Total Environmental Health and Safety Management

Unit I – Question 6

Compare and contrast the advantages and disadvantages of implementing ANSI/AIHA Z10 versus OSHA’s VPP program. In your response, discuss the perceived or real benefits of each standard and the relative difficulty of implementing each. Support your discussion with personal experience and/or sources other than the course textbook.

According to our textbook, there are several similarities and differences between Z10 and OSHA’s VPP program (Manuele, 2008). One advantage of Z10 versus OSHA’s VPP program is that the term “hazard” is clearly defined under Z10. Additionally, Z10 incorporates risk assessment provisions which enable better prioritization of hazards as compared to VPP. OSHA’s VPP calls for the recording and prioritizing hazards but how is this to be done properly without first determining the hazard potential? Another difference of Z10 as compared to VPP is that Z10 requires that a process be in place to conduct periodic audits of the safety and health program. Additionally, Z10 states that “audits should be conducted by individuals independent of the activities being examined” (Manuele, 2008, p.391).

A major advantage of OSHA’s VPP program is that OSHA removes VPP participants from OSHA’s programmed inspection lists. Another advantage of VPP versus Z10 is that VPP spells out specific industrial hygiene requirements. Under VPP a written industrial hygiene program is required whereas under Z10 there is no such requirement (Manuele, 2008). Statistical evidence has shown that the average VPP worksite incident rate for days away from work, restricted work activity, and/or job transfer is 50% below the average for its industry (Manuele, 2008).

References

Manuele, F. A. (2008). Advanced safety management focusing on Z10 and serious injury prevention. , N.J: John Wiley & Sons.

Unit I – Question 7

Review the summary of the ANSI/AIHA Z10 sections in Chapter 1 of the course textbook. From these descriptions, discuss what you think might be roadblocks to implementing the standard in a typical manufacturing organization. Which sections might prove to be the most challenging? Support your answers

I think the biggest roadblock in implementing the Z10 standard in the manufacturing sector is the perceived added costs involved. While the safety design review process would ensure a safer finial product, process redesign could potentially drastically drive up design costs. Additionally, because practically all manufacturing companies already utilize lean concepts; this portion of Z10 would not compensate for the added time and resources required to implement the safety design review process (Manuele, 2008). Another possible concern of manufacturing companies choosing whether or not to implement Z10 is the potential added cost involved in the procurement process. Manufacturing equipment is very expensive to replace and/or retrofit and the added cost involved to bring the equipment up to Z10 standards could greatly impact a company’s bottom line. Additionally, ensuring orders and contracts adhere to strict Z10 guidelines could affect profits for existing contracts as well as decrease the likelihood of competiveness in future contracts. On the flip side if implementation of Z10 is able to achieve significant serious injury reduction the cost savings in insurance/workers compensation could potentially make up for the added costs elsewhere. Also, if employees are union workers the implementation of Z10 by management is likely to garner much praise.

References

Manuele, F. A. (2008). Advanced safety management focusing on Z10 and serious injury prevention. , N.J: John Wiley & Sons.

Unit I – Question 13

A recent OSHA inspection in your machine shop identified several serious deficiencies in occupational noise control. Serious violations were issued citing 29 CFR 1910.95(i)(2) and 29 CFR 1910.95(k). Using the PDCA framework, develop a plan that will correct the deficiencies and ensure that the violations do not recur. 

Your response must be at least 500 words in length. You are required to use at least your textbook as source material for your response. All sources used, including the textbook, must be referenced; paraphrased and quoted material must have accompanying citations.

Due to the fact that both violations have the potential of being interrelated I believe a root cause analysis is in order to determine if the training deficiency led to the lack of personal protective equipment (PPE) compliance (failure to wear hearing protection). A root cause analysis to determine why hearing protectors were not being worn should be a prerequisite to planning in the Plan-Do-Check-Act (PDCA) process. During my eighteen years of experience in the aircraft maintenance field failure to wear appropriate PPE is often a result of inadequate training. Because hearing loss is gradual and instead of immediate often times individuals fail to think of the long term health implications. If working in an already hazardous environment, being unable to utilize one’s hearing to identify immediate safety hazards is often a contributing factor for failing to wear appropriate hearing protection. After determining the root cause of why hearing protection is not being worn, the next step is to develop a solution. Under PDCA, identifying the problem, analyzing the problem, and developing a solution are all part of the planning step (Manuele, 2008). Ensuring that the plan corrects the root cause should be a primary goal of the planning step. It is my belief that the solution must incorporate a level of enforcement of standards through either quality assurance or management involvement to be successful. After the plan has been developed and approved by the appropriate level of company management the next step is implementation. After implementation, an observation period is needed to ensure that the plan achieved the intended result. This step is referred to as ‘check’ in the PDCA process (Manuele, 2008). If the observation revealed that policies, objectives, and requirements were met and no changes are needed the PDCA process proceeds to the ‘act’ step. If changes are needed, it is back to the drawing board with the planning step in the PDCA process. This is why proper root cause identification and analysis is crucial to the planning process. Even after the solution is determined to be effective at correcting problem, routine follow up is essential. This falls under the ‘act’ step in the PDCA process and requires the employer to take action continually as needed to improve process improvement (Manuele, 2008).

If I were the Safety and Health Manager for the company in question I would bring together supervisors, management, and subject matter experts to identify and analyze the root causes of both deficiencies. Together we would use proven methods to determine the root cause(s), analyze potential solutions, and implement a course of action. Next we would monitor previously adopted solutions to ensure that policies, objectives, and requirements were met. If needed, we would revise solutions as necessary to achieve stated goals or improve the process. I would also ensure adequate periodic management review. This would most likely be achieved through periodic program audits to ensure compliance and identify program weaknesses. By implementing the previously stated actions in a systematic manner and adhering to the PDCA process, management can rest assured that is solution is sound.

Reference

Manuele, F. A. (2008). Advanced safety management focusing on Z10 and serious injury prevention. , N.J: John Wiley & Sons.