Safe, Efficient, Profitable: A Worker Safety Podcast
Joe and Jen Allen of Allen Safety LLC take their combined 40+ years of worker safety, OSHA, EPA, production, sanitation, and engineering experience in Manufacturing Plants including Harvest Plants/Packers, Case Readies and Further Processing Plants, Food Production Plants, Feed Mills, Grain Elevators, Bakeries, Farms, Feed Lots, and Petro-Chemical and bring you their top methods for identifying risk, preventing injuries, conquering the workload, auditing, managing emergencies and catastrophic events, and working through OSHA citations. They're breaking down real safety opportunities, safety citations, and emergency situations from real locations, and discussing realistic solutions that can actually be implement based on their personal experiences spending 40+ weeks in the field every year since 2001. Joe and Jen are using all of that experience to provide a fresh outlook on worker safety by providing honest, (no sponsors here!) and straight forward, easy to understand safety coaching with actionable guidance to move your safety program forward in a way that provides tangible results.
Safe, Efficient, Profitable: A Worker Safety Podcast
What to do After A Regulatory (OSHA) Inspection: A Step by Step Guide
In this episode, Joe and Jen try to give you a step by step guide on how to manage the chaos that can be left after regulators visit your facility. What do you do next? Where do you start? It can be so overwhelming, and this episode was designed to help you sort through it all.
Initial Preparation and Documentation: Jen and Joe emphasize that businesses should have a pre-existing plan in place to handle regulatory inspections. A key point here is that the plan should clearly outline how to interact with regulatory bodies when they arrive on-site. This includes establishing protocols for security, communication, and credential verification when the agency shows up. The plan is typically a few pages long but should be detailed enough to provide clear guidance on procedures to follow.
The Importance of Rapid Action: Joe stresses the urgency of addressing the problem immediately, whether it’s a chemical leak or other significant issue. He explains that actions must be taken within minutes to mitigate risks, even if regulatory agencies take longer to conduct their investigations. The goal is to prevent further incidents by quickly implementing temporary solutions.
Evaluating Systems and Gaps: Joe points out that companies often face difficulties when an incident occurs because they may have been following the same systems for years without issue. When an event happens, it’s an indication that the system failed in some way, and now the company must figure out what went wrong and address the gaps. Jen adds that it's tough for people who have been working in the same environment for years to think creatively about how to solve these problems, which is why an external review is often necessary.
Long-term Solutions and Prioritization: The discussion moves toward implementing long-term solutions. Jen and Joe emphasize that the fixes need to be sustainable—not just temporary patches. Joe explains that companies should consider a timeline for implementing changes, from immediate actions to more permanent solutions that can last for months or years. They stress that companies should avoid trying to tackle everything at once, but instead prioritize issues based on risk and severity. Joe also advises companies to document their progress, showing regulatory agencies that they are making consistent efforts toward improvement.
Systematic Approach and Testing: The hosts advocate for regularly testing safety systems and processes, even when there hasn’t been an incident, to ensure they’re still effective. Joe explains that businesses should run their operations as if they expect failures to happen, and then prepare to address those failures. This approach helps uncover hidden gaps before they become serious issues.
Involving Contractors: Jen and Joe also discuss the importance of considering contractors in safety systems. If contractors are involved in high-risk activities like confined space work or hot work, companies need to have different safety protocols in place than for regular employees. These contractor-specific risks should also be addressed in post-incident evaluations and corrective actions.
Budgeting and Financial Considerations: Another major point is how to handle the financial side of implementing fixes. Joe notes that while fixing all issues may add up to a large sum, businesses need to prioritize spending based on risk and necessity. He spends a lot of time analyzing risk levels and timelines to figure out which part of the corrective actions should be tackled first.
Documentation and Follow-Up Visits: The episode closes with advice on documenting every step of the corrective action process. Jen stresses that companies should keep detailed records of what they’re doing to address issues, as regulatory agencies will often make follow-up visits to check on progress. Showing intent through documentation is key to demonstrating compliance and effort.
This week's episode is about. You got an injury, had a chemical leak, you had an event. What do you do afterwards? What's the steps?
Speaker 2:Yeah, what happens next if you are expecting a regulatory visit this week, like we said in the opener we're talking about, we had some kind of catastrophic event. So whether it be an injury, chemical leak, chemical event, it be an injury.
Speaker 1:Chemical leak.
Speaker 2:Chemical event, something like that, you know significant property damage that would require an agency to come in and do some kind of an investigation. What does that process look like?
Speaker 1:For those of you who don't know us and are new to our channel, we spend about half of our year doing this process, yep. So myself especially, that is my main job the last few years is dealing with these events afterwards in sequence. So the first thing you need, you have to have some kind of plan, and the plan should be determined before you ever had the event. You should say this is what we're going to do in case these five things happen.
Speaker 2:So typically we see maybe a couple of page document that just outlines. Here's our process, from the time that agency or that entity shows up on property. What are we doing with them? What does it look like once they arrive through security? How should we be talking to them? What credentials are we asking for? Those are some of the things that we would want to see in that specific document and everybody should have some kind of plan for that.
Speaker 1:This main episode now is what's next? All right, so here we go. So now we have agencies showed up. We've had maybe some litigation, maybe we haven't, but we've got to try to fix this. Yeah, do we fix it in 15 minutes from now or six months from now? Well, let's do it in 15 minutes, even though the agencies may take some time, even though they made an investigation. You don't want to repeat right off the bat. So you want to have some kind of system that says when we have an event, what are we going to do? You can have a chemical leak and we don't have eight hours to wait. We're doing something every 15 minutes.
Speaker 2:Well, and I think the interesting part to kind of tack onto, that is, the regulatory agencies or the entities that come in and do the inspection. They are not really allowed to give you solutions or ideas.
Speaker 2:So they come in, and here's your list of things that you need to fix or work on or whatever that looks like that you have to address in some capacity, and now you've got a management team that maybe didn't identify that those were even risks or hazards, and now they're going to have to come up with a solution on how to deal with it, and so that can be really challenging.
Speaker 1:It is, and it's not that we get a lot of calls during the time we do, but it's really. It's the part of we had a great safety record for years and we had no or no leaks. And so the same system, the same processes you've used to make sure you say, hey, we're doing great. Now I had a hiccup or a fail.
Speaker 2:And we never saw it coming. Obviously, otherwise we would have addressed it.
Speaker 1:You can't use the systems you had in place because they don't work. Now Something's off, so now you have to evaluate what the off is and what the anomaly is and try to address, and that's hard for a lot of people to do.
Speaker 2:It is hard, especially when you're working in that same environment. You're very programmed, almost that well, this is how we do things, and so it becomes hard to be creative outside of that.
Speaker 1:It's almost the same reason why when you write anything, Like any of our documents, all of our documents are reviewed by someone else in our company, right.
Speaker 2:For the same reason, you have typically an editor that would review and make suggestions.
Speaker 1:It's a third party that kind of is a blank screen viewing it, because it can be a challenge when you're in it every day all day for hours, for years maybe, to come up with a creative solution outside of the box and it's got to work next month and in six months and in a year. It can't be something we just temporarily put in place because the gap or the problem is sitting there waiting and you want to get rid of that problem completely.
Speaker 2:Right, so I think that that's the next piece that we want to talk about, too is so there's a sequence of events when you come up with these solutions, so you're going to have temporary fixes.
Speaker 1:What are we going to do the next eight hours to six days?
Speaker 2:Yep, and then what can we start putting into place to start making that a more permanent solution? So you have the next 10 minutes. How do we address it next week? How do we address it in 30 days, six months? And they cannot be the same plan. They got to be there.
Speaker 1:So, like when we get involved with some of these, sometimes it's that day, sometimes it is two months later, and that's what I talk about. So let's put plans together. So maybe you've got a lockout issue or a forklift issue or some kind of event that's part of this litigation or injury or leak, whatever it is. What you've got to look at is you've got initial, did you do it correctly? Then you've got annual training, then you've got revalidation, and if you don't watch it, your list gets so big that you don't know really what to do.
Speaker 1:So now your biggest gap is how do I prioritize? You've got to be able to prioritize not just timelines, but which of this massive list that everyone's saying I may have to fix. How am I going to prioritize? Which one do I do? And then, how much of number eight do I do? Do I do one through 40 or do a number eight could actually take months and I can only do bits and pieces of it as I go through.
Speaker 2:So let's talk about a real, real life scenario on that. So what I'm thinking immediately when I think of multipliers, I'm thinking of things like lockout procedures, confined space assessments and SOPs from the PSM side. So you may take a citation or something along those lines and you may get several and maybe they're all serious. So, like you talked about, how do you prioritize?
Speaker 1:out of all of them that are serious. I could have 800 lockouts and I'm like, okay, tomorrow they're all a problem maybe, but how do I be number one? Yeah?
Speaker 2:So, first thing, maybe we had an injury. Somebody comes in, we know we have to address that, but we also have to do training. We also have to change our lockout. What else is affected? Is there anything else in this system that could also be sitting there as a risk? That could be a problem. That's correct.
Speaker 1:So what I tell people to do is and we're going to do solutions to this episode, but one of the things I tell people to do is, anytime you set up your system. The initial part of this podcast is setting up a system. I always set it up like you had a failure and then that's how I test myself, yeah. So I say, okay, we had a forklift event, or okay, we had a chemical leak or we had an injury. Now what would be all the things that would be supporting documents going to that?
Speaker 2:supporting documents and supporting training.
Speaker 1:And then can I find them? Can I find them in four hours? Can I validate? You know is Joe the one that did it. Can I find him in four hours? Can I validate? You know is joe the one that did it but he quit eight months ago and he's the one that did all the stuff. But now the new people have no idea where it is, or even yeah, the training.
Speaker 2:Or maybe he was the program keeper, maybe he was the one that reviewed the, the annual assessment.
Speaker 1:Absolutely, there's a list of stuff you gotta do annually and they get lost sometimes with the turnover and everything else on saturdays, once a we bring in a contractor that does this service for us Maybe it's hot work, you know, and they come in to do hot work. Well, you've got to look at your system differently for contractors. Then, if you're doing hot work, then there's your contractors doing normal work. So you got to look at your system.
Speaker 2:And that's a really great thing too, because you may have something it could affect a contractor. So, now you're looking at your contractor programs and systems and how you communicate the changes, the updates that you're making with that group. That makes sense Absolutely.
Speaker 1:So that's the biggest thing we're looking for. We're looking for you have an event, you have some kind of agency or maybe regulatory or something. Come in, now you've got some kind of plans, now you're going to fix it. You, now you've got some kind of plans, now you're going to fix it. You're going to get together a temporary fix a six-month, an eight-month year and then you've got to look at any fix that you put into place. Don't fix anything you can't really do. You've got to run your business. Every plant, every business has its own uniqueness. You still have to make it unique. It's not fix the electric cord. That's bad. It's what.
Speaker 2:Why is not fix the electric cord? That's bad. It's what electric cords?
Speaker 1:get tore apart.
Speaker 2:Yeah, why is it getting ripped out to begin with? Let's address whatever that looks like. So I think what you're really trying to say is, when we're putting systems in permanent corrective actions, let's make that there. Make sure there's something that we can realistically do, given our business and what we know we do day in and day out that it's not going to be a problem for, you know, for us, for us for food safety or sanitation or whatever that looks like.
Speaker 2:That it's something real. It's not just an astronomical number. That is going to be a budgetary issue over over time that we can't, and you know, I understand we're not supposed to say, oh, we can't do that fixed because of cost. We're not going to change the compressor in a while, but you know there is a myriad of different options, and so let's pick one that makes sense financially, also if we have choices, and that's kind of getting to the end here.
Speaker 1:That's the other part, dan. Now you've got to budget out your finances.
Speaker 2:Yep.
Speaker 1:You've got to say you know all these items cost $20. But if I add them all up, they could be a million. So now I spend most my time on the risk side. So, yes, I look at timelines on a plan and what I can do severity, and how many people?
Speaker 2:in fact, it is now, yes, now I'm back to that severity and how.
Speaker 1:What is that risk level going to be, that matrix? And then that's how I move my funding to what part of the eight months. I start first yeah and you know what.
Speaker 1:You may have had an idea and it didn't work right big deal. Yep, come up with another one. We put a new strategy in place and try that out, but you've got to test it for how you're going to run your business when you're doing this Well, and I think another key item too is that you know you're going to have potentially additional visits from that regulatory agency.
Speaker 2:So I think it's really critical that you document that.
Speaker 1:All what you're doing, everything that you're doing what works what maybe didn't, but you're still trying.
Speaker 2:You've got to show intent. So let's get credit for the efforts that we are putting in, because we know they're there. And let's make sure that that gets documented so that we can show that.
Speaker 1:And I tell everybody always do percentage, don't say I've got to fix 7,000.
Speaker 2:IDs or 7,000 SOPs.
Speaker 1:I did all of this room 100%.
Speaker 2:I got 20% of this room done.
Speaker 1:I got 30% in it. Break it down that you're showing you're trying. Whether the investigation is done or not does not matter. You want to show that you're trying to do the right thing.
Speaker 2:I wouldn't wait until the end. Result, I guess, is the biggest thing. So, from the time that you get your information or the walkthrough, and you're kind of aware of what's going on and what some of the opportunities are, let's start working on that.
Speaker 1:Absolutely.
Speaker 2:The next visit we can show that intent and that improvement and, like you say, let's show it in percentages of we are making an effort, so it's not. Well, it's not all done, so it's zero. No part of it is done.
Speaker 1:20% you can't fix 500 or 5 000 without doing 10 and 20 and you get. You want to take credit for that so that that initial part of getting the plan that's what this whole episode is about. Think about all these pieces of the puzzle that move, yep and and and. You know we don't ever want to have an event happen, but things happen. So let's plan and then you know what happens when you look at the puzzle. That way you help find your gaps Because, like Jen said, the biggest problem you have is you did great on your audit. You had no injuries. You're so great at everything You've got to go back and test your systems. You've got to see will it make it through the shifts and the contractors and those things.
Speaker 2:The turnover and everything else. Well, and I think the last thing that I would say is that you can also, in some of your programs on how you're going to manage this, look at your EAP and say, if we had this event actually happen, who would we call to help us from the safety side, if we had a medical event, if we had? A severe injury. Who would we call to help us work through this and navigate it? Typically, osha wants to see a third party if it's severe enough.
Speaker 2:And so we would want to start working on identifying that. So maybe you've got some vendors in place. I would start asking some questions. If we have a bad chemical leak, can we call you? You know?
Speaker 1:24-7 at night. It can be your attorneys. Yeah, because people have different attorneys, Do you?
Speaker 2:have an attorney If we have a severe medical injury or incident. Is there someone that we know that we can call? A lot of companies have an entity like that. We are that entity for lots of facilities. We know that there are some folks out there that do that. So you might even want to start identifying what that looks like and who that would be, either for your region, your country, whatever that may be and just start identifying some of those resources so you know you can pick up the phone and have that. It's not. I start my research from now, when everything's chaotic and going crazy.
Speaker 1:It's how you run your business. You want to run your business thinking that you never have to use that system, but if it happens, you still want to run your business, right? Right, keep your wrist down, run your business, take care of your customers and make sure your clients aren't unhappy because supply chain issues.
Speaker 2:Well, there is that fact of it too. It becomes difficult to fix things. If we lose customers, too, it becomes difficult to fix things if we lose customers too.
Speaker 1:So now we're in that weird catch 22. Absolutely so that's where we're at today. Remember, these are our opinions.
Speaker 2:They're based on our opinions, based on our ideas, our experiences. So take it for what's worth. Do your thorough risk assessment. Every situation is slightly different.
Speaker 2:That's why we provide onsite consultation. We don't do any of this type of work over the phone. So I'd highly encourage you that, if you need some advice, to reach out to somebody us or somebody and have them come in and do a site visit and then, if you want to kind of have some more information on how to do that risk determination, we do have some resources over at Allen safety coachingcom the particular risk matrix and how to navigate through any audit findings. That's actually for free, so you can reuse that resource over there and get access to that without having to pay for anything. We put that out there just kind of as an aid to help you. If you need that, so go check that out allensafetycoachingcom. Otherwise, if you do want some on-site resources, allen-safetycom is where you can find all of the services we provide, including this one. It's a little after including this one, so after catastrophic events, and you can reach out to us from there. Otherwise, contact us on any of the socials at Allen Safety LLC is our handle. You can reach out Joe Allen, jen Allen on LinkedIn and talk to us there and direct messages there if you've got questions and otherwise, leave a comment, leave a like.
Speaker 2:We love hearing from you guys. Let us know what you want to hear about, and I think that's it. Thank you, we what you want to hear about, and I think that's it. Thank you. We'll see you next time, thanks everybody. Thank you for listening to Safe, efficient, profitable a worker safety podcast. If you're looking for more in-depth discussions or step-by-step solutions on all of the different safety and regulatory topics, please visit us at wwwallensafetycoachingcom for web-based virtual coaching and training, or at wwwallen-safetycom to book our team for onsite services training sessions, to order merchandise, to learn more about our team and what services we provide in the field, or just simply to request a topic for us to cover on our next podcast. If you found today's podcast helpful and would like to support our podcast further, please help us by subscribing, liking and sharing this podcast with anyone that could benefit from the information we cover here, as that helps us to continue to put out this free content. Thank you.
