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Where Would You Like to Work?

It doesn't matter what the emergency response team or individual is called. The assigned function defines the intent, and the appropriate rules apply.

What follows are the stories of two fictitious companies and how the management of each responded to an emergency incident.

The first story involves a facility manufacturing intermediate chemicals for other production facilities throughout the country. Located in a rural part of the state, in a community protected by a volunteer fire department and ambulance service, it uses a long list of hazardous materials, both flammable and toxic, in its operations. The facility is a large-scale producer with open-air chemical reactors and equipment such as distillation towers, pumps, and compressors. Some buildings and equipment are as high as 50 feet.

Because of the size of the community, public resources are limited for funding emergency services. The local fire department has advised the management at this company that it will "assist in emergencies but does not have the training or resources for any "specialized" emergency response. Company management has changed a number of times over the years; each new management team implemented new programs for safety and personnel management and often changed previous plans. This has led to low-level grumbling and confusion among employees. Emergency plans "exist" but are not practiced or updated with any consistency.

One afternoon, an employee working on some controls at the top of a distillation tower feels queasy -- apparently, he was suffering a mild heart attack. He tells fellow employees he didn't think he could move far, let alone get off the tower. How does the management team summon help? The on-site company nurse is called and responds but cannot climb the tower to help. Although emergency fire and ambulance services are called and respond, they are not trained to handle high-angle rescue -- in fact, they don't even have the equipment to do so. At the worst possible time, management realizes it has overlooked a critical aspect of safety management at this facility.

What happens to the employees who suffered a heart attack 50 feet above the ground? Up arrival, the fire department again tells management it lacks the equipment or training to bring him down. The department calls in mutual aid to remove the man, who may not survive because so much time has elapsed.

In addition to being cited by OSHA, this company may face an expensive lawsuit by the man's family.

The second company is also in the high-hazard chemical business. It operates a similar facility, using much of the same processing equipment, in a rural location beside a river. Much of what the plant receives arrives by ship. It is served by similar local emergency response arrangements. While this company's management has changed from time to time, its approach to safety has been consistent.

A similar situation, with a twist, occurs aboard a ship docked at this plant. A contractor hired by the captain to repair equipment in the communications room accidentally comes in contact with a high-power electrical feed and suffers a serious injury. The communications room is seven levels below the ship's main deck. The lower levels of the ship are a maze, and the communications room is a designated confined space.

The facility's management has had consistent emergency action plans for years. The plans are practiced routinely and cover all incidents likely to occur there. Some workers complain about the frequency, but management enforces consistent emergency response training. Management also issues operational requirements to the various shipping companies and other contractors; the instructions are part of the contract it maintains with shipping companies and outside contractors. One requirement for a ship in the port states that if a ship is docked at the site and any work is to be done on the ship, the ship's captain is responsible for discussing the work with plant management. In this case, facility management was notified and assigned a properly trained and outfitted team from the facility to be on the ship in the area of the repairs as they were being made.

When the incident occurs, positive communications and proper training allow the team to respond quickly to ensure the injured technician is stabilized and then removed to a waiting ambulance. From the occurrence of the incident until the worker is inside the ambulance, just four and a half minutes elapse, and he is in the local hospital's intensive care unit within nine minutes.

This worker may walk out of the hospital in a couple of weeks. An ensuing OSHA investigation may find no fault with management for the way the response was handled. In fact, the company might be commended.

Management's Role in Emergency Response
There have been many revisions and additions to OSHA's workplace safety standards during its 40-year history. Management still is required to provide a safe workplace for all, and this extends to contractors who work at any established manufacturing or commercial site. OSHA rules do not necessarily tell management how to achieve a safe facility. The federal agency requires that the intent of creating a safe workplace is satisfied but leaves it to management as to how to achieve this objective.

One of the most basic misunderstandings about OSHA's standards occurred early in their application. 29 CFR 1910 subpart L lists the requirements for firefighting in the workplace. If management created or assigned personnel to a team to fight a fire in a facility, it was termed a "fire brigade." This term resonates back to the days of textile mills and similar facilities where there was no or very limited public fire service; the "public" fire service often worked in the mill.

A "fire brigade" is defined in 1910.155(c)(18) as follows: " 'Fire brigade' (private fire department, industrial fire department) means an organized group of employees who are knowledgeable, trained, and skilled in at least basic fire fighting operations."

Early on, managers of some organizations used different terms to identify their "fire brigades." One such term was "emergency response team." Some thought if the term "fire brigade" were not used, the requirements of 1910 subpart L did not apply to them, but nothing was further from the truth. It doesn't matter what the team or individual is called; the assigned function defines the intent, and the appropriate rules apply.

In fact, OSHA does not put the burden of firefighting on management. Management can simply state it will never have an employee fight a fire in the workplace, or perform work in confined spaces, or be assigned to the high-angle rescue team. But, in the case of a fire, for example, there has to be a plan in place to ensure all employees safely escape the hazard the fire creates, even if the facility is allowed to burn to the ground.

The plan is the key because it provides the assignments for the employees on site, even if their assignment is to evacuate. The plan is the basis for proper training. OSHA standards do not tell management how to train employees, but its workplace safety standards are meant to ensure that any employee acting in an emergency fashion is properly trained and outfitted as necessary to safely perform the emergency operation. Emergency assignments take many shapes, from the mundane to the highly technical.

For example, in the scenario involving the ship, one person can be assigned through the emergency plan to act as the person responsible for escorting the public ambulance service to the site of the emergency. The assignment may be as simple as immediately going to the facility gate or other established point upon notification of the emergency and waiting. That's it; after the ambulance service is in place per the plan, he or she is done. The training commensurate with this activity has to be defined and the individual trained to perform this function. The rules for training are easy to understand, even though the task may be extremely tough, such as fighting a fire in the workplace or performing high-angle rescue.

Many organizations and individuals can assist in training or educating employees for site-specific functions. The simplest function for which employees require training may be evacuation or informing people to stay in place and wait for further instructions. More intense training will involve the very items involved in the fictitious incidents discussed early in this article. High-angle rescue and confined space training can be extremely intense and require high levels of specific training.

Management must determine how detailed its emergency response will be and then establish the objectives by conducting a site-specific, employee-specific analysis. It is resource management of a different kind than some management teams are used to performing -- especially if the management team believes its only responsibilities are production and profitability. If the analysis indicates the right people to perform a function are not available, and so a contractor is employed for this function, that becomes the plan. If that contractor does not exist or can't get there within a time that is satisfactory, then it is up to management to find the solution. The company may have to hire the correct people and ensure they are properly trained and equipped to handle the defined emergency function.

OSHA is not concerned with how workplace safety in every facility is obtained and maintained, but it is concerned that every individual is safe in the workplace. Training and practice are the cornerstones of workplace safety, especially in an emergency. Given the choice in this article, where would you like to work?

OH&S Digital Edition

  • OHS Magazine Digital Edition - June 2020

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