SMG Recognized by Business & Legal Reports, Inc.
7/11/2002
The following article is reprinted from the July 2002 issue of OSHA COMPLIANCE ADIVSOR, the publication of Business & Legal Reports, Inc.
The experts reiterate that the key to preventing injury and preserving health is to manage safety like other business functions'with systematic methods like those used to manage production, accounting, marketing, etc. This approach is especially productive in the construction industry, where workplaces are not permanent, where tasks (and risks) change from day to day, and where layers of supervision by different entities often exist.
In this Compliance Report, we'll take a close look at a consulting firm that's devised a comprehensive plan for managing safety and health on construction sites. We'll also see how an organization known as the Construction Safety Council is making a difference, and review the services and assistance OSHA offers construction employers.
THE SAFETY MANAGEMENT GROUP
For about a decade, the Safety Management Group (SMG) has managed safety on a large number of construction projects throughout Indiana and the Midwest. The firm's founders were initially hired by an insurance company to serve as loss control representatives for an owner-controlled insurance program (OCIP). Well-known in the construction business, an OCIP is an arrangement under which a project owner provides workers' compensation and general liability insurance to contractors on a job. In exchange, the contractors exclude the costs of insurance from their bid. OCIPs are usually only cost effective on large-scale building projects of more than $100 million.
Today, SMG is an independent entity, led by president and co-owner J. Kent Burget. He explains that the company provides safety and health services to large and small businesses pursuing building projects. "We've been involved in several hundred projects over the last 10 years," explains Burget. SMG services range from consultation, to training, inspections, written safety programs, loss control evaluations, and full-time project safety oversight. Clients include municipalities, as well as healthcare, manufacturing, and insurance businesses.
In its literature, SMG explains that optimistic schedules and budget constraints are among the factors that challenge safety compliance on large construction projects. A "fully integrated safety management program" cannot only prevent injuries, but can promote a climate of efficiency that will ensure the timely completion of a project.
CONSTRUCTION PARTNERS
Burget makes clear that his clients are not absolved of their responsibilities because they have SMG on their team. In fact, a successful outcome is seen as a partnership between the consultant and the project owner. "This is a prominent pan of any program. The owners remain responsible, as if they were working on their own. But we assist them in fulfilling their responsibilities." That includes not only complying with Indiana OSHA rules, but also with the owner's own safety codes. Working with one of its largest clients, SMG sought to create a system that was broad and well documented. Burget notes, "We developed a process that includes 13 steps and starts with a policy statement emphasizing the owner's concern and responsibility for safety." It covers the range of construction stages and activities, and even includes steps to keep safety a priority as job circumstances change.
PROCESS COMPONENTS
The SMG contractor safety management process requires the following:
1. Safety program policy statement. Documents the owner's commitment and responsibility for implementation.
2. Roles and responsibilities. Defines duties for all parties involved.
3. Project safety plan. Develops a safety plan during the early stages of a project for use throughout the job.
4. Contractor safety prequalification. Evaluates contractor safety criteria to indicate level of past safety performance.
5. Contracting process. Promotes safety expectations during the bidding or negotiating process and provides a means to collect safety data.
6. Contract document. Conveys safety requirements in writing.
7. Site communication. Promotes detailed communication of safety information to on-site contractor supervision.
8. Safety orientation. Promotes communication of general safety information to on-site craft workers.
9. Safety permits. Facilitates and documents hazard identification and corresponding required safety efforts.
10. Contractor verification. Lays out a means for auditing the contractor's implementation of safety requirements including training, field practices, and substance abuse.
11. Contractor incident investigation. Investigates contractor incidents to identify and document root causes and outline corrective actions to prevent future incidents.
12. Safety communication process. Describes the network for communicating safety information.
13. Change control process. Allows for a systematic way of updating policies and procedures.
A CLOSER LOOK
Although space precludes a detailed overview of each of the 13 program elements, we gained insight into two'the planning piece (#3) and the SMG audit process (#10)'from Burget and from Todd Detro, SMG team leader. The planning step is based on an extensive checklist that is intended to motivate team thinking about safety. It is completed at the earliest stages of a process, before bidding or the selection of contractors.
The checklist covers common construction safety concerns including fall protection, steel erection, and other areas of compliance. But it also includes suggestions that have come directly from SMG's vast experience in the field. For example, the checklist asks if job planners have considered establishing a staging area'a central location where materials are loaded and unloaded. Says Detro: "On one project, we had trucks loading and unloading wherever there was room. One truck was filled with neatly folded scaffolding. The driver parked on a non-level surface because there was no other place to park. As he started unloading, the pieces of scaffolding tumbled out of the truck. The driver sustained a broken leg, but it could have been much worse." Ever since, says Detro, SMG urges project planners to provide for a dedicated (and flat) staging area.
AUDITS ADD VALUE
SMG has devised a series of audits for use on construction projects it oversees. At the heart of the effort is what the company calls the focused audit, a planned review conducted quarterly at each jobsite. "We give the contractors two weeks' notice, so they know we're coming in and what the audit topic is," says Detro. The topic is selected on the basis of inspection findings, observations in the field, and any incidents that may have occurred.
"We'll conduct an opening meeting, then talk with on-site management personnel and the contractor and let them know what we're doing." The auditors, who are SMG staff members, may spend up to several days at a location, conducting field verifications to ensure that the contractor is following its own safety process, adhering to OSHA rules, and complying with SMG/owner requirements. The audit team looks at training records, copies of written programs, and contractor policies. Detro adds, "We're looking for sustainability. We want to know that when we leave the site, that missing guardrail that's now up in place again won't be down again tomorrow."
Detro warns against using the findings of a focused audit (or any audit) as a snapshot in time. "You have to drill down and continue to pull on the strings until you get to a root cause." Using the example of the missing guardrail, he suggests that possible causes could be poor or improper training, an unsafe employee behavior or attitude, a lack of enforcement, or a corporate culture problem. He adds: "The guardrail has to be fixed immediately, but are you getting to the cause, which may be a systemic issue that could be affecting the entire program'"
Another level of audit built into the SMG safety process is known as process verification. "Here, we look at our own contractor management system to see if the 13 steps were implemented. If an incident occurred, we go back to those involved, asking if they knew their roles and responsibilities, if they planned properly, if they prequahfied contractors, etc.," Detro explains. The process verification audit is conducted after any recordable incident, and at least three times per quarter at each site. In addition to revealing possible contractor failings, the process verification also gives SMG valuable input to constantly evaluate and improve its own management process. If a particular step is repeatedly causing trouble, that might suggest a fault with the system, he says.
Compliance and use of best practices are also assured through informal audits'project walk-abouts. These are conducted daily by SMG staff, who encourage contractors to do them as well.
NO USE FOR USERS
A fourth type of audit used by SMG assesses compliance with a strict alcohol and drug abuse policy. Most project owners, contractors, and unions in Indianapolis are members of the Metro Indianapolis Coalition for Construction Safety (MICCS). MICCS has developed a comprehensive substance abuse policy that's in place at nearly every jobsite in the city. Under the program, contractors are required to comply with its provisions in all of their invitations to bid, or in requests for proposals, as well as in all specifications or contracts.
Under the MICCS program, workers receive identification cards after successfully passing the substance abuse test. A central database retains results of individual tests. This permits contractors and owners to verify the validity of the cards presented by workers. Owners agree to honor the cards on their sites, and provide reciprocity of results from one site to another. Although discipline is part of the program, there is a strong emphasis on finding appropriate help for employees who need it. The program includes provisions for those who receive treatment to be retested after a period off the job and possibly returned to work.
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