If the safety director is catching people doing unsafe acts and writing them up, is he really doing his job? It may seem that way, but this behavior is just playing a game of whack-a-mole. A much better approach is to solve for the underlying causes. Consider these violations that commonly occur in manufacturing facilities.

No. 1: Clipping the fall protection harness onto piping or raceway

A typical reason provided by employees is there was nowhere else to clip, and at least they are clipped onto something. That correctly diagnoses the root cause, but the solution is bad.

In such a case, the employer has violated OSHA’s regulations regarding fall protection [29CFR.1910.29]. The employee’s best solution is to refuse to work at that location until the company comes into compliance with federal law. This refusal protects the employee from extreme harm or even death, and it protects the company from asset damage, potential work shutdowns, and potential criminal and civil liabilities.

The company’s solution is to install the necessary fall safety anchors. Doing this in a reactive mode is expensive, and it has the added drawback of delaying task completion. The smart way to do this begins with canvassing the entire plant for elevated work locations, noting which ones have the anchors and which ones do not.

During this process, also note whether an anchor is possible at that location. Where it’s not possible, make some accommodation (e.g., installing a steel beam for mounting the anchor, relocating equipment, using nets, etc.). Then have a contractor with experience in this kind of work install all of the needed anchors that can be installed. And perhaps fabricate and/or install the accommodations necessary where anchors are not feasible.

No. 2: Using “repaired” test leads

These sometimes get damaged in the middle of a job. The electrician returns to the shop to replace them, but there are no replacements. The job needs to get done. So he wraps rubber motor lead tape or maybe phasing tape around the damaged test lead and continues working. This could provide an acceptable level of risk — depending upon the conditions. In a manufacturing facility, those conditions are almost never present. Now with his “repaired” test leads, the test lead problem is “solved,” so he forgets about replacing them.

The way to eliminate this behavior is to keep a supply of test leads on hand. This supply needs a min/max assigned to it, to ensure the test lead box is never empty. A maintenance tech being pushed to do 12 hours of work on a 10-hour shift would much rather grab a new set than spend time taping up an old one.

No. 3: Not wearing hearing protection

The main reason people forego hearing protection in noisy areas is hearing loss tends to be progressive, so a common attitude is the noise isn’t harmful. Another reason given is they lost their earplugs, and the earplug box by the factory door was empty.

The solution here consists of three parts:

1. Place a box of earplugs in the maintenance shop.
2. Make someone responsible for ensuring that box and the other one are kept full. Start with a daily check, then adjust the interval from there.
3. Conduct an education effort. It can start with a class, which should aim to resolve any attitude issues. The typical approach is fact based — not experience based — and that reduces its effectiveness. Consider asking people to experience not hearing. Ask for a show of hands for who likes music, and then ask people to commit to going one month with no music, no podcasts, and no sound for streaming videos. Suggest they ask everyone in their household to communicate with them only in writing for a week. Get them thinking about how important their hearing is and thus how important protecting it is.

No. 4: Not wearing eye protection

This is similar to the hearing protection issue, but with some slight differences. People with prescription corrective eyeglasses can mostly be excluded from this issue, as the lenses comply with ANSI Z87.1, but they still need their side shields. And contact lenses should never be worn by electricians due to what can happen in the event of arcing.

A big reason people remove their eye protection glasses is the lenses are scratched, and it’s hard to see through them. The problem with this “solution” is eye hazards don’t care what your reason is.

Many companies try to save money by limiting how many pairs of safety glasses an employee can get on the company dime. What you actually want to limit is how many safety glasses need to be replaced due to abuse of them by the employees.

The single best way to protect the lenses is to actually wear the glasses. They get scratched when set down on a table or tossed into a hardhat. The only time they get scratched when worn properly is when they protect the eye from flying debris.

Another common cause of scratching is people “clean” the lenses using their shirt or a paper towel. To prevent this, supply eyeglass cleaning wipes in boxes strategically located in eye-safe areas such as break rooms.

Despite good care, those glasses will eventually need to be replaced. Make that easy by providing boxes of safety glasses. If the cost of safety glasses suddenly skyrockets because people are “field testing” them at home for personal use, then the company will have to institute a checkout process for obtaining the glasses and deal with the “frequent flyers” who are abusing the program. Increasing everybody’s risk just to reduce the cost inflicted by abusers is not an ethical choice.

No. 4: Standing on the top rung of stepladders

A commonly given reason is a long enough ladders wasn’t available.

Maintenance departments have often tried to handle this by creating a ladder corral with X ladders of Y length. This quickly becomes expensive and unwieldy, and yet fails to solve the underlying cause. A ladder isn’t always returned to the ladder corral. Maybe it’s the end of the shift and the tired maintenance electrician doesn’t want to make a trip back to the corral with it. Or maybe after having hunted for half an hour to find the ladder, he squirrels it away out in the plant somewhere. This creates a positive feedback loop of ladder hoarding, sometimes leaving the corral empty.

You can’t keep buying more eight foot ladders to keep people from standing on top of six foot ladders. Lecturing people about ladder safety won’t address the ladder shortage — it will just put them in the position of choosing between working unsafely or refusing to do the task.

Your first line of defense here is to eliminate the need for portable ladders wherever practical. Install permanent ladders, stairs, or walkways. You can also move equipment, in many cases, to eliminate the need for a ladder. For example, the motor overload devices are located 12 feet above grade because that’s where the motor is. Relocating them so they can be replaced by someone standing at grade level eliminates the fall hazard.

Where ladders must be used, add some multi-position ladders to your inventory. One of these can replace several lengths of one-position stepladders and extension ladders.

One drawback of the multi-position ladders is they are kind of heavy. An investment in a few ladder dollies will solve this problem. You can purchase these off the shelf or build your own.