Design the Hazards Away Increased Fall Protection via Sustainable Safety Principles BY MICHAEL C. WRIGHT, JEREMY T. DEASON AND MARK E. WILLIAMS History has shown that just realizing something needs to be done is not the fix; you have to be willing to reject anything that falls short. A perfect example of this is Factory Mutual insurance company and the roofing industry. When the insurer realized that roofing standards were inadequate, they developed their own standards and demanded compliance from those with whom they did business with. Those standards became globally recognized, were incorporated into the American Society of Civil Engineers (ASCE) standards and have become adopted into the building codes. We have the same ability to control our industry. Owners, employers and safety professionals must contractually require design professionals to learn to incorporate Sustainable Safety design principles into every project or facility. Once preplanning to design out the hazards is implemented at the design phase, the direct result will be a drastic reduction in serious injuries. Owners rely on designers, with little or no training on addressing fall hazards, to provide a safe and compliant design. The design professionals, in turn, rely on building design code requirements for guidance on the design, while employers rely on OSHA regulations for constructing, operating and maintenance requirements. Yet, accidents still occur. Building design codes are typically the result of the study of a building’s performance and failures in an effort to establish why a building failed. After a study has been accomplished, the findings and recommendations are presented to the building code committee in order to establish safer buildings in the future. The intent of these well-established and history-based building code requirements is to set the standard of care for design professionals. However, it must be remembered that design professionals are generally focused on the safe performance of a building (in other words, how a building resists the applied forces from natural occurrences or manmade applied forces) and not on the safety of each individual worker. While owners assume design professionals are providing a “safe” product, employers still have an overall misunderstanding of fall protection methods. For the construction industry and general industry, the need for fall protection programs is still one of the most underdeveloped aspects of the health and safety divisions of many firms. OSHA was created to establish employer responsibilities for the construction industry, general industry and maritime industry, and to create the minimum regulation for the reasonable care of that industry. The employer must be proactive about incorporating current and evolving safety solutions, requirements and procedures into the regular and upcoming processes of the facility in order to ensure the latest safety requirements are met and that the safety of its employees is preserved. However, if the design professionals haven’t done their due care in the design phase, the road to obtaining such will be much longer. Design professionals have the opportunity to create a safer workplace, to stop creating fall hazards and to reduce the long-term lifecycle cost for the facility by designing out the hazards. Preplanning to design out the hazard will often lead to modifications of a design professional’s design methods and/or a building contractor’s means and methods of construction. OSHA’s Subpart M preamble quotes from Cleveland Consol. v. OSHRC, 649 F.2d 1160, 1166 (5th Cir. 1981): “The duty to consider alternative methods of construction which permits compliance with the regulation is merely a corollary of the duty to comply.” Since the design professionals don’t do proper and adequate preplanning to eliminate the fall hazards during the design of the building, then the contractors don’t modify their traditional means and methods to accommodate and, thus, fall hazards are most likely present in the construction activities. The goal of design professional, owners and employers must be to eliminates the worker’s risk of falling. It is more reliable to depend on design professionals to “design out hazards” by means of engineering design or “automatic” hazard controls than to depend on the behavior of workers and supervisors. Design professionals must first be trained to understand the actual nature of the hazard( s). A specific definition of the hazard(s) provides the design professional with a basis to create the proper methodology for planning, identifying, designing, evaluating and controlling in order to ensure proper design (i.e., inherently safer designs). A hazard is an unsafe physical condition, an unsafe process, a design defect, an unsafe design methodology or the foreseeable misuse of equipment or facilities that can and/or will result in injury or death if encountered by workers. The owners, employers and safety professionals who are willing to require this “out of the box way of thinking” for their building projects will find the direct results to be a safer building to construct and operate. In order to eliminate the hazards in the design of the building, the design professional must acknowledge the first and overriding priority of designing out the hazards. Owners, employers and safety professionals have a responsibility to require that the designing out and physical elimination of hazards override the building beauty. Proper safety solutions must be designed into the project in order for the building to function properly and not depend upon human safety performance. In the past, tools such as “critical path methodology” were mainly used in the construction industry to include the subcontractors’ work activities and where more contractors could overlap their work activities to decrease the total completion time of the project. Other tools, such as “the hierarchy of control,” have been used by safety professionals to select sustainable safety solutions for hazard abatement in existing facilities. Coming out of the box and using the same tools is crucial to the design professional understanding where foreseeable hazards will or may occur during the same construction workplace activities. Once these foreseeable hazards are identified, the design professional will be able to properly eliminate or control them. The objective of owners, employers and safety professionals should be to require that design professionals develop and/or expand their existing engineering principles to a broader level of safety hazard identification and produce safer design solutions. To complete this, the following basic Sustainable Safety design principles that were first developed by the military/aerospace industry and have been incorporated by the US Army Corps of Engineers and the US Navy should be adopted: • Eliminate the hazard if possible; • Provide engineering design solutions to prevent the worker from making contact with the hazard; • Provide additional safety factors to minimize the hazard; • Provide redundancy to confine the hazard. In order for the hazards to be eliminated, the entire building construction process and maintenance process must be considered. Design professionals have a duty to design in safety for each worker into every phase of every building project —from construction to maintenance. Owners, employers and safety professionals have the ability to stop paying for hazards by requiring that design professionals “design out hazards” with the same professional attention given to the technical safety detail as they would to their designing or planning of the building project. FSM Michael C. Wright, PE, CSP, CPE, president; Jeremy Deason, PE , director of Engineering; and Mark E. Williams, Director of Training, are part of the consulting team for Safety through Engineering, Inc., a pioneer in the integration of engineering and “Sustainable Safety” (Reg. U.S. Pat & TM Off.). All three are actively involved on ANSI and ASTM committees. Contact markwilliams@ste4u.com. or go to www.ste4u.com.