Why prevention through design (PtD) matters
Over my many years working in the area of compliance I have come across many stories, tragedies are more apt, involving workers fatally injured because the equipment, product or environment they were working with or around had risks and hazards which were not fully identified or controlled. Which is why I fully supported the National Institute for Occupational Safety and Health’s (NIOSH) Prevention through Design (PtD) national initiative.
Their mission, or the initiative’s goal, was to prevent or reduce occupational injuries, illnesses, and fatalities through the inclusion of prevention considerations in all designs that impact workers.
And it would be achieved through:
- The elimination of hazards and controlling risks to workers to an acceptable level “at the source” or as early as possible in the life cycle of items or workplaces.
- The design, redesign and retrofit of new and existing work premises, structures, tools, facilities, equipment, machinery, products, substances, work processes and the organization of work.
- The enhancement of the work environment through the inclusion of prevention methods in all designs that impact workers and others on the premises
To further aid in this mission, in 2011 the American Society of Safety Engineers (ASSE) approved the American National Standards Institute (ANSI) standard Z590.3 ‘Prevention through Design: Guidelines for Addressing Occupational Risks in Design and Redesign Processes.’ The standard didn’t replace any existing performance objectives; it merely complemented them to reinforce the ultimate goal – that of protecting the worker.
As NIOSH stated, “This standard can save lives and prevent injury. For example, as skylights become synonymous with green construction and energy conservation, we expect to see an increase in skylight installation. If skylights are designed and installed with proper guarding, deaths and injuries to workers who inadvertently fall though skylights during construction and maintenance activities could be prevented. Another example involves bailing machines used to break down cardboard for recycling in various industries. If the bailers were designed and installed with proper guarding, workers would not be able to enter the machines for trouble shooting thus preventing deaths and injuries.
NIOSH further stated that “Design and redesign also includes construction, manufacture, use, maintenance, and disposal or reuse of equipment used on-the-job. One of the key elements of this standard is that it provides guidance for “life-cycle” assessments and a design model that balances environmental and occupational safety and health goals over the life span of a facility, process or product. The standard focuses on the four key stages of occupational risk management. The pre-operational, operational, post incident and post-operational stages are all addressed within.”
In other words, “Designing out” occupational hazards and risks is the most effective way to protect workers.
The scope of this “designing out” is huge and one blog post really can’t cover the sheer magnitude of the impact it had and continues to have on the workplace.
But I do want to draw attention to one aspect, and that is confined spaces.
Are you aware that there is a new NFPA 350 Guide for Safe Confined Space Entry and Work, which provides information on complying with existing standards by simplifying terminology, addressing gaps, and providing additional information on how to comply with confined space standards and regulations? Writing on OSHA’s website, Nancy Pearce says “OSHA tells you what to do; NFPA 350 tells you how to do it by providing supporting information on how to identify hazards, perform gas monitoring, control hazards, and ventilate.” What is relevant here, is that this NFPA 350 provides a chapter on prevention through design (PtD) specifically for confined spaces, illustrating how PtD can target both the construction and/or installation of new confined spaces; and the redesign, retrofit, and/or renovation of confined spaces to eliminate, control, or minimize hazards.
A bibliography of documents related to the design of confined spaces will be updated as the NFPA 350 Technical Committee is made aware of them, with documents related to manure pit design and ventilation, as well as documents related to the design of water and wastewater facilities to be listed in the next edition of the standard.
Given that each year between 90 and 100 workers die in confined spaces, this very practical advice is most timely, and I can only hope that all those it impacts can and do benefit from its insight.
For further information about NFPA, please go to http://www.nfpa.org/350
I hope that standards like those prosed OSHA, like NFPA 350, and NIOSH PtD will alleviate and address all too common workplace fatalities and injuries and thus make our working environments overall a safer place.
Norman Ford is the VP of Operations at Compliance Solutions for Skillsoft.
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