Environmental

CHAPTER 20

THE PROCUREMENT PROCESS: SECTION 5.1.4 OF 210

Although the requirements in ZIO for the procurement processes are plainly stated and easily understood, they are brief in relation to the enormity of what will be required to implement them. Little"help is given as to utilization of the procure- ment provisions. Advisory notes are brief. Documenting the procurement process is the subject of E5. l.4. Appendix I is a one-page informative description of the procurement process. •

As is the case for the provisions in ZIO on safety design reviews, the purpose of Procurement processes is to avoid bringing hazards and their accompanying risks

into the workplace. The standard reguires that processes be instituted so that reviews ~ade of products, materials, and other goods purchased and related services to

ide~l!fy and evaluate health and safety risks before their introduction into the work ~ 0 VJronment. To fulfill the procurement provisions, safety specifications must be included· h

In pure ase orders and contracts. in thisT? assi

st safety professionals as they give advice on implementing those provisions,

chapter we:

• Conunent briefly on prevalent purchasing practices • Establi b • . s the significance of the procurement processes

Discuss the pre-work necessary to include safety specifications in the procure- lllent Process

• Provide some resources

Sctond F.di/ery t;1anagemem: Focusing 011 ZJO and Suious llljury Prevention . O 2014 John on. red A. Manuele.

W-t1ey & Sons, Inc . Published 2014 by John Wiley & Sons, Inc.

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400 11-lE PROCUREMENT PROCESS: SECTION 5.1.4 OF 210

• Comment on the paucity of publicly available occupational health and s r . 'ti . a,ety

purchasing spec1 cattons • Remark on the need, sometimes, to set specifications above published standards • Give examples of design specifications that become purchasing specifications

THE REAL WORLD OF PURCHASING PRACTICES

Unfortunately, the practice in many companies in the bid process for acquiring machinery, equipment, and materials is that purchasing departments are to choose the lowest-qualified bidder. For many years, safety professionals have told stories about how purchasing personnel have accepted the lowest bid on safety-related products or material~ only to find, after their receipt, that they did no,t fulfill opera- tional expectations and that safety needs were not met. Expensive retrofitting for safety purposes was necessary. ·

Retrofitting to accommodate safety needs starts with evaluating the deficiencies in the equipment as it is in operation: that is, identifying what was overlooked in the design process. Unfortunately, the resulting level of risk when safety requirements are addressed through retrofitting may be higher than would be the case if safety specifications were included in the bid or purcq,asing papers. As retrofitting proceeds, it's easy for decision makers to rationalize acceptance of higher risk levels. Nevertheless, the goal should be to achieve acceptable risk levels.

Getting managements and purchasing personnel to adopt the procurement provisions in z19 will not .be easy. A safety profes.sional who proposes adding procurement provisions as an element in safety and health management systems and to have safety specifications included in a company's purchasing practices should expect the typical resistance to change: I.n most places, a culture change will be necessary for success.

An oblique interpretation of the procurement requirements could be: Safety and health professionals, you are assigped the responsibility to convince managements and purchasing agents that, in the long term, it can be very expensive to buy cheap.

' SIGNIFICANCE OF THE PROCUREMENT PROVISIONS

I place great emphasis on having the procurement provisions in Z 10 becoming_ an el:: in safety and health management systems because doing so prevents introducmg h and risks into a workplace. This is the thinking that supports that position.

Risks of injury derive from hazards. If hazards are properly addressed and avoided, eliminate, reduced or brought under control in the design process t that the risks deriving from them are at an acceptable level, the •potential or harm or damage and operational waste are minimized. 5

Thl ·1. f . d·nproces e og1ca extension o address mg hazards and risks in the esig d • n is to have the design specifications the organization decides upon inclu~:fe;Y purchase orders and contracts so that suppliers and vendors know what

RESOURCES 401

•jjcations are to be met. That reduces the probability of bringing hazards ~pecithe workplace. into

Jthough having safety specifications included in purchase orders or contracts is A ractice applied broadly, safety professionals are encouraged to consider the

not 8 6~ to be achieved if they are. If the ideal is attained in the purchasing process and

be~ and risks brought into the workplace are as low as reasonably practicable, the h ult is significant risk reduction, which means fewer injuries. res UnfortUnately, the only safety-related terminology in purchase orders and contracts roay be to meet all OSHA and other governmental requirements.

PRE-WORK NECESSARY FOR PROCUREMENT APPLICATIONS

As we say in Chapter 15, "Safety Design Reviews," there is a close relationship between establishing safety design specific!ltions and including safety specifications in procurement documents. The latter cannot be achieved successfully until the former bas been accomplished. .

Once safety design specifications are established, the next step is to have them applied internally. Then, an appropriate extension is to have them incorporated into purchase orders and in contracts.

It is common practice for vendors and suppliers of equipment to use their own, and possibly inadequate, $afety specifications if a purchaser has not established its requirements. That could end up being costly for the purchaser, especially if produc- tion schedules are delayed and the retrofitting expense to get systems operating as designed and for safety purposes is substantial.

RESOURCES

In Annex E, "Objectives/Implementation Plans," the following appears under Objectives for the Procurement provision: Distribute' approved policy; Train on ~!icy and procurement procedure; and Distribute safety requirements to be included ID Standard co'ntracts. (p. 44) '

That presumes that a procurement policy and safety requirements have been e51ablished and distributed and that training on their implementation is to be given. Procedurally, that's ' a ,good and recommended practice. Procurement is listed in Appendix_ L, ''Audit;' as one of the subjects to be reviewed when a safety audit is :~e. This audit guide says that in the audit process, the following are to be consid-

as aspects of the procurement section in the standard. ·

Documents to Be Reviewed • Procedures for selection, evaluation, and management

Reco,ds to Be Reviewed . ' Selected 1· supp 1er self-assessments • Selected supplier audits and ratings

402 THE PROCUREMENT PROCESS: SECTION 5.1.4 OF 210

• Selected supplier contracts • Incoming product inspection records • Product risk analyses

Interviewee • Selected ~upplier management personnel • Hourly employees

Observations • Selected purchased products to check associated procurement records

Although the foregoing provides-somei guidance, what is proposed lacks the most important element in a procurement process, which is to establish the specifications that suppliers are expected to meet. Section 5, "Relationships with Suppliers," in ANSI/ ASSE Z590.3, Prevention Through Design: Guidelines for Addressing Occupational Hazards and Risks in Design and Redesign Processes, is informative with respect to the procurement provisions in Z 10. For one example: the standard says that in relationships with suppliers, "top management shall establish and document its occupational hazard and risk specifications."

THE PAUCITY OF AVAILABLE HEALTH AND SAFETY · PURCHASING SPECIFICATIONS

Several safety-related texts were reviewed to determine whether they give guidance on including safety specifications in the procurement process. They do not. Examples of some safety-related purchasing specifications posted on the Internet follow._There are others.

• University of California, Environmental, Health. and Safety (EH&S) Laboratory Safety De!)ign Guide, 2nd edition. At http://us.yhs4.search.yahoo.cqm/yhs/ search?p=University+of+Califomia%2C+Environmental%2C+Health+and+Sa fety+%28EH%26S%29+Laboratory+Safety+Design+Guide&hspart=att&hsim p=yhs-att_OOl&type=att_lego_portal_home

• Queen's University Environmental Health and Safety: Laboratory Flammable and Combustible Liquid Handling Procedures. At http://us.yhs4.search.yahoo: com/yhs/search;-ylt=A0oG7oNbrlhR.ysAu14PxQt.?p=%E2%80%A2%09Uru versity+of+Califomia%2C+Environmental%2C+Health+and+Safety+%28EH %26S%29+Laboratory+Safety+Design+Guide&type=att_lego_portal_home &hsimp=yhs-att_OO 1 &hspart=att&pstart= 1 &b= 11

• Duke University, Summary of Class 4 Laser Laboratory Design Guidance, at www. safety.duke.edu/RadSafety/laser-lab-design.pdf

• Yale University's Procedure 3220, "Purchases of Restricted Items," among which are:

OPPORTUNITIES IN ERGONOMICS 403

• yazardous materials: Materials that present special safety risks during trans- pcrt, stora~e, use,_ or disposal. :niese include, but are not limited to, certain highly toXIC, reactive, or otherwise hazardous chemicals, gases, and biological agents.

• safety-Critical Equipment: Equipment that can present safety hazards to users (e.g., x-ray and laser equipment) as well as equipment used to control exposures to recognized hazards, and whose improper use could subject users to harm (e.g., fume hoods, biological safety cabinets, respirators, automated film pro- cessors). At http://us.yhs4.search.yahoo.com/yhs/search?p=%E2%80%A2%09 Yale+ University %E2 %80%99s+ Procedure+ 3 220+&hspart=att&hsimp= yhs-att_OOl &type=att_lego_portal_home

• University of Wollongong, New South Wales, Australia. WHS Purchasing Guidelines (WHS, Workplace Health and Safety). Available at http://us.yhs4. search.yahoo.com/yhs/search?p=HRD-WHS•GUI-070.9+WHS+Purchasing+ Guidelines+ 2013+&hspart=att&hsimp=yhs-att_ 001 &type=att_lego _portal_ home. (The Guidelines are an ·addendum to this chapter.)

• Toe Bedfordshire Community Safety Guide. At http://www.bedfoi:'d.gov.uk/ environment_and_planning/planning_town_and_country/what_is_plarining- policy/ documents_of_the_bdf/bedfordshire_community _safety.aspx

It is interesting that the first five entities in the list above are universities, and the last is a municipality. Since they are governmental entities, the materials they pro- duce are almost always in the public domain.

Examples of applications of safety-related design standards that become purchasing specifications are not easily acquired. Most companies consider their specifications proprietary and don't make them available to others freely. For a moderate-sized company with a limited engineering staff, writing design·and purchasing specifications will not be easy to do.

It seems appropriate to suggest that organizations prevail on the business associ- atians of which they are members to undertake writing generic design specifications and purchasing specifications that relate to the hazards and risks inherent in their operations. Safety professionals should consider this inadequacy as an opportunity to be of service and make their presence felt.

However, arrangements were made for an additional example of internal design specifications that are also purchasing specifications to be included as an addendum to this chapter.

OPPORTUNITIES IN ERGONOMICS

As is the case with ZlO's safety design review provisions, safety professionals who are ~ot involved in the design or purchasing processes should consider ergonomics as :ertile ground in which to get started. Some of the comments made in Chapter 15, /a_fety Design Reviews," are repeated here because they apply equally to ZlO's esign and procurement provisions.

fi 404 lliE PROCUREMENT PROCESS: SECTION 5.1.4 OF 210 Musculoskeletal injuries, ergonomically related, are a large segment of the spectrum of injuries and illnesses in all industries and businesses. Since they are costly, reducing their frequency and severity will show notable results. Furthermore, it is well established that successful ergonomics applications result not only in risk reduction, but also in improved productivity, lower costs, and waste reduction.

Ergonomists know how to write design specifications for 'the workplace and the work methods that take into consideration the capabilities and limitations of workers. A company that established detailed ergonomics design criteria to be followed by its own engineers and by its vendors and suppliers was DaimlerChrysler. The following intro- duction to the DaimlerChrysler ergonomic design criteria demonstrates the relationship between writing design specifications and including them in purchasing requirements.

This document attempts to integrate new technology around the human infra- structure by providing uniform ergonomic design criteria for DaimlerChrysler's manufacturing, assembly, power train -and components operations, as well as part distribution centers. These criteria supply distinct specifications for the Corporation, to be use4, by all DaimlerChrysler eng.\neers, designers, builders, vendors, suppliers, contractors etc. providing new or refurbished/rebuilt mate- rials, services, tools, processes, facilities, task designs, packaging and product components to DairnlerChrysler.

In effect, the ergonomic design criteria to be used intemally ,at DaimlerChrysler also became the ergonomic specifications that vendors and suppliers had to meet. In a section on supplier roles and responsibilities, it . is made clear that all suppliers were to "make all reasonable efforts to implement all of the criteria and requirements" of the ergonomic design criteria. If a design requirement was to be compromised, the supplier had to so inform DaimlerChrysler and the matter would be reviewed to a conclusion by a DaimlerChrysler ergonomics representative.

DaimlerChrysler's e~onomic design criteria are available at http://www.docstoc. com/docs/25321410/150-ergonomic-design-criteria. The criteria may be downloaded for personal use or business use.

GENERAL DESIGN AND PURCHASING GUIDELINES

Addendu~ A to this chap~er is a combination of design and purchasing guidelines currentlr m use: Not~ agam that design specifications were developed that became purchasing spec1ficauons. The document is presented here as a reference from which engineering personnel and safety professionals can make selections and add subtract, or _alte_r item~ to suit location n_eeds. It would be inappropriate to implen:ent these gm~elmes w1_thout study and adJustment to reflect the hazards and risks inherent in a particular enuty . . Ado~tion. of a modific~tion of the guidelines will usually require persuasive

di~cus~10n w11h_ the p~rchasmg staff. Getting a procurement process as outlined in the gu1delmes applied will require a culture change in all but a few organizations. Safety

oes1GNI N G AND WRITING SAFElY SPECIFICATIONS BEYOND THE LEVEL OF STANDARDS 405

r 1·onals must understand the enonnity of what is b~ing undertaken when they pro1ess 'fi . . 1 d d . bave safety spec1 cations me u e m purchasing documents when that is not trY tourrent practice. Nevertheless, the productivity, risk reduction, and waste-saving tbe c th 'd b · · h t,enefits of a process at av01 s nngmg azards and risks into the workplace cannot be refuted. . . . . . .

The Guidelines begm with sections on general safety requirements, machine arding, industrial hygiene, ergonomics, machine and process controls, and

g\ironrnental impact/hazard evaluation. Section 8 sets forth a procedure for which en · "U thi d the instrUction 1s: se s ocument as a guide whenever purchasing new (or modifying exis~ng) e~uipment.':

Major parts of this section deal with codes and Standards, equipment/fixture design; mechanical design and construction, electrical design and construction, pneumatics design and construction, software, and machine guarding. ·

These guidelines are quite broad. They relate to occupational safety and health, environmental concerns;· productivity and avoiding events that result in business interruption.

DESIGNING AND ·WRITING SAFETY-SPECIFICATIONS BEYOND THE LEVEL OF STANDARDS

In the safety standards writing process, it is common for contributions to be made by many participants, and compromises are made in the deliberations to accommodate the variety of views expressed on the subject being considered. The result often is a standard that includes minimum requirements. The following appears. In Chapter 12: Provisions for Risk Assessments in Standards and Guidelines.

A supplementary and advisory document to SEMI S2 (Environmental, Health, and Safety Guideline for Semiconductor Manufacturing Equipment) is titled Related Information I - Equipment/Product Safety Program. It makes an inter- esting statement, cited below, about the need, sometimes, to go beyond issued safety standards in the design [and purchasing] process.

Compliance with design-based safety standards does not nece~sarily ensure adequate safety in complex or state-of-the-art sys

1 tems. It often is necessary to

perform hazard analyses to identify hazards that are specific with the, system, and develop hazard control measures .that adequately control the associated risk beyond those that are covered in existing design-based standards.

1\vo subjects COJlle to mind that encourage designing beyond compliance standards. Systems designed in accord with OSHA's lockout/tagout and confined space standards may be error-provocative.

' Assume that an electrical system is designed to OSHA lockout/tagout require- ments and to the requirements of the National Electrical Code but that the distance workers have to travel to lockout stations is, in their view, too far and burdensome.

I

406 THE PROCUREMENT PROCESS: SECTION s.1. 4 OF 210

I . ...n: t 'that sometimes workers will not follow the·written standard t IS a near ce~ uun y · . ti. eci""es If the system's·design and the purchasmg contract merely opera ng proc ..... . . ,

say "Meet OSHA requirements," the •result could be an error-provocative sy~tem. S · · ·hasi·ng (construction) contracts that confined spaces should be • aymg m pure . . . designed to meet OSHA's standard may also result ~n creating error-provocative situations. An appropriate goal is, first, to to des1~n out confin~ spaces, and then consider the safety entry and exit needs m the·des1gn process where confined spaces must exist. · · ·

CONCLUSION

Too much stress cannot be placed on the significance of the procurement provisions in Zl O and the benefits that will derive from their impleme.ntation. It stands to reason that if the purchasing process limits bringing hazards and risks into the workplace, the probability of incidents resulting in injury or illness will be diminished. That's what 210 is all about: ''To reduce the risk of occupational injuries, illnesses, and fatalities."

Since very few organizations have processes in place that comply with ZlO's procurement provisions, safety professionals a:re faced with:an enormous task as they attempt to convince managements to adopt: those provi&ions. Surely,. undertaking to do so is a worthy and noble task. Although Addendum A to this chapter is lengthy, it is recommended that safety professionals read it to gain an· appreciation of how extensive design and purchasing specifications can be and how they can serve well to avoid bringing hazards and risks into,th~ . .workplace. Also, it must be understood that design -engineers may not agree with some.of the specifics included in the guidelines and would write different safety-related specifications. .

Addendum B is a find. It is brief but is included because of the entity that issued it. The purchasing guidelines developed at the University of Wollongong are an excellent resource and highly recommended.

REFERENCES

ANSYAIHA 210-2012. American National Standard, Occupational Health and Safety Management Systems. Fairfax, VA: American Industrial Hygiene Association, 2012. ASSE is now the secretariat: Available at https://www.asse.org/cartpage.php?link=i10_2005.

ANSYASSEZ590.3-2011. Prevention Through Design: Guidelines for Addressing Occupational Hawrds and Risks in Design and Redesign Processes. Des Plaines, -IL: American Society of Safety Engineers, 2011.

Ergonomic Design Criteria. DaimlerChrysler. http://www.docstoc.com/docs/25321410/ 150-Ergonomic-Design-Criteria.

OSHA. Summary of ~SHA Permit-Required Confined Spaces Rule. The rule citation is 29 CPR 1910.146. Avadable at http://www.dol.gov/elaws/osha/confined/PRCSGEN.asp.

OSHA. General Environmental Controls. Standard Number 1910.1 47_ Titled "The Control of Hazardous Energy (Lockout/fagout)." At http://www.osha.gov/pls/oshaweb/owadisp. show _document?p_id=9804&p_table=STANDARDS.

REFERENCES 407

EM1 sz-0706, Environmental, Health, and Safety Guideline for Semiconductor Man iifacturing S Equipment. San Jose, CA: SEMI (SeJ!Uconductor Equipment and Materials Inte~onal), 2006.

(Re/aled Information I: Equipment/Product Safety Program is an adjunct to these Guidelines.) WHS ['urchasing Guidelines. University of Wollongong, New South Wales, Australia Available at

http:/tus.yhs4.search.yahoo.com/yhs/search?p=HRD-WHS-GUI--070.9+WHS+Purchasing+Gu ideJines+ZO 13+&hspart=att&hsimp=yhs-att--001&type=att_lego_portal_home.