Even With Best Intentions, it is Easy to Compound a Problem Rather Than Solve it.
Randy K. Logsdon
“Bless your heart” is a phrase that is common in the Southern United States. The phrase has multiple meanings. It can be used as a sincere expression of sympathy or genuine concern. It can be used as a precursor to an insult to soften the blow. It is also sometimes used to mean “you’re dumb or otherwise impaired, but you can’t help it,” by individuals who wish to “be sweet” and do not wish to “act ugly.”
This is how Wikipedia defines this age-old phrase that (in my experience) has been used widely across rural America. Picture in your mind a grandmother figure (let’s put her in a rocking chair) commenting on the performance of her well-meaning grandson who acting in haste or perhaps without thinking (but with the best intentions), has compounded a problem – not solved it. I know for a fact that during my formative years, I was the subject of that “bless his heart” comment repeatedly. Immunity was not assured with transition to adulthood.
When it comes to correcting safety issues, we want the solution to be effective and devoid of uncontrolled negative consequences. MSHA (bless their hearts) has provided us with a wonderful example of one set of unexpected consequences that may serve as learning tool for the rest of us. The example involves unexpected consequences resulting from rulemaking for underground coal mines.
On Aug. 31, 2011, the official process began with the publication of MSHA’s proposed rules for Proximity Detection Systems (PDS) in underground coalmines. These engineered controls were intended to detect when underground personnel were in the “red zone” around underground mobile equipment. The system would prevent movement of the machine when an individual was at risk of being struck by the equipment or caught between equipment and other equipment or against the rib.
On Jan. 15, 2015, the final rule was published with full compliance being required for operating underground equipment by three different dates – Nov. 16, 2015, July 16, 2016, or March 16, 2018 – depending on when the machine was manufactured and whether or not it was equipped with a PDS on or before March 16, 2015.
On April 15, 2016, MSHA issued an advisory to the coal industry reporting that certain instrumentation used underground could interfere with the operational reliability of the PDS. Among the instrumentation identified were:
- Gas detectors.
- Communication devices.
- Respirable dust sampling devices.
- Laser range finders.
- Trailing cables.
- Variable frequency drives.
Operators were advised on methods of testing for electromagnetic interference and that if interference was found, inquiries with the PDS manufacturer should be made to determine what corrective modifications were required to resolve the interference potential.
Because personal dust sampling is also a regulatory requirement, MSHA permitted a brief compliance respite for respirable dust sampling to affected operators. On May 2, 2016, MSHA announced that mine operators must resume the required respirable dust sampling.
We don’t know how many months MSHA studied the PDS issue prior to issuing the proposed rule but we do know that the issue was up for comment, review and study for more than 40 months between the publication of the proposed rule and the publication of the final rule. Still the agency and the industry seem to have been blindsided by the electromagnetic interference piece.
It’s easy to point the finger at MSHA (bless their hearts) but the example cited is just one very public example of the risk we each take when we institute corrective measures for safety. Whether the action involves re-engineering, modified procedures, revised administrative controls or a combination of the three, it pays to explore in advance the possible collateral consequences that may ensue from a change.
Identifying new physical hazards may actually be the easiest chore. Consider also the impact the change may have on workload, employee stress and morale.
Will distractions be created or amplified: rushing, frustration, fatigue or complacency? The best advice: Employ a systematic and thorough review of the potential consequences. Gather comment and advice from all affected groups. Then, you may just avoid that “bless your heart” moment.