September 13, 2020 • 36 mins
Find out how to understand and manage risk in your manufacturing facility – make your organization more profitable, agile, and flexible. Discover initial OSHA challenges and hazard assessments for COVID-19. OSHA 3990 - Guidance on Preparing Workplaces for COVID-19.
Guest: Christy J. Jennings, ARM, COHC. President / Senior Safety and Health Consultant at SafeMetrics LLC.
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Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Speaker 1 (00:02):
Welcome to the buck room marketing, new media
podcast, your resource for B2Bmarketing for manufacturing in
the related industries, youcreate unrivaled products and
services.
We tell your story now onto theshow.
Speaker 2 (00:18):
I'm Deb daily, your host for today's program and
co-founder of Buckaroomarketing, new media today's
guest Christy Jennings, who isthe president and senior safety
and health consultant for safemetrics.
Hey Kristy, welcome to our show.
Speaker 3 (00:33):
Hey, thanks for having me.
Speaker 2 (00:36):
So why don't you tell us a little bit about your
background and how you got to bewhere you are?
Speaker 3 (00:42):
Sure.
So I started out as emotioncompliance officer, um, which
has really given me the abilityto understand how OSHA manages
the interpretation of the law.
Uh, but then I went from OSHA toan insurance company, which is
kind of an unusual jump, right?
Not many people do insurancefrom OSHA, but it gave me a real
(01:03):
perspective on how to managerisks and the interpretations
that maybe other agencies woulduse on applying the OSHA
standards and the EPA standards.
So that was a unique experience.
I was there for 15 years,roughly, and then from there I
went to, um, consulting.
So I gathered all that knowledgethat I got from OSHA and the
(01:26):
insurance companies, and triedto service others in, in giving
them, uh, an understanding and Ifind side of how to interpret
the law, how to manage theirbusiness within the aspects of
the law and how to reduce risks.
So that's kind of, that's kindof my history.
I've been doing this for, uh, 25plus years.
(01:46):
I'm not so sure.
I would always want to say that,but yes, it's been a while.
So I really rely on myexperience and wisdom to help
clients do what they need to doto get done.
Sure.
Speaker 2 (01:56):
And I'm sure that's so much more valuable than book
knowledge because there's somuch you can't learn a book, so
you need hands-on practice.
Speaker 3 (02:02):
Absolutely.
Absolutely.
I think, uh, the boots meets theground is a real valuable asset
because not every condition isthe same.
Right.
But you can identify conditionsthat while I had this client and
, uh, this is what they did.
So I think that a lot of comeswith the wisdom piece.
So I guess, uh, I'll take, I'lltake the wisdom sometimes.
(02:22):
Right.
So
Speaker 2 (02:25):
What does arm and CMHC stand for?
Speaker 3 (02:29):
So arm is an insurance designation is, uh,
associate and risk management,which is a broad certificate
that identifies the concepts ofhow you manage risks.
Right?
You can accept the risks.
Um, you can choose not to managethe risk and take the
punishments or the correctiveactions that come with it.
So it identifies the differentways, um, of risk and managing
(02:52):
risk it's.
Um, again, it's an insurancedesignation, but it's applicable
really along all lines of reallywhat we do.
Right.
Um, and the other one, I thinkthe business see OHC, which is
certified occupational hearingconservationist.
So what that is, is it's reallymore specific to OSHA and how
OSHA reviews, audiograms and theneed for hearing conservation
(03:15):
program.
Um, so it's a little bit of aspecialty that allows us to do
certain things, um, from acertified manner under the
hearing conservation programsthat OSHA requires.
So, okay.
Did not know that.
Yeah.
So
Speaker 2 (03:31):
Why don't you tell me about safe metrics and the types
of services that you provide?
Speaker 3 (03:38):
Okay.
So save metrics, uh, is acompany that was started back in
2006 and we've evolved into abroadly applicable.
We call it a risk managementcompany.
So oftentimes there's varioustypes of risks that
manufacturers have to reallynavigate throughout their
(03:59):
business day, whether it be OSHAor EPA or, um, the loss of an
injured employee.
Um, but they all have risks inthem.
So that's what we try and do ismanage that risk on behalf of
the client, understanding theaspects of the compliance piece.
But also if there's a creativitypiece that if we can manage it
(04:19):
in a way that makes themmanufacturer more profitable,
profitable, um, more agile, moremalleable, right?
Because that's really what youwant to be as a manufacturing.
You want to be flexible.
And so that's what we do is kindof, it's a little bit of
science, but it's a little bitof art.
So we do, um, OSHA compliance,EPA compliance, which is pretty
standard expectations.
(04:41):
And then we have, um, we reachout from the risk management
aspect and we do claimnavigation, which is worker's
compensation adjusting, but witha little bit of a creative
twist.
So, um, that's a unique piece.
We have a telephonic nurse onstaff within COVID.
That was a condition that wethought was very valuable where
(05:02):
people would not necessarilyneed to go to a brick and mortar
facility to receive treatment,but they could get oversight on
how they were feeling and whatthey were feeling.
Um, and if it would impact awork comp claim and if it was
wellness related.
So that telephonic nurse piececame into to be a big player, um
, during COVID.
So it's a lot of items that arerisk management related, but
(05:26):
those are, those are the keyservices, um, OSHA, EPA claim
navigation.
We have, um, online training,classroom training, um, OSHA
audits, I mean just the gamut.
So really it's considering whatthe employer is interesting is
interested in managing and howwe can creatively, make them,
have them meet their goals.
(05:46):
So
Speaker 2 (05:46):
It's not necessarily where you have to do everything.
If they already have thetraining piece in place, you can
absolutely.
You can, you know, your, yourcompany will go in and fill in
the gaps if need be, or providethe full meal deal if necessary.
Speaker 3 (06:01):
So you could get it Allah card, if you'd like, or
you can get it as a menu ofservices.
And so, you know, really that'sthe creative piece, the art and
the science that goes along withit is understanding the client,
understanding a budget,understanding their
expectations, how quickly theywant to get there.
And then having us just sprinklethe salt and pepper on the meal
and making it taste a little bitbetter.
(06:21):
So we can be the full meal, orwe could just be a side dish or
whatever really fits the, um,the client's needs.
Um, some of them are jobspecific.
Uh, we just have this specificniche, we just need air
monitoring completed, or aresponse to an OSHA letter, or
we could be the, um, uh, like acontractor that works that
(06:43):
puzzle piece all the time forthe insured.
So, um, it really varies, but,uh, yeah, we're flexible.
And I think that's part of whatmakes us a little bit unique.
Okay.
Speaker 2 (06:54):
Um, so why don't we talk about some of the shared
challenges that manufacturers,um, face, cause I know a lot of
your clients are manufacturingrelated, right.
Or industries that servemanufacturing.
So what types of challenges, uh,are you currently seeing and
what are they facing?
What are some comments?
Speaker 3 (07:14):
Um, I mean, I think the obvious is COVID right, is
there's, um, uh, a conditionthat's not been assessed before,
so how do we manage it?
So that's, that's quite common,but you could still use those
same principles in many otherthings that manufacturers are
being feeling.
Um, we're seeing now that peoplecan't get the training done
necessarily because either theydon't have a comparable staff,
(07:38):
um, or you have people that arenot always on site because of
COVID or changed workingconditions.
Um, so meeting the complianceelements, uh, are becoming a
little bit more difficult.
Um, and it's not just becausethe individuals or the companies
are not able, but they've beengiven just a whole nother, um,
set of conditions that they haveto manage.
(08:00):
So, uh, under the auspices ofOSHA, um, COVID has to be
managed as a risk, which meansyou need to have a hazard
assessment completed and youneed to have a PPE hazard
assessment completed, which areall technical terms.
But if you have an OSHAcompliance visit on site,
they're going to ask for thesethings.
So it's not just the CDCresponse, which is probably the
(08:23):
natural response, right.
But there is an OSHA response toit.
And perhaps social has not beenthe leading voice in this event.
Um, but they are a voice thatneeds to be addressed.
And there are certain, um,safety methods that still need
to be addressed with the riskbeing COVID.
(08:43):
And so those are some thingsthat we've seen, um, employers
not recognize as a currentcondition or, or made the
connection that, that, thatCOVID is a risk enough that we
have to have those, those otherprotocols in place.
Um, so, you know, PPE and hazardassessments and all those
conditions are methods todetermine the amount of risk and
(09:04):
then how do we manage it?
And I think there's adisjuncture there that employers
don't recognize that COVID is anOSHA issue that they have to
manage effectively as well.
Okay.
Speaker 2 (09:14):
Because I know some, you know, obviously was people
were moving back into theworkplace.
Um, most companies had to have aplan in place.
Right.
You know how to, so we're goingto go in place what they were
going to do, not have to havethe cafeteria open or whatever
those are, those things thatfall under OSHA,
Speaker 3 (09:34):
Believe it or not.
Yes.
So there's two things thatyou've spoken about.
There is actually, um, aresponse plan or a control plan
that OSHA asks that employershave and put together, um, that
all these separate conditionsthat they've managed, uh, travel
policy, um, working at home, um,absentee policy, all those kinds
(09:57):
of things should be put togetherin a single freestanding OSHA
policy for COVID.
All right.
So it's a preparedness planessentially, but then you also
noted, um, the return to workconcepts.
And, um, OSHA's recently, um,listed, um, um, a large
publication, I think, um, uh, Ithink it's OSHA publication, 39
(10:20):
90, uh, but that's one, that's areturn to work.
So she actually has a multi pagedocument that itemizes the
issues that they think should bepresent when there's the return
to work protocols.
And so many of them employersare probably already doing, um,
uh, sanitizing and disinfectingand giving those controls to the
(10:41):
employer to clean theirworkspace.
But there's other things about,um, uh, absenteeism and how do
we manage those policies whensomeone at home is ill, right?
So there is a publication thatpeople can go and look at that
OSHA has put out that is, thatrespects the return to work
phase that w that we're in.
(11:02):
And if you'll take a look atthose specific things, there's
somewhat of a checklist.
So ensure that that checklist iscompleted, or you have those
pieces in your policy.
Um, and then you're, you'regoing to have a much tighter
return to work policy,addressing all aspects, instead
of just perhaps the linearaspects that we would expect
sanitizing disinfecting andthose types of things.
(11:23):
There's telecommuting policiesand absentee policies and
whistleblower policies that areall spoken about in that
publication that, that are, thatare very good to understand.
Speaker 2 (11:34):
Okay.
All right.
Now, um, with that, as far asthe OSHA, is this, I mean, help
me understand when OSHA isapplicable as it, is it to a
particular size of business,public, private,
Speaker 3 (11:52):
No.
Uh, and that is, uh, often anissue that employers don't
understand correctly enough.
Um, so it's, if you have anemployee that's working, um,
then the individual is coveredby the OSHA laws and regulations
and it's, uh, there's public,there's private.
There's, it's just, it's, it'sthe gamut that way.
(12:14):
So there's no, um, there areone, one requirement is if you
have 11 or more people at yourfacility, then you have to do
the OSHA 300.
So anything less than that, youdon't have to do the OSHA 300.
Um, but there, beyond that,there's not an indication of a
head count that makes OSHAregulations apply and OSHA
(12:37):
regulations not apply.
So if you're working and you'rein the environment of the SIC
code and standard industrialclassification code that OSHA
says they cover, then thestandards apply if your
operation is completing that.
Um, right.
So if you don't use beryllium,uh, then the Berlin standard
(12:59):
wouldn't apply, right?
But the basic standards aregonna apply to most employers,
uh, personal protectiveequipment, um, fire
extinguishers, emergencyevacuation, um, safety committee
is not a standard, but it is amethod to get you to execute
what OSHA asks you to completeunder their standards.
So there's no numericalheadcount that would apply to
(13:23):
OSHA compliance or when the OSHAstandards would not apply.
Have
Speaker 2 (13:28):
You had any, um, is OSHA doing any kind of response
in relation to, you know, somany, um, team members have
switched to working from home?
Is there anything that theemployer has to be concerned
about or, you know, somethingthat needs to cover that
umbrella?
Speaker 3 (13:46):
Oh, well, it's interesting.
Yeah, it's interesting.
Just because they're at home,they're working.
Right.
And so the condition of workingis really what OSHA overseas.
So we have had, uh, in our claimnavigation team, we have had
injuries where an employee hastripped on the kitchen table
leg, which is their desk, right.
(14:08):
And have fallen and hit thefloor and had an injury.
So those conditions still apply.
They're not as rigorous as beingon a manufacturing floor, but
they still apply, especially ifyou're doing work on behalf of
the employer, which is work.
Right.
So those are conditions, alittle lighter, um, with respect
to, um, you probably don't have,again, exposure to beryllium at
(14:29):
home.
Right.
But you may have exposure toergonomics at home, which is the
office or the workplace.
So the standard switch a littlebit, but they're still
applicable.
Um, and you know, with thechange in the COVID conditions,
um, those still the COVIDapplications and the conditions
of COVID risk, um, still applyat home.
(14:51):
Um, and so those are uniquethings that don't differ
depending on your workplace.
Some things will differ PPE.
You're probably not going towear it in your kitchen when
you're doing your office work.
Right.
But you may have ergonomics oryou may have, um, uh, potential
for back injury, uh, dependingon what your file box is.
It just really depends, but, uh,there's no exclusion for working
(15:12):
at home.
Okay.
Speaker 2 (15:13):
Okay.
Now, um, you know, we've broughtup, you know, COVID-19 has kind
of thrown a wrench in this wholething, so many levels, but, um,
how, what are you seeing inrelation to if you have single
location versus multiplelocation, uh, manufacturers and,
and maybe share what's going onin that?
Speaker 3 (15:35):
So there are some variables, right?
If they have multiple locationentities, all in one state, it
makes it a little bit easierbecause there were state
specific rules on traveling orstate specific rules on
quarantining that made itdifficult.
So oftentimes you'll see a multilocation employer, um, create
(15:56):
the policy that is the mostrestrictive for all their
locations and that mostrestrictive, uh, uh, policy
applies to everybody, right.
Management enforcement's mucheasier.
There's much less subjective.
Um, why do they get to do this?
And we don't type of thing.
So with the multi-employerlocation with most policies, um,
(16:17):
it's a global application, um,of the expectation.
Um, so that becomes a challengewhen you have multiple locations
at different states.
Um, but if they're all in thesame state, it's just the common
coordination of risk management.
How do we ensure that eachlocation is executing the policy
(16:37):
as delivered?
And there's not so many sites,specific, subjective conditions
that you change.
Right.
And it, depending on theemployer, they're going to give
you that right.
To make it site-specific.
Um, but not.
So site-specific that theapplication, uh, the intent of
the application is different.
(16:57):
So, um, multi-employer locationsjust have a stronger challenge
because they have more people,more locations.
I mean, that's just inherentwith any type of OSHA condition.
Um, but the, the COVIDconditions, again, have that
extra twist, if there's, um,different requirements by, by
state, um, some of the locationshave higher incidence rates.
(17:19):
So Illinois was a little bitdifferent than Indiana for, for
a time.
So we have people living forexample, in Illinois, but they
work in Indiana.
So there are some complexitiesthat way, but, um, employers
just really need to think itthrough.
And, um, my suggestion hasalways been, um, established one
single policy and make itapplicable for all locations all
over for all states that makesimplementation much easier and
(17:41):
policy and procedures mucheasier as well.
Okay.
There's a lot to it.
Yeah.
Yes.
That is, there is a lot to it.
Speaker 2 (17:53):
Now, talk to me about , um, you know, you've had some
worst case scenarios be a littlebit about that.
Um, and things that came up thateither, you know, just new
experiences or challenges that,um, you know, uh, manufacturers
had
Speaker 3 (18:13):
To deal with.
So we had a few clients that,um, early on had conditions that
we didn't anticipate we weregoing to have to manage.
Right.
So, um, one of them was afatality, a COVID related
fatality, which was at thattime, which was considering now
(18:34):
would be considered mid pad, midpandemic, right.
So we didn't necessarily knowhow to respond.
Um, the agency wasn't sure howthey were going to respond.
Um, we, as a consulting team,we're alert, we're looking for
interpretations or enforcementmemos.
And at that time there weren'tmany out in the enforcement men
memos are often things that OSHAputs together that says, this is
(18:57):
what we said, but this is how Iwant you interpreter.
This is how I want you toexecute it.
Right.
So I want you to have a pandemicpolicy, maybe the expectation,
but the interpretation would bethe pandemic policy should
include these items.
So it's short of an OSHAstandard, but it gives guidance
to employers on how OSHA isgoing to enforce, um, the
(19:19):
activities that they've saidthat they're going to look for.
And so at that point, we didhave some difficulty because we
didn't have any enforcementmemos.
So we felt like we were runningblind really.
Um, but to have a fatality thatwas COVID related at a facility
was very difficult because wealso had some other things to
(19:39):
prove we had to prove, uh, wherefrom contact tracing, where the
fatality occurred, was it anexposure from the work site, or
was it an exposure and avocational exposure, not work
site related, um, and to makesure that we made those two
conditions, black and white andthat they weren't gray because
if it was black and white andthe individual past, because of
(20:02):
contact from a family orsomething outside of the work,
um, uh, when OSHA on thiscondition, she actually came in
and had a, um, a complianceinspection.
And so that was very key andidentifying that, yes, it was
COVID related, but the contactwas not at the workplace.
And so what was key about thatis we kind of pulled back the
(20:25):
layers of the onion and theindividual was the first
individual to have a recordedCOVID case at this location.
So that was pretty key becauseif it was the first person to
have a COVID case, he couldn'thave gotten it at the workplace.
So those became very keyindicators on how we then
(20:46):
managed going forward, um, uh,how we were going to manage, not
just the additional conditions,but the perception of risk that
the employees had, but also howwe would respond to OSHA in the
wording that we recused and the,um, mannerisms that we would use
in the compliance letter.
Uh, that was very key, right?
(21:06):
So, um, those are two thingsthat contact Tracy becomes very,
very important to be able totrace the conditions of risks
and to help the employeesunderstand that the perception
of risk is there, but the th thedeath or the passing didn't
occur because of a loss at the,you know, the contact at the
work site.
So those were very key pieces,um, in evaluating a fatality, it
(21:30):
was scary, but once you pulledthe emotion away from it, you
really had to look at thescience behind it.
And what records were did wehave in place and to contact
tracing, and how could we provewhat was truth and not the
perception of truth.
So that was important.
Speaker 2 (21:48):
And, um, I know that you had mentioned to me by
happenstance, a previous clienthad had pandemic preparedness
training before this actuallyhit.
Um, what types of things didthat training cover that helped
them,
Speaker 3 (22:06):
You know, anticipate what was coming?
Yeah.
What was coming?
Yes.
So, um, we did pandemic, uh,training through our online
delivery system in June of 19for this particular client.
And, um, the client had, uh,matured, um, from their safety
program.
(22:26):
We've been working with them for10 or 12 years in the city had
really matured, um, all the OSHAcompliant things we had
completed.
So the next expectation was youlook beyond OSHA compliance and
you go to best practice orindustry practice.
Um, and that was an indication,uh, we just felt some rumblings,
uh, on the OSHA side ofcommunicable disease,
(22:49):
tuberculosis, those kinds ofthings, which, um, is not
tackled in the bloodbornepathogen standard or any other
standard that OSHA currentlyhas.
So that was, um, avoid that wefelt was present.
Um, the timing in part was luck,but once you have a mature
program, you look to things thatare risks that OSHA doesn't
manage.
(23:10):
And this happened to be one ofthem, what was really
communicable disease was theconcept.
Um, and we decided to deliver itfrom a pandemic, um, uh, angle,
um, which is the communical bowl, public disease component.
Um, and so they did thetraining.
And so with that training, ittriggered certain things.
They, um, I response plan, howdid we manage it now?
(23:31):
I'll be honest with you.
Response planning for thatcompany has changed three or
four times because our responseover time has changed, right?
So it's not just been, uh, I'mgoing to create a plan and put
it in a binder and put it on theshelf.
But this was a living documentthat three or four times we
changed it, we've added policieswhen the risk became greater, or
(23:52):
they had clients that said, uh,we've had a, um, a condition
that I want you guys to respondto, and we put it in policy,
right.
So we would talk about it in thetoolbox talk, and then we would
memorialize it into a policy.
Um, but it, it helped us, orallowed us to anticipate those
conditions that I don't thinkmany employers would have
(24:14):
tackled.
Had they not been workingoutside of OSHA compliance into
an industry best practice, orjust a broad management of risk.
Right.
So, um, so yeah, that was, um,that felt good.
So it got them started inadvance, you know, leading the
race.
And then, uh, we've, we've beenreally successful, no direct
(24:36):
contact conditions and nofatalities relative to COVID.
And so it just, it gets you outof the gate a lot quicker.
So it was a good opportunitysure.
Better than
Speaker 2 (24:47):
At least some direction, instead of, you know,
right.
Speaker 3 (24:50):
So you had some right.
And then it has to mature.
I mean, that's really the, the,what both, what policies do when
you're doing risk management,you start with the core concept.
And as you roll that out, you'regoing to get site specific
expectations.
And then you manage those sitespecific expectations.
Each client is going to havetheir unique application and you
(25:11):
need processes and things thatyou could start with something
that's OSHA related, but thenyou have to make it site
specific.
So that's really what we did.
We started with that corepandemic, public communicable
disease policy.
And then we rolled out this,this company happened to be a
contractor, which is unique inthat they don't have their
employees at the same facility,seven days a week or five days a
(25:33):
week.
Right.
They would roll their employeesout to do service work at
different locations.
So that was a different twistthat we had to evaluate.
So there were conditions, um,uh, but having that pandemic
training early on, got us out ofthe gate and we weren't reacting
all the time.
We were had a proactive approachto what we were going to do.
And so it was a little bit lessstressful for the employees
(25:56):
because they could anticipatewhat our thought process was in
that, in that policy and how wewere going to respond well from
the employee
Speaker 2 (26:05):
Standpoint, just knowing that there was something
proactive already in place,right.
Management had already beenthinking about this and, you
know, what do we do, uh, thathalf that would have to be a
little bit comforting because asan employee, the first thing you
worry about is, oh my gosh, whatif I get this and take it home
to my family and my kids and youknow,
Speaker 3 (26:25):
All that.
Right.
Yeah.
So I think just getting out ofthe box early gave us peace of
mind on how to manage itproactively and not reactively.
Although reactive sometimes isthe way you have to manage an
event or an accident or a lossof risk.
Um, but it is comforting to feellike we don't have to do it, um,
(26:49):
quickly, which sometimes leadsto stops and starts or
interpretations that managementmay not know what they're
talking about, you know, andthat's, those are not, um,
conditions that you want to, um,convey to your employees.
Uh, they need to feel safe andsafety is part of having things
done proactively.
Speaker 2 (27:08):
Sure, sure.
Um, now we talked a little bitabout, um, as far as, you know,
with the fatalities and, youknow, whether it starts, you
know, trying to, throughtracking, figuring out where it
started, if it's at work or notat work and what have you.
Um, but why don't you talk to meabout what are some of the most
(27:33):
important things clients,manufacturers need to know?
Um, because we don't always knowwhat we don't know.
Right.
And once we know it, where do wego for help?
How do we execute?
Right.
So to your attorney, do you goto HR for, you know, policies or
, you know, that kind of thing.
Speaker 3 (27:53):
Right.
So what we see, um, what we'veseen recently is employers
having difficulty, um,executing.
So we all do very well atdeveloping a policy, right?
And the policy is developed witha key group of people, whether
it be the management team or thesafety committee team.
But oftentimes we have, um,struggles getting that policy to
(28:17):
ha to be boots on the ground,right.
To train the employees, to havethe employees understand the
reason for the policy.
Um, and just to complete thatcircle of the policy, you don't
create a policy, put it in yourbinder and sit it on your shelf
and let it gather dust, right?
A policy should really besomething that people reflect on
(28:39):
to make the decisions based onwhat the policy is saying.
So those are conditions that wefind employers struggle with.
Um, creating a policy is not thedifficult part, it's the
execution and the training, andthat like a pyramid, you start
with the policy of the tab,which takes a smaller amount of
time, but you get dark downtowards the wide part of the
(29:00):
pyramid and it takes more time.
So the base of the pyramid isthe amount of time it takes to
get people trained and to getpeople on board and to give them
empowerment, to understand thebenefits of the policy.
And so those are pretty commonstruggles that we see from a
risk management side.
Um, if they don't clearly knowwhat to do, they also sometimes
(29:24):
don't know where to find theresources, right.
So the common resources havebeen directed is, um, uh, your
insurance broker or yourinsurance agent, um, and an
attorney.
Um, but sometimes those areprobably not the best sources
just because that's not theirarea of expertise.
Um, we often like to say, we'dlike to be one of the top three
(29:45):
business cards in, uh,management teams, you know, card
file, right.
Because we can satisfy thoseconditions, perhaps that
manufacturers didn't realizethat there was a niche
professional that could providethat information.
I mean, you don't go out lookingfor an OSHA consultant, right?
Oftentimes you look for themonce you have the issues, but
(30:05):
the conditions that we reallylike to have employers do is
manage it as effectively as youmanage quality, um, or you
manage, um, hiring, right.
They should be one of your topthree and safety and
environmental compliance issomething that, um, not only
provides worth but value, butemployee retention, um, comfort
(30:26):
and less stress.
And, um, just nice to pullsomebody up on your contact list
on your phone and say, Hey,OSHA's here.
Um, as opposed to trying to lookin the yellow book pages, right.
And trying to figure out whoshould I call.
So that's the relationship thatwe try and manage.
And, uh, um, it just gives peaceof mind to people, uh, and
(30:48):
companies, you know, in themidst of, of a risk.
Speaker 2 (30:51):
Right, right.
And I'm sure obviously proactiveis much better than reactive.
Speaker 3 (30:56):
Absolutely.
I mean, we, we always say it isright, but it's, it's really
putting the, the, the metal tothe, to the rubber, the rubber
to the road type of thing.
Um, uh, often oftentimes it's onan, a manufacturers with
wishlist, but they don't knowwhere to go to start executing
that wishlist.
(31:16):
So that's part of the servicethat we try and help.
I mean, when I was in oceanspecter, um, we often found it
beneficial that as long as wewere there, the employer now had
some knowledge on how tocomplete what they were supposed
to complete.
But if you're an employer andyou don't know what you don't
know, how do you execute?
Right.
(31:36):
So many times that we, there wasthat service portion of our OSHA
visit is that, um, here's thewebsite, which is osha.gov,
which is a good place just toget started very complex
website, but it's got all thecurrent standards and letters of
interpretation and all thosekinds of things that you would
need to at least get youstarted.
(31:57):
So that would be a good placejust to open that webpage up and
give it a shot.
And then you'll startunderstanding the concepts and
actually have a resource to goto, to help you complete those
requirements.
Speaker 2 (32:11):
Okay, great, great, uh, great advice, uh, as far as
just, you know, because that'sthe first thing that comes to my
mind is, wow, what do I doexactly.
Wouldn't be caught with yeah.
Pants down.
So to be able to figure out whatI, where I should go.
Speaker 3 (32:29):
Right.
Speaker 2 (32:31):
Well, is there anything else that you'd like to
add for today's meeting thatwe've talked about?
Any other
Speaker 3 (32:36):
Words of, I think the only I'll add is it's only
timely to COVID.
There has been some, uh, interimenforcement guidelines that OSHA
has put on the osha.gov, or ifyou're in Indiana on the website
, um, and it gives, uh,employers the flavor of what to
(32:59):
expect when OSHA comes for avisit, if they're actually going
to physically come on site, um,uh, or if they're not going to
come on site, what states theymay not address onsite.
So if you have a high, um, COVID, um, population or a high COVID
, um, incident rate, then OSHAis going to handle those OSHA
(33:19):
inspections for COVIDspecifically, either via mail or
email or phone calls.
So they won't necessarily comeon site unless, you know, the
fatality, they didn't even comeon site that we were involved
with.
So I would just encourage peopleto keep abreast of the OSHA,
interim enforcement guidelines.
And again, there's two of them,there are on low show website.
(33:41):
Now that'll give you a comfortlevel for how OSHA is addressing
those concerns, um, and how toprepare your facility for things
that they will be looking for.
So I guess in the short term,that would be something to help
employers under the currentCOVID crisis.
Okay.
And that's
Speaker 2 (33:58):
A really good point because I've spoken to a variety
of professionals, uh, related toCOVID from different angles.
And everybody always mentionsthe CDC.
You know, you're the first thatsays, Hey, he really needs to
look at OSHA.
And this is where you go to getyou started.
That's not something that maybe,you know, is automatically known
(34:18):
or, you know,
Speaker 3 (34:22):
Yeah.
It's, um, I would have liked tohave seen, um, OSHA to be a
little bit more, um, publiclyvocal in the expectations.
Um, but if you dig down on theOSHA website, there is, um,
expectations.
So if you do your hazardassessment, which is the
protocol for determining risk,and once you find COVID being a
(34:44):
risk, then you have to figureout next process is how do I
manage it?
And so that management does comealong with understanding
enforcement guidelines and theflavor of what OSHA's looking
for, which right now is mostlytraining.
So how have I indicated to myemployees that this is a
condition that they have tomanage and what our policies are
(35:05):
here at the facility?
So, um, when I looked at thewebsite, um, a couple of days
ago, that is what they wereemphasizing on.
The return to work brochure isthe training component can be
done in toolbox talks.
It can be done in zoom calls.
It could be done in a mass emaildistribution, but may make it
regular and make it, um,something that people can
(35:25):
anticipate and use as aresource.
So the training component isbecoming very important or more
important now under the COVIDconditions, um, on what the
policies are and how to react toit that, um, if employers have
no other time than going to theCDC or going to a website that
already has pre-establishedtoolbox talks relative to COVID,
(35:48):
that's a really good start.
Um, we don't always have a lotof time to develop our own, but
there are some out there thatthey can use, um, which will,
uh, document and prove that thetraining concept is being
completed.
Okay.
Speaker 2 (36:00):
Okay.
Well, thanks for that greatinformation.
Uh, it's a pleasure to have youon the show today.
Um, also thanks to our audiencefor tuning in to buck root TV
today.
We hope you've enjoyed the show.
Um, if you have any questions orthoughts, please be sure to let
us know.
And don't forget if you enjoyedthe show today, please be sure
to subscribe to our channel buckroom TV
Speaker 1 (36:22):
Again, Christy.
Thanks so much.
My pleasure.
Thank you.
Thank you for listening to theBuckaroo marketing new media
podcast.
If you'd like to learn moreabout B2B marketing for
manufacturing and relatedindustries, please visit us like
go book a route.com.
Welcome to the buck room marketing, new media
podcast, your resource for B2Bmarketing for manufacturing in
the related industries, youcreate unrivaled products and
services.
We tell your story now onto theshow.
Speaker 2 (00:18):
I'm Deb daily, your host for today's program and
co-founder of Buckaroomarketing, new media today's
guest Christy Jennings, who isthe president and senior safety
and health consultant for safemetrics.
Hey Kristy, welcome to our show.
Speaker 3 (00:33):
Hey, thanks for having me.
Speaker 2 (00:36):
So why don't you tell us a little bit about your
background and how you got to bewhere you are?
Speaker 3 (00:42):
Sure.
So I started out as emotioncompliance officer, um, which
has really given me the abilityto understand how OSHA manages
the interpretation of the law.
Uh, but then I went from OSHA toan insurance company, which is
kind of an unusual jump, right?
Not many people do insurancefrom OSHA, but it gave me a real
(01:03):
perspective on how to managerisks and the interpretations
that maybe other agencies woulduse on applying the OSHA
standards and the EPA standards.
So that was a unique experience.
I was there for 15 years,roughly, and then from there I
went to, um, consulting.
So I gathered all that knowledgethat I got from OSHA and the
(01:26):
insurance companies, and triedto service others in, in giving
them, uh, an understanding and Ifind side of how to interpret
the law, how to manage theirbusiness within the aspects of
the law and how to reduce risks.
So that's kind of, that's kindof my history.
I've been doing this for, uh, 25plus years.
(01:46):
I'm not so sure.
I would always want to say that,but yes, it's been a while.
So I really rely on myexperience and wisdom to help
clients do what they need to doto get done.
Sure.
Speaker 2 (01:56):
And I'm sure that's so much more valuable than book
knowledge because there's somuch you can't learn a book, so
you need hands-on practice.
Speaker 3 (02:02):
Absolutely.
Absolutely.
I think, uh, the boots meets theground is a real valuable asset
because not every condition isthe same.
Right.
But you can identify conditionsthat while I had this client and
, uh, this is what they did.
So I think that a lot of comeswith the wisdom piece.
So I guess, uh, I'll take, I'lltake the wisdom sometimes.
(02:22):
Right.
So
Speaker 2 (02:25):
What does arm and CMHC stand for?
Speaker 3 (02:29):
So arm is an insurance designation is, uh,
associate and risk management,which is a broad certificate
that identifies the concepts ofhow you manage risks.
Right?
You can accept the risks.
Um, you can choose not to managethe risk and take the
punishments or the correctiveactions that come with it.
So it identifies the differentways, um, of risk and managing
(02:52):
risk it's.
Um, again, it's an insurancedesignation, but it's applicable
really along all lines of reallywhat we do.
Right.
Um, and the other one, I thinkthe business see OHC, which is
certified occupational hearingconservationist.
So what that is, is it's reallymore specific to OSHA and how
OSHA reviews, audiograms and theneed for hearing conservation
(03:15):
program.
Um, so it's a little bit of aspecialty that allows us to do
certain things, um, from acertified manner under the
hearing conservation programsthat OSHA requires.
So, okay.
Did not know that.
Yeah.
So
Speaker 2 (03:31):
Why don't you tell me about safe metrics and the types
of services that you provide?
Speaker 3 (03:38):
Okay.
So save metrics, uh, is acompany that was started back in
2006 and we've evolved into abroadly applicable.
We call it a risk managementcompany.
So oftentimes there's varioustypes of risks that
manufacturers have to reallynavigate throughout their
(03:59):
business day, whether it be OSHAor EPA or, um, the loss of an
injured employee.
Um, but they all have risks inthem.
So that's what we try and do ismanage that risk on behalf of
the client, understanding theaspects of the compliance piece.
But also if there's a creativitypiece that if we can manage it
(04:19):
in a way that makes themmanufacturer more profitable,
profitable, um, more agile, moremalleable, right?
Because that's really what youwant to be as a manufacturing.
You want to be flexible.
And so that's what we do is kindof, it's a little bit of
science, but it's a little bitof art.
So we do, um, OSHA compliance,EPA compliance, which is pretty
standard expectations.
(04:41):
And then we have, um, we reachout from the risk management
aspect and we do claimnavigation, which is worker's
compensation adjusting, but witha little bit of a creative
twist.
So, um, that's a unique piece.
We have a telephonic nurse onstaff within COVID.
That was a condition that wethought was very valuable where
(05:02):
people would not necessarilyneed to go to a brick and mortar
facility to receive treatment,but they could get oversight on
how they were feeling and whatthey were feeling.
Um, and if it would impact awork comp claim and if it was
wellness related.
So that telephonic nurse piececame into to be a big player, um
, during COVID.
So it's a lot of items that arerisk management related, but
(05:26):
those are, those are the keyservices, um, OSHA, EPA claim
navigation.
We have, um, online training,classroom training, um, OSHA
audits, I mean just the gamut.
So really it's considering whatthe employer is interesting is
interested in managing and howwe can creatively, make them,
have them meet their goals.
(05:46):
So
Speaker 2 (05:46):
It's not necessarily where you have to do everything.
If they already have thetraining piece in place, you can
absolutely.
You can, you know, your, yourcompany will go in and fill in
the gaps if need be, or providethe full meal deal if necessary.
Speaker 3 (06:01):
So you could get it Allah card, if you'd like, or
you can get it as a menu ofservices.
And so, you know, really that'sthe creative piece, the art and
the science that goes along withit is understanding the client,
understanding a budget,understanding their
expectations, how quickly theywant to get there.
And then having us just sprinklethe salt and pepper on the meal
and making it taste a little bitbetter.
(06:21):
So we can be the full meal, orwe could just be a side dish or
whatever really fits the, um,the client's needs.
Um, some of them are jobspecific.
Uh, we just have this specificniche, we just need air
monitoring completed, or aresponse to an OSHA letter, or
we could be the, um, uh, like acontractor that works that
(06:43):
puzzle piece all the time forthe insured.
So, um, it really varies, but,uh, yeah, we're flexible.
And I think that's part of whatmakes us a little bit unique.
Okay.
Speaker 2 (06:54):
Um, so why don't we talk about some of the shared
challenges that manufacturers,um, face, cause I know a lot of
your clients are manufacturingrelated, right.
Or industries that servemanufacturing.
So what types of challenges, uh,are you currently seeing and
what are they facing?
What are some comments?
Speaker 3 (07:14):
Um, I mean, I think the obvious is COVID right, is
there's, um, uh, a conditionthat's not been assessed before,
so how do we manage it?
So that's, that's quite common,but you could still use those
same principles in many otherthings that manufacturers are
being feeling.
Um, we're seeing now that peoplecan't get the training done
necessarily because either theydon't have a comparable staff,
(07:38):
um, or you have people that arenot always on site because of
COVID or changed workingconditions.
Um, so meeting the complianceelements, uh, are becoming a
little bit more difficult.
Um, and it's not just becausethe individuals or the companies
are not able, but they've beengiven just a whole nother, um,
set of conditions that they haveto manage.
(08:00):
So, uh, under the auspices ofOSHA, um, COVID has to be
managed as a risk, which meansyou need to have a hazard
assessment completed and youneed to have a PPE hazard
assessment completed, which areall technical terms.
But if you have an OSHAcompliance visit on site,
they're going to ask for thesethings.
So it's not just the CDCresponse, which is probably the
(08:23):
natural response, right.
But there is an OSHA response toit.
And perhaps social has not beenthe leading voice in this event.
Um, but they are a voice thatneeds to be addressed.
And there are certain, um,safety methods that still need
to be addressed with the riskbeing COVID.
(08:43):
And so those are some thingsthat we've seen, um, employers
not recognize as a currentcondition or, or made the
connection that, that, thatCOVID is a risk enough that we
have to have those, those otherprotocols in place.
Um, so, you know, PPE and hazardassessments and all those
conditions are methods todetermine the amount of risk and
(09:04):
then how do we manage it?
And I think there's adisjuncture there that employers
don't recognize that COVID is anOSHA issue that they have to
manage effectively as well.
Okay.
Speaker 2 (09:14):
Because I know some, you know, obviously was people
were moving back into theworkplace.
Um, most companies had to have aplan in place.
Right.
You know how to, so we're goingto go in place what they were
going to do, not have to havethe cafeteria open or whatever
those are, those things thatfall under OSHA,
Speaker 3 (09:34):
Believe it or not.
Yes.
So there's two things thatyou've spoken about.
There is actually, um, aresponse plan or a control plan
that OSHA asks that employershave and put together, um, that
all these separate conditionsthat they've managed, uh, travel
policy, um, working at home, um,absentee policy, all those kinds
(09:57):
of things should be put togetherin a single freestanding OSHA
policy for COVID.
All right.
So it's a preparedness planessentially, but then you also
noted, um, the return to workconcepts.
And, um, OSHA's recently, um,listed, um, um, a large
publication, I think, um, uh, Ithink it's OSHA publication, 39
(10:20):
90, uh, but that's one, that's areturn to work.
So she actually has a multi pagedocument that itemizes the
issues that they think should bepresent when there's the return
to work protocols.
And so many of them employersare probably already doing, um,
uh, sanitizing and disinfectingand giving those controls to the
(10:41):
employer to clean theirworkspace.
But there's other things about,um, uh, absenteeism and how do
we manage those policies whensomeone at home is ill, right?
So there is a publication thatpeople can go and look at that
OSHA has put out that is, thatrespects the return to work
phase that w that we're in.
(11:02):
And if you'll take a look atthose specific things, there's
somewhat of a checklist.
So ensure that that checklist iscompleted, or you have those
pieces in your policy.
Um, and then you're, you'regoing to have a much tighter
return to work policy,addressing all aspects, instead
of just perhaps the linearaspects that we would expect
sanitizing disinfecting andthose types of things.
(11:23):
There's telecommuting policiesand absentee policies and
whistleblower policies that areall spoken about in that
publication that, that are, thatare very good to understand.
Speaker 2 (11:34):
Okay.
All right.
Now, um, with that, as far asthe OSHA, is this, I mean, help
me understand when OSHA isapplicable as it, is it to a
particular size of business,public, private,
Speaker 3 (11:52):
No.
Uh, and that is, uh, often anissue that employers don't
understand correctly enough.
Um, so it's, if you have anemployee that's working, um,
then the individual is coveredby the OSHA laws and regulations
and it's, uh, there's public,there's private.
There's, it's just, it's, it'sthe gamut that way.
(12:14):
So there's no, um, there areone, one requirement is if you
have 11 or more people at yourfacility, then you have to do
the OSHA 300.
So anything less than that, youdon't have to do the OSHA 300.
Um, but there, beyond that,there's not an indication of a
head count that makes OSHAregulations apply and OSHA
(12:37):
regulations not apply.
So if you're working and you'rein the environment of the SIC
code and standard industrialclassification code that OSHA
says they cover, then thestandards apply if your
operation is completing that.
Um, right.
So if you don't use beryllium,uh, then the Berlin standard
(12:59):
wouldn't apply, right?
But the basic standards aregonna apply to most employers,
uh, personal protectiveequipment, um, fire
extinguishers, emergencyevacuation, um, safety committee
is not a standard, but it is amethod to get you to execute
what OSHA asks you to completeunder their standards.
So there's no numericalheadcount that would apply to
(13:23):
OSHA compliance or when the OSHAstandards would not apply.
Have
Speaker 2 (13:28):
You had any, um, is OSHA doing any kind of response
in relation to, you know, somany, um, team members have
switched to working from home?
Is there anything that theemployer has to be concerned
about or, you know, somethingthat needs to cover that
umbrella?
Speaker 3 (13:46):
Oh, well, it's interesting.
Yeah, it's interesting.
Just because they're at home,they're working.
Right.
And so the condition of workingis really what OSHA overseas.
So we have had, uh, in our claimnavigation team, we have had
injuries where an employee hastripped on the kitchen table
leg, which is their desk, right.
(14:08):
And have fallen and hit thefloor and had an injury.
So those conditions still apply.
They're not as rigorous as beingon a manufacturing floor, but
they still apply, especially ifyou're doing work on behalf of
the employer, which is work.
Right.
So those are conditions, alittle lighter, um, with respect
to, um, you probably don't have,again, exposure to beryllium at
(14:29):
home.
Right.
But you may have exposure toergonomics at home, which is the
office or the workplace.
So the standard switch a littlebit, but they're still
applicable.
Um, and you know, with thechange in the COVID conditions,
um, those still the COVIDapplications and the conditions
of COVID risk, um, still applyat home.
(14:51):
Um, and so those are uniquethings that don't differ
depending on your workplace.
Some things will differ PPE.
You're probably not going towear it in your kitchen when
you're doing your office work.
Right.
But you may have ergonomics oryou may have, um, uh, potential
for back injury, uh, dependingon what your file box is.
It just really depends, but, uh,there's no exclusion for working
(15:12):
at home.
Okay.
Speaker 2 (15:13):
Okay.
Now, um, you know, we've broughtup, you know, COVID-19 has kind
of thrown a wrench in this wholething, so many levels, but, um,
how, what are you seeing inrelation to if you have single
location versus multiplelocation, uh, manufacturers and,
and maybe share what's going onin that?
Speaker 3 (15:35):
So there are some variables, right?
If they have multiple locationentities, all in one state, it
makes it a little bit easierbecause there were state
specific rules on traveling orstate specific rules on
quarantining that made itdifficult.
So oftentimes you'll see a multilocation employer, um, create
(15:56):
the policy that is the mostrestrictive for all their
locations and that mostrestrictive, uh, uh, policy
applies to everybody, right.
Management enforcement's mucheasier.
There's much less subjective.
Um, why do they get to do this?
And we don't type of thing.
So with the multi-employerlocation with most policies, um,
(16:17):
it's a global application, um,of the expectation.
Um, so that becomes a challengewhen you have multiple locations
at different states.
Um, but if they're all in thesame state, it's just the common
coordination of risk management.
How do we ensure that eachlocation is executing the policy
(16:37):
as delivered?
And there's not so many sites,specific, subjective conditions
that you change.
Right.
And it, depending on theemployer, they're going to give
you that right.
To make it site-specific.
Um, but not.
So site-specific that theapplication, uh, the intent of
the application is different.
(16:57):
So, um, multi-employer locationsjust have a stronger challenge
because they have more people,more locations.
I mean, that's just inherentwith any type of OSHA condition.
Um, but the, the COVIDconditions, again, have that
extra twist, if there's, um,different requirements by, by
state, um, some of the locationshave higher incidence rates.
(17:19):
So Illinois was a little bitdifferent than Indiana for, for
a time.
So we have people living forexample, in Illinois, but they
work in Indiana.
So there are some complexitiesthat way, but, um, employers
just really need to think itthrough.
And, um, my suggestion hasalways been, um, established one
single policy and make itapplicable for all locations all
over for all states that makesimplementation much easier and
(17:41):
policy and procedures mucheasier as well.
Okay.
There's a lot to it.
Yeah.
Yes.
That is, there is a lot to it.
Speaker 2 (17:53):
Now, talk to me about , um, you know, you've had some
worst case scenarios be a littlebit about that.
Um, and things that came up thateither, you know, just new
experiences or challenges that,um, you know, uh, manufacturers
had
Speaker 3 (18:13):
To deal with.
So we had a few clients that,um, early on had conditions that
we didn't anticipate we weregoing to have to manage.
Right.
So, um, one of them was afatality, a COVID related
fatality, which was at thattime, which was considering now
(18:34):
would be considered mid pad, midpandemic, right.
So we didn't necessarily knowhow to respond.
Um, the agency wasn't sure howthey were going to respond.
Um, we, as a consulting team,we're alert, we're looking for
interpretations or enforcementmemos.
And at that time there weren'tmany out in the enforcement men
memos are often things that OSHAputs together that says, this is
(18:57):
what we said, but this is how Iwant you interpreter.
This is how I want you toexecute it.
Right.
So I want you to have a pandemicpolicy, maybe the expectation,
but the interpretation would bethe pandemic policy should
include these items.
So it's short of an OSHAstandard, but it gives guidance
to employers on how OSHA isgoing to enforce, um, the
(19:19):
activities that they've saidthat they're going to look for.
And so at that point, we didhave some difficulty because we
didn't have any enforcementmemos.
So we felt like we were runningblind really.
Um, but to have a fatality thatwas COVID related at a facility
was very difficult because wealso had some other things to
(19:39):
prove we had to prove, uh, wherefrom contact tracing, where the
fatality occurred, was it anexposure from the work site, or
was it an exposure and avocational exposure, not work
site related, um, and to makesure that we made those two
conditions, black and white andthat they weren't gray because
if it was black and white andthe individual past, because of
(20:02):
contact from a family orsomething outside of the work,
um, uh, when OSHA on thiscondition, she actually came in
and had a, um, a complianceinspection.
And so that was very key andidentifying that, yes, it was
COVID related, but the contactwas not at the workplace.
And so what was key about thatis we kind of pulled back the
(20:25):
layers of the onion and theindividual was the first
individual to have a recordedCOVID case at this location.
So that was pretty key becauseif it was the first person to
have a COVID case, he couldn'thave gotten it at the workplace.
So those became very keyindicators on how we then
(20:46):
managed going forward, um, uh,how we were going to manage, not
just the additional conditions,but the perception of risk that
the employees had, but also howwe would respond to OSHA in the
wording that we recused and the,um, mannerisms that we would use
in the compliance letter.
Uh, that was very key, right?
(21:06):
So, um, those are two thingsthat contact Tracy becomes very,
very important to be able totrace the conditions of risks
and to help the employeesunderstand that the perception
of risk is there, but the th thedeath or the passing didn't
occur because of a loss at the,you know, the contact at the
work site.
So those were very key pieces,um, in evaluating a fatality, it
(21:30):
was scary, but once you pulledthe emotion away from it, you
really had to look at thescience behind it.
And what records were did wehave in place and to contact
tracing, and how could we provewhat was truth and not the
perception of truth.
So that was important.
Speaker 2 (21:48):
And, um, I know that you had mentioned to me by
happenstance, a previous clienthad had pandemic preparedness
training before this actuallyhit.
Um, what types of things didthat training cover that helped
them,
Speaker 3 (22:06):
You know, anticipate what was coming?
Yeah.
What was coming?
Yes.
So, um, we did pandemic, uh,training through our online
delivery system in June of 19for this particular client.
And, um, the client had, uh,matured, um, from their safety
program.
(22:26):
We've been working with them for10 or 12 years in the city had
really matured, um, all the OSHAcompliant things we had
completed.
So the next expectation was youlook beyond OSHA compliance and
you go to best practice orindustry practice.
Um, and that was an indication,uh, we just felt some rumblings,
uh, on the OSHA side ofcommunicable disease,
(22:49):
tuberculosis, those kinds ofthings, which, um, is not
tackled in the bloodbornepathogen standard or any other
standard that OSHA currentlyhas.
So that was, um, avoid that wefelt was present.
Um, the timing in part was luck,but once you have a mature
program, you look to things thatare risks that OSHA doesn't
manage.
(23:10):
And this happened to be one ofthem, what was really
communicable disease was theconcept.
Um, and we decided to deliver itfrom a pandemic, um, uh, angle,
um, which is the communical bowl, public disease component.
Um, and so they did thetraining.
And so with that training, ittriggered certain things.
They, um, I response plan, howdid we manage it now?
(23:31):
I'll be honest with you.
Response planning for thatcompany has changed three or
four times because our responseover time has changed, right?
So it's not just been, uh, I'mgoing to create a plan and put
it in a binder and put it on theshelf.
But this was a living documentthat three or four times we
changed it, we've added policieswhen the risk became greater, or
(23:52):
they had clients that said, uh,we've had a, um, a condition
that I want you guys to respondto, and we put it in policy,
right.
So we would talk about it in thetoolbox talk, and then we would
memorialize it into a policy.
Um, but it, it helped us, orallowed us to anticipate those
conditions that I don't thinkmany employers would have
(24:14):
tackled.
Had they not been workingoutside of OSHA compliance into
an industry best practice, orjust a broad management of risk.
Right.
So, um, so yeah, that was, um,that felt good.
So it got them started inadvance, you know, leading the
race.
And then, uh, we've, we've beenreally successful, no direct
(24:36):
contact conditions and nofatalities relative to COVID.
And so it just, it gets you outof the gate a lot quicker.
So it was a good opportunitysure.
Better than
Speaker 2 (24:47):
At least some direction, instead of, you know,
right.
Speaker 3 (24:50):
So you had some right.
And then it has to mature.
I mean, that's really the, the,what both, what policies do when
you're doing risk management,you start with the core concept.
And as you roll that out, you'regoing to get site specific
expectations.
And then you manage those sitespecific expectations.
Each client is going to havetheir unique application and you
(25:11):
need processes and things thatyou could start with something
that's OSHA related, but thenyou have to make it site
specific.
So that's really what we did.
We started with that corepandemic, public communicable
disease policy.
And then we rolled out this,this company happened to be a
contractor, which is unique inthat they don't have their
employees at the same facility,seven days a week or five days a
(25:33):
week.
Right.
They would roll their employeesout to do service work at
different locations.
So that was a different twistthat we had to evaluate.
So there were conditions, um,uh, but having that pandemic
training early on, got us out ofthe gate and we weren't reacting
all the time.
We were had a proactive approachto what we were going to do.
And so it was a little bit lessstressful for the employees
(25:56):
because they could anticipatewhat our thought process was in
that, in that policy and how wewere going to respond well from
the employee
Speaker 2 (26:05):
Standpoint, just knowing that there was something
proactive already in place,right.
Management had already beenthinking about this and, you
know, what do we do, uh, thathalf that would have to be a
little bit comforting because asan employee, the first thing you
worry about is, oh my gosh, whatif I get this and take it home
to my family and my kids and youknow,
Speaker 3 (26:25):
All that.
Right.
Yeah.
So I think just getting out ofthe box early gave us peace of
mind on how to manage itproactively and not reactively.
Although reactive sometimes isthe way you have to manage an
event or an accident or a lossof risk.
Um, but it is comforting to feellike we don't have to do it, um,
(26:49):
quickly, which sometimes leadsto stops and starts or
interpretations that managementmay not know what they're
talking about, you know, andthat's, those are not, um,
conditions that you want to, um,convey to your employees.
Uh, they need to feel safe andsafety is part of having things
done proactively.
Speaker 2 (27:08):
Sure, sure.
Um, now we talked a little bitabout, um, as far as, you know,
with the fatalities and, youknow, whether it starts, you
know, trying to, throughtracking, figuring out where it
started, if it's at work or notat work and what have you.
Um, but why don't you talk to meabout what are some of the most
(27:33):
important things clients,manufacturers need to know?
Um, because we don't always knowwhat we don't know.
Right.
And once we know it, where do wego for help?
How do we execute?
Right.
So to your attorney, do you goto HR for, you know, policies or
, you know, that kind of thing.
Speaker 3 (27:53):
Right.
So what we see, um, what we'veseen recently is employers
having difficulty, um,executing.
So we all do very well atdeveloping a policy, right?
And the policy is developed witha key group of people, whether
it be the management team or thesafety committee team.
But oftentimes we have, um,struggles getting that policy to
(28:17):
ha to be boots on the ground,right.
To train the employees, to havethe employees understand the
reason for the policy.
Um, and just to complete thatcircle of the policy, you don't
create a policy, put it in yourbinder and sit it on your shelf
and let it gather dust, right?
A policy should really besomething that people reflect on
(28:39):
to make the decisions based onwhat the policy is saying.
So those are conditions that wefind employers struggle with.
Um, creating a policy is not thedifficult part, it's the
execution and the training, andthat like a pyramid, you start
with the policy of the tab,which takes a smaller amount of
time, but you get dark downtowards the wide part of the
(29:00):
pyramid and it takes more time.
So the base of the pyramid isthe amount of time it takes to
get people trained and to getpeople on board and to give them
empowerment, to understand thebenefits of the policy.
And so those are pretty commonstruggles that we see from a
risk management side.
Um, if they don't clearly knowwhat to do, they also sometimes
(29:24):
don't know where to find theresources, right.
So the common resources havebeen directed is, um, uh, your
insurance broker or yourinsurance agent, um, and an
attorney.
Um, but sometimes those areprobably not the best sources
just because that's not theirarea of expertise.
Um, we often like to say, we'dlike to be one of the top three
(29:45):
business cards in, uh,management teams, you know, card
file, right.
Because we can satisfy thoseconditions, perhaps that
manufacturers didn't realizethat there was a niche
professional that could providethat information.
I mean, you don't go out lookingfor an OSHA consultant, right?
Oftentimes you look for themonce you have the issues, but
(30:05):
the conditions that we reallylike to have employers do is
manage it as effectively as youmanage quality, um, or you
manage, um, hiring, right.
They should be one of your topthree and safety and
environmental compliance issomething that, um, not only
provides worth but value, butemployee retention, um, comfort
(30:26):
and less stress.
And, um, just nice to pullsomebody up on your contact list
on your phone and say, Hey,OSHA's here.
Um, as opposed to trying to lookin the yellow book pages, right.
And trying to figure out whoshould I call.
So that's the relationship thatwe try and manage.
And, uh, um, it just gives peaceof mind to people, uh, and
(30:48):
companies, you know, in themidst of, of a risk.
Speaker 2 (30:51):
Right, right.
And I'm sure obviously proactiveis much better than reactive.
Speaker 3 (30:56):
Absolutely.
I mean, we, we always say it isright, but it's, it's really
putting the, the, the metal tothe, to the rubber, the rubber
to the road type of thing.
Um, uh, often oftentimes it's onan, a manufacturers with
wishlist, but they don't knowwhere to go to start executing
that wishlist.
(31:16):
So that's part of the servicethat we try and help.
I mean, when I was in oceanspecter, um, we often found it
beneficial that as long as wewere there, the employer now had
some knowledge on how tocomplete what they were supposed
to complete.
But if you're an employer andyou don't know what you don't
know, how do you execute?
Right.
(31:36):
So many times that we, there wasthat service portion of our OSHA
visit is that, um, here's thewebsite, which is osha.gov,
which is a good place just toget started very complex
website, but it's got all thecurrent standards and letters of
interpretation and all thosekinds of things that you would
need to at least get youstarted.
(31:57):
So that would be a good placejust to open that webpage up and
give it a shot.
And then you'll startunderstanding the concepts and
actually have a resource to goto, to help you complete those
requirements.
Speaker 2 (32:11):
Okay, great, great, uh, great advice, uh, as far as
just, you know, because that'sthe first thing that comes to my
mind is, wow, what do I doexactly.
Wouldn't be caught with yeah.
Pants down.
So to be able to figure out whatI, where I should go.
Speaker 3 (32:29):
Right.
Speaker 2 (32:31):
Well, is there anything else that you'd like to
add for today's meeting thatwe've talked about?
Any other
Speaker 3 (32:36):
Words of, I think the only I'll add is it's only
timely to COVID.
There has been some, uh, interimenforcement guidelines that OSHA
has put on the osha.gov, or ifyou're in Indiana on the website
, um, and it gives, uh,employers the flavor of what to
(32:59):
expect when OSHA comes for avisit, if they're actually going
to physically come on site, um,uh, or if they're not going to
come on site, what states theymay not address onsite.
So if you have a high, um, COVID, um, population or a high COVID
, um, incident rate, then OSHAis going to handle those OSHA
(33:19):
inspections for COVIDspecifically, either via mail or
email or phone calls.
So they won't necessarily comeon site unless, you know, the
fatality, they didn't even comeon site that we were involved
with.
So I would just encourage peopleto keep abreast of the OSHA,
interim enforcement guidelines.
And again, there's two of them,there are on low show website.
(33:41):
Now that'll give you a comfortlevel for how OSHA is addressing
those concerns, um, and how toprepare your facility for things
that they will be looking for.
So I guess in the short term,that would be something to help
employers under the currentCOVID crisis.
Okay.
And that's
Speaker 2 (33:58):
A really good point because I've spoken to a variety
of professionals, uh, related toCOVID from different angles.
And everybody always mentionsthe CDC.
You know, you're the first thatsays, Hey, he really needs to
look at OSHA.
And this is where you go to getyou started.
That's not something that maybe,you know, is automatically known
(34:18):
or, you know,
Speaker 3 (34:22):
Yeah.
It's, um, I would have liked tohave seen, um, OSHA to be a
little bit more, um, publiclyvocal in the expectations.
Um, but if you dig down on theOSHA website, there is, um,
expectations.
So if you do your hazardassessment, which is the
protocol for determining risk,and once you find COVID being a
(34:44):
risk, then you have to figureout next process is how do I
manage it?
And so that management does comealong with understanding
enforcement guidelines and theflavor of what OSHA's looking
for, which right now is mostlytraining.
So how have I indicated to myemployees that this is a
condition that they have tomanage and what our policies are
(35:05):
here at the facility?
So, um, when I looked at thewebsite, um, a couple of days
ago, that is what they wereemphasizing on.
The return to work brochure isthe training component can be
done in toolbox talks.
It can be done in zoom calls.
It could be done in a mass emaildistribution, but may make it
regular and make it, um,something that people can
(35:25):
anticipate and use as aresource.
So the training component isbecoming very important or more
important now under the COVIDconditions, um, on what the
policies are and how to react toit that, um, if employers have
no other time than going to theCDC or going to a website that
already has pre-establishedtoolbox talks relative to COVID,
(35:48):
that's a really good start.
Um, we don't always have a lotof time to develop our own, but
there are some out there thatthey can use, um, which will,
uh, document and prove that thetraining concept is being
completed.
Okay.
Speaker 2 (36:00):
Okay.
Well, thanks for that greatinformation.
Uh, it's a pleasure to have youon the show today.
Um, also thanks to our audiencefor tuning in to buck root TV
today.
We hope you've enjoyed the show.
Um, if you have any questions orthoughts, please be sure to let
us know.
And don't forget if you enjoyedthe show today, please be sure
to subscribe to our channel buckroom TV
Speaker 1 (36:22):
Again, Christy.
Thanks so much.
My pleasure.
Thank you.
Thank you for listening to theBuckaroo marketing new media
podcast.
If you'd like to learn moreabout B2B marketing for
manufacturing and relatedindustries, please visit us like
go book a route.com.
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