Many employees work alone at a customer's site or on the road with no immediate supervision or the presence of a safety professional to check for hazards. Some workers, such as journeymen electricians and certified crane operators, are trained to operate with minimal supervision. Other workers may be less trained or less equipped to individually analyze their setting. Unfortunately, both types of isolated workers may violate OSHA standards, and preventing that misconduct is more of a problem when employees are working alone.
Employers have a duty to ensure their employees' safety even when the employer has no supervision or safety professionals onsite. In almost all situations, the employer cannot delegate this responsibility to others for even the most skilled workers. A balance must be struck.
Many employers fail to establish programs to effectively supervise these often highly skilled employees, although some have a solid system in which employees confer throughout the day with supervisors, dispatchers and technicians. Even if the employer has trained employees to exercise greater responsibility when working alone, are these procedures documented?
In addition to the practical need to ensure employee safety, OSHA may cite employers for inadequate safety measures when remote employees are hurt. Consider how your operation would look in a “Monday morning quarterback” scenario. OSHA may envision supervision or a safety professional checking on the work or surveying the site. Such actions may not be practical for businesses such as a ready-mix delivery or a skilled technician working alone on controls.
Employers must continuously remind employees to always pause, consider the site or job's hazards and take steps to avoid these hazards. Of course, this is how all employees are expected to operate, but with isolated employees, you must drum this into their heads and devise processes to remind them to take this approach. For these workers, emphasize their unique role of having to conduct their own site safety or hazard analysis. One employer described the “TRACK” mantra their employees follow, which includes stop and:
- Think through the task
- Recognize the hazards
- Assess the risks
- Control the hazards
- Keep safety in all tasks
Under construction OSHA standards 1926.20 and 21, an employer must:
- Maintain accident-prevention programs providing for frequent and regular inspections of the job sites, materials and equipment to be made by competent persons.
- Instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his work environment to control or eliminate any hazards or other exposure to illness or injury.
How do employers meet their obligations when no supervisory or safety personnel accompany the workers? Possible actions might include:
- Documenting thorough training to equip employees to recognize and avoid hazards.
- Determining the probable range of hazards employees may encounter at various types of jobs and documenting that they actually carried out such an analysis. Many jobs and sites are similar, and it should be possible to determine the routine hazards. Now, go a step further and consider “non-routine” hazards.
- Establishing a rule, procedure or form that requires supervision to pause when assigning employees to non-routine jobs or assigning employees to jobs with which they are less familiar. In these situations, additional training or some type of safety analysis may be necessary.
- Requiring employees to at least complete a very basic and brief site safety analysis for those small remote jobs. Many electrical and other specialized contractors require employees to complete a few questions on the work-order paperwork requiring the employee to pause and consider hazards.
- Using tablets or phone apps for the hazard analysis and as a means of tracking compliance and providing advice.
- Developing procedures for employers to call in whenever they have any questions or concerns.
- Spot-checking line crews, technicians, deliveries or small crews. Do you conduct any sort of quality spot-checks or inspect the final work?
- Considering safety concerns unique to each site, such as lockout for electricians and skylights for those working on roofs or overhead power lines.
- Ensuring that job safety analyses (JSAs) are thorough, accurate and consider challenges posed by customer sites.
- Making sure employees know that you will back them if they refuse unsafe demands by customers.
- Holding a regular teleconference if remote employees seldom report to a site where safety and other concerns can be regularly addressed. Many remote workers may work from home or travel from hotel to hotel.
