Snow and Ice Removal: The Details Matter

Snow Season Isn’t Over

In the realm of slip and fall prevention, attending to snow and ice control is a given in regions where cold winter temperatures are the norm. At the moment, with spring officially here and warm temperatures in many places, some operators have put snow and ice out of their minds. Yet the season is not fully over; for example, much of the Metro Denver area experienced 3-5 inches of snow this morning and it’s not likely the last snow of the season. I encountered a spot in a parking area this morning that is instructive for those charged with maintaining the safety of parking areas and exterior walkways. Here are two photos of the spot in question. I’ll outline the issues below.

Metal Walkway Plate with Snow and Ice

Metal Walkway Plate with Snow and Ice

Walkway metal plate

Side View Showing Drainage Channel

Why Does This Condition Exist?

First, you’ll notice the strip of snow across the walkway, in a localized spot, surrounded by clear sidewalk. The strip of snow if there because the walkway has a drainage channel across that spot, covered by a steel diamond plate cover. Because the steel cover is exposed to air on the bottom, it freezes much sooner than the regular walkway. This phenomenon is the same as what occurs on highway bridges and overpasses. Takeaway: Have you identified spots of special concern in your walking areas and do you know the factors in play?

What About the Cone?

Next, notice that there is a cone in place. It turns out this was placed there a few hours before the photos above were taken. The maintenance person who placed it there put it in place because the steel cover underneath was slippery due a layer of ice on its surface, under the snow. When the cone was placed, the whole walkway was covered with snow. This cone is beneficial because it helps alert pedestrians to the hazard. It is also not ideal because there are several preventative measures that could have been put in place, perhaps removing the need for a cone. Takeaway: Eliminate or reduce hazards first, then deploy warnings.

Possible Corrective Actions

Here is a round-up of possible preventative measures that could have been employed here:

  • Use a different material for the cover that would not function as a heat sink and be as prone to freezing.
  • Put a textured coating or finish on the cover so it would have better traction when wet or covered in snow.
  • Remove the snow from this cover after any snow accumulation, not just after the trigger level of 2-3 inches that prompts full-scale parking lot snow removal.

There may be other solutions as well, but this should give you a good glimpse of how effective risk control requires specific attention to the real-world details of your situation. The sidewalk and cover in question met building code requirements, which is a good start, but in this case prudent risk control takes more than that.

Auto Repair Shop Carbon Monoxide Control: A False Sense of Security?

Car dealer service department

Large auto repair operations often have vehicles running inside.

That was the reading on the handheld carbon monoxide detector brought along on a follow-up safety consultation visit to the service department of a large automobile dealership. The conditions were typical for the the early part of their service day – several vehicles running at once inside their 20,000 square foot service area, with one of the six large overhead doors fully open to the outside and the others closed. A discussion with the service manager revealed that this was typical in the morning, when cars would be brought in to be checked out and run briefly for diagnosis.

Exposure With Consequences

The spot reading of 400ppm of CO does not tell the whole story related to exposure in the garage. Just a few minutes before, the shop was closed and the reading was effectively zero. And a few minutes later the reading began dropping from the peak. But the 400ppm number was definitely cause for concern. That level is enough to approach short-term exposure issues (see the CDC data on that risk) with exposed workers, and if it is sustained for long it could cause serious issues.

Why Was This Occurring

Even though the facility was equipped with good means of ventilation and a dedicated exhaust removal system, neither of these controls were helping much. The early spring moderate temperatures meant that the ventilation system wasn’t running in the morning, and not one of the running vehicles were hooked up to the exhaust removal system. When asked about this, one of the mechanics said that they will use the system if running a car for a while. When he and others were queried further as to just how long that meant, the answer was far from definite. “More than five minutes.”  “Any extended time.” “Ten minutes or more…” It was clear that this wasn’t well defined, and also was not based on any actual determination of what level was an issue. It was much more about convenience, an informal determination on each technician’s part about if it was worth the trouble of hooking a car or truck up.

Learning from Other Environments

Some of the work I’ve done recently that centers on parking lot and parking garage safety has highlighted the usefulness of carbon monoxide monitoring systems. Though I was focusing on pedestrian safety and vehicle-into-building crashes, many elements of parking safety were looked at to some degree. It became clear that the issue of carbon monoxide in parking structures had been given a lot of attention and had subsequently become the focus of regulatory activity. This set the stage for some great technological options for reduction, monitoring, and exhaust of carbon monoxide that could be applied. In the case of the auto dealership service department, it was monitoring that was a glaring omission from their arrangement.

Industrial Carbon Monoxide Detector

Industrial Carbon Monoxide Detector

Appropriate Detection

A survey of some other auto repair environments showed that some were employing consumer/household style carbon monoxide detectors. The rise of UL standard 2034 and its inclusion in many building codes has led to good availability of simple consumer style detectors. Many more homes are protected today than just a few years ago, but the problem with using a UL2034 detector in a commercial setting such as a garage is that the standard for these residential detectors places a great deal of importance on avoiding false alarms, which means that these detectors are not nearly as sensitive as  most commercial models. The right solution for a garage environment typically requires some analysis by an industrial hygienist, and would include an appropriate advanced detector along with both alerts and possibly automatic activation of  ventilation.

What About Procedures?

Note that the engineered solution is the right place to begin controlling this hazard. The service manager’s suggestion that they begin with a procedural response, including a shorter timeframe to attach the exhaust removal system, and more overhead doors open was not a sufficient solution. The way the shop operated, the longstanding practices employed, and the difficulty in determining action triggers in the existing environment all pointed toward not accepting an administrative-only solution. Naturally, every situation is different, and this case does not indicate that all similar operations should employ the same controls, but it does show that the right factors need to be considered, and any controls employed should have a good expectation of actually being effective!

What is Loss Control?

I had a surprising discussion the other day with the COO of a fairly large grocery company about risk, safety, and insurance issues. His company has sizable exposures in the areas of property, liability, and workers’ compensation, and he has policies with several insurance carriers totaling over 7 figures in premiums.

Misconceptions from bad to worse
What was surprising about the discussion was how well versed he was in the costs of his policies, and the claims and administration related to those claims, but what a limited idea he had about the concept and function of loss control related to his policies. What’s even worse about this situation is that a sizable portion of the commercial insurance community shares the same mistaken idea. What is the mistaken idea?

The idea in question
The mistaken idea in question was that “Loss Control” meant “Inspections.” And by inspections, it meant some sort of non-participatory process where an inspector would briefly visit a location, collect some information, make some observations and perhaps take some measurements, and then be gone. Some group of recommendations might appear a month or two later with a little bit of written explanation and not much more.

I asked the CEO if that’s what his idea of loss control was, and he paused and said that was pretty much it from his experience. His stores are nicely organized and maintained, and very well-run overall. He recieves very few recommendations overall.

Engagement determines impact
The issue here is that even though inspections are often an integral part of loss control, and certainly the most visible part for most smaller accounts, inspections are more of an oversight tool (making sure that the insured company isn’t doing anything that will put them at too great of a risk for losses beyond what their business type would indicate) than an improvement tool (helping attain better performance.) The challenge is engaging with business and property owners and operators to help them improve their performance and better their condition.

So what is it really?
If loss control (or risk control as it is also called)isn’t just inspections, what is it then? Here’s a start. Loss control requires two dimensions: The first dimension is the active engagement of insured entities to understand the hazards that they are exposed to, the controls currently in place, the loss experience they have had over time, and their approach to managing and guiding safety. The Second dimension is working together with those insured entities to improve their performance in a collaborative way. That second dimension is often absent.

The challenge
The biggest challenge toward that goal is that every organization is different and needs help in different ways. Some companies have well-developed safety management and only need targeted collaboration on certain key issues; others don’t have a clue of where to start and need more help than may be included with the service level set for their policies. Inspections will always be a part of the picture, and perhaps the most visible one in many cases, but loss control professionals and leaders need to remember and convey the bigger picture.

Retail Industry Safety: Who Needs a Safety Program at All?

“We’re better off without a safety program.”

…Not What A Safety Professional Wants to Hear

The words hung in the air after he said them. Not the best thing to hear when you are the architect and optimizer of safety programs, brought in to discuss just that. Yet the executive did have a point. He had been in senior management and executive positions for in a number of retail companies for years, and he was accustomed to safety programs for retail stores as mostly low-value with more formality than substance. Legitimate as his concerns might have been, though, they really speak to how well designed and implemented a retail safety program needs to be, not whether you need a program at all.


A specialty grocery retailer (not related to the company mentioned in this article)

Setting the Stage
I was meeting with the vice president of loss prevention of a large specialty retailer just over two years ago. The meeting included representatives from their insurance broker, their workers’ compensation insurance carrier, their liability insurance carrier, and their claims administrators.

Proposing A Safety Program

I’d been invited to this meeting by their workers’ compensation insurance carrier because I’d worked with one of the comp carrier’s other retail clients to develop an overall workplace safety, health, environmental, and guest safety program.  After implementation they experienced excellent results in both incident frequency and severity terms, and the carrier was hoping that this retailer would be open initiating a similar program. As they’d grown to several hundred locations and close to one billion dollars in sales, much of what had worked for them when they were a much smaller organization was not necessarily still optimal for their larger (and growing) operation.

Do They Care?

The Vice President’s statement about not needing a program was not proof that he didn’t care about safety – it was more of a statement to how he viewed the formalized safety programs that he’d been acquainted with in the past. To look at things in a little more detail, this retailer wasn’t ignoring workplace safety and health or guest safety entirely – it just was structured as a marginal endeavor completely handled by groups that had other responsibilities.  Basic compliance was being handled by a combination of efforts from facilities, operations, and human resources internally, and the insurance carriers externally.

Safety Efforts Without A Program

We examined the various things that they were doing related to safety. There were quite a few, across divisional lines. For example:
– The facilities and architecture department ensured that their stores met building and fire codes when they were constructed.
– The facilities group would prepare and post emergency evaluation maps for each facility with exit routes and emergency assembly areas.
– Human resources maintained a section on safety and emergency preparedness in the employee handbook and new employee orientation.
– Human resources maintained the procedures and forms for reporting workplace injuries that require medical treatment.
– Operations used a daily manager’s “four corners” guide which instructed store-level management to circulate through the stores and make sure that everything was in good order and well-presented.
– Operations conducted regular pre-shift meetings in the stores, which were mostly focused on sales and presentation issues but occasionally touched on safety-related items to at least some degree, such as crime prevention.
– Operations maintained a “blackout kit” for each location, which included flash lights, batteries, and chemical glow sticks.
– The property insurance carrier conducted inspections of representative locations (perhaps 5% of all locations) once per year, focusing on fire extinguishers, sprinkler systems, fire alarms, material storage, and exits.

How Well Does that Work?

So that is something, for sure. Aside from those specific activities, they also had an overall brand reputation as a company that cared greatly about a well-organized, well-thought-out, carefully presented, total experience for their customers. No casual observer would suggest that they ran a dangerous operation, or didn’t care about the safety of their employees and customers. Yet for any safety or risk professional observing their arrangement, many issues exist with this sort of approach, and much opportunity remains for overall organizational benefits from a well-designed and implemented retail safety program.

High-end retail

High-end retail: Low risk?

The Challenge of Low Risk Environments

There is ample room for discussion about whether his particular company would be most accurately described as a low or moderate risk operation, but suffice it to say that the perception was that the risk was not significant. Of course, if you looked at their historical workers’ compensation and liability claims numbers, you would see that though they had never experienced a headline-grabbing catastrophe, there were plenty of claims that had significant costs, and even some clear trends related to type of injury and circumstances. At the same time, one retail chain with just over 30 locations experiencing a dozen carpal tunnel claims with average total incurred costs over $40,000 each, and over 100 days of lost time average per case, are a very significant issue. Place that in context with the typical retail employee and manager perception that workplace safety “is not a major issue” and you’ll see the difficulty of putting due attention to safety in many retail organizations.

Preconceived Notions

The VP maintained that any sort of focused safety program would not be worthwhile for them, citing the following reasons:

“This isn’t a hazardous environment.”

“Our people have common sense, and we hire good managers who can figure things out pretty well as they go.”

“We don’t have that many accidents”

“Our accident costs are not high, and the cost to implement a safety program would probably be higher.”

…and perhaps most notably:

“We do safety, already, as part of all the other things we do.”

Satisfactory or Self-Satisfied?

Each of those statements from the VP has some level of truth and applicability to it, but each statement also shows some level of misconception or misunderstanding about a prudent approach to hazard risk in a retail operation. Some of what works wonderfully in a small operation just does not scale when you have hundreds of locations, and thousands of employees.

The Rest of The Picture

Yes, the retailer in question was doing a number of things for the safety of their operation. Consider, though, just some of the things that were not covered to any significant degree by their approach:
– Individual and managerial responsibilities to create a safe environment, and specific examples of how that can be done
– What the various hazards that might be encountered in their workplace are, and how to deal with those hazards
– How to identify new and changing hazards as they arise
– How to monitor the work areas and customer areas for hazards
– What to do about hazards when they are found
– How to train employees on specific hazards and control measures
– In-depth emergency preparedness, with location and geographical consideration to specific location preparedness
– How managers can communicate about safety in a constructive and impactful way
– How managers can help employees do their jobs more safety and do a better job at creating a safe environment for customers
– How safety rules and safety practices fit together, and what rules have specific repercussions
– How safety activities are best documented, to fulfill regulatory requirements but also to help reduce incidents and accidents.
– How that emerging exposures and risk trends can be identified and dealt with early
– How that new information from other operations in the retail industry, and other industries as well, can be best brought in to help improve safety
– How targeted safety approaches, particularly in the area of applied practical ergonomics,  can help make employees not only safer, but less subject to fatigue and reduced productivity.
– Any advanced approaches at all, from alertness management, to behavioral safety, to employee-driven safety approaches
– How a positive safety culture and safety climate can contribute to better customer service, quality, and employee morale

What to Do?

Thankfully, the company in question did agree to initiate a safety program, and saw good results from it quickly. Any sizable company or organization needs a deliberate approach to safety. There are many options and stylistic differences possible in the formation of and implementation of a safety program. The common reluctance of retail executives to embrace safety programs should not be a source of frustration for the safety and risk professional. Instead, it should be viewed as an opportunity to show the deep value of a well-devised program.

Risk Perspective: Foodborne Illness Prevalence

Fresh Fish at a Fish Market

Fresh Fish at a Fish Market

Why Foodborne Illnesses Matter
Foodborne Illness is a significant business hazard risk area affecting restaurants, food service, and food production operations, and many other service, hospitality, and manufacturing industries. It is also an important topic for personal risk control. Because of the importance of the issue, and how many people it touches in one way or another, it deserves repeated coverage from several angles and levels of depth.

The types and categories of foodborne illness, risk factors, signs and symptoms, prevalence, severity levels, and control measures are all worth becoming familiar with to a certain degree. That degree varies, of course, based on your business and personal connection to the issue, but we will begin with some items of near-universal applicability. To that end, let’s take a brief look at what individual foodborne illnesses are the most common and the most dangerous.

Most Common Foodborne Illnesses
(By number of cases in the U.S.)
1. Norovirus
2. Salmonella
3. Clostridium Perfringens
4. Campylobacter spp.
5. Staphylococcus Aureus

Most Dangerous Foodborne Illnesses
(By number of fatalities in the U.S.)
1. Salmonella
2. Toxoplasma Gondii
3. Listeria Monocytogenes
4. Norovirus
5. Campylobacter spp.

Bacteria Under the Mircoscope

Pathogens Under the Microscope

A Question for You

So here’s the question and the issue: If you don’t happen to work directly in the area of food safety, environmental health, or sanitation, how many of those sound familiar to you? How many do you think about related to any particular set of conditions that you see? Many people recognize two or three and have just about no sense of the rest. Did you have any sense, looking at the lists, of what sort of numbers we are talking about? Here are the numbers for 2011:

Number of Cases of Most Common Foodborne Illnesses
(Cases in the U.S., in thousands)
1. Norovirus 5400
2. Salmonella 1000
3. Clostridium Perfringens 965
4. Campylobacter spp. 845
5. Staphylococcus Aureus 241

Most Dangerous Foodborne Illnesses
(By number of fatalities in the U.S.)
1. Salmonella 378
2. Toxoplasma Gondii 327
3. Listeria Monocytogenes 255
4. Norovirus 149
5. Campylobacter spp. 76

Note:  Foodborne Illness Data from Centers for Disease Control, 2000-2008 and 2011 data.

Chef making crepes

Crepe Making

And It Makes What Difference?

Now what do those numbers mean to you? What is the relative level of danger and appropriate response? I’d suggest that most people in general, and many people in affected businesses, don’t have good answers to those two questions. We will cover some of the facts, figures, and approaches to the control of foodborne illnesses in restaurants, food service, food manufacturing, and at home. More importantly, though, is the idea that whatever your business or personal situation, you need to understand the most prominent risks you face, and have a sense of what to do about it.

True Total Cost of Risk

There is a term used in Risk Management field, “Total Cost of Risk,” also known as “TCOR.” This is an important concept in the strategic planning process for making decisions about the purchase of insurance, the deployment of alternative risk programs, and setting retention levels. The traditional “Total Cost of Risk” number includes the following costs:

– Insurance premiums and fees
– Retention (losses below the threshold at which purchased coverage applies, or losses which are self-insured)
– The cost of risk management administration

TCOR is an important number to understand and make use of both for management of a specific company’s program, but also for comparing different business units, benchmarking, setting targets, and in the process of evaluating acquisitions, reorganization, and business process reengineering.

What I’d like to suggest, though, is that while you maintain a good understanding of the traditional sense of TCOR and your organization’s performance in that area, that you also consider a broader idea related to the big picture for risk costs. hence, the idea of “True Total Cost of Risk,” which is not a term with the same universal standard meaning as TCOR, but a very useful conceptual idea to help maintain and communicate a broader view of the implications of risk in organizations.

The idea behind “True Total Cost of Risk,” or “TTCOR” is that there are indirect, uninsurable, and peripheral costs beyond those three categories that may be hard to quantify, but have a definite and substantial cost impact on an organization.

The specifics of indirect accident costs deserve separate and detailed treatment, but are basically related to costs brought on by a loss that are not included in the claim costs, such as the costs of replacement workers or supervisor accident follow-up. These indirect accident costs are a major component of the TTCOT idea, but there is more.

You also might want to consider:

– Costs outside the risk management function in an organization per se that still relate to the administration of the risk management function. An example of this might be shared information technology, software development, or systems support functions.
– Time and effort involved in contractor selection and selection of replacement contractors, both for construction and non-construction purposes
– Impact on operations by constraints imposed by insurance policy conditions or limits (this is another potentially complex idea that also deserves more in-depth treatment)
– Hindrances or facilitation of the speed that new products or offerings can be brought to market by the efforts required to manage the risk of those new offerings
– Design, engineering, and planning costs resulting from code compliance, risk control, or liability reduction efforts

… To name a few. Understanding the breadth and depth of the impact of non-speculative risk of loss can help speed organizations toward their goals, and face fewer surprises down the road.

How good are we at judging risk around us?

“I’ve never had a problem before, and I’ve been doing this for years!

You hear it regularly, and perhaps even say it ourselves. We use our own incident-free experience as justification for the acceptability of an activity. Here’s the problem with that: We are notoriously bad at judging many categories of risk around us. The reason is simple. “Getting away” with a risky behavior does not really prove anything, because the relative probability of an incident or injury can vary widely and still have the same result in the very limited sample that is our own experience.

Here is an example: Terry grew up in a home where his mother would cook a meal and leave the remaining food to cool on the stove, and often not refrigerate it for hours afterwards. Terry continued the practice when he began to live and cook on his own. A woman he began dating noticed the tasty batch of stew that he’d made her for dinner was left on the stove (without the burner on) not only after dinner but all the way through the rather lengthy movie that they watched. She said “Are you not keeping the leftovers?” He said, “Why would you ask that? Wasn’t it good? There’s a lot left.” She replied, “It’s just that it’s been sitting out since 7, and it’s nearly midnight now.” Terry’s answer? “It’s fine.”

In his mind it was fine. But here are some facts to consider:
– The meaty stew he cooked was clearly and demonstrably likely to have far more growth of pathogens that could cause foodborne illness when cooled that slowly and held at room temperature
– Thorough reheating of the stew, as was his common practice, could kill many types of pathogens and result in no ill effects, on two conditions 1. That heating is truly thorough, sustained, and to a sufficient temperature and 2. That there are no toxins or toxic byproducts associated with the particular organisms that affected the stew
– Terry’s own childhood and youth contained relatively frequent episodes of what his family called “stomach flu” even though the actual nature of the illness and cause were never really understood.
– Terry didn’t think that the gastrointestinal issues that he’d experienced were out of the ordinary for a typical family, largely because none were particularly severe, and perhaps more importantly because he didn’t really have any sense of how often other families experienced these illnesses.

Do you see how “It’s fine” is really not true in this case?