9.1.5 Risk Treatment Options
Using the hierarchy of controls model, the assessment team and management reviewed possible solutions. Recognizing that higher‐level controls would be more effective and reliable, management stated that higher‐level controls should be strongly considered. It should be noted that this PtD example is a redesign of an existing process, not a new design.
For concern #1, a review of available substitutions for pure SO2 suggests lower concentrations of SO2 (aqueous solution) and powdered, granular, and tablet forms of potassium meta‐bisulfite. Costs for existing chemicals and procedures were determined and compared to the proposed solutions and their projected costs. It was determined that the costs of substituting with the less hazardous forms of SO2 were about the same as the cost of pure SO2, but other benefits of using the less hazardous products were the elimination of potential releases of highly hazardous chemicals to the surrounding community, improved employee morale and enhanced management goodwill, and reduced compliance costs and efforts. For concern #2, the location of the DMDC metering machine directly placed in the congested bottling area was evaluated.
It became apparent that the machine could be relocated away from the bottling area with piping to the bottling system. Similar benefits such as employee health, improved morale, management goodwill, and increased space were considered.
9.1.6 Risk Treatment Selected
For concern #1, the winery decided to replace (substitute) pure liquefied SO2 with much less hazardous 6% SO2 solution and potassium meta‐bisulfide tablets. For concern #2, until the bottling line can be relocated to a more open area with good ventilation, it was decided that the DMDC metering equipment should be removed (eliminated) from inside the bottling room and relocated outside the building with hard piping into the bottling room (Figure 11).
Table 7 Risk levels.
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Where: Dark gray indicates high risk; Light gray indicates serious risks; Gray indicates medium risk; Light dark gray indicates low risk.
FIGURE 11 Hierarchy of controls reprinted with permission from ANSI/ASSP Z590.3‐2011.
Source: From ANSI/ASSP (11). © 2016.
9.1.7 Monitoring, Review, and Benefits of Risk Treatments
Following the implementation of both risk treatments, the HSE manager performed periodic monitoring of the new practices. No new hazards were introduced with the two risk treatments. The results of implementing recommended higher‐level controls including substitution and elimination provided the following benefits to the organization:
A reduction in the risk level of 67% for SO2 exposure risk to employees and surrounding community.
A reduction in risk level of 75% for DMDC exposure risk.
Improved employee morale.
Eliminated EPA reporting requirements for SO2.
Reasonably low costs for the potassium meta‐bisulfite (K2S2O5) effervescent tables and ease of use.
Very little cost to relocate and shelter the DMDC metering machine outside of the winery (relocated the system to the outside of the building to eliminate the risk to employees in the bottling areas).
10 THE BUSINESS CASE
When examined using concepts of a business case (which captures the reasoning for initiating or continuing a project or task), PtD solutions have been shown to be good business decisions, whether the analysis includes financial or nonfinancial measures. The NIOSH Workplace Design Solution, “Supporting PtD Using Business Value Concepts” discusses this and provides further references (16, 17).
To evaluate the benefits of the prevention control measures, a PtD business case tool was developed.
The business case model estimates potential benefits of the improvements. For this project, the risk treatments led to substantial risk reduction and had financial and other nonfinancial benefits for the winery. Risk reduction is considered the most important nonfinancial benefit. Legal issues, improvements in Process Cycle Efficiency, and employee turnover rate before and after the interventions are presented in Figure 12. PtD intervention outcomes are presented in Figure 12.
OSH professionals who participate in the design safety process and PtD efforts should take credit for the benefits derived from a successful completed project. An organization's value creation and protection, as well as achievement of business objectives at an acceptable risk level, improved quality and production, employee and stakeholder satisfaction, and cost savings, are all ultimately derived from successful PtD efforts.
11 CONCLUSION
The speed in risk reduction and prevention improvement is directly tied to the degree of involvement OSH professionals take in PtD. Assessing risk and designing‐in safety and health during the design phase must become a common and dominating practice. Key steps necessary for OSH professionals are (i) become experts and leaders in PtD within their organization; (ii) define and establish safety specifications for designers to incorporate into their designs; (iii) help their organization define its risk levels, what is acceptable and what is not; (iv) be actively engaged in the design process, design safety reviews, management of change and procurement; and (v) implement higher level, more effective risk reduction strategies to avoid, eliminate, and reduce risks throughout the life‐cycle of systems.
FIGURE 12 PtD intervention outcomes.
As an important stakeholder of a design team, OSH professionals must be agents for change and set the safety standards. Taking the initiative to be engaged in the process is necessary. OSH professionals cannot wait to be invited to the design process; they should be active members from the beginning. We must be PtD leaders and influence our organizations in the design phase and throughout the system's lifecycle.
Bibliography
1 1 Lyon, B.K., Walline, D., and Popov, G. (2019). Moving risk assessment upstream to the design phase. Professional Safety 11: 24.
2 2 Bureau of Labor Statistics (2019). Census of fatal occupational injuries (CFOI) – current and revised data. https://www.bls.gov/iif/oshcfoi1.htm (accessed on September 1 2020).
3 3 Safe Work Australia (2014). Work‐related fatalities associated with