A Game Plan for These Tough Times

Head/face protection should be near the top of your list because it affects almost every other safety program you have on site.

• By Linda J. Sherrard
• Mar 01, 2012

Brace yourself and face the situation squarely: Few companies have a fully functional head and face protection program that will pass inspection by trained and qualified inspectors. Most facilities have bits and pieces of a program, but over the years, the various parts of program continuity have dropped into the dust as other, always urgent program needs take time and budget.

Chances are you are working hard to plan and promote the continuing use of all of your safety programs with less staff, no support staff, slashed budgets, and anticipation of more of the same in the foreseeable future. Many of us are weary of hearing about doing more with less (while being reminded to always stay positive) because we know that safety is often quickly marched to the chopping block with upper management declarations of "Safety is making do right now. It'll be all right; divert the funds."

Every penny counts in these perilous times. Long gone are the days of mass purchases and storing items "just in case." Inventory is nonexistent unless it is critical. Employees are often afraid to ask for new head/face protection PPE on the job site and try to make each item stretch even to the point of wearing non-functional PPE or none at all, hoping for the best.

Hope is not a good safety management tool, because it rarely works out well.

As safety leadership, a huge part of what we do is planning for the future protective effect of our programs. Your site may genuinely need a solid head/face protection program. Most safety program developers see each section element as a personal validation of continued success.

We know and have shared with upper management and employees alike the horrors of not providing adequate head and face protection: severe injury, disfigurement, even injuries resulting in the death of the employee. Then there’s the loss of production time and increased liability, which affects the long-term survival of the facility as a whole. We may ask for funding and be quietly declined by management but must continue somehow without showing shock or dismay or despair.

Workplace injuries affect employees’ motivation, their morale, and their continued commitment to the company. Experiencing many injuries of the same nature will be seen as a breach of quality in your program elements; eventually, you as the safety leadership will be called to task by management for compliance inspection activities, audits, or money you’ve spent (or not spent). By keeping your program elements fresh and alive, you protect your corporate safety programs, provide structure for employee knowledge and understanding, and, not to be overlooked, your professional reputation.

A Game Plan of Eleven Items
When updating your head and face protection program, consider the following:

• The Program. Knock the dust off your paper program! When was it originally developed? More importantly, when was the last time it was reviewed? Is this clearly documented? Make sure you regularly update and tweak your program in printed form to reflect the industry you serve and that you meet all requirements. Include a departmental breakdown of hazards and how your head/face protection program meets/exceeds the PPE need. What passed as a written program decades ago is not sufficient now. Hazards have changed as processes changed. Include all areas and plan for future development going forward. Too often, safety personnel see the paper program as static; it takes work and attention to detail to keep it updated and applicable to the work you do. Include remote locations, portable crews, acts of nature such as earthquake or hurricane preparedness, loss of power, and even multiple hazards. Have handouts for those unforeseen items such as storm cleanup, where other employees would be issued head/face protective items. Make your training elements part of the paper program, too, so that the documentation is easily accessible when needed.
• The Media. As part of your program, make sure you have a clear understanding of release of information to media outlets in an emergency or accident follow up. Know who the point of contact is for your facility and what will be released if news media show up asking questions or demanding photos. The freedom of information movement has opened the floodgates, and it is up to you to know what is released and why. Keep copies of everything provided. It matters. Know what PPE is being used, how old it is, and when training was last completed.
• The Committee. Regularly review and update your program, saving time by using your safety committee to initiate the work and report back to you. Document the review, questions or concerns, and meeting dates. Include changes and when it was submitted to management. (How many of us have sent programs up for approval and signatures, never to be heard from again?) As this reminds us, the safety program is not just the safety officer -– it's the entire team.
• The Attitude. Do you know how management and employees view the safety program? Find out and make positive changes when necessary. While at it, consider your own attitude and how you are perceived at all levels. If safety as a program is seen as a burden, as an adversary and not an asset, it is time to make changes so the perception shifts from program survival to program thriving.
• The Numbers. Talk with your worker's compensation provider and get firm numbers. Break down the data by department and task. Track those head/face injuries where PPE was not used or was improper for the task. Consider including replacement dates to see whether the PPE possibly failed due to age. Your worker's compensation expenditures are numbers that garner a lot of scrutiny by management. Use them to your advantage and know them inside out.
• The History. Ask your Purchasing Department for a list of each PPE type by item and how many were ordered. Track this back several years to follow replacements, upgrades, or changes in processes. If the total volume of PPE is declining, determine why. Process change? Reducing the workforce? Make sure needed items are being ordered, are the correct item for the task, and actually are provided to employees.
• The Budget. Request your budget totals by category for the past 10 years or any designated time span you feel is important. Is the total amount shrinking while the hazard level and your worker's compensation costs are increasing? Chart this and provide to management. These are data they will listen to!
• The Training. Document it, of course. How you train, how often you train, and what is covered. Dust off your training plans or agendas for meetings and make sure they cover the topic satisfactorily. Cover the general aspects of safety, first aid, PPE use and care, replacements, and reporting an injury or damaged item. The more data you have on hand for super-fast reference (I really like notebooks for this), the better you are prepared to respond to what you have done in a crisis. Computer databases are great; just have a backup paper copy, too, or be able to pull the information fast when you need it.
• The Purchases. How and why were past PPE items purchased? Who made the decision? Did the safety committee ever review any PPE for task appropriateness? Did you, as safety director, or one of your staff review and make suggestions? Or did the purchasing officer pull the cheapest item out of a catalog and order it? Can you justify your PPE inventory in use today? How often is this plan reviewed?
• The Subs. If your facility utilizes subcontractors, consider expanding their use for duties requiring higher-hazard PPE items or training that you do not have the budget or time to keep updated. This helps to divert your equipment purchases and also may protect your employees from unusual hazards. Also, specialized subcontractors keep their training and equipment (for activities such as confined space entry) very current by using their skills frequently. Be clear in your contractor requirements and obligations, and request copies of their records.
• The Unusual. If you have a unusual, once-a-year type of activity or a combination PPE item that is expensive, consider renting it. This works well for short-term use or one-time use (many companies have once-a-year maintenance and unique activities every few years).

I do not know of one safety professional not under extreme stress right now. The economic downturn has caused massive layoffs of skilled safety professionals and reduced huge budgets to a pittance in only a few years, with more to come. Some multi-person safety teams are reduced to one person with no offset of responsibility. We as safety professionals are told to "handle it" and our time is stretched past the limit each and every day. Our liability is becoming overwhelming because we cannot take the time to do any item well, and we keep thinking, "What do I not do in order to get the new assignment done?"

All this aside, if we do not regularly plan for the future of our programs and update the documentation, we will surely fail and our employees will suffer by not being protected. Or our programs will suffer from lack of use. I'm often seen in the late afternoons with a notepad, making lists. I try to update certain programs at the same time each year. (It's a goal, not something set in stone -- I tag it on my calendar as a reminder.) Consider your audit potential and which programs and records you must maintain and update. Head/face protection should be near the top because it affects almost every other safety program you have on site.

This article originally appeared in the March 2012 issue of Occupational Health & Safety.