As a small business owner or contractor, you may be asked to complete a job that you’ve never done before.
Are you a small business owner or contractor with a reputation for quality work who is highly respected and appreciated in the community? If the answer is yes, you may be asked to complete a job that you have never done before. It is this type of “non-routine work request” from a customer that can potentially lead to a major injury, fatality, or liability exposure. The following provides a brief overview of what management should consider before conducting this type of work as well as a hierarchy of controls to consider (engineering controls, administrative controls, personal protective equipment, etc.) BEFORE commencing work.
General Steps for Conducting Non-Routine Tasks
First, the owner and/or manager of a business must have a policy or procedure in place to determine what to do in the event a non-routine task has been identified. One must ask: Have we done a job like this before? Have we been trained? Do we have a written procedure? It is extremely important to ask these questions before performing the task, rather than wait until after someone is injured or killed. Employees should also be trained to identify what a non-routine task is and not to conduct this type of work until approved by management. OSHA requires employers to inform employees, in writing, of task-related hazards and provide training and other controls as necessary to prevent injury. Examples of non-routine tasks may include, for example: entering a tank to perform cleaning, using equipment that is rarely used, building a structure that has never been constructed, etc. It is important to note that non-routine work may be unplanned or unscheduled and may need to be completed immediately, so employee awareness, training, and ensuring the right employees are tasked for the job is of utmost importance! If procedures and training are not in place, an employer may be at risk for OSHA citations and related penalties.
Conduct a Pre-Task Assessment or Survey
Determine if the task meets the definition of non-routine task. Does the task have some of the following characteristics: performed infrequently, outside of normal duties, no procedure in place, potential high-level of risk, employees not trained or aware of hazards, etc. It is often helpful to first walk the job-site and gather information that may be needed to determine what equipment, supplies, and personal protective equipment may be needed, number of employees necessary, training and supervision required, diagrams/drawings required, etc. It is also important to ask during this assessment: What injuries could potentially occur? What is the potential severity of the injury? What hazards could lead to an injury or injuries? What conditions or series of events could lead to an incident? What hazards are present or a potential? Could the task or end-product potentially injure others? All the information gathered during the pre-task assessment should be documented and used in the formulation of a safe work procedure. Risks associated with activities should be documented per the likelihood and severity of an injury. Controls should be identified and implemented for each identified hazard (this process is also known as a job safety analysis).
Specific topics to consider during the pre-task assessment may include, but are not limited to:
- Is lock-out tag-out needed?
- Is any work conducted in a confined space?
- Is any hot work (welding, torch use, etc.) required?
- Are any chemicals needed for the project?
- Is there any heavy lifting or work from heights (>4’ in manufacturing, >6’ in construction)?
- What tools and equipment are needed to safely perform tasks?
- For construction: are specs, drawings, or blue-prints available? Are employees competent and trained? Who will be using what is constructed? Is there any obligation to perform training and/or warn users of hazards?
- Would the work be safer using a “buddy system?”
- Any maintenance concerns (high-pressure equipment, special tools, etc.)?
- What personal protective equipment is needed?
Develop a Written Plan or Procedure
Based on the results of the pre-task assessment, a written procedure should be developed that identifies the following:
- Identification of the work or task to be performed.
- Responsibilities of management and all employees involved in performing the task.
- Supplies, equipment, and personal protective equipment required to safely perform the task.
- Step-by-step work instruction that has enough detail to be understood by all employees performing the work.
- The procedure should be developed by involving employees. Employees are more likely to buy into the procedure and follow it if they are involved in the process and able to give feedback.
Provide Employee Training
All employees that are involved in performing the non-routine task or have responsibility for ensuring the safety of employees should be trained on the written procedure. Employees should be required to demonstrate competence when necessary (for example: donning fall protection, operating equipment, etc.). All training should be documented and maintained on file.
Perform the Task
Only trained employees should then perform the task. Job supervision depends on the size and complexity of the job and should be determined during the pre-task assessment. Any activities performed outside of the work procedure should be approved by a Supervisor/Management only.
Non-routine work procedures should be reviewed by the employees and manager(s) who were involved in the work. Ongoing reviews will assist with determining if any gaps exist in current controls or if any safety improvements and/or changes are necessary in the future.
In summary, non-routine work or tasks can be deadly if time is not taken to understand the hazards involved with a task and implement safe work controls. Controls may be in the form of engineering controls, administrative controls (procedures, training, etc.), or personal protective equipment (last line of defense). In some cases, it may be decided that the task is too dangerous and may not be conducted at all.
A pre-task assessment, written procedure, training, and post-task review are all very
important steps for ensuring all employees are free of injury at the end of each workday!
Benefits of a non-routine work program include, but are not limited to, no injured employees, regulatory compliance, lower insurance costs, improved morale, increased production and efficiency, and maintenance of your company’s good reputation in the community.
Accidents happen. Mistakes are made. All affect your bottom line. Thankfully, Pekin Insurance has a Loss Control program that helps reduce and often eliminate the occurrences of these undesired events.