The Tongue and the Confined Space: Arbitrary Rules Hurt Your Safety Program
If you’ve ever had a boss that wasn’t fit to interact with other humans, you’ll identify with this story. I had one that defied imagination. Since I don’t have the kind of money required to fund a libel lawsuit I’ve always referred to him as The Tongue. It’s an appropriate name considering some of the vile things was known for saying.
I was working on the startup phase at the end of a massive construction project. At the time The Tongue came into our lives, my crew had been working together for nearly two years. We had figured each other out and had begun to work well as a team. We had one of the best supervisors I have ever had the privilege of working with, but the powers above decided the crew needed a shake up. Thus, our (good) supervisor was swapped for the site’s troll of an Industrial Hygienist.
We’d had rough dealings with him throughout, but no longer protected by our shield, The Tongue’s full wrath was unleashed. He was mean for the sake of being mean. For example, one day he spotted me on site and grabbed my safety glasses from my face. They were Oakleys that I had gotten in the Air Force. He “knew” that Oakley didn’t make any ANSI approved safety glasses, and was convinced I was violating site rules. I learned that day that he didn’t enjoy being proved wrong.
That Christmas, he insisted that we have a full staff on site every day of the break. On the surface that may not seem so odd since most companies work through the holidays. This site, however, released all but a skeleton crew of grounds workers (for snow and ice removal) for two weeks every holiday season. The Tongue made us work because he could, not because we were needed.
He did all kinds of other fun things to torture us. Secretly pitted friends against each other. Put in false ethics complaints with certification boards against people who questioned him. Called us nonsensical names in staff meetings. I’m sure you get the point. He was an ass.
Personalities are an obstacle that everyone faces. If The Tongue being a difficult person was my only gripe, you’d be justified in saying that I’m a little petty and should have just dealt with it. I’m sure pettiness played a role, but his downfall was actually a much bigger issue than personal conflict. As I mentioned, he hated being questioned. In my experience, Safety Professionals who are unwilling to accept they may be wrong cause more harm than good. We’re not all knowing gods. Hell, many of us have never even performed the jobs of those we “advise.”
The real trouble came with his penchant for the arbitrary. The Tongue had spent most of his career in the oppressively burdensome regulatory world of nuclear surety. That mentality (which, I should mention, is warranted in that environment) was something he carried with him as a badge of honor. He made rules about rules and could spew a form or checklist out of any orifice without even having to blink. Until the time he became our supervisor, his rules and forms were confined strictly to things of an Industrial Hygiene nature. No one really questioned any of that as he was clearly the site’s foremost authority. Trouble came, however, when he assigned our crew the task of performing confined space evaluations.
If you recall, the site was transitioning from new construction into startup. There were hundreds of spaces within the plant requiring evaluation. First, we determined if the space was, indeed, a confined space. Then we developed a detailed entry plan for each space that met the definition. In theory, the exercise was a useful one even if it did assume entries would be conducted under the same circumstances and no unknown hazards would ever be introduced. Personally, I prefer conducting evaluations prior to each entry and assuming nothing, but we were given our orders and followed them dutifully.
One space in particular was a housing for a large bank of filters which were to be used to purify air from the laboratory before it was released into the rest of the plant. I was assigned the evaluation task and quickly marked it off my list. In order to do so I had interviewed the lab staff and learned that once it was in operation, the filters would only be removed one at a time. They were about four feet tall, but only about six inches wide. The housing was split into quarters, each quarter only capable of holding two filters. I concluded based on those factors (primarily the fact that you couldn’t bodily enter) that the space should not be considered a confined space at all. That’s not to say that the filter bank was without hazard. The lab dealt with some particularly bad stuff that no one wanted to put into the atmosphere.
This is how I remember The Tongue
When The Tongue received my evaluation he publicly berated me and made a point to explain to the lab staff how ignorant I was. Not only did he want it labeled a confined space, but a Permit Required Confined Space. Here’s the kicker though. He didn’t want it labeled a PRCS because it was one. He wanted it to be called that because it would make people be more careful around that bank of filters.
That line of reasoning is, unfortunately, none too scarce in the safety world. Safety zealots the world over seem to make it their holy mission to find some arbitrary travesty on which to build their legacy. For some, it’s outfitting an entire company in FR clothing without commensurate risk warranting they do so. For others its spending thousands upon thousands of dollars on new machinery without just cause.
My point in bringing any of this up is that doing things without solid, logical reasoning based on responsible risk analysis diminishes the importance of safety. Workers are smart. They can easily distinguish between what’s done for their protection, and what’s done because some pompous safety peacock wants to show how awesome and super smart he (or she) is. Keep that in mind the next time you think about starting a new initiative. If there’s a truly a risk, go for it. Otherwise, save your showboating for the karaoke machine at the company picnic.
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