Five Reasons To Get Serious About Operating Procedures

We are launching a new class on operating procedures.  The objectives of the class are to show people how to write procedures that:

  • Comply with government regulations requiring operating procedures.
  • Are effective, easy-to-understand and can be used in the field.
  • Follow recommended practices to standardize and manage procedures within an organization.

Access class description here: Operating procedures class one-page description

Why offer an operating procedures class now?

Here are five reasons:

  1. Compliance: SEMS Regulations for offshore oil and gas require procedures and poor procedures (or no procedures) can result in fines or orders to shut down operations.  OSHA’s PSM regulations also require written procedures, as do PHMSA pipeline regulations.
  2. Audits: Auditors have identified poorly written or incomplete operating procedures as one of the top noncompliance issues, if not the top issue.
  3. Safety: Good operating procedures are the pathway to safe operations.   They allow you to identify safety hazards early and control them in the design phase.  In the field, they give you a way to align Job Safety Analysis, Personal Protective Equipment and safe practices with the actual operations crews are performing.
  4. Competency & Training: The right procedures help onboarding new employees, pinpoint training needs and make it easy to determine whether personnel have the skills and knowledge to perform their duties.
  5. Investigations and Lawsuits:  The right procedures give you a legal defense if an accident occurs and the wrong procedures (or, worse still, no procedures) may leave you vulnerable in a lawsuit or government investigation.

We are in the process of finalizing our operating procedures class.  The goal is to make it available to people who:

  • Write procedures
  • Manage or oversee procedures in their organization
  • Audit or regulate procedures

The initial classes will be offered at a discount.   If you are interested in holding a class at your office or being contacted when we have classes scheduled, contact us at or by calling (985) 789-0577.

And the Winner Is…..Overexertion

With the Golden Globes, the Oscars and all the other awards that are given out this time of year, here’s one nobody wants to win – Most expensive worker injuries.

Every year, the Liberty Mutual Research Institute For Safety announces the Workplace Safety Index, which looks at the top 10 most expensive workplace injuries.   Once again the award for the injury catagory that costs american business the most goes to…(envelope please)… Overexertion involving outside sources, which is defined as “injuries related to lifting, pushing, pulling, holding, carrying or throwing objects.”

According to the Institute, those kinds of skeletomuscular injuries cost companies a total of $13.79 billion during the analysis period of 2015 and amounted to 23.0% of the total business cost for all workplace injuries.

In total, workplace injuries cost about $60 billion a year, but the top 10 account for nearly $50 billion of that total.

Here is the full top 10 list with the percentage of the total workplace injury cost and dollar amount:

  1. Overexertion involving an outside source  – 23.0%, $13.79 billion
  2. Falls on the same level – 17.7%,  $10.62 billion
  3. Falls to a lower level – 9.2%,  $5.50 billion
  4. Being struck by an object or equipment – 7.4%, $4.43 billion
  5. Other exertions or body reactions – 6.5%, $3.89 billion
  6. Roadway incidents involving a motorized land vehicle 6.2%, $3.70 billion
  7. Slipping or tripping without a fall – 3.8%, $2.30 billion
  8. Being caught in/compressed by equipment or objects – 3.3%, $1.95 billion
  9. Being struck against an object or equipment – 3.2%, $1.94 billion
  10. Repetitive motions involving micro-tasks – 3.0%, $1.81 billion

The only positive to this whole picture is that workplace injury costs have not gone up as a dramatically as other medical care costs.  The cost of all workplace injuries in 2008 was about $53.42 billion.  The cost in 2015 (the year used in the 2017 survey) was nearly $60 billion, about 10% in eight years, versus overall U.S. healthcare costs, which are going up by about 6.5% a year.

The depressing news is that the ranking of the top 10 hasn’t changed much and the costs are not going down.  One area to keep an eye on is roadway accidents, which appears to be growing as a percentage, mirroring the increase in vehicular injuries and fatalities occurring in OSHA statistics.

Want to be a hero in your company?  Let Lifeline Strategies help you develop a plan to reduce skeletal muscle injuries, like bad backs and knees, and falls at your place of work.  Those are the injuries that are costing companies money and focused attention on those areas can produce big results on the bottom line.  Contact us at or by calling Ken Wells at (985) 789-0577.


Update: The Oil Rebound is Happening. Six Steps To Return To Work Safely.

In October, I ran a blog post that predicted that we had seen the bottom on oil prices and that companies needed to start preparing for the upturn, specifically, how to get back to work safely.  It got mixed reviews.  Most people who commented agreed, but several people said it was too early and companies were still laying off employees.  Both sides were right.  One of the problems with this energy recovery is that it is uneven and, depending on areas of operation and how they fit into the exploration and production cycle, some companies are hiring, while others are letting workers go.   However, as I write this, Brent Crude is in the mid-50s and we are waiting to see if OPEC lives up to its promise to hold down production.   With that in mind, I am re-running my list of six things companies should be doing right now to be ready to take advantage of the upswing.  If you need help with any of these areas, please contact us at 

The much-promised rebound in oil prices is starting to look real.  Brent Crude has been over $50 all month.  Predictions of $60 by Christmas are looking like more than wishful thinking. Oil companies are entering their budget cycles with some level of optimism for the first time since 2014.

So are you ready to get back to work?   For many oil and gas service companies, the honest answer may be no.  We may not have the people in the right places to do the work.   By one estimate, the American oil and gas industry shed more than 220,000 jobs, but the true number may be much higher when you count trucking, construction and other providers who may not show up under the “oil and gas” category.   That is a lot of positions to fill. We’ve been to this rodeo before and we know that, when business ramps up, we see the big increase in injuries, accidents and claims.

So what should a company be doing now to take advantage of the coming upturn?  Here is a short checklist:

____ Safety Plan Review:  There have been some changes to regulations since the downturn and some new customer requirements.   More than that, operators are likely to want your safety program to follow a SEMS or other safety management format.   In most cases, I find companies already have the safety management elements; they just need to be revised and reformatted, but it can mean the difference between getting and losing a job.

____ Pre-employment and Post-Offer Testing:  Drug and alcohol testing is a must.   Depending on the job, compliance testing (audio, respiratory fit tests, etc.) may be required.  Physicals and physical assessments should be a part of your program.   Making sure new people can perform job functions is critical when there are so many new hires.  If you don’t budget for testing and have an organized process for onboarding, you risk having injury costs eat up any profits from the new work.

_____ Injury Case Management: Honestly, this hasn’t been much of a problem during the downturn.  Less work.  Fewer injuries.  More time for safety managers to stay on top of injuries.   That all changes when it gets busy.   One of the secrets of successful safety programs is that they focus on case management to keep unwarranted recordables down, help workers get well and back on the job more quickly and minimize workers comp costs.   This is the time to line up a provider who can help support case management so you can focus on preventing accidents.

____ Job Descriptions and Skills Assessments:   This may be a head-scratcher, but if you don’t have accurate job descriptions, how do you know what new hires will do?  And if you don’t have a methodology to assess workers on the particular skills that make up the job descriptions, how do you know whether you have the right people doing the jobs?   Sure, every company has a number of in-house subject matter experts who know every job inside and out. However, those people are worth their weight in gold and they won’t have time to look over every new employee’s shoulder.

_____ Operating Procedures: See above.   Too many companies rely on head knowledge, not written knowledge.  The most experienced people will be too busy to share everything they know.  You also run the risk that they will be hired away just when you need them most.  Operators and government inspectors have already said many service company SOPs are inadequate.   It only gets worse when a lot of new people head out into the field.   Now is the time to make sure procedures are correct and can guide a new employee in the job.

_____ Training:  Review your introductory training.    Does it meet your needs?   How will you make sure every new employee is ready when things get busy.    What about supervisory training?   Supervisors and mid-managers are the most important part of your workforce when new jobs start up.  They need to be ready to lead their crews.

That is a short list.  There are many other things that companies need to have ready when things pick up.  However, we need to remember that we call them “service companies” for a reason.  Service is delivered by people and having the right people ready to do the job is the most important investment you can make when business returns.

Lifeline Strategies has expertise in each of these areas.  If you want to be ready to take advantage of the upswing in the oil and gas cycle, let’s talk.   We can help develop a plan of action or provide you with solutions for any of the challenges listed above.  Contact us at or call at (985) 789-0577.

Safety in America: A Mixed Report Card

When I talk to a lot of the most experienced HSE professionals about the next steps in improving safety, a surprising number of them are not sure where we go from here.   We have made a lot of progress.  The profession has never been as highly educated and respected within individual organizations.  We are spending more on safety and we know more than we ever did about all of the tools that belong in a safety toolbox.  But you have the sense from talking to the experts that the pace of improvement is slowing.   Simply put, when we had a lot more accidents, instituting a new safety approach was likely to produce great results, but now that we have gotten down to just a few accidents, addressing those last few is expensive, time-consuming and frustrating.  And some of our assumptions about the relationship between injuries and fatalities are being called into question.

The latest statistics from the U.S. Bureau of Labor Statistics on injuries and fatalities point that out.   There is a very good overview of the injury statistics in Insurance Journal magazine called What Latest U.S. Statistics on Nonfatal Workplace Injuries Reveal.  The headline news is that workplace injuries continue to drop.

The blue line at the top shows that the Total Recordables Cases (TRC) has dropped for the 12th straight year.  That is progress.  For comparisons sake, local government, which has a much less rigorous approach to safety, has a TRC of 5.6.  So that is really good news.   But it is flattening out.

Now look at the red line.  That’s the DART rate, the rate that looks at days away from work, and it has been relatively flat since 2009.  Progress yes, but not the kind we had been experiencing.

Now look at fatalities. The results are disturbing.

Apologies for the blurry graph.  What it shows is that after falling since 1994 fatalities have risen for the past four years, up to 4821 in 2014. True, the workforce has grown and, if you normalize the data, it shows that fatalities had been somewhat flat for the past few years.  But in 2014, the rate per 100,000 workers went up.  That is a trend we need to worry about.

What does this tell us?  Here are five takeaways:

  1. The “easy” solutions are already in place – Our safety meetings, our JSA’s and all of our safety policies and procedures got us to this point.  They contributed to a substantial and impressive decrease in the number of on-the-job injuries.  However, we are somewhat stuck and we need to become more creative and open to other approaches.

  2. The numbers of injuries and fatalities are no longer paired – Most safety professionals are familiar with Heinrich’s law, developed in the 1930’s, which said that for every major injury accident, companies may expect 29 minor injury accidents and 300 “accidents” with no injury.   Statistical analysis over the last few years have found this to still be a valuable ratio.  It supports the idea that minor and major injuries (or deaths) are connected and if you reduce minor accidents you will also reduce deaths.   What these latest numbers show us is that that connection may not be a strong as we think.  My injury rate may fall because I have a great slip, trip and fall program, but it doesn’t help protect an electrician from dying in an arc flash.

  3. We need to question the effectiveness of some of the tools we are using – Online contractor evaluations and training programs have seen spectacular growth in the last five years, but that coincides with the stall-out in injury reductions and the increase in fatalities.  Those tools may be effective, but the numbers show they aren’t stand-alone solutions.  They should enhance or safety initiatives, not replace them.

  4. We need to look at the changing landscape of hazards and risk – This may be the real key.  The rise in smartphone use and other distractions is clearly impacting driving safety.  Companies are starting to see this as their biggest unaddressed hazard, but it has proven very hard to solve.  Prescription painkillers and opioids are increasingly a concern.  Traditional approaches to drug use may need to adapt for a world where more workers are impaired by legal prescription drugs.  

  5. We could stand to lose a few pounds too – Ok, maybe this one is a stretch, but obesity and its companion problems can affect injuries, balance and stamina.  We are also part of an aging workforce and with age comes a change in the risk level of existing hazards.  

On injuries, there is still a lot of room for improvement on safety, but the race gets harder the closer you get to the finish line.  On fatalities, we need to tackle the problem now before it gets worse.   We have our work cut out for us.


Horses Pull 18-Wheeler From Snow

Every time we turn around, someone is pitching a new and improved approach to safety.   Sometimes we have to remind ourselves that newest isn’t necessarily best.  An example of that has been making the rounds on the internet lately.  It shows an Amish farmer using his horses to pull a truck out of a snow bank.  Sure there are plenty of shiny new tow trucks, but this appears to work just fine.


Workplace Drug Use Is Up -Solutions Are Few

Louisiana Association of Self-Insured Employers Lake Charles, LA
Louisiana Association of Self-Insured Employers
Lake Charles, LA

I’ve been at the Louisiana Association of Self-Insured Employers (LASIE) conference this week and one of the hot topics is drug use.  It is a topic you hear about a lot in workplace health and safety, but opioid use and abuse is especially important in Louisiana, which leads the nation in the number of pills prescribed per patient.

Nationally, more and more workers are testing positive for drugs and alcohol, according to the testing company Quest.  It says about four percent of the U.S. workforce tested positive, the highest level in 10 years.   Given the number of states legalizing pot and the shift in public opinion on its use, it is no surprise that a big part of the increase in positive tests is from marijuana.

Need help turning your drug-testing program into an effective substance abuse program?   Research shows that testing is most effective when used in combination with employee onboarding, fit-for-duty policies, education, supervisor training and post injury case management.   Contact us at for more information.  

But it is the opiate use that is sparking so much interest. the National Safety Council has called overdoses a national epidemic.   In Northern Kentucky, for example, emergency medical personnel run on an average of seven drug-related calls a day.  According to officials, “One person in Northern Kentucky died from a drug overdose every 40 hours last year — nearly five times the number of people killed in car crashes.”

What should employers do?  The answers aren’t clear.  Drug testing is important, but there are limits on what tests alone can accomplish. Don’t forget that we are already testing millions of employees, but drug use appears to be on the rise and drugs like heroin are threatening whole regions of the country.   The other factor is that the motivation for an employee taking recreational drugs and those addicted to opioids because of chronic pain are two very different things.  That impacts the drug testing program.

Beyond the reasons why an employee may use the drug, discovery of its use may also be different.  Heroin often takes no more than 2 days to leave the system.  Oxycodone and hydrocodone don’t show up in commonly used five-panel tests, which the standard DOT-required test (at least for now).   According to a very good article from the Society for Human Resources Management, the bigger problem may be that the the employee is likely to have a valid prescription for painkillers.  That means the employer may never even be informed of the use, unless the Medical Review Officer determines that the use doesn’t match the prescription.

Testing is still a necessary part of an employer’s program, but it needs to be just one part of a multi-pronged approach that both ensures that no one is impaired while working a safety-critical job and removes the stigma that often keeps employees from seeking treatment.

A good starting place for companies is the National Safety Council’s report, The proactive role employers can take: opioids in the workplace.  It lists five steps employers should take:

  1. A clear, written policy
  2. Employee education
  3. Supervisor training
  4. An employee assistance program
  5. Drug testing

One important point that comes from the report is the potential for pain management programs to actually increase chronic pain.  The best time to address the problem appears to be at the point of injury when more options may be available.

Pokemon Go: How Much of Safety is Protecting People From Their Own Stupidity?

pokemonWord from Washington State, where the Coast Guard is apparently investigating whether the popular game Pokemon Go is creating a safety hazard at a public ferry.  Players use their smartphone maps to track down  “Pokestops,” virtual hotspots where the game designers have placed Pokemon characters.   Unfortunately, a lot of Pokestops have been placed at ferry terminals, resulting in players wandering into unsafe areas, bypassing security rules and generally disrupting the operations, according to Maritime Executive magazine.

It raises a serious and fundamental question about safety and prevention.   Is safety a matter of identifying hazards and then controlling them, the way they explain it in textbooks, or does it also include trying to anticipate every possible thing that humans can to to to under over or through the safety controls we put in place?

Ferry terminals barriers, fences and warning signs to protest passengers, but they are no match for a 22-year old with his nose in an I-phone wandering towards the edge of a pier.   As Albert Einstein famously said “Two things are infinite: the universe and human stupidity; and I’m not sure about the universe.”

To address this we can go to one extreme of banning any activity in the name of safety.  There is a famous story of a British man who has been mowing the grass by the roadside by his house in Wiltshire Council for 43 years, but was ordered to stop  by the town council for fear that he might get hurt “whilst working on land that was not his responsibility.”

In general we tend to go to the other extreme.  We develop safety plans and policies for a world where everyone behaves rationally and then we are surprised when they don’t.  For example, there are plenty of signs, walls and barriers at the edges of the Grand Canyon.  Yet, according to a book named Over The Edge: Death in Grand Canyon, two-to-three people fall from the rim and die every year.  Causes include:

  • Crossing retaining walls or guard rails
  • Walking off the trail
  • Jumping rock to rock or ledge to ledge
  • Snow and ice
  • Hiking at night

Would one more sign or barrier fix stupid?   Doubtful.

In every day practice we focus on the physical aspects of safety – the flammability of a chemical or the force of a falling object – because those are the aspects that are the most predictable and can be controlled.  We tend to shy away from the human factors, which turn out to be the least predictable aspects and, lets face it, uncontrollable.  When Yogi Berra said that “Baseball is ninety percent mental and the other half is physical,” he could have been talking about safety.

Or we could take the opposite approach, as outlined in a famous letter to the editor at the Arizona Republic by a man named Lawrence A. Bullis:

Every day, some new do-gooder is trying to save us from ourselves. We have so many laws and safety commissions to ensure our safety that it seems nearly impossible to have an accident. The problem is that we need accidents, and lots of them.

Danger is nature’s way of eliminating stupid people. Without safety, stupid people die in accidents. Since the dead don’t reproduce, our species becomes progressively more intelligent (or at least less stupid).

With safety, however well-intentioned it may be, we are devolving into half-witted mutants, because idiots, who by all rights should be dead, are spared from their rightful early graves and are free to breed even more imbeciles.

Let’s do away with safety and improve our species. Take up smoking. Jaywalk. Play with blasting caps. Swim right after a big meal. Stick something small in your ear. Take your choice of dangerous activity and do it with gusto. Future generations will thank you.

Pain From OSHA Fine Increase Already Being Felt

What a difference a day makes when if comes to OSHA penalties.  America’s safety watchdog had not raised its penalties since 1990, but last November Congress tied the agency’s fines to inflation and OSHA set August 1st as the day the penalties would go up.  So, if your company was cited by OSHA on Friday, July 29th, you would have been fined under the old penalty schedule.   However, starting on August 1, those fines went up almost 80% to reflect the inflation rate during the 26 years that the penalties were frozen.

So what happened at the beginning of August?  Clearly the price tag for violating safety rules jumped.  To get a feel for how much, I looked at the cases reported by OSHA online for the end of July and beginning of August. (Note: this is by no means scientific. Each case is different, citations change and the agency has a lot of discretion about its recommendations on total fines).

On Monday, August 1st, OSHA issued nearly $900,000 in fines.  All told there were six companies cited with an average fine of $148,617.

However, on Friday July 29th, OSHA cited 21 companies for a total of $3.9 million.   The average fine was $186,288.  That number needs some analysis to get true picture.  Three of those fines were  so high that they need to be considered individually:

  • Fraser Shipyards Inc
  • Tyson Fresh Meats Inc.
  • Material Handling Systems/MHS Technical Services

If those three very large cases are taken out of the total, the fines against the remaining 18 companies averaged $74,281.   So one way to look at the difference for a “run-of-the-mill” case was $74,281 on July 29th vs. $148,617 on August 1st.    That is the type of difference that gets people’s attention!

The hidden headline may be that so many companies were cited right before the deadline went into place.  On most days OSHA cites a handful of companies maybe four-to-six, but on the last day for the lower fines, OSHA cited 21 companies.  Why so many?  The simple answer is that each case is different and it may be impossible to draw conclusions.   There is a lot of communication between OSHA and companies that are under investigation.  It may be that the companies worked hard to clear up problems in order to get the citations handled under the deadline.

Does the abnormal number that “lucked out” matter in terms of a deterrent?  Maybe not. The objective of fines is to cause companies to address safety concerns.  If you were cited under the old schedule and you know that the next violation would skyrocket, you are probably going to do everything possible to fix the problems.

The bottom line is that Congress and OSHA wanted to make sure that penalties have some bite to them.   Looking at the difference in fines from one day to the next shows OSHA is wasting no time in driving home that message.

Worried about the potential impact that higher fines may have on your business?  Contact us at for a company safety audit or help in developing an effective safety management program to ensure compliance.

Making Sense of OSHA’s Confusing New Recordkeeping Rules

Recently  OSHA delayed enforcement of its recordkeeping rule. The announcement drew a lot of attention and, with the new deadline less than 90 days away, I wanted to provide some guidance to help you comply with some of the more controversial pieces.  Much of industry’s confusion is over:

  • The requirements to inform and encourage employees to report injuries in a timely manner, and
  • OSHA’s anti-retribution clause, under which OSHA may fine companies that try to discourage reporting. That included a warning from OSHA to not use post-incident drug testing as a way to discourage reporting.

OSHA says it will come out with guidance on the requirements, but in the meantime, here is some additional information:

Informing workers of their right to report injuries – Employers have a responsibility to make sure their employees understand they have a right to report injuries and illnesses without threat of retaliation. Fortunately this should not be hard to comply with.

  1. Get the latest edition of the OSHA “It’s the Law” worker’s rights poster and post it in a conspicuous place. It can be found here:
  2. Cover the information in a safety meeting or toolbox talk. Document the subject and participation by workers.
  3. Update written safety policies with the regulatory information.

Injury Reporting Procedures – OSHA has said, “An employer’s procedure for reporting work-related injuries and illnesses must be reasonable and must not deter or discourage employees from reporting.” Perform an internal assessment. How do employees report injuries in your company? Who do they report to? What is the reaction of supervisors or managers?

CORE WheelConsider the value of CORE’s TimeZero injury case management in meeting this requirement. Employees receive a card with a dedicated phone number to call if they are injured. That number connects them to a registered nurse who will assess the injury and determine the right level of treatment, if treatment is necessary. Because TimeZero is available around the clock, anywhere in the country, an employee can still report and that may manifest itself if an injury, like a muscle pull manifests itself after hours, the employee can still report it in a timely manner. If you would like more information about ways to incorporate this into your injury reporting procedures contact us at or by calling 281.630.3724

Do not retaliate against workers for reporting injuries – This is a lot trickier than it may appear, because OSHA has taken the position that company policies that punish workers for taking too long to report an injury are retaliatory. From a company perspective when an employee claims that an injury occurred days or even weeks late, it makes it hard to determine if it was indeed work-related and covered by workers comp.

However, in February, OSHA sued US Steel for suspending two workers without pay for five days for not reporting injuries in a timely manner. OSHA said the policy was retaliatory and that workers should have at least seven days to report an injury.  That case settled last month and, among other things, US Steel agreed to a policy that says workers must report injuries as soon as reasonably possible, but in no event later than leaving the plant or eight hours after becoming aware of the injury or illness. They must also report near misses as soon as they are aware of them and no later than when they leave the plant.

What does that mean for employers? You really need to ask qualified counsel that, but it appears to make it easier to adopt policies that require reporting in a reasonable time-frame. However, companies are also advised to communicate very clearly with their employees why they have the policy and why quick reporting helps improve their overall recovery if they are injured.

Again, OSHA has said it will come out with guidance for industry on compliance, but these suggestions should help companies prepare for the new deadline, which hits November 1st.
For more information, contact

Meeting Announcement: What To Do In The First Minutes After A Worker Injury

Please plan to come to the next meeting of the South Louisiana STEPS Network on Thursday, July 21 in Lafayette, LA.  My colleague from CORE Occupational Medicine, John Landry, and I will be talking to the group about the importance of handling worker injuries properly and the things that companies should focus on in the first 15 minutes after an injury occurs.

S. LA StepsSTEPS Meeting Details – The STEPS network is a formal alliance between OSHA and the oil and gas injury.  There are 20 different STEPS chapters that meet around the country.  Their goal is to serve as a forum to discuss safety issues and to provide an opportunity for industry and OSHA officials to work towards the safety and protection of oilfield workers.

You can find more information on the South Louisiana STEPS chapter here.

Admission is free and the meeting will be held:

8:30 a.m., Thursday July 21

Safety Management Systems

2916 N. University Ave., Lafayette, LA 70507

Our Speech – We will focus on the steps that companies should take right after an employee is or may be injured.  Study after study shows that the actions you take right after an incident play a large role in determining whether the worker will receive the right treatment, whether the worker winds up on workers comp and how long he or she may stay off the job. We will also answer your questions on how to interpret OSHA reporting requirements from a medical professional’s standpoint.

CORE Wheel



CORE Occupational Medicine – CORE is an industry leader in occupational medicine, providing a full spectrum of workplace health services across the entire employee life-cycle in an organization. CORE’s nationwide network of more than 3400 clinics provides the assurance your company will receive the right care at the right time. CORE can help increase workforce health, wellness, and productivity – and reduce overall medical costs.



What if You Can’t Attend?  – Drop me a note at and I will be glad to send you the powerpoint presentation and talk through how it may apply within your company.