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August 2008

Aug 01
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MEET THE ‘LOTO FATAL 5’

By Risk Management Bulletin

As safety professionals know — but unfortunately, many employees don’t — lockout/tagout (LOTO) procedures are designed to keep workers safe while servicing and maintaining machinery or other energized systems.

Unintentional equipment startup accidents injure some 50,000 workers a year and kill 120 people. LOTO is not only good practice; it’s the law (29 CFR 1910.147). Even with the law in place, LOTO remains one of OSHA’s most violated standards, and these violations are expensive.

A leading safety resources Web site posted these “Fatal 5” main causes of LOTO-preventable injuries:

  1. Failure to stop equipment. Some workers value productivity above all else. That’s normally a good thing, but not in this case. Others feel that their age or long experience with the equipment lets them work on it without “taking the trouble” to safeguard it properly. Either attitude can lead to the same, possibly deadly, result.
  2. Failure to disconnect from the power source. In the case of electrical equipment, some workers feel that simply operating the on/off switch is all it takes to be safe. This ignores the fact that the switch might be defective or that power might find its way through a short circuit or other source — until they’re shocked to learn otherwise.
  3. Failure to drain residual energy. Ask workers why TV sets carry a warning about trying to open the case even if the device is disconnected. You know, and they should, that it’s because many electrical devices store power in a capacitor or battery. Even with the plug out, the risk of shock remains. Employees need to expand this concept to other kinds of devices. A compressed spring, hot pipe, pressurized tank, or even a heavy object hanging overhead, also represent energy that continues to exist, even when the initial source of this energy is disconnected. To be safe, all forms of stored energy must be completely blocked or released.
  4. Accidental restart of machinery. Even if one employee knows to shut down equipment before working on it, others might not. All too many unknowing workers have injured their fellow workers by restarting machines being worked on.
  5. Failure to clear work areas before restarting. Restarting machinery must be handled with as much care as shutting it down and locking it out. A repair tool left in the works to fly out, or a restart while a co-worker remains in the path of danger represent hazards as significant as not locking out the machine at all.

Our risk management specialists would be happy to review your LOTO program. Just give us a call.

Aug 01
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SIGN UP FOR SAFETY

By Risk Management Bulletin

They might not be exciting or high tech, but safety signs in the workplace can be worth their weight in gold! Says a recent article on businessknowledgesource.com: “The importance of workplace safety signs can’t be stressed enough. [If properly designed and used] … signs can overcome a number of losses due to language barriers, reading abilities, and insufficient work experience. Wherever there’s need for general instruction, there should be a safety sign to help avoid potential injury.”

Of course, even the best signs won’t help if poorly designed or improperly used. Although OSHA uses ANSI standards to specify the design of such common signs as EXIT or CAUTION, there’s no way to regulate how every sign will be made and used.

An effective safety signage program should meet these standards:

  • Visibility. It sounds basic, but signs can’t do any good if they’re not visible. There are plenty of reasons they might not be. Check your break room bulletin board. Is one sign plastered over others? Are the signs so old they’re now the color of the Declaration of Independence? Are they hidden in corners or in hard-to-reach places on the equipment they’re designed to explain? To enhance visibility, especially from a distance, choose such contrasting color choices as yellow on black and put borders around every sign.
  • Noticeability. Qualities that make a sign stand out include shape and color; most people recognize a “stop” or “yield” sign without even reading it. Perpendicular signs are among the most noticeable, which is one reason that they’re used by stores seeking to stand out in a streetscape, and why they can be useful in identifying areas of special hazard.
  • Legibility. One reason it’s hard to read government regulations as published in the Federal Register is the size and grayness of the type. In the same way, type size can make important safety signs stand out more, as does spacing between words and individual letters. Printing a sign’s message in a second color improves retention of the message by 82%.
  • Durability. Signs need to survive the environment in which they’re placed. High heat, humidity, or corrosives can wilt or stain a sign beyond recognition. Don’t use cardboard when sheet metal is called for.

Even if your signs meet all these criteria, OSHA still requires that they be posted and maintained properly, either by you or by the supervisors of the areas involved. That leads to the classic compliance issue of how to make sure that all regulations are observed when you can’t be everywhere at once to check.

Aug 01
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BUILDING SAFETY AWARENESS

By Risk Management Bulletin

If you’re like most business owners or managers, you spend your days (and probably nights, too) working on and thinking about ways to reduce risk in your workplace. Unfortunately, all of it can come to naught without one thing your workers need to develop: A sense of safety awareness.

Without it, workers won’t wear their personal protective equipment (PPE), or won’t wear it properly. They won’t make full use of the safety features built into their equipment. And they won’t observe basic rules, such as those of good housekeeping, that can prevent accidents. Without safety awareness, workers might be thinking about production, their compensation, or tonight’s softball game — but not about safety on the job.

Here are four ways to instill safety awareness in your workplace.

  1. Develop a Safety Manual. This book given to new workers on day one, says NIFB, should “pool safety information from department managers, equipment and tool manufacturers, and workplace safety experts,” and should include “startup and lockdown procedures, types of activity to avoid at work, and proper attire for operating equipment.”
  2. Name a Safety Champion. Appoint one employee in each department or work area to research and report on safety at regular safety or department meetings. It’s often amazing how workers take to this responsibility. In one organization the safety coordinator, as he’s called, subscribes to safety magazines and continually contacts safety organizations to bring his co-workers the best and latest information. The gratitude he receives from colleagues is his only payment for this work.
  3. Hold a Safety Event. Encourage employees to plan and carry out safety demonstrations or create exhibits for these events, which can be either freestanding or part of larger company gatherings. This as an ideal time to hold contests or distribute safety awards. You can also invite guest speakers from vendors or safety or trade associations.
  4. Build Safety into Employee Communications. Every employee contact, from daily e-mails to paycheck stuffers to newsletters, should stress workplace safety. In fact, the more you focus on safety, the more it will become a core value for your organization. Don’t forget posters, and how to display them properly. This means locating safety messages so they’re not lost in a sea of EEOC and Wage and Hour announcements. Make sure that these messages get priority placement in work areas and aren’t covered by other postings as time passes.

For guidelines on creating and nurturing a sense of safety awareness in your workforce that can reduce the risk of accident or injury (and keep your insurance premiums under control), feel free to get in touch with one of our risk management professionals.

Aug 01
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REAP THE RETURNS ON INVESTMENT IN WELLNESS PROGRAMS

By Employment Resources

Comprehensive wellness programs not only improve employees’ health — they also can slow the rate of an employer’s health care cost increases. This results in a positive return on an employer’s investment in the wellness initiative. According to a study published in the Journal of Occupational and Environmental Medicine, employers can save $1.65 in health care costs for every dollar spent on a comprehensive employee wellness program.

The study followed participants in a wellness program sponsored by health insurance provider Highmark for its own employees. The wellness initiative was launched in 2002 and offered the following free of charge to employees (some program components were not included initially but were added in later years): Health risk assessments; online, onsite and/or individual programs on nutrition, weight and stress management, and tobacco cessation; screenings for cholesterol, blood sugar and blood pressure levels; campaigns to increase fitness awareness; disease management initiatives; and (at some locations) onsite fitness centers. Wellness program expenses averaged $139 per employee per year.

In order to assess the impact of the wellness program, participants were matched to nonparticipants based on gender, age, 2001 medical expenses, claims-based evidence of heart disease and diabetes, and certain predictive morbidity scores. For both participants and nonparticipants, individuals with $100,000 or more in annual health care costs were excluded.

Health care expenditures grew more slowly 2001 through 2005 for wellness program participants than for nonparticipants. Specifically, estimates of health care expenses per person per year were $176 lower for participants, and inpatient expenses were $182 lower. Over the four-year period, during which the wellness program cost Highmark just over $808,000, more than an estimated $1.3 million in health care cost savings were gained. This translates to a return on investment of $1.65 for every dollar the employer spent on the wellness initiatives.

The study also examined whether the wellness program participants made greater use of preventive services available through the health plan. In comparing data from the year before the wellness program launched and the next year, preventive visit screening rates increased from 56% to 60% for employees who completed a health risk assessment (HRA), from 57% to 60% for employees who completed an HRA and also participated in an online, group or individual wellness program component, and from 62% to 64% for employees who took an HRA and also used a fitness center. For nonparticipants, use of health plan preventive services remained unchanged at 55% during the comparison years. As a further measure of the impact of the wellness program on use of health plan preventive services, the study found that preventive care visits accounted for 16.5% of total health plan expenditures for wellness program participants, compared with 13.5% for nonparticipants.

Because the analysis only considered health care cost savings, the authors note that, “This savings estimate is most likely an underestimate of benefit as it does not include savings realized from improved productivity or reduced absenteeism or presenteeism.” They go on to cite other studies that found wellness program participants were absent a third- to a half-day less in the year following participation in a wellness program, and that wellness program participants have higher morale, productivity, job satisfaction and overall health and fitness levels than nonparticipants.

Though the Highmark initiative might be more comprehensive than many employers are willing or able to do, the study does show that wellness programs return the investment employers make in them, in financially measurable ways and in intangibles like a happier, more committed and productive workforce.

Aug 01
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MAKE SURE YOUR EMPLOYEES UNDERSTAND AND APPRECIATE THEIR BENEFITS

By Employment Resources

As an employer, you spend a significant amount of money providing your employees with an attractive benefits package. It is a necessity if you’re in a competitive industry where you need to find and retain top talent. But do your employees appreciate your investment? Do they have any idea how much you spend to provide their benefits package?

If your workplace is like most, the answer is probably no. Surveys on employee attitudes toward their benefits reveal that most vastly underestimate the amount their employers spend. Studies also show that employee attitudes toward their benefits packages tend to be negative, focusing on focusing on rising premiums and cost-sharing methods rather than employer contributions.

TELLING YOUR STORY

Generally, it’s not that employees are ungrateful; it’s that they truly don’t realize how much you pay to provide benefits. How can you tell your story so that employees appreciate their benefits? There are a number of ways to accomplish this, and it’s a worthwhile undertaking since you need a return on your considerable investment. Here are low or no-cost tips that may help:

  • Provide a total pay statement: When employees think about their compensation, they typically only consider their gross pay. However, as you know, benefits make up a large part of the full amount you pay to keep them on board. You can spell out the details in a total pay statement, which is typically a chart illustrating the value of the total compensation and breaking it down into its various parts. You can include other employee perks you offer, such as tuition reimbursement, licensure fees you pay, etc. There are companies that provide custom total pay statements, or you can use a spreadsheet application to generate them yourself.
  • Make costs a part of benefits education: Many businesses provide educational meetings about employee benefits during new-hire orientation or annual benefits enrollment. This is a perfect opportunity to emphasize the value of the benefits package and to underscore the fact that it is part of the employees’ total compensation. If your insurance carrier conducts employee training on benefits, you can ask your representative about the possibility of mentioning the total cost and the employer portion.
  • Add free or low-cost perks: You might also consider adding voluntary benefits or perks such as pet insurance, discounts on gym memberships, community service days or other incentives to help employees see the overall value of their relationship with your company. Sometimes employees focus on quantity, so having additional choices — even ones that are 100% employee paid — can result in a greater level of appreciation. Your insurance broker may have suggestions if you’re ready to explore this option.

A TOKEN OF APPRECIATION

If your employees don’t appreciate their total compensation, you can’t fully capitalize on your investment in benefits as the important motivational tool it can be. It pays to take a second look at how your employees perceive their benefits. Remember, improving their perception can be relatively inexpensive — and well worth the effort.

Aug 01
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CHECK CAFETERIA PLANS FOR COMPLIANCE WITH CONSOLIDATED REGULATIONS PACKAGE

By Employment Resources

During the past 20-plus years, the Internal Revenue Service (IRS) has issued, in dribs and drabs, regulations, notices and other guidance on Sec. 125 cafeteria plans. In proposed regulations effective in general for 2009 plan years, the IRS now has consolidated its cafeteria plan guidance, along with clarifying and elaborating on various cafeteria plan issues. The regulations are lengthy — 124 pages — so in this article we highlight some of the points that are most significant for employers that offer some type of cafeteria plan.

Keep in mind that the term “cafeteria plan” can encompass arrangements as simple as premium-only plans or flexible spending accounts (FSAs), those as elaborate as choice-making plans with employer credits and a wide selection of benefits, or something in between. These requirements for cafeteria plans apply to any of these types of arrangements.

The cafeteria plan must be in writing, and the plan must be operated in accordance with the written plan terms. The regulations specify all that must be included in the written plan document. Remember that the requirement that the plan be in writing applies to all types of cafeteria plans, even premium-only plans.

All participants in a cafeteria plan must be employees, which the regulations define to include common-law employees, leased employees and full-time insurance salespeople. Former employees, including laid-off employees and retirees, may participate, but the plan cannot be maintained predominantly for them. Spouses and dependents may receive benefits under the cafeteria plan, but cannot “participate” in the plan. Self-employed individuals, including sole proprietors, partners, directors and 2% shareholders in Subchapter S corporations, are not considered employees and thus may not participate in a cafeteria plan, but they could sponsor a plan for employees.

The regulations specify the kinds of benefits that can be included in a cafeteria plan. Of note:

  • If Group-Term Life insurance is offered, employers must use Table I as the exclusive method of computing the cost of such coverage in excess of $50,000 (which is includible in an employee’s income). This provision is effective immediately.
  • Individual Health insurance premiums, as well as an employee’s or former employee’s COBRA premiums, can be paid through a cafeteria plan (but not through an FSA).
  • Among benefits defined as nonqualified (and a plan that offers nonqualified benefits is not considered a cafeteria plan) are contributions to Archer medical savings accounts, contributions to health reimbursement arrangements, Group Term Life insurance for spouses or dependent children, and elective deferrals to Sec. 403(b) plans.
  • A change in plan year, or a short plan year (less than 12 months), is only permitted for a valid business purpose.
  • Though a cafeteria plan may not provide for deferred compensation, the regulations specify certain types of plan features that are not considered deferred compensation, such as a Long-Term Disability policy paying benefits for more than one year, certain two-year lock-in vision and dental policies, and certain advance payments for orthodontia.
  • Though cafeteria plan elections generally are irrevocable (other than for changes in status or life events), the regulations permit employees to prospectively elect, revoke or change salary reduction elections for HSA contributions at any time during the plan year with respect to salary that has not become currently available at the time of the election. The regulations also permit automatic default elections for employees who fail to actively elect, and they permit new employees to make elections within 30 days of hire that are retroactive to the date of hire.
  • Health FSAs may be established for limited purposes, such as an HSA-compatible limited-purpose health FSA or a post-deductible health FSA. Also, an employer can limit FSA enrollment to employees who participate in the health plan. A dependent care FSA may allow terminated employees to spend down their account through the end of the plan year. Employers can retain FSA forfeitures, use them to defray administrative expenses, or allocate them to participants.
  • The regulations provide guidance on cafeteria plan nondiscrimination tests, define several key terms (including highly compensated individual, 5% shareholder, key employee and compensation), and specify that nondiscrimination testing must be performed on the last day of the plan year. They also create a nondiscrimination testing safe harbor for premium-only plans.

With this consolidated package of guidance for cafeteria plans, the IRS is likely to take enforcement more seriously. Now would be a good time to go through your cafeteria plan written document and administrative procedure and check for any compliance issues. Call us. We can help.

Aug 01
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TAKE FREQUENT BREAKS TO PREVENT BACK INJURIES FROM HEAVY LIFTING

By Workplace Safety

You’ve just taken a new job, and many of your tasks involve lifting heavy objects. If you’ve never done much lifting in the past, you need to remember an important rule. Until you become accustomed to lifting, you should take frequent breaks during the workday to avoid serious injury.

When you are inexperienced at lifting, your back muscles experience fatigue after only a short period of time. When this happens, the body has a natural tendency to become rigid in the area experiencing pain and that muscle group can no longer be used. You try to compensate by lifting with other muscle groups that don’t hurt so that you can complete the task.

Although this seems like the right course of action, it creates a series of negative consequences that could cause you to sustain a major injury. The first of these consequences results from the tensing itself. Tense muscles prevent proper blood flow, which deprives your muscles of the oxygen they need to sustain their repeated action.

The second negative consequence derives from using different muscles to lift. Although this might lessen your pain at first, it increases the stress on the joints and spine. The back muscles begin to fight the abdominal muscles until they both eventually contract. That simultaneous contraction of both sets of muscles creates a kind of “seesaw,” with each muscle group pulling from either end while your spine is caught in the middle. This not only provides an additional source of pain, but also increases risk of serious injury.

When you take a lunch break of a half-hour or more, you give your muscles the time they need to recover from the morning’s exertion. However, once you start working again, the amount of oxygen your muscles need in order to complete the same amount of work increases significantly. That requirement will keep increasing during the afternoon. That’s because your muscles are becoming fatigued much quicker during the afternoon, having already been exerted to complete the morning tasks. Taking breaks throughout the day gives your muscles the opportunity to replenish the oxygen they need, which helps counteract the risk of back injury. This is especially important at the end of the day when muscles are most vulnerable.

The necessity of taking frequent rest breaks can’t be stressed enough because on-the-job back injuries from heavy lifting are widespread. According to the U.S. Bureau of Labor Statistics, in 2002, there were more than 345,000 back injuries requiring employees to take time away from work. A 2004 study by Harvard Medical School and Massachusetts General Hospital found that back pain results in over 100 million lost workdays per year. But beyond the time lost from work, which could mean trying to manage financially on disability income rather than your regular salary, there is also the possibility of a permanent injury that could end your work career and leave you unable to enjoy activities with family and friends. Why would you risk such a possibility when preventing it so simple?

Aug 01
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PREVENT HEAT STRESS THROUGH EMPLOYEE AWARENESS

By Workplace Safety

As if construction work was not hazardous enough, when summer arrives and brings record temperatures, workers must take extra precautions to prevent heat-related illnesses. Although it might be difficult to escape the heat during a hot summer day, preventing heat stress is possible. The key is taking action before it becomes a problem.

Preventing heat stress among your workers starts with proper awareness, and that starts the day an employee is hired. As part of your orientation, educate new hires on the various types of heat stress, including heat exhaustion, heat cramps and heat stroke. You should also encourage your workers to look for the warning signs of heat-related illness for themselves and their colleagues, possibly by instituting a formal buddy system.

In addition to being on the lookout for usual signs of heat stress — headaches, dizziness, weakness, mood changes, queasiness, vomiting, pale and clammy skin and fainting — workers should know where to get help when a co-worker is suffering from heat stress.

Education about heat stress must be consistent and continue after orientation, otherwise workers might not remember everything they were taught. Furthermore, everyone on a job site should be knowledgeable about the hazards of heat stress. Training should not be limited to hourly employees, but should also be required for foremen, supervisors and subcontractors.

Many construction workers ignore the seriousness of heat stress. This is why it’s important that supervisors start each day by reminding workers how to protect themselves from the heat.

If at all possible, try to schedule workdays around the sun’s peak times. Start projects early in the day before the sun peaks, and if forced to work into the afternoon, encourage frequent breaks.

Certain types of personal protective equipment can make the summer months more bearable for outdoor workers. For example, dark-colored safety glasses offer more protection from the glare of the sun than do light-colored glasses; full-brimmed hardhats provide better coverage than front-brimmed hats; and light-colored clothes with sleeves and a collar offer additional sun protection. You could also hand out sunscreen and encourage it to be liberally applied throughout the day.

Prevention and awareness are the keys to developing heat stress prevention policies. But the most important thing you can do is to not wait for something to happen before taking action.

Aug 01
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KEEP WORKERS SAFE BY INSPECTING HARD HATS FOR DAMAGE

By Workplace Safety

Hard hats are easily the most recognizable piece of personal protective equipment (PPE) used in workplace environments such as construction sites. Although its function of protecting the head from trauma is the most important of any, this equipment is rarely inspected, maintained, or replaced.

The rugged appearance of a hard hat can disguise the need for replacement. In fact, many workers unknowingly wear hard hats everyday that are well past their useful life. Although there is standard service life for hard hats, most manufacturers recommend replacing hard hats every five years regardless of appearance. Under extreme work conditions, hard hats should be replaced more often.

The common ANSI Type I hard hat, which provides protection from overhead impact and penetration, consists of two components: The shell and suspension. Because these components work together as a system, if any component is not in good working condition, the hard hat wearer does not have adequate head protection. So, inspecting the helmet before each use is important.

INSPECTING THE SHELL

Shells should be inspected routinely for dents, cracks, gouges, and any damage due to impact, penetration, or other wear that might reduce the level of protection. When the shell becomes stiff, brittle, faded, or exhibits a chalky appearance, the hard hat should be replaced immediately.

Although most manufacturers add an ultraviolet inhibitor to the shell material to protect it from the harmful effects of direct sunlight, all hard hats remain susceptible to ultraviolet light damage. Workers should never store their hard hats in direct sunlight, such as the rear window of a car, as this is the quickest way to degrade the shell material and reduce the useful life of the equipment.

A recommended test for degradation is to compress the shell inward from both sides about one inch and then release the pressure without dropping the shell. It should return to its original shape quickly. If the elasticity is not similar to a new shell, it should be replaced.

INSPECTING THE SUSPENSION

The hard hat suspension is just as important to worker safety as the shell. The suspension helps to absorb the shock of a blow, so it must remain in good condition at all times. Like the shell, the suspension must be inspected regularly and replaced from time to time. Suspensions should be inspected closely for cracks, frayed or cut crown straps, torn headbands or size adjustment slots, loss of pliability, missing components, or other signs of wear.

OTHER GUIDELINES

All new employees should be provided with a new hard hat. Reissuing used hard hats must be avoided, as the cost of a new hard hat is minimal when considering the potential for injury.

If a hard hat has suffered a severe blow, it should be replaced immediately, even if it shows no signs of visible damage. Hard hats should also be replaced if dropped accidentally by the worker from the height of a two story building or higher.

Aug 01
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SHARPEN YOUR CONTRACT LIABILITY AWARENESS IN CONSTRUCTION RISK MANAGEMENT

By Construction Insurance Bulletin

Contractual risk transfer is an indispensable part of any construction risk management program; and the primary goal of effective contractual risk transfer is to place the financial consequences of a loss on the party best able to control and avoid the possibility of injury or damage, without violating statute or creating an “unconscionable” contract (defined as a contract that is unreasonable due to the unequal bargaining strength of the parties, or the result of undue influence or unfair tactics). Two key elements necessary to effectively accomplish this goal are: 1) a strong “Indemnification Agreement” within the construction contract; and 2) assurance that the entity to which the financial responsibility is being transferred has ample financial means to protect each party to the contract, either by sufficient financial reserves or adequate amounts of insurance.

The indemnification agreement is the heart of contractual risk transfer. Such an agreement may read, in some form, as follows: “For and in exchange for fair and equitable consideration, the “Transferee” (the sub-contractor, sub-subcontractor, etc.) agrees to indemnify and hold harmless “transferor” (the GC, owner, project manager, etc) for and from any and all loss or cost arising in whole or in part from the “transferee’s” negligence, or wrongful act.” “Indemnification” shields the transferor from the financial consequences of the loss and the “Hold Harmless” wording protects the transferor against the legal process that may result from an injury.

Indemnification agreements, in whatever form, are not affected by, nor do they directly affect the insurance coverage; they are purely contractual requirements. But beyond the indemnification agreement, and in order for contractual risk transfer to accomplish its stated goal, the entity to which the financial consequences are being transferred (the “transferee”) must extend some level of financial protection to the “transferor.” This can be accomplished by naming the transferor as Additional Insured, and by use of a Waiver of Subrogation endorsement in favor of the transferor.

Requiring the transferee name the transferor as an “Additional Insured” is recommended and a generally accepted contractual insurance requirement. Being named as an additional insured satisfies two necessities of effective contractual risk transfer for the transferor: 1) the transferor is defended against and financially protected for the negligent acts of the transferee by the transferee’s insurance carrier; and 2) the transferor is insulated, except in rare circumstances, against the subrogation rights of the insurance company.

Construction contracts can and often do require the transferee endorse a “Waiver of Subrogation” in favor of the transferor onto the insurance policy. However, insurance carriers may refuse this request for reasons outside the scope of this article. The waiver of subrogation endorsement is not absolutely necessary – if the indemnification agreement is written to include such waiver, and the additional insured requirements are met.

Subrogation rights flow from the injured party’s right to subrogate. If the subcontractor’s right to subrogate is waived by contract prior to a loss, the insurance carrier has no right to subrogate. The indemnification agreement should include provisions waiving the subcontractor’s right to subrogate; this waiver may need to be included as a separate paragraph in the contract, depending on how a particular state’s statute addresses the breadth of indemnification allowed.

Properly drawn construction contracts delineate the contractual risk transfer responsibilities of the contracting parties. However, no single article can anticipate every individual need or answer every question regarding contractual risk transfer. Outside expertise is necessary when developing a contractual risk management program or when responding to one as the transferee.

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