Proactive planning, a strong safety culture and well-documented procedures are all key to responding to safety incidents at your precast plant.
Precast concrete plants produce incredible structures. From the smallest blocks to the largest bridges, seemingly no project is out of the question. Thanks to the ingenuity of the workforce, along with ever-advancing machinery and concrete technology, the industry is constantly evolving, generating projects that are structurally complex, aesthetically pleasing and capable of lasting long into the future.
Despite these advances in manufacturing, safety remains a primary focus for the precast industry. With heavy machinery in operation and large products on the move, the potential for accidents necessitates robust safety plans aimed at protecting employees from the many hazards that exist inside plants.
Accidents and injuries can never be eliminated completely. As such, leadership groups and safety teams across the U.S. and Canada must be adequately prepared to respond to possible inspections, violations and citations from OSHA or the Ministry of Labor. The best defense in these situations is establishing a strong safety culture that is anchored by training programs, open lines of communication, auditing processes and strong documentation.
Establishing a Strong Safety Culture
Preparing for an inspection or investigation begins long before the accident ever takes place. As Thomas Jimeno, occupational safety and health manager at Wilbert Precast of Spokane, Wash., explained, it’s all about developing a safety approach that is enhanced through time.
“With your safety program, you never have one that’s complete,” he said. “It’s always evolving and will only be as strong as you are actively engaging with it and making it available to your employees.”
Promoting and sustaining a strong safety culture is a constant process that requires buy-in from the leadership level all the way down through the rest of the plant. Ensure open lines of communication exist between all teams, and encourage workers to report issues they see while conducting operations.
“You must foster a workplace environment where employees will come forward to talk about safety concerns and incidents, whether it’s mistakes they’ve made or noticed in the workplace,” said Marlo Harley, MBA, manager of environmental health and safety at Ontario, Canada-based DECAST. “They need to know that their opinion and voice counts. We cannot solve safety issues here without worker participation.”
Beyond open lines of communication, plants also should consider establishing a safety committee that can focus on site-specific elements of need. Such committees should include team members from across the company.
“Safety committees are extremely important,” Jimeno said. “They are the ones who see what’s going on. Here, I’ve got guys from pretty much every department on my committees. They help maintain the culture and assist with the enforcement of the program.”
Training programs are another key part of the recipe for a strong safety culture. Evaluate your plant, considering the types of products you manufacture as well as the machinery used, and develop appropriate safety training around your specific situation. These programs can prove extremely effective in not only mitigating accidents and injuries, but also in how you respond to a governing body like OSHA when an inspection takes place.
Document all the steps you take as you create and refine your safety program, including when incidents occur and how you respond to them, what new training you have offered and anything else related to preparing your employees for the many different situations they may experience when working in your plant. Such documentation will prove instrumental should an inspection or violation occur.
Auditing for Success
In addition to developing a strong safety culture, consider working with your local or regional labor department to engage in consultations. These will help you identify areas of strength and any deficiencies you may have pertaining to safety in your plant. This process will help pinpoint weaknesses while also allowing you a chance to address issues without the risk of incurring a violation. In Washington, Jimeno works with the Washington State Department of Labor & Industries (L&I) throughout the year to make this happen.
“I have L&I come into my three plants every year for this,” he said. “They go through our safety program and processes. Then, they let us know what we are missing along with any improvements or changes we need to make.”
Chad Meyers, operations manager for Kansas City, Kan.-based precaster PRETECH Corp., follows a similar approach with the Kansas Department of Labor (KDOL).
“We perform our own self-audit alongside KDOL every year,” he said. “They send a representative out to the plant, and we go through all the buildings – if they see any violations, they will let us know. And, because they are so well-versed with OSHA rules, they can address any questions we have as we seek to improve.”
Engaging with these organizations opens a line of communication that shows good faith in your efforts and allows your plant to identify and correct potential safety concerns before they become major issues.
At DECAST, Harley and her team recently worked to achieve ISO 45001 certification. ISO 45001 is an internationally recognized standard that provides a framework for organizations to manage risks and enhance occupational health and safety performance. Obtaining the certification adds another layer of protection for employees that goes beyond DECAST’s interactions with the Ontario Ministry of Labor.
“For us, going through an audit certification process like ISO has been very helpful,” Harley said. “Engaging in any audit process, whether internal or external, is a smart way for a team to evaluate how well they are performing against legislation. It’s really a way for you to benchmark your program around successful ones.”
An Accident Occurs. What’s Next?
Despite best efforts, safety incidents at precast concrete plants are a reality of working in the industry. Once an accident takes place, the due diligence you have performed in setting up and establishing your safety program and culture will play a key role in what happens next, but it’s imperative to respond appropriately.
First, address the employee in question. Depending on the severity of the injury, decide what medical services may be needed, such as a visit to urgent care or the emergency room. Once the affected employee is taken care of, fill out an injury incident report. Typically, this report will include information such as the type of injury sustained, how the accident happened, what bystanders witnessed and more.
At Wilbert Precast, Jimeno said his team looks at the process being used during the incident, any equipment involved and whether the affected employee was using the correct training. Utilizing the incident report as a guide, you can refine your safety program and training efforts to put your employees in a better spot to succeed moving forward.
In the U.S., should a sustained injury result in a hospitalization, amputation, loss of an eye or death, employers are required to notify OSHA. Fatalities must be reported within eight hours, while the other significant injuries must be reported within 24 hours. In Canada, rules for reporting vary by location and are governed by each province’s Ministry of Labor. However, in most cases, significant injuries and deaths should be reported as quickly as possible.
Typically, after the incident is reported, you will be asked to provide documentation of what took place – this includes the injury report filed, your accident prevention plan, OSHA 300 logs (in the U.S.) and anything that is pertinent to what occurred. If the accident involves equipment, your governing body will also want to see any training programs offered or certifications held in relation to that equipment.
“In the end, it’s all your preparation in the beginning that will determine how well your investigation goes,” Jimeno said. “Everything with an OSHA violation really stems from if you do the work up front and have all your documentation to show that you did everything you could to train and protect your employees, things will go very well.”
Should an investigation result in a violation, precast plants in both the U.S. and Canada retain rights to dispute the decision. In the U.S., companies have 15 working days from the date the citation is received to contest, in writing, the citation, proposed penalty or abatement date. OSHA encourages those considering an appeal to speak with an area director to discuss options for addressing the issue. If the appeal is not contested within 15 working days, the citation becomes a final order and is not subject to review by any court or agency.1 While the situation varies by province across Canada, in Ontario, companies who dispute a Ministry of Labor decision can complete an Application for Review that sets out the facts and reasons for the application within 30 days of the citation’s issuance.
Preparation is Key
The best way to bolster your defenses against safety incidents and potential citations is to establish a strong safety culture armored with robust training programs, sound documentation and open communication from leadership to the plant floor. While incidents cannot be completely avoided, they can be mitigated, which will minimize the potential for serious retributions resulting from accidents. As Jimeno hammered home, it’s all about preparation.
“99% of the work in a successful investigation is done before OSHA ever shows up,” he said.