SAFETY CULTURE AND ROBUST SAFETY MANAGEMENT SYSTEM

By United Cleanup Oak Ridge LLC (UCOR)

Management Leadership Defines Safety Culture Expectations

Management should clearly establish safety culture expectations to foster a psychologically safe environment in which workers are expected and encouraged to identify concerns during planning, work performance, and closeout phases. Management has the ultimate responsibility to ensure that resources necessary to safely accomplish the work are available. In addition, management should reinforce the importance of robust conduct of operations that yields unwavering compliance with company procedures and work controls, regulations, and standards.

Safety Management System Ensures Safety

While the following basic SMS functions are vital to safe excavation and trenching activities, they can be applied to any industry and type of work being performed.

• Define the Scope of Work: All members of the planning and work performance teams should have a clear understanding of the work to be performed and the expected outcomes.

• Analyze Hazards: Existing and predictable hazards such as the potential for cave-ins, falls, being struck by equipment, tools, or materials, contacting dangerous utilities, or being exposed to toxic substances or hazardous atmospheric conditions must be considered. Aids such as drawings, maps, historical documents, and soil analysis are required to adequately identify hazards.

• Develop and Implement Controls: The hierarchy of hazard controls should be implemented when developing measures to protect the workforce, members of the public, and the environment. Highquality training which includes confirmation of proficiency, should be considered when identifying administrative controls. Installation of protective systems such as trench boxes when required; complaint means of safe ingress and egress within 25 feet of workers; setbacks for spoil piles and heavy equipment; and physical barriers to prevent accidental entry into the excavation must be considered when developing and implementing safety controls. Given that quick expert assistance is critical to the success of an emergency response, a comprehensive response plan must be in place.

• Perform Work: Work teams must always proceed in a manner that consistently conforms with company policies, procedures, and work controls—every task, every activity, every time. A heightened sense of situational awareness and the use of critical thinking skills are required from every team member for high-risk operations such as excavation and trenching.

• Feedback: All members of the work team must be empowered to raise concerns and stop or pause work if a changed or previously unidentified condition is encountered. Feedback during and after work completion from team members is required to understand what went right and what should be improved.

It Takes a Team

Excavation and trenching teams require an OSHA competent person, a diverse team of subject matter experts (SMEs), and highly trained and skilled workers to be successful.

OSHA defines a competent person as being, “one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees and who has authorization to take prompt corrective measures to eliminate them” [29 CFR 1926.32(f)]. A competent person must demonstrate understanding of excavation regulations [29 CFR 1926.650 and 1926.651], be able to classify soil types, be familiar with the installation and use of protective systems [29 CFR 1926.652], and perform inspections of the excavation/ trench work area. The competent person acts as the official authority who authorizes and suspends excavation/trench work activities.

Access to subject matter experts representing disciplines such as industrial or construction safety, industrial hygiene, construction/heavy equipment, hoisting and rigging, electrical safety, and fall prevention and protection is required to ensure safety during excavation and trenching activities.

Equipment operators must be trained to operate the specific equipment to be used. Training should include hands-on, field-based activities to verify proficiency of operational capabilities, understanding of load charts, inspection requirements, hoisting and rigging operations, the recognition of struck-by hazards, work zone safety, and the impact of field/ environmental conditions.

Heavy equipment spotters should be trained to recognize potential struck-by hazards and be able to demonstrate proper use of signaling and three-way communication.

All workers both inside and outside of the excavation/trench and emergency responders should be trained to recognize and respond to changing conditions and potential hazards.

In Review

Excavation and trenching operations are inherently dangerous and require an advanced degree of planning and preparation. Don’t start an excavation/trenching operation if you don’t have:

• A well-defined and clearly understood scope of work

• An adequate hazardous analysis that identifies both existing and predictable hazards

• Trained workers with critical thinking skills; access to subject matter experts; and an OSHA competent person

• Resources to implement physical controls such as work zone barriers and protective shoring and shielding systems; the proper personal protective equipment; and an established emergency response plan

• A safety culture where all team members are empowered and capable of voicing concerns.

It is equally important to be prepared to stop work if a changed condition occurs.

As the Department of Energy Oak Ridge Environmental Management lead environmental cleanup contractor, United Cleanup Oak Ridge LLC (UCOR) has worked for more than a decade to demolish, cleanup, and dispose of waste associated with some of the most hazardous nuclear facilities in the DOE Complex. Under a shared governance leadership model, UCOR’s 2,200 member highly skilled workforce has accomplished first-of-a-kind environmental restoration projects and stands mission ready to accomplish future DOE milestones.

Contributors:

• Jay Hocutt, CSP, SGE, CWD, UCOR Construction Heavy Equipment Program Manager

• Dustin Hanuhorst, CSP, Construction Heavy Equipment Subject Matter Expert

• Lynn Trout, UCOR Heritage Center Safety and Health Operations Manager

• Ryan Cannday, CSP, UCOR Heritage Center Deputy Safety and Health Operations Manager

• Christian Barnhill, UCOR Safety Specialist

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