Aggregates Manager Pull-out Guide: Keep a Clean House
Housekeeping Heightens Safety
It seems like such a little thing: keeping a clean house. But failure to do a minimum of housekeeping leads to some of the most common citations from the Mine Safety and Health Administration (MSHA). More importantly, it can cause injuries — or even death — from slips, trips, and falls.
The MSHA regulation for housekeeping (30 CFR 56/57.20003) states that the following applies to all mining operations:
(a) Workplaces, passageways, storerooms, and service rooms shall be kept clean and orderly.
(b) The floor of every workplace shall be maintained in a clean and, so far as possible, dry condition. Where wet processes are used, drainage shall be maintained, and false floors, platforms, mats, or other dry standing places shall be provided where practicable.
(c) Every floor, working place, and passageway shall be kept free from protruding nails, splinters, holes, or loose boards, as practicable.
According to Zach Knoop, safety director for Knife River Corp., housekeeping was the 15th most cited standard in surface sand and gravel operations (408 violations) — and the 6th most cited standard in surface stone operations (557 violations) — in 2011.
“As you can see, it is a focal area for inspectors,” he says.
Knoop says there are a number of situations that can lead to a citation being written for housekeeping. “Within Knife River, we usually see them written for material buildup on catwalks,” he says. “We don’t always agree with the citations, but that is where we typically see them.”
Why is material buildup a problem? It can cause unsteady footing that can lead to the aforementioned slips, trips, and falls, Knoop says.
Mark Rock, vice president of risk management for CalPortland Co. agrees. Employees should be educated that it is necessary to pick up a broom or shovel and clean up a mess that might be on hand — and the lesson sticks better when they know why. “Let them know, as an industry, how many folks have been injured because of a mess like that,” he says.
“It may just look like a pile of material, but it is a heck of a lot more,” he continues. “That pile of material can indicate there is a belt slipping, or a maintenance problem with a piece of equipment. It can indicate contamination problems. It’s really helpful to teach employees to take care of the little things — and also look beyond them to the cause.”
Joseph Casper, vice president of safety services for the National Stone, Sand & Gravel Association (NSSGA), notes that the housekeeping standard for MSHA certainly may sound like a minor thing to follow, but it can set the foundation for meeting other safety standards. “If you do well in your housekeeping, you will do well in compliance with a lot of other standards,” he says.
Keep a Clean House
1. Frequently cited
MSHA has a standard that focuses directly on housekeeping. In a nutshell, its directives outline the need to keep operations clean, orderly, and dry (so far as possible) — with safe access that is free of spilled material, refuse, protrusions, apparatus, or holes — to prevent slips, trips, and falls. Still, housekeeping is the 15th most cited standard in surface sand and gravel, and it ranks 6th most cited in surface stone.
2. Safety perspective
Poor housekeeping practices — allowing loose material or lubricants/oils to accumulate on walkways and access points — can easily lead to slip and fall injuries. But it’s beneficial to educate employees about looking beyond the mess to the maintenance issues that might be the cause. A pile of material might indicate there is a belt slipping. Oil or lubricants could mark a mechanical problem.
3. Disproportionate importance
Housekeeping for aggregate operations is disproportionately important to the way its implications might be perceived amongst employees. It may not seem as though the practice (or lack thereof) should carry serious connotations, especially when guarding seems to bear greater emphasis. But not only does a clean operation present fewer hazards, it also tends to provide a basis of compliance for other standards.
4. Small steps
It’s somewhat counterintuitive to take care of small housekeeping issues when larger ones may loom. Paying attention to the small things — looking beyond the task at hand to scout out possible housekeeping issues — can pay big dividends. The goal should be to go beyond compliance, and teach workers to look out for housekeeping issues to protect themselves and their co-workers.
5. Look under the hood
In order to exceed mere compliance, employees should learn to be proactive, and “look under the hood” in an operation to see what might be causing housekeeping problems. This is a mindset that takes some work to instill in workers. One way to start is to conduct audits of past citations and even near misses to discover their causes. In time, such training can lead to better habits throughout the workforce.
6. Awareness opens doors
Fewer citations and a safer overall workplace are worthy reasons to improve housekeeping for any aggregate operation. But less obvious benefits to improving practices are improved customer and neighbor relations. Good housekeeping, with attention paid to the details, shows pride in the operation — and it also opens the door to being perceived as an overall productive, efficient, and community-friendly facility.
Zach Knoop has been safety director for the past seven years for Knife River Corp., a Bismarck, N.D.-based construction and construction materials company. He is responsible for developing a culture of safety throughout Knife River Corp. Knoop, who has been in the safety field for more than 12 years, is this year’s winner of NSSGA’s James M. Christie Safety and Health Professional award.
Joseph Casper has been vice president of safety services for NSSGA for almost four years. He previously is vice president for Environment, Health & Safety with the Brick Industry Association (BIA). Prior to his time at BIA, Casper worked for the Point-of-Purchase Advertising Institute, BMW of North America, the U.S. Department of Commerce, and the office of the vice president in the White House.
Mark Rock is vice president of risk management for Gendora, Calif.-based CalPortland Co. With 36 years of experience in the safety and health field, Rock is currently working with NSSGA’S Health and Safety Committee, as well as the Portland Cement Association’s Health and Safety Committee. Rock graduated from Indiana State University with a bachelor’s degree in Safety Management.
Voices of Experience
“Housekeeping issues are easy to spot,” says Zach Knoop, safety director for Knife River Corp. He explains that they can comprise such problems as material buildup on catwalks; cables in walkways; tool trailers and Genset trailers not being clean and orderly; lack of housekeeping in service trucks; accumulation of mud and/or water in tunnels or travelways; and material such as boards, screen cloth, and tools on work platforms.
Knoop says guarding is, arguably, the biggest offender for MSHA inspectors, followed by electrical issues. “With all the power cords it takes to run a crusher or wash plant, there are lots of opportunities for inspectors to find violations,” he notes, explaining that the electrical cord issues can tie in with housekeeping citations. In fact, everything ties together when working toward a safety culture, including housekeeping, power, guarding, ground control, and more.
Ultimately, to minimize citations and eliminate injuries, Knoop says, operators must define the expectations of the crew. What are the desired safe behaviors? “Once you have identified those, you train your employees on them, observe to make sure those expectations are being met, and then recognize performance. It takes more than just being compliant,” he says. “You have to set your sights higher and work on creating a culture of safety if you want to eliminate injuries and illness. If you have an operation where nobody can get hurt, then, theoretically, you should never get a citation (and I stress theoretically).”
Knoop says the key to ensuring a safe work environment is to conduct quality workplace examinations, which MSHA requires to take place during each shift. “Having employees trained in what to look for and how to go about correcting unsafe conditions or acts is fundamental in ensuring that the house is kept clean,” he adds.
Keeping a clean house in your operation, as the title might imply, is “nice,” says Joe Casper, NSSGA vice president of safety services. “But it has a dual set of meanings. Yes, it is important to keep your site neat and clean, because it affects how your customers and neighbors perceive your operation. But it also is extremely important for safety,” he says.
To Casper, housekeeping issues can lead to a number of injuries and near misses. In order to effectively address the safety aspect of housekeeping, it is important to “get under the hood” of what is going on behind the cause of housekeeping concerns, to ensure that standards are truly being met. In addition, operations should work to create processes for analyzing near misses, as well as conduct audits of the practices or mistakes that led to the near miss. All of these endeavors work toward an ultimate goal of operating under a culture of safety.
Casper says housekeeping telegraphs an obligation to employees to think for themselves. “This includes thinking about exceeding the standards and taking care of the little things,” he says.
He offers a parallel between housekeeping at aggregate operations and former New York City mayor Rudy Giuliani’s crime-fighting efforts. “When Giuliani was elected mayor of New York City, he said he would go after crime by first attacking the little crimes — for example, the ‘squeegee’ people,” Casper says. “His theory was that by going after the little crimes, the big crimes would follow. It seems counterintuitive, but the data showed he was right.”
The same holds true when making an effort to address the “minor” aggregates housekeeping issues, says Casper. “If you take care to address the smaller things, the larger things will follow. And that will lead to better compliance overall with MSHA standards and a safer overall operation,” he explains.
“Housekeeping, to the outside observer — whether he or she is a customer or an MSHA inspector — is a good indicator of where a company is in respect to safety,” says Mark Rock, vice president risk management for CalPortland Co.
That said, CalPortland works hard to tie housekeeping in with its extensive safety regimen, which has made some groundbreaking progress with MSHA.
According to Rock, CalPortland approached and formed a partnership with the Western District of MSHA in 2006, with a goal of creating better understanding between the two entities. “MSHA came up with criteria that it wanted in our agreement, and we were able to come up with our own agreement criteria,” Rock explains. “There was give and take, and, in October 2006, we had a formal, structured agreement.”
With the agreement in place, Rock says, MSHA holds CalPortland to a higher standard than usual, but MSHA also is part of the solution to reaching that standard. “We wanted to be able to meet on issues and collectively solve them,” he says.
Since that time, the increased rapport with MSHA has been nothing short of incredible, Rock says. Inspectors know they will be treated with respect and will get cooperation from personnel at CalPortland sites. And in return, they are a great resource for best practices. “We can pick up the phone and call them. It’s an incredible benefit,” he adds.
The partnership does not mean CalPortland doesn’t receive citations, and it doesn’t mean the company won’t contest them, if necessary. “But without this partnership, I don’t think we could be as good as we are in respect to employee safety,” Rock notes.
“We know there’s not one silver bullet. It takes small steps to put things into place, which leads to taking care of the bigger things where safety is concerned,” Rock says. “MSHA is helping us get there.”
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