Scotomas: What We Don't See in Vision Protection
We've focused mostly on regulations and PPE--things that are usually pretty visible. Let's move on and look at reducing the need for PPE.
A scotoma is the medical term for a blind spot. Various definitions are out there; most explain that a scotoma is a darker or dimmer spot within a person's field of vision, and the spot is surrounded by pretty much normal vision. In psychology, scotoma is often used to describe a trait or behavior an affected person does not see.
Protecting workers' vision is a pretty straightforward task in a lot of ways, but do scotomas keep us from seeing ways to promote eye safety? Eye safety articles and statistics are all over the place. I won't state that more than 1,000 eye injuries happen at work in the United States every day or that 90 percent of the eye injuries could have been prevented through the use of proper safety eyewear. I won't repeat that safety glasses have to meet ANSI Z87 standards. I won't dig up the fact that injuries are caused by flying debris or particles, chemical splashes, etc. There's no need to mention that there are more user-friendly eye protection equipment choices out there than ever before. Choices abound regarding styles, fit, and applications.(Well, I guess I did bring up all that stuff, but these are the things that live in the field of vision we could call normal vision.)
OSHA rules are pretty specific and easy to see. Look at 29 CFR 1910.132 and 1926.102 for details and actually hold your facility's actual, real-world, happening-right-this-minute-if-you-walk-out-in-the-aisle-now conditions up to them for comparison. The OSHA standards are the minimum steps we must take to be in compliance, but they provide great templates from which to base our safety activities if we look a little deeper at them. Let's examine a few paragraphs, quickly, to see whether we can get find scotomas there that we can eliminate in order to improve our eye safety. (I am purposely skipping around, picking paragraphs to use as examples only. Be sure to look at the standards and get SMART about each point; more about SMART in a minute.)
The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer shall: (The standard then goes on.)
Déjà vu all over again . . . but if you've done it, prove it.
The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment.
Doing the steps in the preceding paragraph would be pretty strong proof of complying with 1910.132(d)(1).
Defective and damaged equipment. Defective or damaged personal protective equipment shall not be used.
Do you have written instructions for employees to use to define defective or damaged?
The employer shall provide training to each employee who is required by this section to use PPE. Each such employee shall be trained to know at least the following: (Read the standard for specifics.)
Is this documented in writing for all PPE? For each employee?
Each affected employee shall demonstrate an understanding of the training specified in paragraph (f)(1) of this section, and the ability to use PPE properly, before being allowed to perform work requiring the use of PPE.
Have you ever demonstrated your understanding of the training or your ability to use PPE properly? Do your employees actually do these steps? Are those activities documented? (Could be a scotoma here. . . .)
When the employer has reason to believe that any affected employee who has already been trained does not have the understanding and skill required by paragraph (f)(2) of this section, the employer shall retrain each such employee. Circumstances where retraining is required include, but are not limited to, situations where: (See the standard)
I'll bet you know at least one employee who has expensive prescription safety glasses, equipped with appropriate sideshields, who looks over the top of the glasses when engaged in conversations or when performing certain tasks. This could be a knowledge deficit or habit, either of which must be addressed.
The employer shall verify that each affected employee has received and understood the required training through a written certification that contains the name of each employee trained, the date(s) of training, and that identifies the subject of the certification.
Can you lay eyes on these written certifications? Are they current?
Going Beyond the Standards
Until now we've focused mostly on regulations and PPE--things that are usually pretty visible. Let's move on and look at reducing the need for PPE. Good safety practices say we have to eliminate hazards, if possible. Then we engineer hazards out, apply work practice controls, and, finally, use PPE. When you compare your efforts to 1910.132(d)(1), be sure all other control means have already been implemented before resorting to PPE.
Take a quick walk through your work site. Look at your drill presses and milling machines in particular. Do they have chip guards as required? Have you seen that before? There are some great makers of chip guards for this equipment out there whose products have almost no adverse impact on the speed and ease of using the equipment. These guards can supplement safety eyewear for additional safety.
What else do we not see when it comes to promoting eye safety? Employee engagement? Employee attitudes? Barriers to effective use of hazard control?
Some things to do to beyond the standards to promote vision protection:
- Do a gap analysis of your current situation. Define where you want your vision safety to be. Write down where it really is at present. Write down what you would have if you could wave your magic safety wand and get your dream program. Analyze and document your current status, then fix the gap.
- Use the tools you have already. Put your safety committee to work. State your vision and get the members to help make it a reality.
- Hold a training session on SMART goals for all employees and have each person write his or her own SMART goal on how they will protect their vision. SMART is an acronym that generally stands for actions that are: Specific, Measurable, Attainable, Realistic, Timely.
A quick Internet search for SMART goals will give you many excellent results for this concept, which is a portable, versatile tool with wide safety applicability. The act of thinking through a situation and putting it on paper is a great way for employees to internalize the training they have had. Awareness has to go way up after such an effort.
- Encourage employees to take their safety eyewear home and use it for chores and hobbies.
- Hold regular training sessions and include information regarding home eye safety. In fact, encourage employees to start educating their children, now, on eye safety issues. If they start early enough, kids will report to school labs and to jobs with a genuine awareness of vision protection practices.
- Provide care sheets, instructions, or manufacturer's literature with any eye protection that you issue.
- Have interested employees actually present eye safety training or hold tailgate/toolbox meetings. This can provide the new speaker an opportunity to develop his or her skills and can let other employees realize, "Hey, that's one of us up there!”
- Steal from Emergency Medical Services (EMS) and fire department training methodology; develop skill sheets to use in verifying that the employees' motor skills are adequate when addressing PPE. Have workers select proper PPE for their particular tasks. Get them to put it on and take it off correctly. Have them describe storage and maintenance requirements. Have them do hands-on demonstrations. Check the employees off and file the skill sheets.
- Provide training on eyewash stations and conduct drills. There is at least one version of the portable eyewash station in use that has a nice set of instructions in the recess where the user's head goes. It might be a good idea to move these instructions to the wall beside the unit; if an injured employee can't read the instructions and his head is in position for flushing, a helper won't be able to see the instructions, either. (Talk about a scotoma!)
- Provide safety glasses with bifocal lenses to the folks who have entered the phase in their lives (getting older) where they encounter presbyopia, the natural loss of visual clarity at close distances. Be careful the users don't use bifocals that are too strong. Have them leave room for more aging.
- Include vision health in you wellness program.
- Look at Prevent Blindness America's Wise Owl program and the new program it has launched for businesses, Healthy Eyes Vision Wellness Program.
- Remove barriers to getting PPE. If employees have to jump through a bunch of hoops and hear lectures about the cost of PPE, or justify why they need replacements, or wait in line, or go through their supervisor, or other things they perceive as deterrents, proper use will be a casualty.
Finally, a co-worker's scotoma may be very different from your scotoma. The blind spots may be in totally different places. Encourage open discussion of all safety issues so the VIEWpoints of all employees can FOCUS on the VISION of eye safety and help others SEE the light.
Enough of that, but I do wonder, what is the actual level of light, in lumens, of your shop? (Another scotoma?