OSHA Director David Michaels has responded to PMPA’s letter challenging several aspects of the OSHA  March 12, 2012 Memorandum  on Employer Safety Incentive and Disincentive Policies and Practices.  

No incentives that dissuade employees from reporting injuries!

PMPA felt that the guidance document removed employer authorities  to use safety incentives and tools  (such as discipline for failure to report injuries) to assure that employers could meet their obligations to maintain a safe workplace.  We challenged the memorandum in a letter to Director Michaels on April 18, 2012.

Director Michaels replied with a letter July 30, 2012, in which he “whole-heartedly agrees” with the use of incentives  to encourage positive behaviors and that OSHA “recognizes the employers’ legitimate interest in establishing procedures for receiving and responding to reports of injuries and nothing in the memo is intended to undermine that interest.”

Employer’s rights to discipline  and offer limited incentives are maintained.

However, Director Michaels maintains that  “Programs that give awards based on an employee or work unit not having any reported injuries are likely to have the reverse effect of incentivizing workers to simply not report their injuries. When injuries are not reported, as noted above, employers are without information that will help them protect their other employees and insure the injured employee receives appropriate treatment. In programs that penalize an entire workgroup because a single member reports an injury, the effect may be magnified because workers are often especially reluctant  to report an injury if the that report will have a negative effect on their colleagues as well as themselves. In addition, if the employer fails to record an injury because the employee does not report it, the employer is in violation of OSHA’s recordkeeping requirements.”

Use of affirmative incentives for achieving safety goals is likely to be targeted by OSHA as discriminatory unless it can be shown that the awards do not dissuade personnel from reporting injuries.

Bottom Line: Employers may continue to discipline employees who fail to report injuries appropriately.  Positive incentives for safety performance remain targeted by OSHA as potentially discriminatory and dissuasive of reporting injuries.

PMPA has prepared a one page summary of the Director’s comments.

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This post inspired by a comment from John at HyTek Manufacturing  in the Chicago suburbs who commented on our post The Most Important Tool.

What is the most important job in a company? In any organization?

What is absolutely the one thing that truly determines organizational success?

Ford says Quality is Job 1…

Is it Supervision? Operations? Accounting? Purchasing?

Each of these are core competencies without which a company can struggle and ultimately fail.

But what is the most important Job for the organization? Let me quote John:

“The strongest department or skill a company can have is the hiring department. Getting the right person for the job is the majority of the task. The most successful companies always hire the best people for the job. Ones that think and contribute, not just punch in and punch out thinking.”

I think John has this right.  Having the right people is key for any organization. After all the organization is those people and their attitudes, knowledge and abilities as demonstrated by their performance.

Thanks John, for leading this conversation.

But I would expand it just a bit.

The most important job in a company is the selection of employees, suppliers, and customers.

A failure at any of these spells trouble in operations, production, and sales.

What do you think about this?

What is the most important job at your company?

Photo credit

OSHA Memorandum on Safety

Incentive Disincentive Policies – Update

Tuesday August 07, 2012

 

OSHA Director David Michaels has responded to PMPA’s letter challenging several aspects of the OSHA March 12, 2012 Memorandum on Employer Safety Incentive and Disincentive Policies and Practices. Link here: http://www.osha.gov/as/opa/whistleblowermemo.html

PMPA felt that the guidance document removed employer authorities and tools to assure they could meet their obligations to maintain a safe workplace. PMPA has summarized the Director’s comments. Employer’s rights to discipline and offer incentives are maintained. Positive Incentives for safety performance remain targeted by OSHA as potentially discriminatory and dissuasive of reporting injuries. Links to all documents are provided. For further information contact Miles Free gro.apmp@eerfselim.

 

Miles Free Letter 18 April 2012

David Michaels Letter 30 July 2012

OSHA Memorandum on Safety Incentive Disincentive Policies – Update

 

 

 

 

 

 

 

OSHA Memorandum on Safety

Incentive Disincentive Policies – Update

Tuesday August 07, 2012

 

OSHA Director David Michaels has responded to PMPA’s letter challenging several aspects of the OSHA March 12, 2012 Memorandum on Employer Safety Incentive and Disincentive Policies and Practices. Link here: http://www.osha.gov/as/opa/whistleblowermemo.html

PMPA felt that the guidance document removed employer authorities and tools to assure they could meet their obligations to maintain a safe workplace. PMPA has summarized the Director’s comments. Employer’s rights to discipline and offer incentives are maintained. Positive Incentives for safety performance remain targeted by OSHA as potentially discriminatory and dissuasive of reporting injuries. Links to all documents are provided. For further information contact Miles Free gro.apmp@eerfselim.

 

Miles Free Letter 18 April 2012

David Michaels Letter 30 July 2012

OSHA Memorandum on Safety Incentive Disincentive Policies – Update

 

 

 

 

 

 

 

A new OSHA Quick Card provides guidance to minimize employee exposure to mercury when cleaning up a broken fluoresecent light.

I think we have all heard the urban legends about broken mercury  thermometers being cause of school evacuations that turn out to be true stories of overreaction.

And that the EPA ‘s draconian procedures require hazmat suits (Not true- at least the part about needing a Hazmat suit). There is nothing about Hazmat suits in their EPA CLEAN UP BROKEN CFL INSTRUCTION  (Although one Maine couple got some bad advice that cost them over $2000 for the cleanup of a single broken CFL bulb.)

And the MSDS sheet sure can put the fear into you if you don’t understand dosing quantities, air volumes and circulation,  and exposure.

So we were pleased to find that OSHA has actually published a quick card to protect workers and companies from bad advice and give authoritative guidance on reducing the risks from broken mercury containing fluorescent bulbs and tubes.

Official common-sense, non-hysterical guidance for cleaning up a broken fluorescent bulb. Whew!

Safe Cleanup of Broken Fluorescent Bulbs

  • Notify workers and tell them to stay away from the area.
  • Open any windows and doors to air out the room.
  • Do not use a broom or vacuum cleaner unless the vacuum cleaner is specifically designed to collect mercury.
  • Wear appropriate disposable chemical-resistant gloves.
  • Use a commercial mercury spill kit if available, or scoop up pieces of glass and powder with stiff paper or cardboard to avoid contact with the broken glass.
  • Use sticky tape to pick up any remaining pieces of glass.
  • Wipe down hard floors with a damp paper towel.
  • Place all pieces of glass and cleanup materials in a sealable plastic bag or a glass jar with a lid.
  • Wash your hands thoroughly after cleanup.
Grainger sells mercury spill kits that look like they contain most of what OSHA”s guidance says you need.

Myself, I’d put the debris collected in a metal paint can type of container. Why put the hazardous debris in a plastic bag which will not contain the mercury vapors? Why put it in another easily breakable glass jar? Metal can is safer.

Maybe it has something to do with recycling?

This won’t break if it’s dropped. Hmmm?

Disambiguation alert: Don’t confuse this quick card with the fact sheet which is specifically for people working in the fluorescent disposal industry.

No special precautions needed if you encounter one of these.

Paint can photo

Mercury Record

In July, the European ISM  manufacturing index has now fallen over 12 consecutive months to hit a 37-month low. The  rates of  decline  in manufacturing in Germany, France and Spain were “either at or close to the steepest since mid-2009.” Reporting by Industry Week

More than temporary doldrums…

Graph by Newswhip

In July, the U.S. summary “Purchasing Managers’ Index (PMI)” from the Institute for Supply Management (ISM) inched up 0.1  points for July, to a level of 49.8. In plain English, “Industrial activity at the nation’s factories remained stalled in July” according to Dr. Ken Mayland, PMPA’s retained Economist.

In July, business hiring slowed while still growing, according to the ADP payrolls report,  adding yet another mixed signal to the conversation. ADP said that private-sector employment rose by 163,000 in July, slowing from a downwardly revised June gain of 172,000. The  increase in jobs for July beat most analyst predictions which were in the 125,000 area.

In July,”in China and South Korea  The Purchasing Managers’ Index in China unexpectedly fell to 50.1 in July, the weakest in eight months, from 50.2 in June, a government report showed today. South Korea’s exports slid by more than double the amount forecast by analysts and inflation moderated to a 12-year low.” –Bloomberg

Below 50, manufacturing is contracting…

July is a little early to be expecting a push from Santa…

Stalled

It’s like manufacturing, except without us actually making anything.

According to the Federal Register Vol. 74, No. 4 / Wednesday, January 7, 2009 / Notices:

C. Factoryless Goods Producers

The factoryless goods producer outsources all of the transformation steps that traditionally have been considered manufacturing, but undertakes all of the entrepreneurial steps and arranges for all required capital, labor, and material inputs required to make a good.

Characteristics of factoryless goods producers include:

  • Does not perform transformation activities;
  • Contracts with manufacturing service provider to perform transformation activities to its specifications;
  • Owns rights to the intellectual property or design (whether independently developed or otherwise acquired) of the final manufactured product;
  • Owns the manufactured product it contracted another establishment to produce;
  • Controls and facilitates the production process; and
  • Sells the final product.

As noted in NAICS United States 2007, units that perform chemical, physical, or mechanical transformation of inputs into new outputs are usually classified in manufacturing.

Speaking of Precision:  Nothing in those bullet points have anything at all to do with actually manufacturing. So why would we call a company that doesn’t transform  inputs a manufacturer?

Federal Register: Alternatively, these units could be classified within the wholesale trade sector, because they purchase critical input transformation services from others and are more like a traditional wholesaler who buys and sells goods.

SOP: That’s the ticket!

FR: Classification of factoryless goods producers to either manufacturing or wholesale trade will affect current statistical programs and the estimates that they produce.

SOP: You betcha! Imagine not adding any workers to the manufacturing sector, but now counting all those billions of dollars worth of outsourced goods from China now as somehow magically being “manufactured” here in the U.S. Our worker productivity numbers would soar.

Except it wouldn’t.

Factoryless Goods Producers. Not manufacturing at a location near you.