Corrosion Monitoring Services, Inc. (CMS), dedicated substantial time, energy, and resources to create a world class safety program, tailored specifically to address the risks inherent with permit-required confined space operations.  CMS was motivated to create a best-in-class safety program because of their commitment to ensure the safety and well-being of all their employees. This commitment led CMS to evolve from being purely a specialty mechanical contractor working in confined spaces to a safety and rescue company.

Since CMS’ participation in Occupational Safety and Health Administration (OSHA) On-Site Consultation Program began, a superior level of safety has clearly been in evidence.  CMS improved upon many of its safety hazards, such as machine guarding and implemented aggressive administrative and engineering controls when working in permit-required confined spaces. Machinery and personal protective equipment were better, less costly to own, and easier to use.  CMS found that productivity in their repair division rose dramatically. CMS Director of Safety Alan Schullo stated,  “if it were not for the Program [On-site Consultation], we would not have attained the high level of safety that we have today.”

Company Description

CMS is a specialty mechanical contractor that specializes in the inspection and repair of tubular air heaters and rescue services. The company has been in business for 30 years, providing service to pulp and paper mills, waste-to-energy plants, electric utility generators, and refinery operators. Over the years, the company developed methods for creating safe productivity increases while maximizing worker safety in permit-required confined space environments.

The Situation

CMS knew of the On-site Consultation Program through their knowledge of OSHA’s Safety and Health Achievement Recognition Program (SHARP) and Voluntary Protection Program.  Before working with OSHA, CMS believed their safety program was very good compared to other companies in this high hazard industry. Upon closer analysis, they realized many gaps existed in their safety program. CMS believed even though they spoke often of safety, they were not “walking the walk.”  They decided it was time to take action and make an absolute commitment to safety, financially and organizationally.  To be successful and exceed expectations, CMS decided to partner with the Illinois On-Site Safety and Health Consultation Program.

OSHA’s On-site Consultation Program offers free and confidential safety and occupational health advice to small and medium-sized businesses in all states across the country and in several territories, with priority given to high-hazard worksites. On-site Consultation services are separate from enforcement and do not result in penalties or citations.  Consultants from state agencies or universities work with employers to identify workplace hazards, provide advice on compliance with OSHA standards, and assist in establishing injury and illness prevention programs.

With the assistance of Illinois On-site Safety and Health consultants, CMS identified and addressed the safety gaps which significantly helped to reduce their hazard incidents.  For example, the consultant identified that three of CMS’ large saws in their production department lacked guarding.  The machines were manufactured with little safety guarding and no manufacturer input on guarding. To begin the safeguarding project, CMS contacted Rockford Systems, LLC, headquartered in Rockford, Illinois.  Rockford Systems is a company that designs and delivers innovative machine safeguarding solutions to organizations working with industrial machinery.  Working with Rockford Systems, CMS enclosed hard guarding panels, installed lock safety switches, interfaced the lock safety switches and light curtains, and installed appropriate danger signage for each piece of equipment (saws and cutters) at their production facility. The total cost of the project, which did not reflect equipment out-of-service time during the upgrades, was $88,246.43 and CMS spared no cost in purchasing the best. 

After the first consultation visit, CMS realized that the more they practiced safer processes, the more productive they became.  According to CMS, proactive safety has made them faster at what they do. For example, CMS conceived, designed, and implemented proprietary air heater repair techniques that resulted in faster, safer, and more predictable repair projects that met or exceeded even the most aggressive deadlines. CMS stated that they executed an air heater repair using best-in-class safety practices, and for this reason, their air heaters replacement technology is recognized as special and unique.  They assessed the confined space, using a highly refined assessment system.  Hazards were identified, mitigation strategies were developed, a rescue plan was developed, all required safety and rescue and decontamination utilities were installed and inspected, and a rescue drill was conducted. This procedure was repeated daily for every shift to perfect the process.

The Solution

CMS stated that from the beginning of the program, they took an unconventional approach to safety. Instead of developing repair procedures and then applying safety management to the procedures, they used what they knew from years of forethought about staying safe in permit-required confined spaces to develop their own procedures and workflow that resulted in deeply ingrained work habits.  CMS planned projects to keep workers “out of the line of fire” while maintaining consistent productivity rates.  As a result, doing difficult and dangerous work safely in confined spaces became their specialty.

CMS employees perform work in permit-required confined spaces and routinely confront oxygen deficiency, hexavalent chromium, arsenic, cadmium, lead, and volatile non-condensable gases.  The company built a full scale simulated permit-required confined space that allows its employees to perform simulated safety and rescue exercises year round.  They currently provide this year round safety training to local municipalities, the private sector, and to government and military contractors. CMS employees are fully rescue trained under the National Fire Protection Association (NFPA) 1006, 1670, and 350 and certified rescue technicians. The extensive training given to CMS personnel led OSHA to reclassify the company from boilermaker to specialty contractor.  

Aside from training, CMS safety team provides standby rescue and confined space attendants throughout the United States.  The safety team consists primarily of former firefighters and rescue personnel with decades of experience and the highest levels of training.  The safety team’s  training, experience, and qualifications not only helps to ensure that each confined space operation is fully OSHA compliant, but also ensures that capable and effective rescue personnel are present to perform immediate rescue operations in the unlikely event of an emergency. CMS customers were so intrigued by the safety and rescue services that many began to inquire for additional information.

In 2012, CMS developed and implemented the Worker-to-Rescuer Program.  This training program was created as a result of the company’s vision for the training and skills they believe every worker entering a confined space should possess. The Worker-to-Rescuer Program trains workers to transition into a rescue team capable of responding to any confined space emergency.  All field employees as a condition of employment were and are required to successfully complete this training, which meets the rescue requirements in 20 CFR 1910.146(k). CMS believes that this training represents the future standard for confined space safety, so its mission is to make this program readily available throughout the United States.

Lastly, in order to achieve SHARP certification, CMS developed a performance-based safety program aligned with the traditional Hierarchy of Controls approach.  The program began with observing and identifying at-risk or unsafe behaviors and taking immediate action to correct them. Generally, the corrective action included wearing personal protective equipment and following safety rules.  During the early phases of CMS’ behavior-based safety program, they saw many positive results.  The staff began to express interest and exert control of the program.  The company began to identify core concentration areas for enhancement, such as education, training, communication, procedures, physical plant, equipment, and continuity.

The Impact

CMS is proud that they are a contractor that maintains a best-in-class safety program as well as a safety and rescue company that has a contracting and inspection division.  CMS stated that because of their participation in the SHARP, they have been able to get the job done faster and safer.  This faster and safer expectation has had a profound impact on everyone at CMS and its overall culture.  The most visible impact from CMS’ safety programs has been the increase in productivity.  CMS stated that they can now easily measure the direct costs of injuries.  They believe that the indirect cost savings of preventing injuries may be much greater than simply the workers’ compensation dollars that they have saved thus far. 

Being very aware that they are a specialty contractor performing extremely hazardous work exclusively in permit-required confined spaces, CMS stated that they came into the On-site Consultation Program with a highly practical and experienced perspective on safety.  However, with the assistance of Illinois On-site Safety and Health consultants, the company was able to hone its understanding of OSHA compliance requirements and became well-equipped to confidently solve any compliance issues that may arise. CMS believes that for this reason, they were ready to achieve OSHA recognition and become SHARP certified.

The employer began its relationship with Illinois On-Site Consultation in 2012.  The injury rates were low and remained low throughout the consultative process leading up to approval of SHARP certification.  The company has appreciated the advantages of having fewer injuries and illnesses since working with the OSHA consultants and achieving SHARP.  In 2012, CMS’s Total Recordable Case Rate (TRC) rate was 1.38, and their Days Away from Work, Job Transfer and Restriction (DART) rate was zero. In 2013, the TRC rate was 1.38, and the DART was zero.  The 2014, TRC was 2.66, and the DART rate was zero.  In 2015, the TRC was 1.37, and the DART rate was zero. 

In comparison, the Bureau of Labor Statistics reported that the national average TRC rate for this industry in 2012 was 3.4; in 2013, it was 3.1; in 2014, it was 3.6; and in 2015, it was 3.6.  BLS reported the national average DART rate in 2012 was 2.1; in 2013, it was 1.8; in 2014, it was 1.7; and in 2015, it was 2.3. 

In 2014, CMS became SHARP certified for the first time.  In 2016, they were approved to continue participating in this valuable workplace safety and health program.  SHARP recognizes small business employers who have used OSHA On-site Consultation Services, and operate an exemplary injury and illness prevention program. Acceptance of worksites into SHARP from OSHA is an achievement of status that distinguishes a company amongst its business peers as a model for workplace safety and health.

“CMS Inc. is proactive in safety and health management which is why we chose to invest in protective measures rather than wait for an injury to occur,” said Steve Turner, CMS Owner.

Additional information about OSHA’s On-site Consultation Program and other small business resources is available at http://www.osha.gov or 1-800-321-OSHA (6742).

Sources:

Steve Turner, Owner, CMS Inc.

Alexander Turner, President, CMS Inc.

Alan Schullo, Director of Safety, CMS Inc.