Effectively measuring compliance with
Government, Corporate and Plant requirements is a responsibility of management.
Checklists and audits are effective tools in providing management with feedback
on the degree of compliance and are an ideal way of involving employees in the
safety process.
Midland Engineering, Ltd. (MEL) has proven audit and inspection
experience with the use of tools in the areas of safety, process safety
management, industrial hygiene, reactive chemicals, loss prevention, pre-startup
and many others. MEL can provide onsite auditing of practices and programs for
regulatory, corporate standards and policies, and for site/plant rules and
policies compliance. We can also develop auditing programs for company wide or
site/plant specific application (to be administered locally), including auditing
standards, auditing protocols, auditing tools (questionnaire, sampling methods,
evaluation and prioritization, etc.), and training of auditors (including
interview methods, report writing, recommendation writing, etc.). These programs
can include practical day-to-day or by-task checks for key program elements,
internal self assessment, corporate management reporting, government required
audits, etc.
The Behavioral Safety Process offered by Midland
Engineering is based on awareness training and field observations followed by
performance feedback to workers. This process leads to safety expectations being
conveyed to workers and performance measured against identified expectations.
The essential basis for this very successful program is that most employees want
to please their supervisor. Knowing what is expected and receiving frequent
feedback results in employees performing more safely by reducing the number of
risks they take while performing their job.
Midland Engineering, Ltd. will provide overview training on the principles,
application, and program elements and development of a site/plant specific
program including behavior selection, observer and intervention training,
measurement methods, ABC (?) analysis, behavior re-enforcement, etc. We can also
provide periodic program and practice review, program coaching, and program
enhancements. This program will also provide a behavior program for leadership
that includes goal identification, plus identification and detailed development
of local practices to achieve the goal, and development and implementation of
the specific leadership behavior to influence the use of the selected practice.
This program will involve development of behaviors for each leader (both
organizational and natural) that has a potential to influence the selected
practice. This program will also include metrics to verify that leadership
behaviors are being properly implemented and having the desired impact.
The Community Advisory Panel (CAP) process
enables a greater openness and trust to be developed between a plant and its
community. It allows the company to "Open Doors" and receive thoughtful input
and dialogue with the community on its plans and activities. We have experience
setting up and leading Community Advisory Panels.
Midland Engineering, Ltd. will provide technical support for the CAP committee,
including research and reporting on governmental requirements, industry
practices, evaluation of local programs, etc.
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A Compliance Audit is a process designed to provide
operations with a means of identifying needs to meet requirements for various
Government and Company mandated Safety and Health reviews as well as audits
conducted by outsiders to operations. This audit is intended to ensure that
plant management is taking the appropriate actions needed to minimize
(Environmental, Health, & Safety (EH&S) risk, including complying with
regulatory and company requirements and best practices. The audit process will
result in a list of suggestions for improvements.
Midland Engineering, Ltd. will conduct Comprehensive Compliance Audits and can
also provide references and explanations of applicable regulations, provide
recommendations regarding means and methods to achieve compliance, provide
alternative methods to achieve compliance and enhance performance.
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Contractors continue to play a significant role within
manufacturing facilities and their performance can have a significant impact on
its overall safety performance.
Midland Engineering, Ltd. provides a safety management system that can be used
to manage the performance of contractors within the facility. Significant cost
savings can be realized by effectively managing contractor safety performance.
Specific elements of the process include development of a program that
incorporates site/plant specific considerations and includes contractor
pre-qualification, selection criteria and process, pre-job safety protocol,
field evaluation, and performance reports.
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Historical data of injuries and incidents is used to
establish trends and prioritize safety activities to reduce recurring injuries
and incidents. Deficiencies, causes and corrective actions identified by audits,
inspections, and accident investigations and employee suggestions should be
registered and tracked to analyze trends.
Midland Engineering, Ltd. can facilitate the implementation of a Data Analysis
System, including support for or design of data systems that will collect
critical data to facilitate analysis and identification of actions to change
performance.
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The goal of emergency planning is to develop an
appropriate level of preparedness and to have in place all procedures necessary
to reduce the effect of the emergency. Additionally, the Emergency Response Plan
will provide a protocol and procedures necessary to summon support services as
well as notify supervision, authorities, and others who have a need to know or
whose assistance may be needed.
Midland Engineering, Ltd. can provide each operating location with an Emergency
Planning and Response program that will include the minimum guidelines for
emergency planning including Distribution Emergency Response Planning, Safety,
Loss Prevention, and Security programs.The programs will address regulatory
requirements and reflect local resources and situations.
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All levels of the organization have roles and
responsibilities in the safety process. Clear communication, documentation and
understanding of these expectations on the part of all employees, especially
management and supervision, is a building block to good safety performance as
well as a way to establish measurements for evaluating individual performance.
Midland Engineering, Ltd. can facilitate the development and implementation of
these Safety Expectations that can include broad guidance for all people in an
organization or site or they can be detailed and designed for specific tasks or
jobs. The program will provide the tools and training for the organization such
that they can refresh and revise the expectations to reflect changes in
performance, work, employees, etc.
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An effective Hazard Communication Program summarizes the
chemical and process hazards of the work place, ensures that the employees
working in the area are knowledgeable of these hazards and provides for
regulatory compliance.
Midland Engineering Ltd. can develop and implement this Hazard Communication
program at your sites.
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The ability to effectively intervene is a problem for
many employees and supervisors in that the people performing the unsafe act
might recognize themselves as becoming defensive and the person intervening is
uncomfortable about approaching a co-worker concerning unsafe acts.
Midland Engineering, Ltd. can train and coach your employees to conduct and
receive effective safety interventions.
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Management of change is required by OSHA Process Safety
Management and is the process for obtaining approval for changes to facilities
that produce product, use, handle or store chemicals or any functional work
process. It is a formal process that will help obtain the desired results of a
change, with limited adverse reactions.
Midland Engineering, Ltd. can help develop and implement a Management of Change
process for your company or location. This program will include administrative
controls, forms, roles and responsibilities, an audit protocol, and a method for
selection of changes to be managed such as process, equipment, operating
procedures, etc.
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In many instances, employees are safer at work than they
are while off the job. As health care costs escalate, more and more attention is
given to employees enjoying their time off without injuries and illnesses. There
are many off-the-job activities that can increase the risk of on the job
injuries/illnesses. A well-designed off-the-job safety program can reduce these
risks and supplement on the job safety.
Midland Engineering, Ltd. offers a program that provides information to the
employee and their families that will affect their off the job behaviors,
resulting in reduced injuries and cost. An off-the-job safety program can
address hearing conservation, personal protective equipment, hazard
identification, ergonomics, etc.
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Operating procedures are the documentation and the use of
the best collective knowledge and experience that ensures each job can and will
be performed successfully. This ensures that jobs are done safely in a
consistent fashion thereby reducing operational incidents and costs.
Midland Engineering, Ltd. has the experience and expertise to help you develop
and implement effective process and safety operating procedures for your
facilities.
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OSHA requires employers to provide a safe work
environment. OSHA does this through specific regulations and the "General Duty
clause". OSHA regulates such topics as energy isolation (Lockout/Tagout),
permit-required confined space entry, Process Safety Management, Injury/Illness
Recordkeeping, Emergency Response Planning, Hazard Communication, HazWOpER,
forklifts, etc. OSHA includes in the regulations the training requirements, the
documentation, what must be addressed in the local programs, auditing, etc. For
many regulations there are compliance directives that describe how a Compliance
Officer will inspect for compliance.
Midland Engineering, Ltd. reviews exiting programs or develops compliance
programs by first assessing the local work activities, determining what are the
effective means and methods to enhance performance and then what is necessary
for compliance. When there are existing programs or recommendations we can also
provide copies of the pertinent OSHA documents and an explanation as to how the
program addresses the regulatory requirements. Midland Engineering provides a
research function that will assess current or proposed practices and report how
that practice is regulated, if it is in conformance with the regulations,
propose practices that will be in conformance with regulations, and, as
appropriate, make formal requests for interpretations from OSHA or state
administering agencies. Mel also has the capability to provide support during a
regulatory inspection or as applicable during an appeal of citations.
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A process is available to conduct a VPP site assessment
using a template for defining deficiencies. Expertise is also available for
coaching clients to improve their compliance with VPP requirements.
Midland Engineering, Ltd. will present to management and site personnel the
costs/benefits of VPP application and participation as well as provide coaching
for application for VPP recognition. The program would include on-site
assessment, a program evaluation report, recommendations, support for the
development of the VPP application, preview and presentation preparation for an
OSHA/MiOSHA on-site visit, coaching to address any 90 day issues, and support
for a VPP award ceremony.
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A well-designed, comprehensive safety program results in
OSHA compliance, reduced injury rates, lower operating cost and reduced risk for
your personnel and equipment.
Midland Engineering, Ltd. will develop the means and methods for hazard
identification, evaluation/prioritization, control/mitigation, and verification
and we will train identified personnel the principles and proper application of
the program. The safety program will address all elements of OSHA’s Guide for a
Safety Program..
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Safety performance measurements are necessary to manage
any safety program. Identification of the appropriate goals by employee, team,
department, and site are important in driving the desired behavior. The
appropriate consequences should be provided to reinforce that behavior.
Attaining the goals set forth by the organization warrants appropriate
recognition.
Midland Engineering, Ltd. can help you establish an appropriate performance
measurement and recognition program. Recognition programs may include awards
that recognize both individual contributions and the Leader’s role in success,
metrics that measure both proactive contribution and their successes, and
special emphasis programs that focus on particularly challenging issues (such as
hazard identification and control, specific hazards, performance concerns,
safety intervention, risk tolerance, etc.).
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Capital project teams must use environmental health and
safety reviews of varying complexity determined by the nature and size of the
project. These reviews will reduce the long-term cost of ownership and improve
Safety, Health and Environmental performance.
Midland Engineering, Ltd. has extensive experience and proven tools to perform
these reviews at the various stages of a capital project including design,
construction and startup.
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The Chemical Manufacturer Association has developed a
program entitled Responsible CARE that includes both a Code and specific
Elements.
Midland Engineering, Ltd. has the background, experience, and expertise to help
develop and implement programs that meet these requirements. We will develop the
internal protocol for self assessment for each of the Responsible Care Codes and
provide support for a facility preparing for a third party validation of the
Responsible Care Codes (corporate or facility verification).
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Midland Engineering, Ltd. offers a 3 day seminar that is
designed to educate Safety and Process Safety (Loss Prevention) managers and
supervisors on over 30 Risk Management techniques that, when implemented, will
lead to a well rounded process for minimizing risk and maximizing value for a
company or site. The seminar includes 3 field exercises to help participants
practice observing operations for Safety and Process Safety deficiencies at
their manufacturing sites..
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EPA (Environmental Protection Agency) has regulations
that list 77 toxic and 63 flammable materials and requires that companies using
these materials develop a Risk Management Program (RMP) for handling them. The
RMP process starts with a hazard assessment of the listed materials to determine
the nature and extent of the hazards and potential consequences that might
impact the public and the environment from a release of these materials.
Midland Engineering, Ltd. can establish programs that, when successfully
implemented, can ensure regulatory compliance. We will also carry out
assessments and audits to provide clients with a "third party," unbiased review
of their program.
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Elimination of recurring injuries, illnesses, and
incidents is of primary concern to Management and Employees. A Root Cause
Investigation process will help ensure root causes are determined and
appropriate action is identified to prevent recurrence.
Midland Engineering, Ltd. will provide a program that identifies the immediate
and underlying causes of an incident, reporting that will address the potential
of regulatory or third party review, and a tracking method to facilitate
addressing all causes and completing corrective actions in a timely manner. It
will also provide training for the investigation facilitator and potential
investigation team members. This training will provide guidance on how to be
effective and expeditious in the investigation and finalizing findings while
ensuring that extraneous information or concerns do not detract from the
investigation. The program also provides training on how to define and
investigate success to ensure that the programs and practices that are achieving
the success are formalized and made part of the rules, policies, and workplace
culture
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The active involvement of the employees in the safety
program is a goal of every manager. This can be accomplished using teams to
address specific issues either chartered by management, or when provided with
the right information, self-directed.
Midland Engineering, Ltd. can facilitate the formation and implementation of
Safety Activity Committees at your sites, including design tools and methods to
facilitate ownership and actions by the people at the point of risk.
[ return to Topic List ]
A safety improvement system is an assessment of the
strengths, opportunities and recommendations for improvement of a location's
Safety and Health programs.
Midland Engineering, Ltd. will facilitate this process, including assistance
with implementation of identified recommendations. The process will provide the
tools and methods and training for self assessment of current practices and
development of a gap analysis for improvement. These tools identify several
issues for assessment, and describe activities and distinct levels of practices
that are designed to achieve progressive improvements in safety and health
performance.
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Safety meetings are an effective way to improve employee
involvement in the safety process and supplement employee training on critical
topics. We have extensive experience in designing and conducting safety meetings
that will allow a client to streamline training efforts, and improve employee
interest and involvement.
Midland Engineering, Ltd. can develop a safety meeting program than can include
extensive annual or semiannual training session to address all formal safety and
health training, monthly meetings to focus on specific hazards or program
elements for individual facilities, and "tool box" meetings that are only 5-10
minutes to alert a crew to special concerns just prior to beginning a work week
or shift, etc.
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An effective safety program will minimize personnel risk,
employee pain and suffering, government compliance citations and workers’
compensation costs.
Midland Engineering, Ltd. will assess the facility or organization based on the
nature of work and relevant hazards, the available resources, and workplace
culture and will develop programs that are most effective for the specific
situation. Supplemental support that will re-enforce the implementation of the
program and will modify the program based on success or barriers to success can
also be provided.
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Midland Engineering, Ltd. has developed a program that
calculates the potential savings that would result from reducing injury rates at
any given site or company wide. MEL can provide a safety improvement process
that can be used to prioritize a site's or company's safety improvement
opportunities leading to injury rate reduction and lower Workers Compensation
costs. We can also help develop a program that facilitates employee return to
work or "restricted" work that re-enforces the value of the employee and
facilitates their recovery.
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Midland Engineering Safety and Loss Prevention Resources and Services
Midland Engineering, Ltd. has many resources available that are designed to help
improve your Safety and Loss Prevention (Process Safety) performance. Contact
MEL anytime you have a client, project, or concern where safety or loss
prevention programs, OSHA regulatory concerns, processes, materials, or subject
matter experts may be useful. We look forward to working with you.