The Danger of 'Rubber-Stamping' Specs

A significant number of advancements and alternatives often don't get considered because they weren't around when the original spec was generated.

DO you remember the days of the typewriter? Correction tape, carbon paper . . . the days when editing usually meant re-composing your thoughts once again from scratch. The word processing capabilities of the modern computer changed all of that forever, and for the better! However, the ease of today's "copy and paste" functions can sometimes make it too easy to duplicate past directions without visiting appropriate changes.

Consider the emergency equipment specification: Today, it's very easy to duplicate the specs provided in past requests for proposal, sometimes without consideration of changes with respect to the needs being addressed or advancements in the products available to address those needs.

From the manufacturers' perspective, "getting spec'd" is the name of the game. It’s what keeps us on our toes and ensures that innovations continue to flow. Advancements such as flow controls, diffused spray outlet heads, ADA (disabled worker) designs, and victim comfort features exist because of efforts to stay on the cutting edge of innovation. Likewise, from the specifiers' point of view, validating existing specs is critically important in ensuring the correct (read: state of the art) solutions are obtained. The spec validation process is also an ideal time to review your operation and make certain that changes in the business are reflected in the specifications you are issuing. There is an inherent danger in not re-assessing your needs and alternatives every time you initiate a new buying cycle.

The World's Oldest Spec?
A while back, I remember reading an article on the continuation of sometimes antiquated specs, simply because "that's the way it's always been done." It gave a great perspective on "legacy specs." As I recall, the story focused on the reason why railroad tracks are the width they are--the reason being that the dimension was a carryover from ancient horse-drawn chariots. Train tracks were standardized against the width of ruts made by chariots and other (later) horse-drawn wagons and buckboards, and it's been that way ever since.
While it's unlikely we would ever rip out train tracks to do it a better way, it begs the question: Are there specs that are followed over years and whole generations, simply because they were "right" at some far-distant earlier time? Are there better ways that are overlooked because the safe and easy way is to do it the way it was done the last time and the time before that?

While much in the safety arena is bound by regulations, there are still a significant number of advancements and alternatives that often don't get considered because they weren't around when the original spec was generated. Likewise, there are certain "accepted norms" that make little sense in the real world today. Consider the emergency shower and eyewash category: Manufacturers still sell several times as many eyewashes as eye/face washes, when for almost any application the eye and face wash is a superior solution at about the same price point. Why? "Because it's always been done that way!" And how about an advancement such as the availability of flow controls in emergency equipment? Flow controls ensure a smooth, consistent stream over the course of the full 15-minute use cycle. Even though they are a significant advancement, few specs actually reflect them as a requirement.

Or how about the color of emergency equipment? Even though most major industrial companies have adopted the use of standardized colors to depict hazards and assets (red: fire protection and response, yellow: caution and physical hazards, green: safety, first aid, and emergency showers and eyewash stations, etc.), many specs still do not reflect that requirement.

Perhaps the most glaring example of spec lag in emergency equipment deals with tempered water. Today, tempered water is a clearly stated ANSI requirement. Outlet water temperatures must be between a low of 60 degrees F and a high of 100 degrees F for the full 15-minute drench shower or eyewash irrigation cycle. Aside from being a compliance issue, the absence of tempered water also represents a significant potential legal risk. Imagine the impact of an injured worker short-cutting his or her emergency shower or eyewash regimen because the water was too cold to endure for 15 minutes. If that person could reasonably prove that he/she sustained a greater injury over time than would have occurred had the response system met the ANSI standard for tempered water and a 15-minute use cycle, most attorneys would have a field day. Yet only a small portion of companies have stepped up to add tempered water to their official specs. Why? We believe it is because the needed changes haven't been considered when issuing specs; this is the danger of a mostly automatic spec reissue!

Points to Consider Before Issuing an RFP
Before issuing an RFP, here are some points to consider:

1. Is your operation, in terms of overall size and the risks associated with the business, the same as it was when the spec was originally developed? If not, what has changed, and how could those changes best be addressed by additional emergency assets and/or placement changes?

2. What, if anything, has changed in terms of the regulations associated with providing emergency response to your employees since your current spec was developed? Remember the example of tempered water, and bear in mind that there are other significant changes to consider, as well.

3. What has happened to the "state of the art" in terms of products and features that might better address your needs and associated requirements? Product advancements among the more aggressive safety manufacturers occur with great frequency these days, which is a great thing for specifiers . . . if you are aware of them!

The point here is that specs should be critically reviewed at regular intervals to ensure they accurately reflect requirements that are up to date with technical advancement already made in the marketplace and that they challenge manufacturers to innovate, even in "mature product categories." Don't be afraid to ask, "What's new?" Likewise, don't be afraid to ask for something that doesn't yet exist. Some of our greatest advancements begin that way.

it's a good idea to get an outside opinion of the state of your equipment on an annual basis. Most emergency equipment manufacturers have programs to assist in this regard. Who better to provide the latest product information and share best practices from other facilities and operations? Also, that outside--third party--assessment is an ideal way to document your ANSI-required annual evaluation.

This article originally appeared in the July 2007 issue of Occupational Health & Safety.

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