This article is based on a panel discussion on hazard assessment held July 13 at the CONVEY ‘21 conference in Omaha, NE.
Panelists included: Joe Mlynek, content creation expert, Safety Made Simple, Port Clinton, OH; Jim Nolte, safety director-environmental services, Wisconsin Agri-Business Association, Madison, WI; and Terry Wright, EHS senior specialist, Cargill, Parker, SD.
The session was moderated by Jim Seibert, director-safety, education, and training for the National Grain and Feed Association, Arlington, VA.
When to Perform Hazard Assessments
Jim Nolte: You want hazard assessments to be proactive rather than reactive to a major incident or injury. Therefore, hazard assessments should be a big part of your company’s safety program and ought to be performed on a regular basis to stay ahead of any risks or hazards.
Joe Mlynek: Hazard assessments should be performed not during the off-season, when you have more time. Rather, they should be done during the times of year that your facility is operating at peak efficiency.
Harvest often is a time where safety takes a backseat to operations, but it’s the time of year when safety is most important.
A key goal of hazard assessment is to capture an accurate snapshot of a standard day’s operations, so avoid having facilities spend too much time preparing for the assessment. Sure they want to put their best foot forward, but it’s important to see things as they are on a typical day.
Terry Wright: You should perform a hazard assessment any time you have a change in operations, such as introducing a new piece of equipment or, for example, changing the way you load railcars. Think proactively about the potential effects from making a change to the facility. Consider “How am I going to access the equipment to perform maintenance safely?” and “How should I train my team to be safe and successful handling the change(s)?”
Nolte: By performing hazard assessment during the planning stage of a project, rather than after it has been completed, you will save so much time and money. It’s obviously a lot easier to make changes to the design of a system before it has been implemented.
Establishing Goals for an Audit
Wright: When I visit a facility for a hazard assessment, I like to target a small area. This allows me to take my time and be thorough. If I’m trying to walk around the entire facility in a day, it’s possible that I’ll miss some crucial details or skim over something.
Mlynek: Define why you are performing a hazard assessment, because the reasons can vary greatly. Are you just trying to maintain regulatory compliance, or are you wanting to audit your company’s established protocols? Maybe you just want another set of eyes to spot any problem areas.
To put it as simply as possible: The purpose of a hazard assessment is to drive as much exposure out of the workplace as possible. If you are successful in eliminating exposure, you’ll significantly reduce the likelihood of injury, property damage, etc.
I consider exposure to be the intersection of a hazard and a person. That’s why just walking around a facility looking for hazards isn’t enough. You have to consider both variables – talk to the workers to hear their thoughts on the processes, systems, and protocols in place. Workers will have different perspectives from safety managers, and there’s a lot of value in that.
Nolte: The majority of my clients are small, mom-and-pop grain companies. When they ask me to come out for a hazard assessment, they are typically interested in just making sure they are compliant, but that’s the bare minimum, and it’s very easy to achieve. I try to explain that there’s much more to safety than just being in compliance. You can be compliant with every regulation but still have significant hazards present at your facilities.
I encourage clients to go deeper, to look at things like best practices, assessing employee exposure, and evaluating protocols, among others.
Wright: When an auditor finishes a hazard assessment of your facility and hands you a report with 50 items for you to address, it can be very overwhelming, especially considering you still have the burden of running the facility. I recommend evaluating the risks with your team to determine what needs to be addressed first.
Mlynek: I think it is very important to quantify risk in some manner, whether by using a matrix or relying on personal knowledge and experience – I use the latter method.
In ranking hazards, I use Roman numerals:
• I – high risk.
• II – moderate risk.
• III – low risk.
When I work with a new client, regardless of the company’s size or the existing safety programs, the first question I ask is, “What are the things here that could kill somebody?” The answer dictates where we start.
Value of Outside Assistance
Wright: It is so valuable to have a fresh set of eyes to assist with a hazard assessment. People get so used to their environment that you can walk by a hazard hundreds of times and go blind to the problem. Your risk tolerance builds to a point where you don’t consider a hazard to be a hazard.
Mlynek: The value of a second set of eyes is one of the big reasons outside safety consultants exist. But it doesn’t have to just be a consultant. Anyone can add something to the equation by lending his or her unique experiences and perspectives. That’s the beauty of having someone else involved.
The right way to look at hazard assessment is to consider it a teaching opportunity. I like to teach employees about how to find hazards so that they can look out for them daily, and they’re not relying on a hazard assessment once or twice a year to keep them safe. I also like to teach the Hierarchy of Controls, so that each employee has the ability to evaluate a hazard and determine the best way to address the problem. (Editor’s note: For Joe Mlynek’s Grain Journal safety column that explains the Hierarchy of Controls, go to grainnet.com/HOC.)
Wright: When you show employees that you care about their safety, they’ll be honest with you. They’ll be comfortable telling you if things are unsafe. If they inform you of a hazard and you address it, it goes a long way toward building trust.
Mlynek: I was speaking with a client recently who said, “We’re really good at conditions but not so good at conversations.” If you really want to determine exposure at your facility, employee interviews are the best tool. My favorite questions to ask an employee are, “What scares you about working here?” and “Is there a particular task you do that makes you nervous?” If you don’t ask these questions, you’ll never find the exposure; you can’t see it by doing a visual inspection.
Nolte: I like to stay in touch with facility managers to know what’s going on operationally, because I want to watch them work. There’s a lot of value there.
There’s also a lot of value in employee interviews. I’ve been doing this job for a long time, and the answers you get from the managers are totally different from the ones you get from the frontline workers. You can really uncover a lot of good information with employee interviews that you couldn’t get any other way.
Tracking and Documentation
Wright: When we find and address a hazard, we’ll conduct a root cause analysis. Information is recorded about how the hazard arose and what measures and/or controls and measures were put in place to mitigate the hazard. If we did a root cause analysis at Site A, we’ll share the findings with Site B and Site C so they can check their respective facility for the relevant hazard.
Mlynek: When I worked on the corporate side, we were encouraged to report hazards as near-misses so that they would be tracked. A near-miss can be many things – it doesn’t just have to be an incident.
- Tucker Scharfenberg, managing editor