Active shooter situations typically occur without warning and are over within 15 minutes. That’s a short window of opportunity to shelter in place and/or respond defensively. Being trained and prepared for the worst can help you better determine how to respond when faced with a real threat.
Keeping calm is critical in this situation. It is imperative that you be able to quickly assess your environment. Identify exits and evacuation routes. Determine the location of the shooter(s) and assess how many others are in the building. Depending on your position in the building and the layout of the structure, you should get to the nearest room and secure the door from the inside.
Your best option is always to evacuate, if possible. If evacuation is not an option, shelter in the most secure location available to you. Lock doors and hide beneath desks or behind heavy doors or furnishings that offer some protection. Barricade doors and windows with heavy furniture if time allows. Assess your surroundings and identify items in the room that can be thrown at the shooter or used defensively. You should only attempt to take action against the shooter if you are in imminent danger and have no other choice.
When police arrive on site, their primary task is to identify and immobilize the shooter or shooters. They must quickly assess the situation upon arrival. This includes processing the physical layout of the scene, placement of victims and perpetrators, and responding to rapidly changing conditions in real-time. Upon arrival, every person they encounter is a potential threat. You should stay in place until the police have issued an all-clear or emergency responders are able to assist you. Never rush the police upon arrival.
Plan for worst case scenarios in advance. Identify evacuation routes and potential shelter areas. Provide your staff with professional training. No one can predict when such an event will take place. Train your managers about the warning signs of potential violence by an employee. Every preventative step you can take is a step in the right direction.
Most businesses dread the thought of an OSHA inspection. Much of this dread may stem from misconceptions and lack of preparedness. Do yourself a favor by knowing how to respond before a compliance officer arrives at your door.
10 Things You Need to Know About OSHA Inspections
1. OSHA inspections are not random. Most inspections are the result of one of the
A. In response to a fatality or catastrophe;
B. In response to an employee complaint;
C. A “targeted” inspection, which is part of the national emphasis program (NEP) or local emphasis program (LEP); or
D. A result of an imminent danger observed by a compliance officer (commonly a fall from height or trenching exposure).
2. With few exceptions, OSHA inspections are not scheduled or pre‐announced. An OSHA compliance officer may arrive at your business unannounced, and will advise you of the nature of the inspection.
3. You do not have the right to refuse an inspection, but you do have the right to refuse entry to your property. Because your business is private property, you may refuse entry to the property and require OSHA to obtain a warrant in order to conduct their inspection.
4. You should always verify the credentials of the OSHA compliance officer. Are they from the proper jurisdiction governing your business (federal or state)? It is your responsibility to know which division has jurisdiction over your business.
5. There are three parts to every inspection:
A. Opening Conference
B. Walkthrough Inspection
C. Closing Conference
6. Once on site, OSHA’s Compliance, Safety, & Health Officers (CSHOs) have “line of sight” authority. If a hazard or condition is observable, it is citable. You determine the access route or path to the inspection area, even if that means taking the CSHO outside the front door, around the outer perimeter of a building, and into another entrance door with more direct access to the identified inspection area. You may control much of what the officer sees by limiting their access through the facility.
7. OSHA representatives will want to speak with your employees. Your employees have the right to speak with these officers freely, privately, and without fear of consequence or retaliation. Employees have the right to speak with CSHOs without management present, but may request the presence of a peer, a union officer, or another non‐management person. Your employee is not required to participate in any discussion, but you may not influence their decision.
8. OSHA has the right to view and obtain copies of your injury reporting logs (300, 301, 301A) while on‐site.
9. OSHA does not have the right to view or obtain copies of personnel files, inspection reports, or other internal documentation during the inspection visit. These documents may become discoverable at a later time, but the compliance officer does not have open access to your files and documentation during the inspection visit.
10. Your company should have a designated person to interact with OSHA and to respond to investigations and citations. Your staff should know who to contact on site if an OSHA compliance officer arrives, and know how to respond to an inspection request.
10 Steps to Outline Your OSHA Inspection Policy
An OSHA inspection response policy is worth its weight in gold. OSHA makes people nervous. Having a policy in place alleviates the pressure on your customer‐facing front office personnel and helps them remain calm and professional in the presence of an OSHA compliance officer.
At a minimum, your policy should include the following:
1. An OSHA compliance officer (CSHO) will arrive on site and state the intended purpose/scope of the inspection.
2. You should request to see the compliance officer’s credentials.
3. Seat the CSHO in a clean area at the front of your facility.
4. Call the company‐designated OSHA representative for the company.
5. Your company‐designated OSHA representative should:
a. Take the CSHO into a conference room or private office near the front of the facility for the opening conference, or
b. Refuse entry to the facility and request the CSHO obtain and return with a warrant to conduct the inspection.
6. The company‐designated OSHA representative should determine the path of access to the inspection area based upon the scope of the inspection identified by the CSHO. This may entail taking the CSHO out the front door and around the exterior of the building to another entrance with more direct access to the inspection area in order to limit and control the CSHO’s line‐of‐sight.
7. The CSHO should never have unaccompanied access to your facility. Your company‐designated OSHA representative should lead the CSHO to the inspection area and should remain with the CSHO at all times (except when the CSHO is speaking with an employee). If possible, there should be two or three company representatives who accompany the CSHO during this inspection.
8. Your company‐designated representative should always document the inspection. If the CSHO takes a photo, you should take the same photo. If the CSHO takes measurements, you should take measurements. If the CSHO expresses concerns or asks questions, these items should be noted. Your documentation should mirror the compliance officer’s documentation as closely as possible.
9. Be cooperative. Answer questions that are asked, but do not volunteer any additional information.
10. Upon completion of the walkthrough inspection, your company designated OSHA representative should lead the CSHO back to the conference room to conduct the closing conference. Make notes of the officer’s observations and concerns.
After the Inspection
The OSHA compliance officer will return to the local field office to prepare the final inspection report. OSHA has six (6) months within which to issue any citations. Your company has 15 days in which to respond to these violations. Your response may detail your OSHA‐compliant training policies, employee training attendance records, or some other proof of abatement.
Violations may be abated and/or dismissed, may be appealed, or the case may be tried in court. You should understand your right to appeal, your right to request an informal hearing, and your right to request a reduction of fines. Settlement should always be explored before proceeding to trial.
It is your responsibility to know your rights. Be prepared for the unexpected by establishing an OSHA inspection procedure before it is needed.
Do you know how to respond to an impromptu OSHA inspection visit? Are you responsible for workforce safety or risk management? Email us or give us a call at (816) 349-0850 to see how we can help design a safety and risk management plan that meets your unique needs.
Thank you for being the best of 2018.
I have witnessed tremendous strides being made at many of your companies over the past year. This is a direct reflection on your commitment to safety and your desire for continued improvement. You have stepped up, asked the tough questions, faced the challenge, and done the work. You have embraced change and achieved goals. YOU are the best of 2018. I am humbled to be a part of your safety journey.
The goal here on the blog is to deliver practical content – information that helps you improve safety and achieve goals. These were the articles you read the most in 2018. I hope you found useful information in each of them and welcome your ideas about topics you want to learn more about. This information is for you. Chime in – make it yours!
- Crane & Rigging Operations Carry High Risk
- Aviation Workplace Safety: High-Risk MRO Division
- Missouri Construction Industry: Job Site Safety Tips
- INTRO: Insurance Inspector Success Training
- Workers Compensation Extends to Temporary Workers in Missouri
- It’s Not Enough for your Missouri Business to Have Formal Safety Policies
- Workplace Safety: 5 Steps to Ladder Safety
- Automotive Mechanics: Spotlight on Safety
- Fleet Management Basics for Missouri-based Businesses
- Missouri Workplace Best Practices: Materials Handling is More Than Lifting
It’s been an amazing year. Thank you so much for trusting me to be part of your safety and quality improvement journey. Change is difficult. It is also good. You are a valued part of the CRMKC family, and I sincerely appreciate each and every one of you.
You are taking control of safety and it is paying off. Here’s to a safe and successful 2019!
Safety Is No Accident.
How do you define “safety?” Is it an act, a concept, a mindset, a process, a philosophy, a theory? Ask 20 people and you will likely receive 20 different answers. According to dictionary.com, “safety” is:
(1) the state of being safe; freedom from the occurrence or risk of injury, danger, or loss;
(2) the quality of averting or not causing injury, danger, or loss; and
(3) a contrivance or device to prevent injury or avert danger.
This definition provides us with a repetitive reference to words like “danger,” “loss,” and “injury.” It also tosses out the big word, “contrivance,” which, used here, refers to a planned or created (contrived) device used to achieve (bring about or effect by plan) a state of safety.
If safety is a state of being, the next question should be, how do we achieve that state of being? We’ve identified 8 markers along the way to developing a successful safety program. A true culture of safety starts at the top and is revisited and improved along the way. If safety isn’t part of your long-term continuous improvement strategy, it will not become an ingrained culture.
The 8 C’s of Safety Success will help any company achieve their safety goals, whether you are starting from scratch or reworking an existing safety management system.
COMMITMENT. The commitment to safety starts at the top. Many of the tools, changes, and improvements along the way will require time, money, and enforcement. Change is difficult for many people, and workers take their cue from company leaders.
COMMUNICATION. Involve your employees. The people doing the work have the hands-on experience needed to identify problem areas and the insight to explain why certain ideas may work in theory, yet fail in practical application. Communication must be a two-way street. In addition to delivering information to your staff, leaders must also learn to listen. Create a culture where discussion is welcomed.
CONSISTENCY. Consistency is key. Perform JSAs, create SOPs, and draft formal written policies and procedures. All of these documents provide a consistent point of reference so that all work is completed in an orderly, consistent fashion. Take the guesswork out of the process.
CHECK! Safety is never “one and done.” Routinely evaluate processes, tools, materials, and other variables for opportunities to improve.
COLLECTION. Our goal is to avoid as many accidents as possible and to reduce the severity of those that do occur. We are human, and accidents will happen. Investigate accidents and near-miss occurrences immediately. Interview witnesses, take photographs, inspect equipment and machinery, and gather as much information as possible. Identifying the steps that preceded the accident helps identify how or why the accident occurred.
CORRECTION. Knowing what happened, in what order, at what point of the process, helps us identify root causes and develop corrective actions to prevent future recurrences of the same event.
CONFIRMATION. Information empowers you over the long-term. Keep accurate records and track your progress. Analyze annual and quarterly data. Compare and contrast loss data to learn where you gaining strides, where you have a continued need to focus, and any new areas of concern.
COACHING. Host routine safety meetings, provide ongoing training opportunities and conduct frequent, informal toolbox talks. Beyond these basics, learn to coach your employees in real-time. If you see them without PPE, correct it on the spot. Be consistent. Real-time coaching enforces consistency and shows your commitment. Coaching should not be punitive. Employees who refuse to comply or become repeat offenders should be disciplined, but you start with non-punitive, real-time corrective actions to enforce compliance and reward safe work behaviors.
Eight simple steps. Safety is achieved through commitment and consistency.
Does your company have formal safety policies in place? Are you responsible for workforce safety or risk management? Email us or give us a call at (816) 349-0850 to see how we can help design a safety and risk management plan that meets your unique needs.
An airport is a busy place. It takes hundreds of personnel to assure smooth operations. The airline services industry encompasses a number of functions, including customer service ticketing agents, wheelchair transporters, baggage handlers, security officers, cleaning crews, and ground crews. These functions operate simultaneously in the background to keep flights on time and serve travelers. The work is fast-paced and speed is a major contributor to errors and accidents.
Ticket agents and customer services representatives are on their feet the majority of the day, often standing in one area for long periods of time. Even with anti-fatigue mats, standing all day can be hard on the joints and musculature of the body. I am reminded of the TV commercial that says, “A body at rest stays at rest. A body in motion stays in motion.” So true. These workers should be provided (and required to take) frequent breaks, even if that means 5 short minutes per hour, to move around and relieve the “body at rest” pressures on the spine, hip, and knee joints that results from this extended standing in place.
These workers also perform repetitive data entry from a standing position. Counter heights and proper ergonomic equipment are important in maintaining good physical alignment and relieving the repetitive motions that place strain on the hands, wrists, arms, elbows, shoulders, and necks. Certainly, repetitive injuries are not limited to these body parts, but these parts are frequently reported as strain/sprain injuries for this job classification.
Baggage handlers have frequent strain/sprain and overexertion injuries as a result of bending, lifting, and slinging luggage onto and off of carts, conveyors, and up into cargo compartments of planes. Shoulder and rotator cuff injuries are common in this job classification, as are back injuries and general arm and neck strain/sprains. Like other exterior grounds crew workers, baggage handlers may work from heights and are, thus, susceptible to falls. Weather is always a factor for these workers, as they are subject to extreme heat and cold temperatures, rain, ice, wind, and the risk of black ice and rapidly changing conditions resulting from those hazards.
Housekeeping and janitorial staff are subject to chemical exposures (inhalation, contact burns), falling from heights when working on ladders or lifts, strain/sprain injuries resulting from the physical labor performed, cumulative trauma injuries resulting from repetitive motions such as mopping, and slip and fall injuries.
Wheelchair transporters commonly experience strain/sprain injuries as a result of lifting or assisting limited-mobility passengers (and/or their luggage) and pushing wheelchairs through the airport. Non-skid soles are important for these workers, as is proper lifting technique.
Security officers (and all of the above service workers) are also subject to angry or confrontational passengers on a routine basis. We have all read the news accounts of negative passenger experiences, but think about that from the perspective of the worker as well. Security officers, in particular, are charged with scrutinizing every passenger, every bag, every laptop – every single item that passes through security. Their job is to identify any potential hazard and stop it at the checkpoint. This is often inconvenient and is a common source of irritation for passengers. These officers must not only do their job (and do it well, for all our sakes), but also know how to diffuse situations and handle confrontations, all the while processing large crowds through security checkpoint stations.
Interior cleaning crews must clean a 737 in minutes between flights. They climb steps and ladders, bend, stretch, reach overhead, lift, and twist all within the confines of the aircraft cabin. They work at a clipped pace to minimize time between deplaning and boarding passengers. Exterior cleaners often work in extreme heat or cold. Inclement weather is not their friend. Rain, snow, sleet, ice, and gusting winds all impact the safety of the exterior workers, particularly when they are working from heights. Racing against the clock in inclement weather conditions only increases the likelihood of a fall, strain/sprain, or struck-by injury.
These exterior workers must remain alert to their surroundings at all times. Mobile ground equipment (lifts, cherry pickers, tugs) and taxiing planes all create hazards for pedestrians and each other. Struck-by injuries commonly occur from walking into a wing. The use of ladders and lifts contributes to fall-from-height injuries which frequently result in lacerations and broken bones. The potential for severity from these injuries includes permanent brain injuries, paralysis, and even death.
By no means is this list inclusive of all the operational support services carried out at an airport. It does, however, paint a broad picture of the types of exposures these workers encounter on a daily basis. Because the exposures are so diverse, it is vital that support services employees receive training in proper lifting, chemical exposures, biohazards, conflict resolution, accident reporting and investigation, and even emergency first aid. They should be equipped with proper footwear, hearing protection, gloves, and other PPE as is appropriate to their job function. Their job is to keep us safe, and that starts by equipping them to carry out their functions in the safest manner possible.
Does your company have formal safety policies in place? Are you responsible for workforce safety or risk management? Email our commercial risk and safety consulting firm or give us a call at (816) 349-0850 to see how we can help design a safety and risk management plan that meets your unique needs.