Unintended Consequences

By Randy K. Logsdon

One of the things that makes this country great is our collective ability to innovate. Perhaps it’s a byproduct of capitalism. Perhaps it’s innovation and entrepreneurship that drives capitalism.

One thing is certain. We value invention and that innovative spirit. Motivation may be derived from want for efficiency, quality, laborsaving, timesaving, compliance and more recently, environmental consideration. And yes, safety may also be the impetus behind innovation.

Safety and Health is the monthly publication issued by the National Safety Council. A section in each issue is dedicated to safety innovations: “Workplace Solutions,” “Product Focus,” and “New Products.” Toward the back of each issue, one can find information on innovative products and process designed to address safety and health needs. It’s one of the places I turn to early each month. I just like to see what’s new.

Your local safety supplier will also keep you updated on the latest and greatest safety equipment ¬– what a few of us sometime call “toys.” But you don’t always have to go to the marketplace to find innovation.

Many of the most effective innovations are developed and implemented in the workplace by those with the most invested: the workers. I recall one case where a balance was needed between guarding the underside of an elevated tail pulley and managing the accumulation of fines collecting at that location. The field solution was a guard section attached to a frame that would slide between channel guides mounted on either side under the pulley.

A handgrip made removing and replacing the guard easy. Periodic removal and deposit of the fines collected on the slide-out guard made fines management efficient. The guard was effective in preventing access to the underside of the tail pulley and when cleaned regularly, guard deformity from over-accumulation of fines was eliminated.

There is one risk with field innovation and subsequent adaptation of changes. Remediation of one hazard may produce another (and possibly more severe) hazard.

Innovation, whether at the workplace level or at the management level, must be thoroughly vetted for unintended consequences. Early identification of those potential new hazards offers the best opportunity to make meaningful corrections intended to abate the negative impact.

In the case of the removable tail pulley guard, an unintended consequence was that when the bottom guard was removed (even if only momentarily), the tail pulley was exposed. To mitigate that exposure, it was necessary to add a procedural step to ensure that the conveyor was secured against motion while the under-tail guard was removed.

Perhaps one of the most common corrective innovations involves the location of emergency stop cords along walkways that are adjacent to unguarded conveyors. E-stops are a very useful safety feature designed to mitigate the effects of someone contacting or falling onto a conveyor.

Often, these safety devices are positioned (or repositioned) to reduce unintended contact when performing work along the conveyor (such as shoveling material onto the moving belt). Unintended contact with the cord trips the power on the conveyor necessitating a trip to the motor control center to reset the power.

So, if the E-stop cord is strung close to the belt structure, it will be less likely to be inadvertently tripped. The unintended consequence is that if someone is caught in the conveyor, the E-stop cord is more difficult to reach and activate. Other options include a temporary electrical override (jumper) of the E-stop – clearly a safety-diminishing action and a regulatory violation especially when working near the running conveyor. Another possibility is replacement of the E-stop with a guardrail (permitted by 56/57.14109). Depending on the design and construction, this may or may not constitute an actual safety improvement.

Ideas and innovation do need to be encouraged. We progress through innovation. But such innovation must be carefully vetted to ensure that the effects of potential unintended safety consequences are carefully controlled.

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