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MODEL NOTICE
Here's a Model Form showing you an appropriate way to reject a safety committee recommendation that you consider unrealistic. This form is based on a hypothetical situation in which a safety committee recommends adoption of a new lockout standard from a standards organization like CSA, which is very expensive to implement. You'll obviously have to adopt the form based on the facts of your own situation. The important thing to take from this form, though, aren't the substantive details but the approach of explaining how you deliberated over a recommendation, why you rejected it and proposing more suitable alternatives. Create a similar document when deciding not to implement a safety measure suggested by an outside consultant or adopt a voluntary standard approved by a non-governmental standards organization like CSA.
LOCKOUT
To: The members of the Health and Safety Committee
From: John Doe, Health & Safety Director on behalf of the management of XYZ Company
Date: August 1, 2008
Re: Response to Committee's recommendation regarding the adoption of lockout safety measures
A. BACKGROUND
The XYZ Company Health and Safety Committee ("Committee") held its monthly meeting on July 11. The Committee recommended that XYZ Company make a commitment to fully implement the new Canadian Standard Association, CSA Z460 Control of Hazardous Energy—Lockout & Other Methods by July 31, 2009 at the latest.
B. NOTICE OF DECISION
I and the other members of XYZ Company management wish to thank the Committee for its recommendation. However, after careful deliberation, we have decided not to adopt the recommendation. The purpose of this notice is threefold:
- To describe the deliberations that led to this decision;
- To set forth the reasons for the decision; and
- To reassure the members of the Committee that we take the safety concerns voiced in the recommendation very seriously and describe the efforts the Company is taking to address those concerns.
C. MANAGEMENT DELIBERATIONS
I received the Committee's report, including the recommendation of the adoption of CSA Z460, on July 13. On July 14, I sent a memo to members of management notifying them of the recommendation and expressing my views on its adoption. I attached a copy of CSA Z460 and a summary of its provisions to my memo. A copy was sent to the following officers:
- Jane Roe, CEO
Bill Boe, CFO
Moe Joe, COO
Don Ho, VP Engineering
Joe Blow, VP Maintenance Operations
Flo Crow, Dir, Plant Operations
On July 21, a management meeting was held at which all of the above individuals were present. Each officer stated that he or she had looked at the standard and read my summary and thus was familiar with the Standard's contents. We then spent two hours discussing whether to recommend adoption of the Committee's recommendation to the XYZ Board of Directors. When the discussion ended, we voted to reject the recommendation.
D. REASONS FOR THE DECISION
Management made this decision because implementing CSA Z460 would force the Company to take measures that are not reasonable or appropriate given its current situation.
- Excessive Costs of Retrofitting: Last year, the XYZ Board of Directors approved a new capital improvement program calling for the replacement of machinery by the end of 2008. CSA Z460 requires retrofitting current machinery with controls. Retrofitting the machinery would cost more than replacing it under the Board's plan. Adding to the cost and delays, each piece of machinery would require a thorough engineering evaluation before and after retrofitting. Thus implementing CSA Z460 at this time would not only delay implementation of the Board's plan but make it financially unfeasible.
- Expensive and Non Cost-Effective Training. Implementing CSA Z460 would also require the complete re-training of 90 percent of the XYZ workforce. Employees would then have to go through the entire retraining process again when new machinery is put into operation in 2009.
E. AVAILABILITY OF LESS COSTLY ALTERNATIVES
The management of XYZ Company fully supports the Committee's goals and understands the importance of lockout and the need to protect personnel against the inadvertent startup of machines, equipment or processes. However, management is also confident that its current policies and systems will accomplish the same goals. Rather than implement CSA Z460, the company should stay the course and replace all machinery by 2009 in accordance with the Board's plan.
In support of this position, management wishes to point out that:
- The new machinery will be equipped with state-of-the-art power controls that will achieve essentially the same level of lockout protection as retrofitting old machines under CSA Z460;
- XYZ's current lockout procedures and safeguards have proven effective. There hasn't been an energization incident at any XYZ facility for more than three years; and
- Management is prepared to consider additional improvements in the lockout system in the interim period before 2009 when machinery is replaced in accordance with the Board's plan.
F. CONCLUSION
Management wishes to thank the Committee for its recommendation and express support for its work in making XYZ Company workers the best protected in the industry.
John Doe
Safety Director
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[...] you engaged in such process. A central part of documentation is to create a rejection notice. The model language in the TOOLS section of SafetyXChange is an example of how to notify a safety committee that you’re rejecting a [...]