Substandard Standards?

A Call for Universal Safety Standards

by Jan Semenoff

Health, safety & environmental professionals have used terms like “substandard” for many years to describe deviations from acceptable acts, practices or conditions. “Standards” are used, because we can then quantify a measurable difference between the way things are, and the way things should be. For many of us, the “standard” used is the one outlined in the local Occupational Health & Safety Regulations. We then use those values to determine whether or not our health and safety programs are meeting the required goal.

Although I fully support the notion of measurable objectives, I think we’re off track a little. I suggest to you that the “standards” themselves are “substandard” and I want to forward the argument for a thorough review and revision of these values. Here’s how I’ll make my case:

We are putting the finishing touches on the Fall Arrest in the Workplace e-learning module, and have had a heck of a time coming to grips with variations in Occupational Health & Safety Regulations across Canada, the United States and overseas. As our programs have grown for national and international customers, we’ve had to contend with differing requirements from one jurisdiction to the next.

Fall Arrest, as an example, has widely varied “standards”:

• Canadian Federal Regulations stipulate fall protection for workers on an unguarded structure more than 2.4 metres (8 feet) above the nearest permanent safe level, or 6 metres (18 feet) from a temporary structure.

• In British Columbia, Alberta and Ontario, from 3 metres (10 feet).

• In Saskatchewan, more than 3 metres from a “temporary installation” or 1.2 metres (4 feet) from a “permanent installation.”

• In the United States, Federal OSHA regulations require fall protection when a worker could fall more than 6 feet (2 metres) above a lower level.

• In Australia, NOHSC regulations require fall protection above 2 metres.

I suggest that this variations in standards is a mess. A worker in Saskatchewan must use fall protection protocols when working 4 feet above a surface on a permanent installation, while his cousin working slightly to the south in North Dakota can be 5’11” above a similar surface and work unprotected. Their friend working in Alberta doesn’t have to use fall protection until that platform is at the 10 foot level.

The standards themselves are substandard.

We use terms like standard and substandard to replace terms like “safe” and “unsafe”. But if regulatory agencies, presumably following the safe work practices of local safety professionals, can’t agree upon a standard, then how can companies working in many geographic locations hope to know what is allowable or illegal or unsafe. I suggest that safety regulations should be standardized.

Don’t get me wrong – I’m all for standards. I just think that these standards must have firm footing in the fundamentals of safety. With Fall Arrest, as an example, the human body can only withstand a certain amount of force before physical damage occurs. Having differing standards for fall distances somehow implies that workers in Australia are less tolerant to injury from falls than workers in Alberta. That just doesn’t make sense.

Fall arrest is just one example. Different jurisdictions use different definitions of what constitutes a forklift. Permissible Exposure Levels for carbon monoxide can double from one jurisdiction to the next. I suppose it is much like legal limits for alcohol consumption when driving. In one State, the limit may be 0.10, and across the border 0.08. Add the Omnibus requirements of 0.02 for commercial drivers, and the issue gets more and more confused.

Some argue that these levels reflect the amounts tolerated in a particular community, as if a fall from 4 feet hurts more in Saskatchewan, or a commercial driver in Minnesota at 0.021 is more of a hazard than one in Ontario at 0.045. I just don’t get the differences. These different levels offer only confusion to an already murky situation.

Ultimately, what we are trying to accomplish is a reduction of loss. Carbon monoxide poisoning is not twice as acceptable in the state of Washington (50 ppm) than it is in British Columbia (25 ppm), so why are the permissible exposure levels different? Are workers in Washington heartier? Is British Columbian carbon monoxide stronger?

I suggest that the “standards” used by these various jurisdictions, more probably in all jurisdictions, are out of date. We need to determine the following values, to name but a countless few:

• When a driver, commercial or otherwise is not able to safely operate a motor vehicle.

• At what height should a worker use fall protection protocols?

• What is the acceptable amount of carbon monoxide that a worker can absorb?

Why have one universal standard? Well, for one, it would ease the confusion faced by companies who work across geographic boundaries. They would have to adhere to only one regulation, and would then be able to standardize their safe work practices.

Secondly, any standard that was universally accepted would have to go through some sort of vetting process, where the standard was determined based upon sound engineering and science principles, as opposed to being bureaucratically appointed. The regulatory values would then be founded in principles of safety.

Finally, having a universally applied regulatory requirement would firm up the notion of safe work practices. The standards would themselves establish universal safe work practices. Those who deviate from the standards would face tough questions as to why they chose to do so.

Remember, regulatory compliance is only half the job. Acceptable safe work practices should dictate when you will employ a particular safety protocol, use of personal protective equipment, or engineering control. Companies that are multi-jurisdictional should adopt the “safest standard” and apply it as a corporate safety protocol.

Perhaps the notion of universally acceptable safe work practices is not feasible. But at least if governmental regulations pointed to an outside scientific authority that studied and tested levels according to their degree of risk, we would have a “standardized set of standards”.

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A Call for Universal Safety Standards

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