Last week, I discussed the concept of standardization and its application to occupational health and safety training. Today, I will look at the practical difficulties that arise when companies try to implement a standard at different locations within their organization and what to do to overcome these problems. I will use the crane industry's experience with standardization as a case study.

Regulation as Standardization

Many OHS laws and regulations are themselves a form of standardization in the sense that they impose a uniform set of requirements covering all companies in the jurisdiction regardless of industry and form of operation. Thus, the same regulatory requirement may apply equally to a manufacturing plant, power station, pulp mill, oil refinery, underground mine and construction site.

This is particularly true of legal requirements covering particular kinds of equipment, machinery and tools. Cranes and lifting apparatus are a perfect example. Such equipment is used at all kinds of sites. But the safety regulations governing the use of the equipment might be the same at each of these locations (at least within the state or province covered by the OHS regulation).

What does differ is the training and work instructions given to implement the terms of that requirement. Such training and instruction may be unique to each location. It might also vary based on the instructions of the manufacturer of the equipment involved.

Example: One shop is moving pipe and only uses a lifting apparatus on the hoisting hook, and another location is a welding shop using plate clamps on the hoisting hook. Each shop would be subject to the same regulatory requirements and follow the same standardized procedure for the lifting equipment but would also have a different work instruction for the application that's unique to its location.

The Challenge of Implementing Standardization

The implication of this is that standardized regulations and requirements aren't enough. To capture the advantages of standardization (which I explained in last week's issue), it's necessary to standardize the implementation of those regulations and requirements at each site.

Industry standards are analogous to regulatory standardization. They also impose a set of uniform requirements and procedures but leave room for variation in the implementation. Thus, to stick with the crane industry example, companies that use certain kinds of overhead lifting equipment can adopt a standardized procedure for equipment maintenance, operation and training that applies to all locations. But each location needs to document and implement unique work instructions that account for their jurisdiction's OHS regulations and the manufacturer's instructions of the equipment they use.

When ISO 9000 Quality Management systems were first introduced in North America 25 years ago, they included instructions for documentation and implementation. Manufacturers interested in the standard had to ensure implementation by each of their distributors, dealerships and warranty repair depots. Because each of these operations acted independently of one another and had different operating requirements, they each fashioned their own management system translating the intent of the standard to their own circumstances. Needless to say, when the manufacturers began auditing the different systems, it was like trying to read a manuscript in hundreds of different languages.

Standardizing Standardization

To resolve these implementation problems, the manufacturers who adopted ISO 9000 developed a standardized quality management system set of operational procedures that applied to all locations. They then required each of their locations to document and implement instructions unique to their location.

Example: ABC Manufacturing owns ABC Warranty Repair Depot whose sole operation is the repair of hoists. Thus, ABC Manufacturing documented the general operational procedures. ABC Warranty Repair Depot then documented its own unique instructions that included the requirements for the repair of a hoist. The same process was applied to all other locations. ABC Manufacturing now has a quality management system that gives it control over quality and production. It also has total traceability at each location and can determine which locations require further auditing to bring their systems up to the company's quality standard expectation. The end result is better production, reduction in all related costs, less rework, waste and a better bottom line.

The Experience of the Crane Industry

Crane industry training requirements are becoming standardized to comply with CSA, ASME, CMAA and ISO standards. This means standardization is becoming applicable to all the training programs for crane drivers/operators. The only thing that differs is the operating instructions for each type of lifting device, and the regional regulatory requirements for qualifying drivers/operators.

In Canada, the centerpiece of crane industry standardization is the revision of CSA (short for Canadian Standards Association) B167 Overhead Crane Standards. The revision, which is in its final stages (the final version will be available for public review this fall), is designed to make the CSA standard compliant with the ISO International World Standard for Cranes.

The ISO 9926-1-Training of Drivers is a single training element of the ISO standard for drivers/operators that is applicable to every type of lifting device,--tower and mobile cranes, boom trucks, overhead cranes, etc. The only documentation that has not been defined is Parts two through five, the training instructions unique to each type of lifting device and the regional regulatory or governing body that stipulates the criteria required for registration or certification for drivers/operators.

Conclusion

I'd like to conclude with a brief discussion of the All Canadian Training Institute Inc. (ACTI) which provides licensing of "Train-The-Trainer" programs for "Crane Operator and Supervisor Safety Training" that is annually audited and verified by a professional Engineer who is an industry expert. The purpose of the audit is to ensure that all material content complies with CSA B167, ASME B30 series, CMAA, United States CFR 1910.179 and 1910.184, and ISO 9926-1, Training of Drivers. This annual audit also reduces responsibility of liability to ACTI, our instructors and our clients in the event of an incident or injury.

In addition, KOLO Holdings Inc. and ACTI have recently published a hoisting and rigging handbook written by Lisa and Kelly Olver which applies to any operation that recognizes the ISO 9926-1. Entitled KOLO'S HOISTING & RIGGING HANDBOOK (International Edition), the handbook was a finalist for the SafetyXChange "Saxcie" award for Best New Product. To learn more, see www.allcanadiantraining.com.

MEMBER REPLY
Company's Rights to Have a Representative at OSHA Interview of Employee

Two weeks ago, SafetyXChange published the second in a two-part series by lawyer, Amy Watkins, about how to prepare on-site staff to deal with OSHA/OHS inspectors who show up at your site to conduct a surprise inspection.

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QUESTION:

Ms. Watkins:

I am confused by the statement in your recent article that a company representative can be present while an employee is interviewed by an OSHA Compliance Officer. My training has always said that this was a privileged conversation between the CO and the employee. And at our last site inspection, the CO specifically stated that we were not allowed to be part of the conversation and repeatedly took employees of various subcontractors aside to interview them and take written statements. This was a focused inspection on fall protection. We are the controlling GC on a multi-employer site. The CO would not even let the direct supervisor of the questioned employees be present. Can you please help me understand the difference.

Scott Marsh
Manhattan Construction - Oklahoma Div.
Safety Engineer

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ANSWER

Scott:

Thanks for your question and for reading the column. You are correct that in many cases, OSHA interviews are conducted privately and are privileged. In general, a compliance officer has the right to conduct private interviews with non-managerial employees and nothing requires the agency to allow a company representative or the company's attorney to participate in the interview.

Employees may, however, ask that their own attorney or employee representative (typically a labor representative or a union shop steward) accompany them during the interview. See, OSHA Field Inspection Reference manual, Section 6, Chapter II (Inspection Procedures). In Reich v. Muth, 34 F.3d 240, 244 (4th Cir. 1994), the court upheld an employee's right to request its employer's counsel prior to an interview with OSHA.

Even though it is possible for an employee to request his or her employer's attorney (a company representative), OSHA frowns on it because of the potential for a conflict of interest.

I hope that this answers your question.

Amy Watkins

POP QUIZ - US

By Glenn Demby

What do the following states have in common? Hint: It has to do with OSHA.

• Alaska
• Arizona
• California
• Hawaii
• Indiana
• Iowa
• Kentucky
• Maryland
• Michigan
• Minnesota
• Nevada
• New Mexico
• North Carolina
• Oregon
• South Carolina
• Tennessee
• Utah
• Vermont
• Virginia
• Washington
• Wyoming

ANSWER

Each of these states are what’s known as “OSHA equivalents.” That means that they have received permission from OSHA to set and enforce their own state-specific health and safety standards rather than OSHA standards. OSHA grants equivalency to states whose standards are equivalent to or stricter than OSHA requirements.

POP QUIZ - CANADA

By Glenn Demby

Name That Province:

1. The only two provinces that don’t require employers to establish a Joint Health and Safety Committee (unless the government directly orders them to):
2. The only province that specifically bans “psychological harassment” in its OHS regulations:
3. The only province that bans the use of handheld cell phones by drivers:
4. The only two provinces where the OHS laws don’t cover agricultural operations:
5. The only province ever to prosecute a company’s safety director for a safety violation committed by the company:

ANSWERS:

1. Alberta and Quebec
2. Quebec
3. Newfoundland
4. Alberta and Prince Edward Island
5. Nova Scotia

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