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04 Apr
SMS Best Practice Tips
Making Your SMS Work for You

A Safety Management System (SMS) is a systematic organization of policies, processes, programs, procedures, and records. Like other management systems, an SMS is built on the Plan, Do, Check, Act/Adjust (PDCA) cycle. Ideally, safety-related activities are planned, done, checked (through auditing, inspections, investigations), and finally reviewed by both local and executive management to facilitate continuous improvement (i.e., adjust).

Keys to a Successful SMS

The primary purpose of an SMS is to effectively manage safety-related risks. But how does an organization ensure that its SMS—new or existing—actually does this? Kestrel has compiled the following best practice tips for implementing an effective SMS:

  1. All employees with management or supervisory responsibilities must be visibly and conspicuously committed to safety and the SMS. Management demonstrates leadership and promotes commitment to improving safety performance through active and visible participation. It is up to management to routinely demonstrate that this is not just the “flavor of the month” but the organization’s way of doing business. (Choudhry, Fang & Ahmed, 2008; Hansen, 2006; Lyon & Hollcroft, 2006; OSHA, 2015)
  2. Employees are engaged in the SMS—emotionally and cognitively. Employees must understand how the SMS works and believe in the value that it offers them and the organization. (Wachter & Yorio, 2014; Moraru, Babut & Cioca, 2011)
  3. The SMS is integrated into other business objectives and aligned with other in-place management systems (e.g., quality, environmental). The SMS should support the company’s goals and objectives. Aligning and integrating with other systems further improves efficiency, consistency, and understanding. This also provides the flexibility needed to function in a dynamic business environment. (Hansen, 2006)
  4. There are clearly defined safety policies and principles. Policies should be established, communicated, and updated, as necessary. (Hansen, 2006)
  5. The SMS establishes challenging objectives, goals, and plans. High standards of performance that are tracked and measured ultimately lead to performance improvements. (Hansen, 2006; OSHA, 2015)
  6. Contractors and other third parties are effectively managed. Contractors, suppliers, and others must be assessed and monitored for their capabilities and performance. Clear performance standards should be established to ensure that these third parties meet needs and uphold safety management expectations. (Hansen, 2006; OSHA, 2015)
  7. The SMS ensures compliance with legal and other requirements. The SMS should help the organization to measure and verify compliance with applicable legal and regulatory requirements. (Hansen, 2006)
  8. There is effective communication about the SMS, including clearly defined roles and responsibilities. Employees need to understand the purpose of the SMS and their roles in achieving related goals and objectives. (Hansen, 2006; OSHA, 2015)
  9. Staff receive continuous safety training and development opportunities. Safe operations rely on well-trained employees and contractors who understand the SMS and how to perform their jobs in the safest ways possible. (Choudhry, Fang & Ahmed, 2008; Moraru, Babut & Cioca, 2011; Lyon & Hollcroft, 2006; OSHA, 2015)
  10. The organization is committed to hazard identification, risk assessment, and implementing effective controls. Identifying, assessing, and prioritizing hazards can mitigate risks to employees, customers, contractors, and the general public. Procedures should be put into place to continually identify workplace hazards and evaluate risks. Doing so must be a continuous process with periodic inspections to identify new hazards. (Hansen, 2006; OSHA, 2015)
  11. The organization conducts injury and incident investigations, produces reports, and follows through on corrective actions. Effective incident investigations provide the opportunity to learn about and improve safety performance. Investigations should identify the root cause and contributing factors, determine and track corrective actions, and share lessons learned across the organization to prevent recurrence. Perhaps most importantly, the organization should refrain from using the investigation to figure out who to blame for the incident. Fault-finding, rather than fact-finding, leads to mistrust and a negative safety culture. (Singh, 2014; OSHA, 2015)
  12. Audits provide the opportunity for ongoing re-evaluation and to demonstrate a strong commitment to continuous improvement. The SMS must be regularly reviewed to ensure that it is delivering consistent, desired performance. Planning and implementing internal audits helps verify whether safety processes and activities are meeting goals and creating the desired outcomes. Audits also help determine the effectiveness of the SMS and uncover new opportunities to systematically guide the PDCA continual improvement process. Sharing best practices and lessons learned further promotes ongoing improvement. (Hansen, 2006; Choudhry, Fang & Ahmed, 2008)
  13. Risk-based, data-driven decision-making is informed by both leading and lagging indicators. While lagging indicators provide valuable information for SMS improvement, leading indicators provide that information without waiting until someone gets hurt. Advanced statistical techniques and predictive analytics can help predict where and when an incident will happen based on leading indicators. Organizations can make drastic safety performance improvements by making a strategic, sustainable investment in gathering and analyzing leading indicators.
  14. Implementation is guided from the top down; buy-in is obtained in all levels of the organization. Ownership of the SMS resides with the safety department and executive management, while ownership of implementation and performance resides with all departments and operations. Safety should be continually reinforced as a line-organization responsibility. (OSHA, 2015; Choudhry, Fang & Ahmed, 2008; Moraru, Babut & Cioca, 2011)
  15. The SMS builds on and improves what already exists. The SMS should fit within the organization’s existing business structure and be tailored to the organization’s needs, operations, risks, processes, culture, and existing strengths.

SMS Benefits

For organizations that are able to implement a strong SMS, there can be many benefits. For example, the Health and Safety Executive in the UK (Greenstreet Berman Ltd, 2006) published six case studies in 2006 illustrating the benefits of implementing an SMS. Some of the business benefits identified in these case studies included the following:

  • 50% reduction in absenteeism
  • Static or decreased insurance premiums
  • Access to wider market based on improved safety outcomes

Another case study published in 2010 describes Newell Rubbermaid’s SMS success, as the company realized an 80% reduction in recordables and an 81% reduction in workers compensation costs after implementing a proactive SMS (Zahn, 2010).

In general, most organizations that adhere to the best practices described above may realize:

  • Improved health and safety performance and compliance
  • Greater operational efficiency
  • Reduced injuries and injury-related costs
  • Lower insurance premiums by demonstrating to insurers that risk is effectively controlled
  • Better morale when employees see employers actively looking after their health and safety
  • Improved reputation that comes with the public noticing the organization’s responsible attitude toward employees
  • Improved business efficiency and, correspondingly, reduced costs

 

26 Mar
Drones 101 Top 6 Tips
Drones 101: Tips for Managing Your Drone Program

This is the fifth article in Kestrel’s Drones 101 series.

As we’ve discussed in our Drones 101 series, both large and small companies can establish safe and reliable drone programs; however, lack of planning will (at best) add up to a short-lived drone program or (at worst) cause your company undue risk or injury.

In short, buying and operating UAS equipment without a plan in place can lead to:

  • Sunk costs
  • Delayed success
  • Safety incidents
  • Service delays
  • Employee injury
  • Loss of financial backing legal and regulatory issues

On the flip side, when implemented appropriately, using drones often results in a solution that is:

  • Faster – Significantly reduce manhours to complete work (e.g., inspections, audits, monitoring) without requiring plant shutdown.
  • Safer — Eliminate the need for humans to complete high-risk activities (e.g., climbing towers, entering confined spaces, inspecting disaster zones).
  • More accurate — Gather comprehensive and reliable data with less room for human error and less variability.

Top Tips

Here are Kestrel’s top six tips for managing a successful drone program:

  1. Establish a plan and budget to accurately track and communicate costs and determine your return on investment.
  2. Establish standard processes, procedures, and communication protocols to ensure end users, company, and management teams understand expectations and obligations.
  3. Engage a cross-functional team, which may include program management, field operations, engineering and maintenance, human resources, legal, information technology, etc. to effectively manage all aspects of your UAS program.
  4. Create a UAS program operations manual that lays out expectations and company-approved applications of UAS technology.
  5. Set metrics and evaluation methods for the UAS program overall and its impacts on the core business. This will help show the value of your UAS program.
  6. Follow the classic management system plan-do-check-act cycle to drive continual improvement in not only the drone program, but in the core business, as well.

Learn more about Kestrel’s UAS Program Management services. Be sure to check out the entire Drones 101 series:

11 Mar
Drones 101 UAS Program Management
Drones 101: UAS Program Management

This is the fourth article in Kestrel’s Drones 101 series.

Drones can reduce risk in commercial operations, but it is important to acknowledge that they can also introduce risk through damage to property, safety incidents, loss of UAS assets, and legal and regulatory issues. And without a planned, organized UAS program, your risks increase significantly.

Why UAS Programs Fail

Why do some drone programs fail? Both large and small companies can establish safe and reliable drone programs, but a solid foundation early in the process is essential for success. Lack of planning will (at best) add up to a short-lived drone program or (at worst) cause your company undue risk or injury.

In short, buying and operating UAS equipment without a plan in place can lead to:

  • Sunk costs
  • Delayed success
  • Safety incidents
  • Service delays
  • Employee injury
  • Loss of financial backing legal and regulatory issues

Foundations of a Drone Program

A solid, sustainable UAS program starts with consideration of a handful of essential elements, as discussed below.

Financial Resources. Your program needs to consider cost. Not only will you need to create a budget for approval, but you will want to be aware of and able to accurately communicate costs and have a basis for arriving at a return on your investment. A good approach is to categorize your costs into one-time capital costs; recurring costs related to equipment, software and pilots; and costs for expansion.

Financial Resources UAS ProgramIncidentally, the cost to take the Part 107 Airmen Knowledge Test is $150 per attempt. A prep course online will run about $200 -$300.  To stay current, pilots are required to take a test every two years, which also costs $150 per attempt

 The key point is to understand your costs, budget for them, and put the drone program in the best position to be funded as needed.

Cross-Functional Strategy

Ideally, you want a team of people with different functional expertise working toward the common goal of helping the company achieve the benefits associated with a drone program. Consider involving individuals in program management, operations management, legal/compliance, human resources, information technology, and others.

Depending on how large your organization is, the team may be one or two individuals who wear many hats and juggle responsibilities. Larger organizations may expand the size and functions beyond this example. Think about how your organization might function:

  • Is your program manager and operations manager the same person?
  • Which of the following is the highest priority for your legal team: data security, regulatory compliance, or employee safety?
  • Do you have the in-house IT resources to support the technical needs of a UAS program?

You don’t necessarily have to have a large team, but you do need to consider how you’ll cover all the related functions and responsibilities.

UAS Program Operations Manual

A UAS program operations manual – whether it is a paper binder or an online resource – is a must. It’s important that you have well thought-out policies and procedures, standard practices, and emergency plans. It is just as important that all your pilots and team members are familiar with them, so everyone is operating from the same playbook.

Your operations manual should lay out expectations and company-approved applications of UAS technology. In general, it should include the following:

  • Policies, procedures, standard operating practices, safety programs
  • Identified risks, hazards, and emergency situations; mitigation measures
  • Data management and documentation requirements
  • How/when to verify federal and state regulations for UAS technology
  • Employment terms/contracts (employee, contractor, vendor)

Integrated Systems

Much like the cross-functional team we just covered, your internal business systems should include drone program-related tasks and subsystems. These should be integrated into the normal flow of business in your organization.

If your company operates under an ISO-style management system (e.g., ISO 9001, ISO 140001, or ISO 45001), you have the opportunity to align and integrate systems with your existing program and take advantage of the plan-do-check-act cycle associated with ISO management systems. Consider systems for communication, inventory management, data management, employee management, and technical support, among others.

Measurable Goals

It’s a standard exercise in any management system to set measurable goals and track progress against them. The same standard should be upheld for drone program management. Setting metrics and evaluation methods will allow you to show the value of your UAS program.

  • First, set goals for the drone program overall. This may include:
    • UAS pilot effectiveness (e.g., safety, training status, reportables, compliance)
    • Effectiveness of policies and procedures
    • ROI of the UAS program (e.g., money saved, time saved, fewer injuries, lower workers compensation rates)
  • Second, set goals to measure the impact of the drone program on your core business.
    • How will UAS enhancements change/improve existing company performance metrics?
    • For example, can you move from biannual inventory of resources to quarterly due to ease of inspections? Or monitor high-risk bridges, wind turbines, etc. every 3 months?
    • Set or adjust thresholds based on the knowledge you gain from UAS enhancements.

Plan for Continuous Improvement

Finally, you should have a plan for continuous improvement. An effective plan will follow the classic management system plan-do-check-act cycle to drive improvement in not only the drone program, but in the core business as well.

In the diagram below, drone program goals related to improved policies and procedures lead to standard operations practices. The effectiveness of these actions is evaluated, gaps are identified, and additional goals are set. As an example, let’s say one of those policies and procedures is to address how we manage flight data. A goal is set, the procedure is examined, previously unidentified risks are discovered, and mitigation measures are put in place in the policies, procedures and SOPs.

UAS Plan for Continuous ImprovementKey Takeaways

Drones can enhance your current business operations by reducing the time and safety risks involved with routine tasks, but they bring with them their own operational and regulatory considerations. To help ensure your drone program’s success:

  • Establish a solid foundation early.
  • Establish policies and procedures to reduce inefficiencies and ensure compliance.
  • Create systems to reliably track the location, status, and condition of your drone fleet – regardless of size.
  • Establish systems to track and manage the training and certification status of all employees or contractors in the UAS program.
  • Monitor and manage maintenance and repairs/replacements of the drone fleet to reduce operational risks of drone failure during flight and to ensure that employees are operating their drones safely and efficiently.
  • Develop systems to manage and organize huge quantities of data from drone flights so you can easily find footage/stills and leverage the data gathered.
  • Design and implement integrated software systems to prevent liabilities, loss of ROI, and safety risks.

Learn more about Kestrel’s UAS Program Management services. Be sure to check out the entire Drones 101 series:

 

05 Mar
Drones 101 sUAS Regulations
Drones 101: Regulations for sUAS

This is the third article in Kestrel’s Drones 101 series.

Drone usage is regulated by the Federal Aviation Administration (FAA). In 2016, FAA issued new rules for non-hobbyist (i.e., commercial) small Unmanned Aircraft System (sUAS) operations in 14 CFR Part 107. Part 107 covers a broad spectrum of commercial uses for drones weighing less than 55 pounds at time of takeoff and landing.

Commercial vs. Hobby

For the purposes of Part 107, commercial is considered as anything except recreational or hobby use. Whether you are making money directly with your drone or just using it as a tool within your company, Part 107 applies to drone pilots and drones used for business purposes.

Operating Requirements

Many of the rules in Part 107 are common sense; others are not. This list provides an overview of the operating requirements for complying with Part 107:

  • The remote pilot must keep the drone within visual line of sight (VLOS) at all times.
  • The operator should always avoid manned aircraft.
  • Neither the pilot nor a visual observer can be responsible for more than one sUAS at a time.
  • You are only allowed to fly during daylight hours. If you attach the proper anti-collision lighting, you may conduct operations during twilight hours. Night operations are prohibited without proper authorization from the FAA.
  • Minimum weather visibility is three miles from your control station.
  • Maximum allowable altitude is 400 feet above the ground (higher if your drone remains within 400 feet of a structure, such as when you inspect a tower or tall building).
  • Maximum speed is 100 mph (87 knots).
  • You cannot fly directly over any people unless they are directly and knowingly involved in the operation.
  • You can carry an external load if it is securely attached, does not adversely affect the flight characteristics or controllability of the aircraft, and maintains the weight limit of 55 lbs. at time of takeoff and landing.
  • The National Airspace System is divided into several categorizations and it is imperative that all UAS operators know and understand the various airspace designations.
    • Operations in Class A are prohibited unless authorizations from the FAA are secured and the operators coordinate their operation through air traffic control. sUAS operations in Class A airspace is extremely unlikely due to the altitude.
    • Class B and Class C airspace designations surround all major and minor airports. Operations in Class B and Class C airspace require prior authorization from the FAA, which can be difficult to obtain. Certain exceptions are made and, in the event that operations are approved in either of these airspaces, coordination with air traffic control and/or airport operator is required.
    • Class E airspace resides between the top limits of all the other airspace designations and the bottom of Class A airspace. Class E airspace can also be found around non-towered airports with instrument approach requirements and can require air traffic control or airport operations coordination during hours when the tower is operational. This varies, and operators should refer to their sectional maps and flight planning tools before every flight to verify their current airspace requirements.
    • Class G airspace does not require any additional approvals for operations; a majority of commercial UAS operations occur within these areas.
    • Airspace designations can change, and temporary flight restrictions are frequently established for various reasons. Operators should always refer to their sectional maps and flight planning tools before, during, and after all UAS operations.

You can request a Certificate of Waiver from certain Part 107 regulations, and/or authorization to operate in restricted airspace by submitting a request directly to the FAA. There are tools that can help with this process, but waiver requests can be complicated, and most are not approved by the FAA. Kestrel can help you write effective waivers.

Low Altitude and Notification Capability (LAANC)

For access to restricted airspaces that are at low altitudes (under 400 feet), operators can use a new tool recently released by the FAA referred to as LAANC (Low Altitude Authorization and Notification Capability). LAANC aims to provide near real-time airspace authorizations for UAS operations under Part 107.

LAANC automates the application and approval process for airspace authorizations at nearly 300 air traffic facilities covering approximately 500 airports. It dramatically decreases the wait time experienced with the manual authorization process, provides greater flexibility in operational planning, and directly supports UAS integration into the airspace.

Pilot Certification

To operate a sUAS under Part 107, pilots need a remote pilot airman certificate with a small UAS rating or must be under the direct supervision of a person who holds such a certificate. This certification entails passing a two-hour Airmen Knowledge Test to become certified, and then applying for your certificate online, which includes passing a TSA background check. Operators must retake the Airmen Knowledge Test every two years to stay current.

If you already have a Part 61 pilot certificate, other than a student pilot certificate, you must have completed a flight review in the previous 24 months and you must take a sUAS online training course provided by the FAA. Pilots receive a certificate of completion, which must be renewed every 24 months.

If you are acting as pilot in command, you must:

  • Make your drone available to the FAA for inspection or testing on request, and provide any associated records required to be kept under the rule.
  • Report to the FAA within 10 days any operation that results in serious injury, loss of consciousness, or property damage (to property other than the UAS) of at least $500.

Drone laws and regulations are constantly evolving as the industry evolves.

. As an example of the ever evolving regulations, effective February 25, 2019 the FAA now requires that all sUAS display their aircraft registration number on an external surface of the aircraft. This rule was established under 14 CFR Part 48. Additional rules regarding night operations and flights over people are in the proposed rule phase and are expected to become effective by the end of April. In addition, record retention laws are forthcoming for drone footage and may vary by state.

Not surprisingly, pilots can unknowingly (and easily) violate FAA regulations. One very important task as part of your overall UAS program management strategy should be to keep current on pilot certifications, drone registrations, and regulatory changes to remain compliant.

Learn more about Kestrel’s UAS Program Management services. Be sure to check out the entire Drones 101 series:

26 Feb
Facility safety equipment
Know Where You Stand: Facility Safety

Strong safety performance is a cornerstone of any business. For many companies, it can make the difference in being qualified to work with customers and successfully expand the business.  On the other end of the spectrum, repeated safety accidents can lead to potential serious penalties and higher insurance rates for failing to comply with OSHA safety requirements.

Safe facilities, work practices, and training help to attract and retain employees and enable them to go home at the end of the shift without workplace injury or concerns. In addition, workers’ compensation rates and the ability to maintain adequate insurance both depend on an organization’s safety performance.

OSHA Safety Compliance and Inspection

Safety compliance with federal regulations is getting much more attention by the Occupational Safety and Health Administration (OSHA) due, in part, to a variety of significant accidents occurring over recent years. Many relate to the manufacturing in high risk industries where the impacts have caused injury, evacuation, environmental impacts, and significant business disruption. While not frequent, accidents like this draw attention from the public and communities, news media, regulators, and regulatory agencies. This, in turn, has increased scrutiny on all businesses, especially those in high risk industries or having a history of safety issues. When it comes to safety compliance, an organization should never be overly confident.

Increased inspections for non-compliance with safety regulations have been emphasized. OSHA tracks the types of safety violations found and their classification as “serious” or as “willful”. A serious violation is defined as “one in which there is a substantial probability that death or serious physical harm could result, and the employer knew or should have known of the hazard”. A willful violation is defined as one “committed with an intentional disregard of or plain indifference to the requirements of the Occupational Safety and Health Act and requirements”. Willful violations can also be applied to multiple plants in the same company.

The top 10 “serious” violations reported by OSHA for federal FY 2018 were:

  1. Fall Protection
  2. Scaffolding
  3. Hazard Communication
  4. Ladders
  5. Lockout/Tagout
  6. Respiratory Protection
  7. Machine Guarding
  8. Powered Industrial Trucks
  9. Fall Protection – Training Requirements
  10. Personal Protective and Life Saving Equipment – Eye and Face Protection

All of these violations can be associated with the typical equipment and practices associated with manufacturing operations or other physical plant activities for maintaining processes and equipment.

Willful violations can result in significantly greater penalties, with related fines tripled should a violation be classified as in this category, and even greater penalties for multiple plant violations under the same corporate ownership.

The top 10 “willful” violations reported by OSHA for FY 2018 were:

  1. Fall Protection
  2. Lockout/Tagout
  3. Grain Handling Facilities
  4. Requirements for Protective Systems
  5. Respiratory Protection
  6. Machine Guarding
  7. Fall Protection – Training Requirements
  8. Mechanical Power-Transmission Apparatus
  9. Hazard Communication
  10. Permit-Required Confined Spaces

A best practice recommendation is that plant management should take the opportunity to review this list and validate their understanding of the related regulations and the level of compliance at their plant(s).

Opportunities for Improvement

Each of these standards represents an opportunity for assessment and improvement for plant managers and owners in the industry. Violations in these standards can take a variety of forms, including a failure to have not only the appropriate procedures, but necessary updates, training, internal inspection and recordkeeping. Be aware that vulnerability in compliance could be associated with evolving changes, including time, process, personnel, and materials. This is also known as “management of chain” necessary for maintaining and keeping programs current with requirements.

The question for plant owners and managers is, “What should we do now to both meet the requirements and establish a plan should we be confronted with an OSHA inspection?” These represent two related activities that need to be addressed to best ensure that the company can and will achieve the best in both situations.

Taking Action

When it comes to determining the level of your existing OSHA programs against compliance issues and potential accidents, there needs to be both short-term and longer-term actions. The goal of the actions will be to provide the results of what will need to change in your OSHA compliance programs. There will be a range of results depending on how well the programs were developed, implemented, and updated. Regardless, the goal is to provide a means to assess and make this determination. We recommend taking the following short-term (if not immediate) actions:

  • Schedule a meeting with key management and safety and health staff to develop a plan to review and confirm all OSHA programs for compliance to the standard. It is not uncommon for internal audits and insurance company audits to be based on confirmation of a compliance policy and not the level of detail required in the implementation of the policy. In the meeting, a complete review of programs should be delegated, including a review of the OSHA standards themselves. This should be based on criteria, including the level of detail, training, and updates and supporting logs/records.
  • As part of this process, conduct a review of the last three years of internal and loss prevention reports, including local fire. The findings of these should be compared against review findings to verify that necessary changes have been implemented.
  • The review should include a review of the OSHA reporting and recordkeeping requirements. Again, this should be reviewed based on three years of historical records.  Not only should these records be verified to be accurate and complete, but each accident should have resulted in a corrective action of either an unsafe situation or the retraining of an employee. This information should be checked, as well, and any additional actions made to fully comply.
  • Should you have had any past OSHA inspections at your facility or if you have multiple locations, you need to ensure that proper actions were taken to close these issues. Again, it is very important to verify and assemble all of the related records.
  • You will need to require that multiple physical walk-troughs are conducted for all work, personal, and administrative areas for compliance. This should be done by updating or creating a safety inspection checklist for each section, area, and department to confirm that there are no violations in manufacturing and administrative areas alike. Note that one area often missed is the adequate spacing and egress from office cubicles and file rooms.
  • Your review should lead to the determination of corrective actions of your programs.  These corrective actions need to result in immediate “short-term” updates and implementation of your safety programs. This needs to be announced and included in the training that will need to be scheduled and documented.
  • Concurrently, a qualified person should be assigned to compare the review findings, your accident statistics and the top OSHA violations. If there are common links to programs, statistics, and OSHA violations report, an added level of scrutiny should be placed on this area and the resulting program updates.
  • Ensure that all of the basic requirements are met and in compliance, including accident/injury records, training records, inspection logs, and a log for all program updates implemented.

Inspection Readiness

Provided that the items above are done correctly will greatly reduce your risk for compliance issues and create a safer work environment for your employees for the short term. To fully verify the changes, a confirming review or audit should be completed within a 30-45-day strict timeframe, and any additional changes or training should be completed immediately. This will also put you in a much better position for an OSHA inspection should you be identified to require one. Some additional points to readiness for an OSHA inspection include the following:

  • Ensure that you have or develop a policy for a regulatory inspection that can be implemented immediately. This would cover OSHA and other possible inspections.
  • Assign a designate with responsibility for representing the company for an OSHA inspection. Until the designate is ready for an inspection, the inspector should be kept in a neutral office or conference room and away from all levels of activity.
  • The tour should be as that for any other visitor. Ensure that the inspector wears all of the required PPE at all points during the tour and is provided all of the awareness required for all personnel. The inspector should never be left alone and not allowed to disrupt the work activities in any way or at anytime.
  • Develop a list of the do’s and don’ts of information to be provided or shared with an inspector. When in doubt, decline to answer until the proper answer can be determined.  This list should include what the inspector is entitled to request and what you do and do not have to provide. Say very little and even less if asked.
  • A copy of all information, notes, photos, and videos should be kept for the company records, and the designate should ask the inspector to answer any related questions.
  • Note that if the inspection carries for multiple days, it will provide the designate to verify and communicate specific concerns for direction from senior management or counsel.
  • At the closing conference, the inspector will take time for a write-up and to determine apparent violations. During this presentation, you need to challenge any such issues and take the position that there are no violations.
  • The inspector will take several weeks to formalize the report, during which time you are not required to answer any follow-up calls.

This information presents a briefing on handling a typical OSHA inspection. Certain events could change how you handle an inspection in follow-up to an accident. Additionally, note that if you conduct an OSHA Program review and make the proper changes, you will be in much better readiness condition for an OSHA inspection. Regardless, the planning and demeanor of the designated contact for the inspection should be the same.

Owners and managers of companies need to focus on prevention and on the overall culture of the company in terms of taking the necessary steps to reduce risk and make prevention part of daily operations. Good practice is to examine the workplace broadly, identifying and assessing hazards, and developing and implementing appropriate controls. This helps ensure employees are protected in the workplace and regulatory compliance is achieved.

 

19 Feb
Drones 101 Applicability
Drones 101: Applicability

This is the second article in Kestrel’s Drones 101 series.

 As we move into this important new phase of everyday use of drone technology in the workplace, some questions may arise:

  • How many drones are there operating in commercial space?
  • Where are they being used?
  • How are they being used to help operations?

Commercial Drone Operation

The chart below illustrates actual data from FAA’s aerospace forecast from this year. It highlights the phenomenal growth in drone use. The FAA projects that the commercial drone fleet is set to grow from over 110,000 in 2017 to over 450,000 by 2022 using its base, or most likely numbers. FAA’s high-end estimate predicts over 700,000 commercial drones in use by 2022. The number of remote pilots (indicated by the blue dotted line) is set to increase from 73,673 in 2017 to over 301,000 by 2022.

Commercial sUAS Remote Pilot PredictionsFurther, the map below shows the distribution of registered commercial drones in the U.S. in 2017. The larger dots indicate a higher number of drones registered in that area. From this information you can see that commercial drones are popular and in use all over the country, not just in isolated pockets.

sUAS Registrations 2017Typical Uses of Commercial sUAS

This pie chart from the FAA shows in a general sense how commercial drones are being used in the U.S.  By far the most common use is aerial photography and mapping, followed by industrial inspection and agriculture. Insurance and state & local governments round out the chart. Construction is not represented separately on this chart, but it has been identified as the fastest growing industry segment in terms of drone use.

Uses Commercial sUASWhy Drones?

Using drones in commercial settings can clearly save time and money in many different ways, including the following:

  • Outputs from drone applications can provide support, such as 3D modeling of existing facilities, evidence for insurance or legal claims, or cause-finding efforts for incident investigations.
  • Drones can also be used to objectively monitor changes over time, such as erosion control, flood rise and water damage, or the rate of deterioration of fixed outdoor assets like tanks and towers.
  • Sensors and software designed for drones offer quick, convenient means to measure stockpile volumes and inventories, evaluate flood plains, or quantify spills.
  • Data captured can be used proactively to anticipate environmental risks, indicate preventive maintenance needs, or inform everyday decision-making.
  • Drones can quickly and accurately determine stockpile volumes, which is very useful in the mining and aggregate industries.
  • Finally, one of the most important uses of drones is to reduce employee exposure to hazardous conditions. These might include working at heights, confined spaces, or any situation where there is a risk of injury or death.

Drone Applications in Action

Let’s take a look at two examples of drones in action.

Application 1: Cause Finding.
Drones are being used across various industries to enhance cause-finding efforts. These tools are especially useful when hazardous materials or conditions are involved, and when the assets involved are on fire, at height, or pose a high safety risk to those involved.

One example of this is railroad derailment prevention. Standard derailment prevention operations involve derailment cause-finding efforts, such as interviewing those involved, walking the site and taking photos by hand and at eye-level. Derailment sites for large Class I railroads can be well over a mile long and can include spilled hazardous materials or active fires depending on the severity of the incident. Inspecting these sites can be time consuming, risky and, since these events are always unplanned, they can be disruptive to those involved.

Using drones, companies have been able to fly a derailment site in a fraction of the time it would have taken a person or persons to walk the entire site. With a LiDAR unit attached to the drone, companies scan the site and, using the data points generated during data collection efforts, recreate the accident scene to scale back at home base. This technology allows for more advanced analytics to be run on the incident. By recreating the accident scene using the data gathered by the drone and an appropriate software package, companies have been able to pinpoint the exact reasons that a train has derailed.

In one such instance, a company was able to determine that one of its trains was loaded in such a way that the push and pull being placed on the couplers was stressed to the point of breakage after the train went over and down a section of undulating territory at a certain speed. The company was able to analyze the degree of the undulation, the relative age of the coupler(s) involved, and the exact moment and location of the derailment. By digitally reconstructing the scene, they could see exactly which part of the train began to wobble, why it became unsteady and what caused the trajectory observed at the derailment site. With the application of UAS technology, the company was able to turn these detailed insights into multiple proactive and response mitigation actions.

Application 2: Industrial Inspection.
Drones are being used at processing and manufacturing plants to identify faults and aid in predicting required maintenance on equipment. In certain applications, specially designed drones are flown into hazardous and confined spaces instead of sending workers in.

One example of the latter is the periodic internal inspection of a large industrial boiler at a mine in Utah. Typically, this is accomplished by installing scaffolding down the middle of the boiler so that a team of technicians can climb down and observe specific features looking for cracking and signs of wear. What is normally a week-long process is now done in half a day with a confined space drone, and literally saves hundreds of thousands of dollars, because production is shut down for hours instead of days.

At another tank farm, UAS operators set waypoints to fly the same route periodically to check for irregularities and deterioration on the tanks, as well as evidence of releases from tanks and piping. This allows for proactive repairs and more efficient maintenance efforts. With a thermal imaging camera attached to the drone, the operator can perform a rough visual level check on the tanks to confirm that individual level sensors on the tanks are performing as expected, so that product inventories are accurate.

Enhancing Operations

There are many ways that drones can be used to enhance operations, regardless of industry. Drones offer a tool to access and assess physical conditions, minimize risks, and enhance employee efficiency during job tasks that are otherwise routine/time consuming, difficult to accomplish (i.e., have a high safety risk, exposure to hazardous materials that could result in injury or death), challenging to reach/excessively large (i.e., working at heights or in confined spaces), or time-sensitive.

When implemented appropriately, using drones often results in a solution that is:

  • Faster – Significantly reduce manhours to complete work (e.g., inspections, audits, monitoring) without requiring plant shutdown.
  • Safer — Eliminate the need for humans to complete high-risk activities (e.g., climbing towers, entering confined spaces, inspecting disaster zones).
  • More accurate — Gather comprehensive and reliable data with less room for human error and less variability.

Learn more about Kestrel’s UAS Program Management services. Be sure to check out the entire Drones 101 series:

12 Feb
Drones Terminology Technology
Drones 101: Terminology & Technology

This is the first article in Kestrel’s Drones 101 series.

Industries like transportation, manufacturing, utilities, mining, construction, oil and gas, and agriculture are crucial to our country’s infrastructure, particularly in a rapidly changing global market. Yet these industrial sectors continually face the challenges of an aging workforce and high-risk job tasks, including exposure to moving freight cars, high-voltage transmission lines, and hazmat materials and risks of slips, trips, falls, maiming and premature death.

Emerging Technology

Fortunately, drones are an emerging technology that offers a solution both to the shrinking workforce and as an additional mitigation tactic for various operational safety needs of heavy industries.

What was once a very niche market, drones are emerging into an important new phase: everyday use of drone technology in the workplace. It’s no longer just tech-savvy companies that are using drones. Enterprise-level Unmanned Aerial System (UAS) operations are becoming a big deal in industry. Organizations ranging from municipalities and agriculture companies to the Fortune 500s are getting involved in drone operations.

In another three to five years, it will potentially make business sense for nearly every major industrial company to incorporate UAS technologies into their operations for two reasons:

  1. Drones are effective at both mitigating risks and increasing operational efficiency.
  2. Drones are a tool that can bolster workforce recruitment and retention efforts.

Terminology & Technology

As drones become more popular and the industry continues to grow, newer and more varied versions of them are hitting the market, making it difficult to keep up with the technology and the related terminology.

If you’ve observed or read anything about drones, you may have noticed a few acronyms thrown around, and that can be a little confusing. Some of the most common terminology includes the following:

  • Drone is used to define just about any type of Unmanned Aerial Vehicle (UAV). The term refers to many different types of an unmanned aircraft of various sizes, which are used for multiple functions, ranging from armed forces aircraft to hobbyists taking amateur digital photography.
  • Unmanned Aerial Vehicle (UAV) refers to the platform, airframe, or body of the craft you are flying. The term can be used interchangeably with drone.
  • Unmanned Aerial System (UAS) includes the vehicle or aircraft, the controller, and the link(s) that connect them. A small Unmanned Aerial System (sUAS) is a UAS weighing less than 55 pounds at takeoff and landing.

It is best practice to use UAS in formal documents like policies and procedures. If you have a diverse approach that includes both light and heavy drones, then specifying whether a document pertains to sUAS or UAS operations would be optimal, as the regulations vary based on weight, and your operational policies and procedures would need to reflect this.

Types of UAS

While there are variety of drone technologies on the market, the three main types of UAS available in the commercial space are the following:

  1. Multi-rotor UAS is the most popular drone type for both commercial use and for hobbyists. This type of drone is typically less difficult to operate. They offer vertical take-off and landing and the ability to hover, both of which can result in highly detailed data points and targeted insights. Quad-, hexa-, and octo-copters are all available (i.e., 4, 6 or 8 rotors). There are a number of typical use cases of multi-rotor drones, including industrial inspections, aerial mapping, site planning and monitoring, cause finding, resource management, crop spraying and many more.
  1. Fixed-wing UAS function more like an airplane than their multi-rotor counterpart. These drones often resemble small airplanes or mechanical stingrays. They consist of two fixed wings on either side of the craft. This design provides for more efficient aerodynamics and longer flight times (~45-60 min per flight). Fixed-wing have high aerial coverage (up to 2,400 acres per flight) but offer less detailed imagery, are typically unable to hover, and are more suited for covering large areas of land, resulting in large data sets with less detail than you would collect using a multi-rotor or a hybrid UAS. These drones require a suitable runway area for takeoff and landings and are usually able to carry heavier payloads than other types of UAS. Typical uses include beyond visual line of sight (BVLOS) operations, photogrammetry and 3D mapping, crop inspections, and other tasks that require significant area coverage.
  1. Hybrid UAS are gaining popularity, as these platforms offer the benefits of a vertical takeoff and landing and the ability to fly quickly in a forward motion to cover larger areas of land, while still having the ability to hover. Hovering allows for close-up inspections and produces more detailed information than a quick fly by. Hybrids range in their load carrying capability. Hybrids can be used in many of the same ways as fixed wings and multi-rotors but are most excitingly known for their use in delivery services and unmanned air taxi applications.

Payloads

In addition to the drone itself, there are many types of payloads, which is a generic term for the cameras, sensors, or other equipment that can be attached to and carried by drones:

  • Specialized cameras are the most often used payloads for drones.
  • Various cameras offer the ability to gather higher resolution images with greater detail.
  • LiDAR units can be attached to gather data points from any work site, which can then be translated into 3D-modeling efforts to aid in volumetric applications.
  • Thermal/infrared cameras provide heat sensing capability.
  • Gas detection cameras detect fugitive gas leaks at pipelines and tanks.
  • Multispectral and hyperspectral sensors are electromagnetic energy sensors that offer insight into details on resources that would otherwise be invisible to the human eye.
  • Environmental sensors (e.g., chemical sensors) can measure chemical compositions and traces of particular chemical substances, including radioactive particles and particulate matter.

Undoubtedly, the types of drones and the payloads will continue to expand as the market and applicability of drones continues to grow.

Learn more about Kestrel’s UAS Program Management services. Stay tuned for the rest of our Drones 101 series, featuring:

28 Jan
OSHA Recordkeeping
OSHA Final Rule: Electronic Recordkeeping

On January 24, 2019, OSHA published the final rule revising the Improve Tracking of Workplace Injuries and Illnesses regulation. This rule rescinds the requirements for establishments with 250 or more employees to electronically file information from OSHA Forms 300 and 301. These establishments will continue to submit information from their Form 300A.  In short, all covered employers must electronically submit, as follows:

  • Establishments with 250 or more employees that are subject to OSHA’s recordkeeping regulation must electronically submit to OSHA some of the information from the Log of Work-Related Injuries and Illnesses (OSHA Form 300), the Summary of Work-Related Injuries and Illnesses (OSHA Form 300A), and the Injury and Illness Incident Report (OSHA Form 301).
  • Establishments with 20-249 employees in certain high-risk industries must electronically submit to OSHA some of the information from the Summary of Work-Related Injuries and Illnesses (OSHA Form 300A).
  • Establishments with fewer than 20 employees at all times during the year do not have to routinely submit information electronically to OSHA.

In the final rule, OSHA emphasized the new rule does not change any employer’s obligation to complete and retain injury and illness records under OSHA’s regulations for recording and reporting occupational injuries and illnesses.

Additionally, OSHA is amending the regulation to require employers to submit their Employer Identification Number (EIN) electronically as part of their submission to enhance data and further improve worker safety and health.

Post Your OSHA 300A by February 1

Do not forget! The OSHA Form 300A log must be posted every year by February 1, summarizing all injuries from the previous year. The log must be visible from February 1 until April 30, and must be signed by a company executive or authorized representative, indicating that the information is true and accurate.

 

28 Jan
compliance cartoon
How to Effectively Resource Compliance Obligations

Regulatory enforcement, customer and supply chain audits, and internal risk management initiatives are all driving requirements for managing regulatory compliance obligations. Many companies—especially those that are not large enough for a dedicated team of full-time staff—struggle with how to effectively resource their regulatory compliance needs.

Striking a Balance

Using a combination of in-house and outsourced resources can provide the appropriate balance to manage regulatory obligations and maintain compliance.

Outsourcing provides an entire team of resources with a breadth of knowledge/experience and the capacity to complete specific projects, as needed. At the same time, engaging in-house resources allows the organization to optimize staff duties and ensure that critical know-how is being developed internally to sustain compliance into the future.

Programmatic Approach to Compliance Management

Taking a balanced and programmatic approach that relies on internal and external resources and follows the three phases outlined below allows small to mid-size companies to create standardized compliance management solutions and more efficiently:

  • Identify issues and gaps in regulatory compliance
  • Achieve compliance with current obligations
  • Realize improvements to compliance management
  • Gain the ability to review and continually improve compliance performance

Phase 1: Compliance Assessment

A compliance assessment provides the baseline to improve compliance management and performance in accordance with current business operations and future plans. The assessment should answer the following questions:

  • How complete and robust is the existing compliance management program in comparison with standard industry practice?
  • Does it have the capability to yield consistent and reliable regulatory compliance assurance?
  • What improvements are needed to consistently and reliably achieve compliance and company objectives?

It is important to understand how complete, well-documented, understood, and implemented the current processes and procedures are. Culture, model, processes, and capacity should all be assessed to determine the company’s overall compliance process maturity.

Phase 2: Compliance and Program Improvements

The initial analysis of the assessment forms the basis for developing recommendations and priorities for an action plan to strengthen programs, building on what already exists. The goal of Phase 2 is to begin closing the compliance gaps identified in Phase 1 by implementing corrective actions, including programs, permits, reports, training, etc.

Phase 2 answers the following questions:

  • What needs to be done to address gaps and attain compliance?
  • What improvements are required to existing programs?
  • What resources are required to sustain compliance?

Phase 3: Ongoing Program Management

The goal of Phase 3 is to improve program processes to eliminate compliance gaps and transition the company from outsourced compliance into compliance process improvement/program development and implementation. This is done by managing the eight functions of compliance—identifying what’s needed, who does it, and when it is due. Ongoing maintenance support may include periodic audits, training, management review assistance, Information Systems (IS) support, and other ongoing compliance activities.

Case Study

For one Kestrel client, business growth has increased at a rate prompting proactive management of the company’s regulatory and compliance obligations. Following a Right-Sized Compliance approach, Kestrel assessed the company’s current compliance status and programs/processes/procedures against regulatory requirements. This initial assessment provided the critical information needed for the Kestrel team to help guide the company’s ongoing compliance improvements.

Coming out of the onsite assessment, Kestrel identified opportunities for improvement. Using industry standard program templates, in combination with operation-specific customization, Kestrel created programs to meet the identified improvement from the assessment. Kestrel then provided onsite training sessions and is working with the company to develop a prioritized action plan for ongoing compliance management.

Using the appropriate methods, processes, and technology tools, Kestrel’s programmatic approach is allowing this company to implement EHS programs that are designed to sustain ongoing compliance, achieve continual improvements, and manage compliance with efficiency through this time of accelerated growth.

Making the Connection

Kestrel’s experience suggests that the connection between management and compliance needs to be well synchronized, with reliable and effective regulatory compliance commonly being an outcome of consistent and reliable program implementation. This connection is especially important to avoid recurring compliance issues.

Following a programmatic approach allows companies to realize improvements to their compliance management and:

  • Organize requirements into documented programs that outline procedures, roles/responsibilities, training requirements, etc.
  • Support management efforts with technology tools that create efficiencies and improved data management
  • Conduct the ongoing monitoring and management that are vital to remain in compliance
  • Gain the inherent capacity, capability, and maturity to comply, review, and continually improve compliance performance

 

25 Jan
Compliance Assurance
Compliance Assurance Review

An audit provides a snapshot in time of a company’s compliance status. An essential component of any compliance program—health and safety, environmental, food safety—an audit captures compliance status and provides the opportunity to identify and correct potential business losses. But what about sustaining ongoing compliance beyond that one point in time? How does a company know if it has the processes in place to ensure ongoing compliance?

Creating a Path to Compliance AssuranceBusiness Process Improvement

A compliance assurance review looks beyond the “point-in-time” compliance to critically evaluate how the company manages compliance programs, processes, and activities, with compliance assurance as the ultimate goal. It can also be used as a process improvement tool, while ensuring compliance with all requirements applicable to the company.

This type of review is ideal for companies that already have a management system in place or strive to approach compliance with health and safety, environmental, or food safety requirements under a management system framework.

Setting the Scope

The scope of the review is tailored to a company’s needs. It can be approached by:

  • Compliance program/topic where the company has had routine compliance failures
  • Compliance program/topic that presents a high risk to the company
  • Compliance program/topic that spans across multiple facilities that report to a central function
  • Location/product line/project where the company is looking to streamline a process while still ensuring compliance with multiple legal and other requirements

While each program, project, or location may differ in breadth of regulatory requirements, enforcement priorities, size, complexity, operational control responsibilities, etc., all compliance assurance reviews progress through a standard process that ties back to the management system.

Continual Compliance Improvements

Through a compliance assurance review, the company will define and understand:

  • Compliance requirements and where regulated activities occur throughout the organization
  • Current company programs and processes used to manage those activities and the associated level of program/process maturity
  • Deficiencies in compliance program management and opportunities for improvement
  • How to feed review recommendations back into elements of the management system to create a roadmap for sustaining and continually improving compliance
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