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Mitigating the Risks of Extra Hazardous Work
Contributed by Brandon Hogan, P.E. - President & CEO of H+M Industrial EPC
At H+M, we follow the mantra “Inspiring a Lifestyle of Safety” and encourage safety in all daily activities. A Safety Lifestyle follows you home from work and spills into your personal life. Whether the task is doing yardwork or putting a phone away while driving in the car, being thoughtful about each activity is essential. At work, there is an embedded safety focus at each stage of every project: beginning, middle, and end – won or lost.
H+M safety programs include an observational program called the "Good Catch Program," our behavioral component that we call our "Take It Personal, T.I.P. Program," and a critical hazards identification and mitigation program named "Extra Hazardous Work Program" (EHW). Each program is good in and of itself, but we believe that it takes all three, working together, to provide a comprehensive way to identify and prevent injuries.
One of my proudest achievements at H+M is creating and implementing our Extra Hazardous Work Program (EHW), which I believe is an industry best practice. Our safety and operations teams worked together to develop it and began using it about four years ago. We have successfully conducted several hundred EHW processes. I believe it has contributed significantly to our Recordable Rate of Zero in 2021 and no lost work time in many years.
What is the Extra Hazardous Work Program?
The EHW Program identifies and mitigates the risks for the routine construction activities that we perform that have the potential for severe consequences to personnel and property. We maintain a list of the ten activity categories that trigger the EHW process and rigorously test the job for them at several project stages: Bidding, Planning, and Execution.
At any point in a project that an Extra Hazardous Work activity is identified, a detailed Safe Work Plan is created by the project team and approved by our Director of Safety and our Director of Construction. To fully close the loop, the EHW categories are identified on our daily JSA forms, with the requirement to stop work if an EHW activity is identified that does not yet have a Safe Work Plan. This enables clear communication of when and how hazardous activities will be performed and breaks down communication and decision-making silos between management and field activities. The activity categories include:
- Commissioning: Before work beings, verify whether the site requires cleaning, flushing, or operation of client valves and equipment.
- Confined Spaces: A qualified rescue team must be on-site for certain types of confined space work.
- Demolition: This addresses any explosive or cutting work done to dismantle existing structures.
- Electrical: Key risk factors are overhead electrical lines with voltage above 50 kV and live electrical equipment.
- Energy Isolation: Maintaining pipeline and other conduit integrity is critical to preventing catastrophic events.
- Environment: Plans must be made to limit exposure to asbestos and other toxic material.
- Excavation: Excavations deeper than four feet must include proper shoring methods to prevent structural collapse.
- Falls: Guidelines exist for any work performed directly over the water.
- Flammables: Take caution when the work scope involves temperatures near ignition points for combustible elements.
- Lifting: Special policies are in place for cranes using more than 75% of their capacity and for the usage of multiple cranes and operations over live electrical lines.
Why was the Extra Hazardous Work Program Created?
The EHW Program was created to fill a gap that we saw in our safety programs at the time, around the management of and visibility into potentially dangerous tasks performed at various sites. Our clients all have high expectations for safety, but we find different levels of requirements and oversight from site to site. Therefore, H+M needed to develop a way to ensure our people and clients remained safe, independent of the client's safety processes.
Experienced field and safety supervision have always been a minimum requirement, but we wanted a system to identify and apply expectations for high-risk activities consistently. In any contracting company with construction crews working in multiple locations, relying on supervision and experienced craftsmen to be the main line of defense leads to various levels of communication and judgment calls unless expectations and processes are clearly defined.
Is it Worth It?
Our EHW process is used for every single construction job we perform. It is a critical piece of who we are and a driver of our culture. It takes extra resources and costs to sustain and requires consistent commitment from H+M employees and our clients. Despite this, I am certain that the cost of not doing it is higher. So yes, it is worth it. It is one of the best programs we have, and I’m proud to be a part of it.