Safety Wars
FRC and Heat Stress
June 7, 2021
A discussion of Fire Retardant Clothing and Heat Stress. Jim shares a story about an Oil Terminal with inconsistent safety enforcement and OSHA Policies. The moral of the story: Own your decisions.
This is this show is brought to you by safety. FM. The following program is rated for mature audiences. It may contain adult language, adult situations and frank safety discussions. The names in certain details have been changed to protect the safe and the unsafe. But believe me, every item in here is true. He stressed and fire turn clothing today on state wars. So this is a topic we get into every summer at my projects up here in the Northern Hemisphere's summer. I know in the southern Hemisphere where some of these programs are listened to, it is now going into winter. So I worked in the oil refining industry and environmental cleanups and oil terminals for many, many years. The environment and some of these job sites, we'll just say they're hotter than hell. Right. One of the questions that always comes up is why are we wearing fire retardant clothing and all this protective equipment when these hazards are very remote? But can I have ensured that there really never going to happen right. And why are we wearing all this stuff when he stresses a real hazard that we get, we're going to be hot, It's gonna be sweaty, it's gonna be miserable. So what's the story here? I was on a job site where it was well into the triple digits here. That's Fahrenheit, not Celsius. I was on an industrial painting crew where we were wearing FRC because it was a facility policy and because we could not be exposed to flammable materials like oil and gasoline and on top of that, the paint that we were using was flammable also. So two part epoxy. So what do we do eat? War FRC? We implemented the work rest schedule, had cooling, fast water, sports drinks, everything else that you're supposed to have in this situation. So just to let you know if you've ever worked in an oil terminal, there's a lot of sampling and tank gauging where they're measuring levels of the tank every day practically. And all this stuff has to happen for them to move oil around. So it makes it to the downstream market. That is the retail market. So one day the guy who is issuing work permits and forcing us all the wear FRC and being a real jerk about it pulls up to the tank next to us, passenger of his vehicle, gets out with sample containers, but get this. He's wearing sneakers, nylon shorts, a nylon tank top and a pair of sunglasses. And we're definitely not AnSI Z 87 approved. He goes up to the top of the tank, gets a sample of gasoline, comes down, goes in the truck and leaves. He was handling the real stuff all while holding a cell phone and that was not an intrinsically safe. Cell phone. I might have no gloves, no nothing. Any idea what happens if nylon catches on fire by any chance? It's not a pretty sight. It basically melts to your skin. It's a horrible, horrible, horrible situation. The guys look at me like WTF is going on here. I mean, this is nuts. The pyramid is sure comes out about an hour later to do is normal audits and checks and everything is questioned by the crew. His response, If you don't shut the bleep up, get the bleep out and don't, you have to finish by friday. Yeah. Look at the situation that spent safety in your whole safety department. This is not an uncommon situation and it makes safety look real bad. And this is where you come up with the safety doesn't know what the hell is going on in the field type thing. Some of my thoughts here companies don't want to manage different jobs or hazards or PV requirements so they make cookie cutter decisions. Everyone will swear FRC whether it makes sense or not. I've also been on construction jobs. Let's get out of FRC fire retardant clothing and let's go into fall protection. I've been on jobs where? Every time you left that trailer? That office trailer, that lunch trailer, no matter what you had to wear a harness. For what reason had to wear a harness. And if you didn't you were thrown off the job number two. This leads to a situation of not trusting the work or field supervisors to actually make decisions. In this case you have a qualified safety professional. Me and a qualified permission issue that could have made decisions. I think it was the right decision where F. R. C. In this case. But what about all the other job activities going on at that facility? Makes us all look stupid. One things like this happen. What's the deal with letting a sampler on site? No PV not even gloves to handle something that's even more hazardous than what we were handling again. It makes us look like a joke. No four. The attitude of this guy. I suspect he was under pressure but at the time he undermined his own credibility stepped on his own foot. There's probably forced by the situation to let this happen because these are the types of conversations that happen. Someone comes in and they're like I'm only gonna be here for five minutes and take a sample. I'm not putting all this stuff out. And by the way if you don't let me work this way your work doesn't get done. You don't get to sell that oil, you don't get to move that product and guess what? You're gonna have a problem. So the guy goes and let this stuff happen and what's the priority its production as usual. And the last one, this is not a psychologically safe environment, how we pursue this. Like we're supposed to write, we're supposed to report in your missing catches and this thing and that thing, right. And basically, because of the attitudes of everybody on this job, this stuff never gets reported, puts people at risk and the long term outcomes are moving up. They're horrible. So what does Ocean say? I'm all of this stuff, especially with FRC. I was recently preparing a safety meeting for a client and came across a letter of interpretation from OSHA from May 2010. This scenario that I'm going to give you is right off of the Ocean website, but I had to edit it down for content. Dear OSHA, I'm an electrician in 30 years of experience. Currently I'm working as an electrician and a certain workplace. I will mention it for the past 10 years, I've been wearing lightweight, light colored, loose fitting clothing while working in the heat and humidity. So this worker had everything figured out we'll have to work safely here. However, my employer has now instituted the mandatory use of heavy, flame resistant uniforms, which has to be warned at all times, 90% of the time. I'm not exposed to anything that's going to give you a fire hazard or an electrical hazard. So this is what the guys question it was. Why can't the employees where the regular, loose fitting, lightweight clothing when doing one activity and then where the appropriate flame resistant clothing when we're doing the other activities that warranted? So how does OSHA answer this? The long and short is that the employer has to protect the employee from both hazards. Electric and heat stress. Although there is no official OSHA heat stress standard. The employer can be cited under the general duty clause, which requires the employer to supply a safe and healthful workplace through the employees free of recognize hazards. In this case to recognize hazard is heat. What are some of the options that the employer has supplying water and maybe sports drinks that are appropriate work rest regimen that's put out by certain organizations? Uh, heat stress program, maybe scheduling the worker, uh, to work at other times and it's not so hot. So the employer does have options if they tell you otherwise. And this is me saying this. The employer tells you otherwise. They may not realize that they have other options. Or they may be hoping that you don't know what's going on and hoping that you go away blaming OSHA safety or the man for these types of policies really isn't right. And it's really a cop out. No one owns their decisions. Right? What's this? You got to own a decision. You make a decision. You gotta own it. We talked about that recently in one of our other broadcast. It makes everyone's job harder when no one wants to own a decision when no one wants to be innovative, No one wants to look out for. The employee may be explained to the employee why we have these policies and be open and frank with them. That makes your job easier. And let me point out something. Usually those folks that make those kinds of decisions, those cookie cutter decisions are working in nice air conditioned office. Hey, that's just my experience. I have heard of oil refineries and oil terminals down in the southern United States that actually go out of their way to try to assess hazards. They don't come up with a cookie cutter approach is especially with heat stress. They go and they do an assessment and figure out ways of managing things. Put some authority back into the hands of the field supervisors and employees to manage these hazards. Getting everybody involved, making decisions that make sense. That's how you're going to win the safety war here guys for safety wars. This is jim proposal. The views and opinions expressed on this podcast are those of the host and its guests and do not necessarily reflect the official policy or position of the company. Examples of analysis discussed within this podcast are only examples. It should not be utilized in the real world as the only solution available as they are based only on very limited and dated open source information, assumptions made within this analysis are not reflective of the position of the company. No part of this podcast may be reproduced, stored in a retrieval system or transmitted in any form or by any means mechanical, electronic recording or otherwise, without the prior written permission of the creator of the podcast, jay Allen.