Now that we’re aware of the new requirements for Construction Confined Space, we’re at a decision point. We have to decide:
This part is relatively simple. If your organization operates in environment where construction is occurring, then the answer is “yes” (regardless of whether or not crews participate in construction / confined space activities). For organizations that don’t operate in the construction environment, there’s not much else to talk about.
*The exception would be organizations that have a strong safety culture and are interested in the more protective provisions of the new statute.
Once you (or your organization) have made the decision and commitment to integrating the new regulation into the safety management system or safety program, the rest is relatively straightforward depending on how your organization manages change. The next steps involve ensuring that change is accomplished in a systematic, accountable manner.
An ANSI/ASSE Z10-, OHSAS 18001-, or ISO-45001 compliant management system is helpful here, as it provides a framework for addressing change. There are other change frameworks that can be utilized instead of a SMS, but they usually do not help sustaining the change. If there’s no SMS in your organization, consider using a Before Action Review/After Action Review (BAR/AAR) framework to help with implementation (HBR has a neat package for After-Action Reviews if you need help getting started).
Irrespective of the framework you choose to implement change (that’s another blog post for a different time), the next step is to compare and analyze the two regulations. Depending on the complexity and length of the rules, a simple side-by-side comparison can usually help visual the structure of the rule, and help you to identify the different aspects. For example, the infographic included below can help you identify and select the more protective provisions of the two rules (in this case, confined space).
The purpose of integrating the two rules into one safety program should be obvious. As a safety professional, the goal is to provide protection for the health and safety for employees without making the system so unmanageable that it creates a barrier to its use. These are some aspects that you should consider during the integration and implementation:
Addressing these aspects of change and implementation can ensure that any change is lasting and that the management system / program conform to legal and other requirements.
The final step to this entire process is actually completing an internal audit, and then ensuring that continued audits are scheduled. This should be done no later than 1-2 months following implementation for this simple reason: “what gets measured, gets done.” As a corollary, an audit is a high-visibility tool to ensure that the implementation is complete, and that it was important enough to receive management’s (and your) attention.
Hiring a third party safety consulting company can assist you in safety management system implementation, change management, auditing, and more. Click the button below to download our free outsourcing guide for more information.