus must be on the mitigation of risk. Consider a more pertinent example involving the common Chicago coupler. 30 CFR § 56/57.13021 High‐pressure hose connections. Except where automatic shutoff valves are used, safety chains or other suitable locking devices shall be used at connections to machines of high‐pressure hose lines of 3/4‐in. inside diameter or larger, and between high‐ pressure hose lines of 3/4‐in. inside diameter or larger, where a connection failure would create a hazard. While conformity with 30 CFR § 56/57.13021 delivers some measure of safety, strict compliance when applied to Chicago couplings can fall short of providing a full measure of safety. Compliance is commonly achieved by inserting keeper pins designed to prevent unintended uncoupling under stress. The MSHA standard omits this requirement for connections of hose lines less than ¾‐in. inside diameter, low‐pressure hose lines, and even pressurized water lines. A realistic risk assess‐ ment reveals that an unintended uncoupling under those other conditions can also result in injury. To elevate our safety, we must understand not just the text of the standard, but the intent. In this case, the intent (our in‐ tent) is to prevent the sudden release of injury resulting from an unintended disconnection of hose connections. To reach that higher plane of safety, our practice must answer not the text, but our intent – to prevent any unintended release of in‐ jury. The extension of the standard is the practice: Pressurized hose connections are always secured against unin- tended disconnect and intentional disconnect is only performed when the pressure source has been blocked and bled. The practice can be observed, measured, and audited. The practice will meet both the standard and the intent. So many of our practices are based on what a government agency re‐ quires. We've learned to ask: "What do we have to do?" to avoid the negative consequence – a citation. We should be asking: "What do we need to do?" to reach that higher plane of safety. E

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