Safety And Occupational Health Action Plan
Safety and Occupational HealthAction PlanU.S. Department of the InteriorBureau of ReclamationDenver, ColoradoMay 2014
Mission StatementsThe U.S. Department of the Interior protects America’snatural resources and heritage, honors our cultures andtribal communities, and supplies the energy to power ourfuture.The mission of the Bureau of Reclamation is to manage,develop, and protect water and related resources in anenvironmentally and economically sound manner in theinterest of the American public.
Safety and Occupational HealthAction PlanPrepared by:Safety Action Plan Team, Bureau of ReclamationDenver, ColoradoContact information:Safety and Occupational Health Program Office, 303-445-2695Team Lead: Bruce Muller 303-445-2986 or bmuller@usbr.govU.S. Department of the InteriorBureau of ReclamationDenver, ColoradoMay 2014i
Safety and Occupational Health Action PlanAcronyms UsedANSIAmerican National Standards InstituteBPABonneville Power AdministrationCFOCChief Financial Officer CouncilCFRCode of Federal RegulationsCMMCapability Maturity ModelDASHODesignated Agency Safety and Health Official (DeputyCommissioner, Policy Administration and Budget)DOI (Department)Department of InteriorEPAPEmployee Performance Appraisal PlanFTEFull-time EmployeeGPGreat PlainsGSGeneral ScheduleHRHuman ResourcesIBWCInternational Boundary Waters CommissionIDAction IdentifierIDPIndividual Development PlanJHAJob Hazard AnalysisLCLower ColoradoMESHManaging Employee Safety and HealthMPMid-PacificO&MOperation and Maintenance (Office)OSHAOccupational Safety and Health AdministrationPNPacific NorthwestRACRisk Assessment CodeRDCCTReclamation Design and Construction Coordination TeamRLTReclamation Leadership Team
RSHSReclamation Safety and Health StandardsSDSSafety Data SheetSOHSafety and Occupational HealthSSLESecurity Safety and Law EnforcementTVATennessee Valley AuthorityUCUpper ColoradoUSACEU.S. Army Corps of EngineersWAPAWestern Area Power Administration
AcknowledgmentsThe team would like to thank the following individuals for their insights and guidance in thedevelopment of this action plan: Michael Ryan, Regional Director, Great Plains Region (Executive Sponsor)Steven Jarsky – Deputy Regional Director, Pacific Northwest Region (Peer Reviewer)We’d also like to acknowledge all of the team members who dedicated many hours from their alreadybusy schedules to generate and develop the actions identified in this report. The team consisted of:PN Region:Lesa Stark, Program Manager ESA and Planning Programs, Snake River Area Office, Boise, IDShawn Smith, Safety and Occupational Health Manager, Safety Program, Boise, IDMP Region:Joseph A. Ascoli, Supervisory General Engineer, Mechanical Maintenance, Shasta Lake, CAMonte Bowman, Safety, Occupational Health, Security, & Emergency Management Manager,Sacramento, CALC Region:Seth Ostrowski, Supervisory Engineer, Operations Support Group, Boulder Canyon OperationsOffice, Boulder City, NVJuli A Smith, Industrial Hygienist, Safety Office, Boulder City, NVChris Andrews, Regional Safety and Occupational Health Manager (acting), Boulder City, NVUC Region:Ken Rice, Assistant Area Manager, Facilities O&M, Albuquerque, NMDan Mitchell, Regional Safety Manager, Occupational Safety and Health, Salt Lake City, UTGP Region:Larry D. Schoessler, P.E. Regional Construction Engineer, Construction Services Group,Billings, MTSteve Marquez, Regional Safety and Occupational Health Manager, Billings, MTTyler Johnson, Regional Public Affairs Office, Billings, MTSSLE:Jim Meredith, Reclamation Safety and Occupational Health Manager, Safety and Health Office,Denver, COKen Somolinos, Denver/Washington Office Safety Manager, Safety and Health Office,Denver, COTheresa Gallagher, Industrial Hygienist, Denver, COOffice of Policy and Administration:Terence Berger, Human Resources Specialist, Employee Relations/Labor Relations, Denver, CO
TSC:Yvonne Bernal, Natural Resource Specialist (Editorial Assistance), Denver, COCommissioner’s Office:Peter Soeth, Public Affairs Specialist, Denver, COBruce Muller, Senior Advisor, Denver, CO
Safety and Occupational Health Action PlanExecutive SummaryThe Bureau of Reclamation (Reclamation) has had a long tradition of settingindustry leading safety practices and instilling safety values in its workforce.Reclamation Safety and Occupational Health (SOH) Program efforts have helpedthe bureau maintain injury and illnesses rates (injuries per 100 employees) near orbelow most other benchmarked organizations and the power generation industry.As Reclamation’s program has transitioned from water resources development towater resources management, there are new functions and risks that were not asprominent in Reclamation’s prior lines of business. At the same time, budgetpressures have instilled a value of doing more with less. While this pressure hasbrought about efficiencies, it has also limited resources to focus on potentialsafety risks and to provide safety professionals to advise Reclamation managerson these risks and how to mitigate them.A review of Reclamation’s SOH Program by the Department of the Interior’sOffice of Occupational Safety and Health resulted in a report that identifiedseveral opportunities for improvement in its program. Perhaps the mostdisturbing statement in the report was, “A degree of cultural complacency existsthat results in the acceptance of facility hazards and contributes to the presenceof uncorrected facility hazards, OSHA non-compliance issues, and incompletesafety and occupational health program implementation.” Reclamation conveneda Rapid Improvement Work Team to evaluate the assertion by the Department.The team identified a number of issues which were consistent with theDepartment’s assertion. The Department did note a commitment to safety atReclamation’s leadership level, but the same degree of commitment was notapparent to the reviewers from all levels of the organization. On January 24,2014, Reclamation convened the SOH Action Plan Team to develop this actionplan as a road map for addressing the identified issues. Reclamation wants itsemployees to actively participate in their own safety, the safety of those aroundthem, and go home safely at the end of the day.The current state of Reclamation’s safety culture didn’t develop overnight andwon’t be corrected overnight. However, an action plan for adopting/improvingkey elements of a robust safety and occupational health program will instill/renewvalues and shape a new culture to accelerate the process of improvingReclamation’s recent safety record. Reclamation assembled a team of managersand safety professionals to develop this report which identifies 21 actions toprovide a multifaceted approach to raising awareness and reducing risk. Theactions will also provide the basis for accountability for following establishedstandards while also encouraging better recognition of hazards and exposureconditions. The goal of taking these actions is to ensure that all Reclamationemployees see themselves as having a responsibility in the establishment ofi
Reclamation's safety culture while also integrating key concepts of hazard andexposure mitigation into their jobs and operations of Reclamation facilities.Executing the action plan will require resources from across Reclamation. It willalso require commitment to accomplishing Reclamation’s work both efficientlyand safely. By implementing these actions, Reclamation can put SOH back at theforefront of work activities and create a climate where Reclamation employeescan feel that productivity and safety are equal and complementary goals inaccomplishing work.ii
Safety and Occupational Health Action PlanTable of ContentsPageIntroduction . 1Background . 3SOH Program History at Reclamation . 3Current Reclamation SOH Program . 3Occupation Safety and Health Administration (OSHA) Compliance Inspectionat Hoover Dam . 5Department Evaluation . 5Reclamation Assessment of Department Evaluation . 6Strategy . 9Actions . 11Implementation . 31References . 33iii
IntroductionReclamation has developed a tremendous set of assets for managing waterresources in the western United States. Many of these are physical assets thatenable storage, transport, and delivery of water. They also enable the generationof power for customers and stabilization of nation’s bulk electric power system.Even more important than these physical assets are the people who serve inReclamation. Every person in Reclamation is part of a legacy of hard-workingpeople who have helped build and continue to sustain the West. Reclamationpersonnel play a critical role in determining how the physical assets will be usedto meet many competing demands or ensure that the physical assets successfullyfulfill their intended purposes. As an organization, Reclamation invests extensiveresources in developing staff to perform their assigned duties. Knowledge, skillsand abilities are its most important asset in assuring that the mission ofReclamation is successfully executed. Injuries, lost time accidents and other SOHissues can have devastating impacts on the ability to effectively carry outReclamation’s mission and return home safely upon completion of daily workactivities. Therefore, Reclamation must have an effective SOH Program torecognize, understand and manage the potential hazards and exposures associatedwith our facilities and work activities. All can help rebuild and strengthen ourculture of caring about the person working next to us.In many ways, Reclamation is similar to other organizations. Reclamation canand does realize many benefits from standard SOH practices. Some of thesestandard practices are codified by the Occupational Safety and HealthAdministration (OSHA) and require compliance. In other cases Reclamationbenefits from sharing best practices within and outside the Department of theInterior. There are also tools available to help implement the SOH Program in amanner that has been shown to effectively reduce lost time injuries, chronicconditions, and even death. These sources and tools have formed the basis fordefining the basic elements of Reclamation’s SOH Program.The nature of Reclamation’s mission also exposes us to potential hazards that arewell beyond the scope of a basic or common SOH program. A small sampling ofsuch hazards includes: High voltage electricityHigh pressure waterHigh velocity waterLarge industrial equipment operation1
Safety and Occupational Health Action Plan Access and operations in confined spacesInspection and maintenance of facility components with special accessneeds (ropes, diving)Conducting natural resources activities and gathering data near waterbodies or in remote backcountry locations at unusual times and in unusualweather conditionsThe potential consequences of these types of operations require much morerigorous planning of work activities to assure the potential hazards and exposuresare recognized and mitigated in a manner that allows the work to be safely andefficiently accomplished.A number of near misses, serious accidents and an evaluation of Reclamation’sSOH Program by the Department of the Interior (Department) have suggested adegree of cultural complacency has developed with respect to SOH. When thisassertion was supported by a team of Reclamation employees, Reclamationleadership requested this action plan be developed to engage management andemployees in scoping and presenting a series of activities to re-establishReclamation’s commitment to improve the delivery of a safe and healthful workenvironment.Many of the same principles that apply to employee safety are also extendable topublic safety at Reclamation facilities. Where the public uses the same facilitiesas Reclamation, their safety will certainly be enhanced by addressing a number ofemployee safety issues. However, public safety initiatives are considered to bebeyond the scope of this report.2
Safety and Occupational Health Action PlanBackgroundSOH Program History at ReclamationReclamation has a long history of including SOH in its daily work activities andmission accomplishment. In fact, the construction of Hoover Dam was the firstproject where hard hat usage was mandated. It was also where the agencydeveloped a much better understanding of the hazards of carbon monoxide inconfined spaces and the need for ventilation. Unfortunately these lessons came atthe cost of human life.In the years that followed, with Reclamation’s construction of dams across thewestern United States, it was recognized that having a strong safety program inplace supported timely completion of the construction work. Beginning in the1940s, the bureau regularly published safety newsletters, detailing safe workpractices and provided accident information to help prevent similar eventselsewhere. It was during this time the first Reclamation safety requirementsmanual was developed, the forerunner of today’s Reclamation Safety and HealthStandards, commonly known as the “Yellow Book”.OSHA published the first federal safety regulatory requirements in the early1970s. Those requirements were said to have been based, in part, on existingrequirements established by Reclamation and the US Army Corps of Engineers.Current Reclamation SOH ProgramReclamation’s SOH Program is defined at its highest level in the ReclamationManual in policy SAF P01. This policy describes the responsibilities of personnelfrom the Commissioner down to employees. The policy also defines the roles ofSafety and Occupational Health personnel. In addition, SAF P01 programdevelopment and implementation is to be based on ANSI Z10 (American NationalStandard for Occupational Health and Safety Management Systems); therefore,the policy establishes SOH the requirement for credentialed senior SOHmanagement personnel in the Commissioner’s office and each regional office whoreport to a director/regional director or their immediate deputy/assistant.In practice the current program is implemented locally at each office withcoordination from the Commissioner’s office and regional offices. The key entityfor coordination of SOH issues across Reclamation is the Safety and HealthCouncil. It’s comprised of the Reclamation SOH Manager and the safety3
Safety and Occupational Health Action Planmanagers from Denver and each regional office. The council supports theReclamation Program through collaborative discussion of common issuesaffecting the safety and health of employees, contractors and the public; byincreasing program awareness and visibility; through review of Reclamationinjury and accident rates and trends, with subsequent management initiativesleading to reduction of rates, and through active involvement of the developmentand implementation of program policy and guidance. The council workscollaboratively in the development of services (including job hazard analysis,workplace inspections, industrial hygiene, exposure assessments, ergonomicassessments, training and education, and occupant emergency training) to supportaccomplishment of SOH goals. Specific programs are also supported for specificoccupational risks including hazardous energy control, permit-required confinedspace entry, underwater diving, rope access, and law enforcement.Table 1 compares the injury and illness rates (injuries per 100 employees) withother benchmarked organizations.Table 1. Injury Rate Benchmarks in Injuries per 100 EmployeesTotal Case Rate*FY 09–13 Avg.Lost Time Case Rate*FY 09–13 Avg.Reclamation4.281.19Army Corps of Engineers3.001.32U.S. Geological Survey2.520.54DOI5.421.87Other Federal Agencies3.641.65Power GenerationIndustry3.501.77Organization* Wokers’ Comp. Cases/100 employees. Not comparable with recordable and DART rates.Shown for agency comparisons only.4
Safety and Occupational Health Action PlanOccupation Safety and Health Administration(OSHA) Compliance Inspection at Hoover DamIn July, 2012, OSHA initiated an unannounced comprehensive complianceinspection at Hoover Dam. As a result of that inspection, OSHA issued 58notices of violations to Hoover Dam in January, 2013. The Lower ColoradoDams Office worked closely with OSHA to successfully address all notices ofviolations. As a follow-up to the Hoover notices, the Deputy Commissioner,Operations directed that all regions conduct inspections of all their facilities andtake corrective action to abate identified deficiencies.Department EvaluationIn May 2013, Reclamation requested the Department Office of OccupationalSafety and Health to conduct an evaluation of Reclamation’s SOH Program tohelp identify gaps in the SOH Program. The evaluation was conducted in July,2013, was presented to Reclamation in a draft report dated September 16, 2013,and was finalized in March, 2014. Key findings from the evaluation included: Reclamation senior leadership and management demonstrate leadershipand management commitment for SOH and have established essentialresources and various management systems for the implementation of theSOH program.Despite the above positive attributes, senior leadership and managementhave not established safety as an organizational value throughout allranks of Reclamation.The conditions, issues, and causes that led to the OSHA hazard notice atHoover Dam and Power Plant are systemic to Reclamation.A degree of cultural complacency exists, which results in the acceptanceof facility hazards and contributes to the presence of uncorrected facilityhazards, OSHA non-compliance issues, and incomplete SOH programimplementation.The report gave Reclamation’s Safety and Occupational Health Program a scoreof 3.03 out of a possible score of 5.00.The DOI Evaluation recognizes that there are several aspects of the ReclamationSOH Program that are considered strengths. It is important that Reclamation notlose focus in these areas of strength while pursuing opportunities for furtherimprovement. It is also important to recognize that implementation of the SOHProgram may exhibit some variation from one office/facility to another as5
Safety and Occupational Health Action Plandifferent facilities can have substantially different hazards to be mitigated.Identified strengths that Reclamation wants to sustain include: Leadership and management commitment to and communication of SOHas a priority for the organization.Existence and staffing of safety and health offices at various levels of theorganization.Systems are in place for policy, worksite analysis, deficiency tracking, andhazard identification and control.The overall SOH policy is built on the principles of ANSI Z10.However, the most disturbing finding of the Department evaluation was theassertion that Reclamation has developed a degree of cultural complacency withrespect to safety.Reclamation Assessment of Department EvaluationIn January 2014 convened a Rapid Improvement Work Team to assess theassertion of a degree of cultural complacency identified in the Departmentevaluation. Following
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