EMR, or experience modification rate, is a calculation of injuries versus hours worked in any given time period. Some companies, such as General Motors, Lockheed Martin, and Bell Helicopters, won’t allow a contractor to work on-site if their EMR is over a 1.

A&G is a commercial/industrial manufacturing, welding, plumbing, and HVAC contractor in the Dallas/Fort Worth area — and those three manufacturers are some of its major clients. Grimes feared that the company he and his Navy buddy, Tracy Auen, had bought from their dads might soon be left without work. So in December 2016, Grimes tasked Ken Trotter, the company’s project manager, with implementing a safety program that would bring the company up to speed.

A&G has been in business since 1984. Currently, it has between 75 to 100 employees and about 38 fleet vehicles. It’s a member of the Mechanical Contractors Association of America (MCAA); Mechanical Service Contractors of America (MSCA); Pipe Fabrication Institute (PFI); American Society of Mechanical Engineers (ASME); United Association Union of Plumbers, Fitters, Welders and Service Techs (UA); and ASHRAE, as well as the Better Business Bureau (BBB) and The Unified Group, an organization of independent HVAC commercial contractors.

When Trotter took on the safety program, he added another acronym to the list: OSHCON, the Occupational Safety and Health Consultation. It’s a free, confidential service, available to private employers in Texas through the Texas Department of Insurance (division of Workers’ Comp), to help employers navigate and comply with regulations set forth by the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA).OSHA is the enforcement arm.

“They’re basically the police,” Trotter said.

A lot of companies are visited frequently by OSHA and get slapped with noncompliance fines, and that scares them, he said. OSHCON, on the other hand, assists companies that know they’re not in compliance and want to improve.

“OSHCON does not issue fines, but if you are involved with them, and they see a hazard, they have the authority to tell you to stop,” he said. “If there’s an immediate danger to life and limb, you have to shut down. You have to stop now. If it’s not an immediate hazard, they’ll give you a time limit. For example, you might have three days to take care of the issue. If you fail to comply, they will let OSHA know, but if you make a good-faith effort to resolve the problem, they will work with you.”

Plus, while a company is contracting with OSHCON, OSHA will not visit its job sites or facilities, as long as no serious injuries or fatalities occur.

“If we ever were to get a job site visited from OSHA, we could kind of hold that card out and say, ‘We’re a member of OSHCON; we’re trying to do everything right,’” Grimes said.

“Just that benefit alone is well worth the effort,” Trotter added. “For companies like us that are kind of novices in the safety aspect, it’s a valuable resource to tell you what you’re doing wrong but also what you’re doing right.”

Joe Crowson is the safety inspector at OSHCON Fort Worth and worked with A&G. OSHCON was formed to help small businesses in particular after OSHA was formed in the 1970s, he said.

“Big businesses have the resources to employ a safety person or safety staff,” said Crowson. “But small businesses with 10 or 15 people, they’re like, ‘We don’t have the knowledge or resources to do this.’ We’re a small-business consultation resource because they don’t have the ability to hire someone full time.”

Many of the businesses Crowson works with have already had an OSHA enforcement inspection, although that wasn’t the case with A&G.

“Sadly, that’s our advertisement — someone tells them we’re out there and can help,” Crowson said. “A lot of the businesses working with us for the first time are starting from scratch. I go out there, and they’re stressed out; they don’t know where to start, don’t know what programs they need. I think it’s a relief to them that there’s somebody out there who can hold their hand and be a resource for them even after the inspection.”

Every state and territory in the U.S. has an equivalent of the Texas OSHCON program. The program is funded by federal grant money and controlled by the state, which sets procedures and hires inspectors. Last year, the OSHCON program provided 2,225 consultations total, including follow-up visits. It also performed another 527 compliance assistance activities, according to Kate Sidora, communications specialist, Texas Department of Insurance, Division of Workers’ Compensation.

“We go look at issues … we do a wall-to-wall inspection, so OSHA doesn’t come out and fine them,” Crowson said. “Not only do we do the inspection and try and get you in compliance, but if you have issues with silica dust, or if you have a building that’s too loud, and you’re worried about damaging employees’ hearing, we can get a program set up for you, so you can get into compliance. It’s a full shop: We can pretty much do everything — 99 percent of it or so.”

At A&G, OSHCON’s first step was a visit to the offices and fabrication shop, where they gave some recommendations, Grimes said.

“There was a lot of details we were ignorant about — just little safety items that were beyond our knowledge: appropriate machine guarding, safety labeling, and signage — like marking the location of fire extinguishers,” Trotter said.

A&G also implemented a hearing conservation program, since noise levels sometimes came very close to permissible limits.

After serious hazards were addressed, OSHCON’s focus switched to safety training and proper documentation of training, tools, and procedures.

“Our safety program was collecting dust; it was a good manual sitting on the shelf,” Trotter said. “We wanted to be more dynamic, more proactive.”

For Trotter, that meant a lot of research.

“It’s a really complex field, and I’m not a trained safety person,” he said. “It’s almost overwhelming to sort through all of that information. Reading OSHA, they leave a lot for interpretation.”

Luckily, according to Trotter, there are a ton of resources available through insurance carriers, the state, OSHCON, and workers’ comp as well as professional organizations, like MCAA, which has an open blog where you can ask questions and get answers straight from the pros.

A&G’s first step in upgrading its safety program was to implement a monthly video training regimen for employees.

“We all have [company-issued] iPads,” said Thomas Lance, a superintendent at A&G. “Ken has actually set them up so we go into the iPads and watch the video at the job site.”

Videos take about 30 minutes each, with time for questions afterward.

“It kind of keeps the guys up to date on all the new safety regulations and rules … keeps them aware of the surroundings, keeps everybody on focus,” Lance said.

“We know that we don’t do some tasks on a day-to-day basis, like confined space entry: You’ve trained on it, but you haven’t done it for nine months,” said Trotter. “So the foreman’s going to pop out a video and go through it with his crew like it’s the first time, as a refresher before we do this hazardous task, so that the material is fresh.”

Supplementing the videos are Monday morning “toolbox talks,” led by the supervisors on a topic pertinent to that week’s work. If they’ll be working on lifts, it might be fall protection. They’re about 10 or 15 minutes long, and they are pulled from MSCA, MCAA, PWB (Pipe Welding Bureau), and toolbox.com.

Lance said the videos have ultimately proved pretty popular among the guys in the field.

“At first, they weren’t too happy about it — kind of ‘Oh man, more safety?’” he said. “After they’d done a couple of them, they realized, man, this could really save my life.”

One thing that’s proved less popular is moving to standardized tools: something A&G felt would be not only safer but also more cost-effective in the long run.

“It’s difficult to cross-train on different tools and makes it extremely difficult to be consistent in training,” Trotter said. “Our guys, like most guys, are very, very picky about what they like. It’s all about trying to get them to come to a consensus on what’s best … you may have to live with this type of grinder to get that type of drill.”

Getting everything switched out takes a while, too.

“We’ve been on this for a couple years now,” Grimes said. “It might be one thing, like our safety harnesses, that we figure out they weren’t in compliance. We have 100 guys out in the field in a harness; now we’ve got to get all these harnesses back, get them all changed, tagged, and out again.”

Creating the safety program was the first step, but holding everyone accountable came next. Trotter found it more effective when the workers came up with the guidelines themselves. So, he had technicians write their own checklists that management reviewed.

Peer pressure helps, too.

“Early on, we kept tabs on who was doing the safety videos and who wasn’t, and we’d actually call them out on it,” said Grimes.

They’ve also implemented procedures that make accountability part of the daily routine. For example, tools are now tracked and checked in and out using barcodes, Gigatrack software, wireless locks, and digital flowcharts.

“We give the site foreman a handheld device and show them how to track and audit all the tools used on the job,” said Trotter. “It goes through the decision matrix: if a tool is not checked out to you but you have it, what to do and why.”

As a result of the safety program and the OSHCON partnership, A&G now has an EMR of .61 — the lowest possible score in the industry.

“If a company has a 1 or above, you wouldn’t even be able to work; there is a financial benefit to being safe,” Trotter said.

Having what amounts to a score of zero is pretty rare, he said. A&G got congratulatory calls from its insurance provider when the score came out, and the company gets a dividend at the end of each quarter with no accidents.

Trotter said it’s good for the bottom line, for morale — and, of course, for the employees themselves.

“One thing I’ve noticed about the guys is, by making the hearing program live and active, they really feel like the company cares about their safety,” he said.

“At the end of the day,” Grimes added, “we want everybody to go home with all their hands and feet.”

Publication date: 8/13/2018

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