Site rules enforcing safety

This foreman was talking about his own site operatives and his own management of safety, however, the way he talks about site safety rules gives them a very minor status - just an odd rule. Reference to violations as odd reduces their impact in both frequency and severity, and positions them within a reality where safety violations (which in practice could be very serious in terms of consequences) are frequently minimised through relatively casual talk and linguistic associations. Furthermore, this foreman s enforcement process does not fit within any wider management practice or process framework and no punishment is included within this level of interaction. This subcontractor s foreman is happy to simply enforce safety without further recourse or punitive action to his own site... 

But the corporate voice also requires some elements of safety enforcement at times, although this is often dressed in the clothes of safety propaganda, seeking to shift enforcement from the implementation of rules through punishment to the encouragement of individuals to follow the rules of their own volition. For example, a common way of positioning the site rules in corporate site safety guides is to ask that the operatives ... 

OSHA- Occupational Health and Safety Administration The U.S. Occupational Health and Safety Administration, OSHA, is a federal government agency in the U.S. Department of Labor. OSHA s Web site is http //www.osha.gov/. The primary goals of OSHA are to save lives, prevent injuries, and protect the health of America s workers. OSHA employs over 2,000 inspectors to ensure job site safety. OSHA was created by the Occupational Health and Safety (OHS) Act of 1970. While many see OSHA as an intrusive government agency intent on enforcing arcane rules, the fact is that OSHA saves lives. And if that is not enough... 

Therefore it is required of all buyers that, while they essentially retain the right to propose and enforce the rules of the water treatment contract, they have to also accept some responsibility in its smooth passage. Buyers thus cannot place responsibilities on field representatives, for areas of the operator s plant or process, over which they have no final control. It is untenable. Buyers have to manage their own plants and ensure that proper maintenance and repair work is carried out. Buyers also have to provide adequate resources to ensure the health, safety, and welfare of all company workers and visitors on-site. Service company representatives, in turn, have to work within established plant rules. 

In such cases where should management draw their line of safety, beyond which violations will not be tolerated, when it often depends on a split second, and needs someone there to witness it This closely links to both the enforcement of safety rules and also worker engagement with safety. This is explored in more detail in Chapter 7, and of course begins to explain why safety violations also form such an accepted aspect of site life. 

However, engagement and enforcement are not mutually exclusive and, when unpacked, it can be suggested that through these two different voices of safety, different realities are developed and again incoherence and inconsistency of safety can be found sometimes rules are made to be broken, punishment is a necessary evil, whilst engagement can prove problematic in its impact, raising far more complex issues of the ownership and responsibility for safety on sites. 

The distinctions between these two voices create a dissonance in the way the enforcement of safety works. Whilst those at the higher corporate level seek to develop and position safety only positively, through no-blame cultures and realities intolerant of violation to the point of denial, those who manage and participate in construction site practices on a daily basis at site level instead have a version of safety firmly positioned within a reality of rules, violations, enforcements and punishments. Yet this latter approach also has the potential to create an understanding, or rather misunderstanding, that safety is the rules, rather than any wider considerations of safety and practice. In fact, when the safety rules are explored in more detail, their associations with safety become rather irrelevant and the enforcement of safety is much more bound up in issues of discipline and punishment on a societal level, rather than the potential consequences of any safety violations themselves. 

This creates and perpetuates an understanding of safety as the safety rules, which are in turn inevitably broken and therefore closely linked to punishment. This naturally embeds safety within the site hierarchy, through the allocation of safety roles for managers, supervisors and foremen. As the previous quote quite rightly notes, it is whoever is running the site that seemingly takes responsibility for enforcing the safety rules to the bitter end. In contrast, as this subcontractor s foreman said ... 

The different levels of management found within the construction site context, and the different ways in which they implement and construct safety on sites create what can be termed a hierarchy of safety. Through the relationships that develop between the violators of the safety rules and those tasked with their enforcement at various levels of management, further considerations of how the responsibility for, and ownership of, safety works in practice can be explored. 

Unpacking the enforcement of site safety rules has suggested that both site supervisors and operatives simply accept violations as part of their daily work, and are also resigned to the punishment dealt out if the perpetrator is caught. However, this clearly shifts responsibility... 

What I found instead was an inconsistent, incomplete and often incoherent safety a safety that often didn t make sense, contradicted itself and was ever changing depending on time, space and place. But actually, this worked for me. As someone who has spent a long time on site, and for whom a key part of everyday was involved with enforcing the site safety rules whilst also attempting to engage with people and convince them why safety was important, these mixed up and messy ideas of what safety was really spoke to me. They explained why things were as they were, why safety was as it was, and were able to fit really well with how my world on site worked. 

After almost 10 years of aggressive enforcement, Occupational Safety and Health Administration s (OSHA) Hazard Communication rule remains the agency s standard that results in the most numerous fines and penalties. From October 2001 to September 2002, OSHA wrote 2,073 citations for Hazard Communication (HAZCOM) violations that totaled 680,000. The citations occurred because most of the hazard communication programs and their site enforcement were very deficient. In 2010, Hazard Communication violations remained high on the list of the top 10 violated standards and unchanged at number three on the list (Thomas Galassi, 2010, MSDSonline Environmental, Health Safety Blog). 

Compliance with the established legislative and statutory framework for safety and environmental protection has to be enforced. No other responsibility assigned to the regulatory body should jeopardize or conflict with this mission. The regulatory body shall implement the licensing process and shall, where appropriate, develop and update the rules, criteria, guidelines, etc., and ensure that adequate records of radioactive waste management facilities or sites are maintained for an appropriate period of time. 

That site, national and organisational health and safety rules or regulations v/ill be enforced, and that those violating them may be subject to some form of discipline... 

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