The idea behind this hierarchy is that the control methods at the top of graphic are potentially more effective and protective than those at the bottom. Following this hierarchy normally leads to the implementation of inherently safer systems, where the risk of illness or injury has been substantially reduced.The Hierarchy breaks down as follows, with the most effective measures at the top of the pyramid and the least effective at the bottom.

1. Elimination/substitution. At the very top is the best way to deal with a safety hazard, which is to eliminate it altogether by preventing exposure to the hazard before it even occurs.  In substitution, you seek to permanently reduce the risk by substitute a less hazardous material or reduction of system energy. These are process design solutions that require a permanent change to how a job is performed.
2. Engineering controls. Change the structure of the work area to reduce exposure using safety devices or barriers.  An example would be to place a high fence around a dangerous location to prevent access or adding plywood walls around jackhammer activities to stop flying debris.
3. Administrative & work practice controls. Implement procedures that require workers to do things to reduce their exposure to a risk.  A lockout/tagout program is an example of an administrative control.  Set expectations that workers will engage in safe work practices. Another example is the use of warning signs, sirens and alarms.
4. Personal protective equipment (PPE). Make sure employees wear the proper protective clothing, gloves and eyeglasses for the job.  Examples are safety goggles, respirators, fall protection and hearing protection.

It is easy when conducting work risk assessment  or incident investigations to focus on the use of PPE and administrative controls because these are often the easiest to see and implement.  But because these rely on human behavior, they are not always the best approaches to take.  During your work risk assessments you  should look further up the pyramid to the higher order engineering solutions and risk elimination strategies, which can prevent the exposure to a risk before it occurs and reduce the risk without relying on fallible human behavior.

There are two key aspects of risk management we need to focus on for all of our work:

1.  Identify key risks to your project; and
2. Implement appropriate actions to help manage those risks.

If we don’t have action plans and mitigation’s for the identified risks, we have done nothing to manage the risk.

At Stratus, project risk management is actually a project managers best friend. What is risk management trying to do? It is trying to help a project manager deliver her/his project safely and efficiently with no surprises?  If you find yourself thinking that identifying, documenting, and creating mitigation’s and an action plan for your projects as a waste of time,  step back and ask yourself what that action plan is trying to do, manage a risk that if not managed could derail your project, and the Stratus reputation.

Another incident stressing the importance of LOTO and conducting a thorough WRAT. Most importantly, LOTO communication to effected employees and physically verifying energy sources are de-energized.   Click here to read about the incident.

During the staff risk evaluation, Gravity was identified as a risk.  The How, Where, When stated “Gravity – injury from slip, trip, or fall”.  The mitigation stated “Gravity – be aware of surroundings”.  The reviewer was correct in determining that the reduction strategy was light on a proper explanation of how to mitigate the risk.  Added, slip/trip/fall hazards should be considered Motion risks, not Gravity.  Gravity risks are those from dropping things on feet or objects falling from above.

In the future, a thorough explanation of the mitigation should be spelled out as a Motion hazard (remember the How, Where, and When).  For example, a better mitigation strategy would say what we actually do “Be aware of and eliminate slip/trip/fall hazards in your surrounding work area”.

In general, all activites we conduct at an active retail site have a SIMOPS component.  If there is no other work being conducted at the site, just your activities, SIMOPS is still occuring if the station is active.  The public fueling of vehicles is considered SIMOPS since there can be an occurance (drive off, car hitting dispenser, car accident,…) that can directly impact you and your subs.  Since we are not in the position to have everyone fueling their car complete and sign a SIMOPS mitigation workplan, we need to state in the WRAT SIMOPS mitigation section that SIMOPS is occuring with a line like “Yes, public fueling of vehicles.  Mitigation discussed at toolbox meeting“. During the toolbox meeting, drive offs, spills, and car accidents should be discussed and how they will be handled if they accor during our work (Stop Work, evacuate to muster point,…). 

If you show up on a site, and there is other work going on at or close to the site (say on the tanks or in the street), you are required to develop a SIMOPS Workplan ( included in the HASP), negotiate the terms and items in the Workplan with the other crew, and follow the terms agreed to.  If the other crew will not agree to enter into an agreement (Workplan), stop work and contact your PM for discussion.