By Todd Plain
If you can brush your teeth without getting injured, then you can stay safe at a job site.
And if you're a small business owner, that's exactly the kind of advice you'll get from Marjorie McDonald, chief of safety at the U.S. Army Corps of Engineers Sacramento District.
"Every morning when you get up to brush your teeth, just stop and think about all the hazards," McDonald says. "There's probably a rug in front of the mirror you could trip on. Then, you could strain a muscle reaching for the toothpaste or bending over to pick up something you dropped. And don't forget to check the water's temperature coming out of the faucet!"
It's an example of a thought process and one McDonald likes to share with just about every small business owner when explaining how to do work with the Corps.
Thinking in these basic procedural steps mirrors the thought process necessary when putting together an accident prevention plan and activity hazard analysis--safety risk analysis documents required before any work begins on most Corps projects.
An APP and AHA are only part of an overall safety plan. And a safety plan is more than a teeth-brushing drill; it's a program that defines how businesses will manage their safety and occupational health during construction, and must be submitted and accepted by the Corps prior to performing any work.
A safety plan basically identifies four basic elements: the task, the hazards associated with the task, the corrective action necessary to mitigate those hazards, and what kind of training may be required to fulfill those corrective actions.
A "how-to" formula for developing a comprehensive safety plan can be found in a yellow book called the Engineering Manual EM385-1-1. It's a comprehensive set of safety standards first published in 1941 and is the go-to guide for Corps' occupational safety and health requirements.
McDonald said the EM3851-1 can show small businesses what the Corps expects from their safety plan, but can seem daunting to people who haven't used it before.
"We do a lot of in-person coaching for small businesses when we are able to," McDonald said. "On top of that, we conduct site assessments and document audits in order to help them achieve their safety goals."
Large and complex projects, such as the district's nearly $1 billion Folsom Dam auxiliary spillway project in Folsom, have dedicated safety staff who serve as points of contact for McDonald and her team. Because small businesses that want to work with the Corps may not have dedicated safety personnel or a separate safety office, McDonald says they really benefit from direct and personal contact on how to approach mandatory safety requirements.
This extra help is one of the reasons McDonald and other Corps staff invite businesses to the annual veterans and small business training and outreach conferences. For smaller businesses, coming to regional conferences allows them to meet face to face with federal government safety officers and small business specialists.
Michelle Stratton, small business chief for the Sacramento District and the person who started the annual conferences, agrees. "It's especially important to reach the small business group since over half of the Corps' construction work is fulfilled by certified small businesses, like woman-owned small businesses and service-disabled veteran-owned small businesses."
With an average of $200 million awarded annually to small businesses by the Sacramento District, small business contractors are a vital part of the Corps' missions. Those missions today fall in four broad areas: water infrastructure, environmental management and restoration, response to natural and man-made disasters, and engineering and technical services to the Army, Department of Defense and other federal agencies.
With such broad mission areas and varieties of occupational hazards, sometimes keeping concepts as simple as brushing your teeth can be a good way to start talking about workplace safety.
"Educating small businesses about safety is just as important as educating our own employees," McDonald said. "Every action that occurs in safety and occupational health doesn't just belong to the small businesses--it belongs to the Corps of Engineers."