General – Malta Safety Lens

The AED – A Real-Life Rescue

December 7, 2022December 9, 2022 Franklin GrimaLeave a comment

The Automatic External Defibrillator

In 1978, the first portable Automated External Defibrillator (AED) was designed. This was the first design which allowed the AED to be used in emergency cases by minimally trained people. Since then AEDs have been researched and evolved into extremely light, user-friendly equipment that can be used anywhere, by anyone.

AEDs automatically detect whether the person (in layman’s terms) is alive, provide CPR instructions and decide on the provision of a shock. When the AED is used within a minute of the cardiac arrest, the survival rate is 90%. However, time is of the essence as the survival rate decreases by 10% every minute. Furthermore, it records the data and heart rhythms at the time of its use, assisting medical practitioners in the diagnosis of any heart conditions which may be present.

AEDs in Malta is becoming more popular. Local councils, clinics, schools, football grounds and shopping Malls are some of the sites which are most likely to have an AED.

An application called “AED Malta”, shows a number of AEDs which has been registered with the NGO running the application. The application shows the location of the nearest AED in your position.

Subsidiary legislation 424.13, regulates the requirements of first aid at the workplace in Malta. This legislation is quite simple, outlining the need for first aiders, a first aid room and first aid boxes, all depending on the number of workers employed. However, there is no mention of AED requirements. The decision to implement one is up to the company’s discretion and the H&S practitioners managing the safety provisions at the workplace.

We spend 8 hours a day at work, not at places of service and recreation, that’s one-third of our lifetime. And where we need it most, the AED might not be readily available.

It is a significant investment to procure the AED, train the personnel to use it and upkeep both the training and the equipment. However, I believe it is more important when a person survives an emergency requiring its use and returns home.

The following picture is data extracted from the use of an AED, showing the moment when regular heart rhythm was established by delivering CPR and using the AED following a sudden cardiac arrest caused by an irregular heartbeat. I was involved in this event, and within 5 minutes, due to the availability of the AED, and trained personnel, we were able to save this person.

AED Extract - Malta Safety Lens — AED Extract – Malta Safety Lens

I am sharing this information to raise awareness of the importance of AEDs at the workplace, and to show that they do actually save lives.

Doesn’t the above event justify the investment in an AED or several AEDs in bigger workplaces?

Put forward the idea to management, share this event, get approval, and have one at your workplace. Hope the need for it never arises, but if it is required, it’s invaluable to have one.

Safety Glasses

September 7, 2022September 7, 2022 Franklin Grima2 Comments

“In-Nuccalijiet”

The human eye is one of the most vulnerable and exposed organs in our body. Most of the other organs are protected behind the human skeleton, however, the eye only has the eyelids and the eyelashes as natural protection. In conjunction with our natural reflex to blink our eyelids protect our eyes from dust, wind, intense light and small flying objects such as insects.

However, this protection is natural and only protects against natural sources of harm. At the workplace, we have several industrial processes which bypass such natural protection due to their excessive speed, forces, radiation and/or light. It is often observed that grinding, rock breaking, metal work, polishing, lathework and other work processes which may create flying particles or intensive radiation/light (such as welding) are carried out without the required collective protection.

Usually, the first thing that comes to mind as protection for the eyes is safety glasses. However, as per the hierarchy of controls in health and safety, these are the last item to consider when implementing control measures. Safety glasses offer only individual protection and should they fail, they do not fail to safety, meaning the individual will be harmed. Other collective protective measures should be considered prior to the provision of safety glasses.

We’ll be using a pipe-cutting machine as an example to outline what some of these measures are.

Elimination: Is it possible to remove the process of using the pipe-cutting machine? For example by purchasing pipes of the correct length?
Substitution: Is it possible to change your equipment or process to use lesser hazardous equipment? Will a hand operated pipe cutter do the required work?
Engineering Control: Does the machine has the required guards to make sure that in case of failure the hazard does not reach the user? Can the machine be completely isolated from the worker by enclosing it?
Administration controls: Is the pipe cutting machine subject to a periodic maintenance regime? Have the personnel been trained on the use of this equipment? Are safety signs posted and rules implemented?

After considering the above, PPE is to always be implemented when using industrial high-risk equipment. All the above-mentioned measures reduce the risk significantly, but some residual risk will always remain as we can never be completely safe and this is mitigated by PPE, more specifically safety glasses in this case.

Different types of eye protection are available depending on the hazard one needs to protect against. Amongst others, these include safety glasses, safety goggles, hood and face shields.

The type of eye protection made available to the employees should be based on a risk assessment, based on manufacturer guidelines and certification.

The main types of certification for safety glasses are EN166 (European standard) and ANSI Z87.1 (American standard). Such certification would be outlined on the safety glasses frame and also on the lenses.

_{Quality & certification | Bollé Safety (bolle-safety.com)}

For employees who wear prescriptive glasses, there are two options, either safety over-glasses or prescriptive safety glasses. Over glasses, as the name implies, are safety glasses which are designed to be worn over normal prescriptive glasses. Prescriptive safety glasses are specifically designed safety glasses which have integrated certified prescriptive lenses.

Regardless of the type of safety glasses chosen, it should always be ensured that these are manufactured to the previously mentioned standards. I have come across situations where suppliers provide frames which are certified but fitted with normal non-certified prescriptive lenses. Personally, I do not accept or recommend these types of glasses within my workplace and practice the rule “no certification means not allowed”.

For any equipment to be certified, this has to be manufactured according to a standard, as such the only local shops which provided these prescriptive safety glasses are PPE importers who order the glasses directly from the PPE manufacturer.

When a grinder wheel is spinning up to 2000 RPM, all safety features fail and it detaches, you want to be sure that the personal protective equipment provided to the employees is certified as safety equipment. PPE is always the last line of defence.

_{(Picture by Gillian S: Safety Glasses Save Lives (bulksafety.com))}

Have a look at the safety glasses used by yourself or at the workplace, are these adequate and certified? Are the employees who use prescriptive glasses offered the same level of protection as all other employees? Are you making use of safety glasses to reduce the level of residual risk?

Management of Change

June 26, 2022July 24, 2022 Franklin GrimaLeave a comment

“L-Immaniġjar tal-Bidla”

Articles, blogs, entrepreneurs and business leaders all state that change is required for a company to grow and maintain a competitive edge against its competitors. Changes may occur in the product being provided, the company’s branding, management of people and technological changes. Such changes can promote the company’s profits, increase employee engagement and growth, and lead to a safer workplace. However, they can also lead to uncertainty, additional financial costs, reduced performance and the introduction of new hazards and risks.

The effectiveness of a change depends entirely on the management of the said change.

Management of change is a process by which the changes are systematically analysed to identify inherent environmental, health, safety and business risks which may be introduced in the process of implementation. It is so important in health and safety that it is an identified clause required to be implemented for ISO45001 Occupational Health and Safety Management Systems certification. Furthermore, although not mentioned directly in legislation, the General Provisions for Health and Safety (S.L. 424.18), places an obligation on the employer to evaluate the risks arising from equipment, chemicals, work processes and the workplace. As such, it can also be said that a procedure for the management of change helps the employers stay compliant.

Management of the change process would usually involve the following steps:

A request for a change
An evaluation of risks and hazards related to the change
An evaluation of compatibility with current work equipment, infrastructure, chemicals and work processes.
Identification of any changes required
Training on the change and
Implementation

A concept which goes hand in hand with “Management of Change” is “Safety by Design”. Which, as defined by Worksafe is “the process of managing health and safety risks throughout the lifecycle of structures, plant, substance or other products”, perfectly illustrated in the picture below.

Should a change not be managed correctly, and safety not be given importance at the designed stage, the costs to remedy the risks introduced and the possibility of harm increase significantly.

When considering environmental, health and safety, quality and business requirements, change is not a matter of procuring and implementing equipment. It requires time, careful planning and proper evaluation. The personnel leading the change must make sure that the following pitfalls are avoided:

Lack of communication and consultation with the stakeholders who may be affected by the change
Tackling a big or several small changes all at once without the adequate resources
Think that the change will affect only its immediate surroundings, without giving due consideration to secondary equipment, processes, legislative and standard requirements.
Beliving that the change has been fully implemented, without proper long-term monitoring of its effectiveness.

In today’s fast-paced industry, change is no longer optional to stay ahead within your sector but is most often imposed by legislative changes, technology advancements and stakeholder requirements. As such, having a robust system to manage such changes is as important as any other day-to-day procedure required to keep the company afloat.

Out of sight, out of mind (heart)

February 8, 2022July 24, 2022 Franklin GrimaLeave a comment

“Il-bogħod mill-għajn, il-bogħod mil-qalb”

When I was young we used to play a game called “dahar ma’ dahar” (back to back) at school. We used to sit 5 kids in a row with papers attached to our back. The first kid would draw something on the back of the kid in front of him. The kid in front would in turn draw the same thing on the kid in front until all the kids draw the image.

The image always changed from one kid to the next. The purpose of this game was to teach us the importance of clear and correct communication and to always question where the information is coming from.

This is exactly what happens when a health and safety practitioner engaged in a company does not have a direct line of communication with senior management, the people who have the ultimate responsibility of health and safety and the ones who have the authority and power to implement change within a company.

The same would apply if the health and safety practitioner does not have a direct line of communication with the workforce. They would not be hearing the problems, concerns and good practices from the horse’s mouth but these would be passing through several lines of communication prior to being received by the health and safety practitioner, as such the practitioner may not be working with the correct information.

This may result in a situation where the correct and current information is out of sight from the employer, as such no action is taken on persisting health and safety issues.

The General Provision for Health and Safety at Work Places states that the employer must designate competent people to assist them in the undertaking of their health and safety duties. Although there is no mention of who this person is to report to, if this person is an employee ranking low on the company’s organisational chart when their message is passing through the different employees to arrive at its final destination to the managing director or CEO, their message will be tarnished with every other person’s opinion and personal/professional agenda along the way.

ISO45001, a health and safety management standard, requires organisations to hold management reviews so as to review the company’s health and safety management system. Several items are to be reviewed during this review, which include, opportunities, risks, legal compliance, trends in incidents, reports and communication from the workforce and continual improvement.

Such reviews ensure that management is never too distant from the reality of the health and safety culture within the company.

Appointing a competent person to assist you in fulfilling health and safety law requirements is a legal requirement. Most of the time, the responsibility of the same legislation lies with the employer.

Should employers feel comfortable that their competent person fulfilling the legal duties pertaining to their position as the employer, is answering to another or several other managers before they are aware of any item identified by the competent person? Should they consider holding monthly management reviews so as to ensure that they are always aware of the current situation of health and safety within their company? Wouldn’t this ensure that health and safety are given the attention required and that the current level of health and safety within the organisation is improved?

Bonus PaterFamilas

December 19, 2021December 19, 2021 Franklin GrimaLeave a comment

Good Father of the Family

Bonus Paterfamilias, is a phrase that I personally use quite often in discussions that concern employees wellbeing, decisions that may affect their work or quality of life and decisions which may have a business impact.

But what does this mean? Where is it used?

Bonus paterfamilias direct translation to English is “Good father of the family”. Bonus Paterfamilias is mentioned in the legal system of several different countries including Malta, European, Italian, French, Roman and Austrian Law. It is also mentioned in Maltese, UK and European Court Judgements. As described in the paper by Baldacchino (2016), Bonus Paterfamilias is not a real person, but more of a standard of a person in power who acts with compassion, skill and prudence to his subordinates.

This “standard” reminded me of McGregor’s Theory Y (participative) management style, whereby management sees employees as highly enthusiastic to work, self-motivated and one of the most valuable assets in the company.

McGregor Theories — ^{User:ZellmerLP SVG, CC BY-SA 3.0 https://creativecommons.org/licenses/by-sa/3.0}

In Maltese Civil Law it is stated that a person shall be deemed to be at fault if, “in his own acts, he does not use the prudence, diligence, and attention of a bonus paterfamilias”

Anton John Mifsud (2009) made reference to a Court of Appeals Judgement where workers were assigned to remove a winch at height using scaffolding to reach the work area and as a working platform. The director of the same company was supervising the works and had to temporarily leave the site. As such, he gave a clear order for works not to continue until he returns. During the time of his absence, the workers continues work, fell and sustained severe injuries from a collapsed scaffolding. The director was initially found guilty because the court stated that the instructions given not to continue work cannot excuse him from his responsibilities as an employer.

However, when the director appealed the case, the Court of Appeal stated that the attention required from the employer is that of Bonus Paterfamilias and not of a higher degree. Since there was continuous surveillance and specific orders not to carry out works, the director could not be found liable for these damaged.

So why do I find this phrase helpful in the application of Health and Safety? These are the questions I ask myself when I encounter such situations:

Sun Exposure: If it is too hot in the summer to work directly under the sun……would I allow my children to play outside at midday or would I tell them to play at times where the sun is not as powerful?
Personal Protective Equipment: What if an employee is not wearing the correct PPE……would I allow my child to ride their scooter without a helmet? If they do, would I reprimand them in any way?
Covid-19 Commuting: If during the covid-19 pandemic, my child tells me he will be using public transport to go to their friend, will I let them?……Will I provide transport or will I tell them to meet them online (join remotely) ?
High risk works: Should my children be playing a sport which entails an amount of risk……would I continually supervise them and ask them to stop when I can’t stay there?
High cost processes and equipment: Will I incur a significant expense to my family if the same job can be the done in other means at a lower cost, if there is no other way will I buy the required equipment to make the household safe?

I dare to ask if we as health and safety practitioners always ask this question if we always think of Bonus Paterfamilias prior to giving guidance and suggestions. Wouldn’t we already be in compliance with most legislation and guidance?

^{Original version: NIOSHVector version: Michael Pittman, CC0, via Wikimedia Commons}

In layman terms, the law asks the employer to reduce the risk as far as reasonably practicable by following the hierarchy of controls, isn’t this what a good family father would do?

One would never expose his children to unnecessary risks, one would always risk access the activity prior to asking their children to participate, one would always talk and inform their children of the dangers and risks involved, one would always train their children in the activities they ask them to do and the last one would always be of an example in front of his family.

The Unsung Heroes

November 10, 2021July 24, 2022 Franklin Grima1 Comment

“L-Eroj Mhux Imsemmija”

On the 13^th of September, Deputy Prime Minister Dr Chris Fearne presented the Occupational Health and Safety Authority (OHSA) CEO with the commemorative coin “Heros of the pandemic”. This coin is being awarded to all health care workers and OHSA employees in recognition of their work during the Covid-19 Pandemic. Everyone is aware of the excellent work carried out by the health care professionals and the OHSA however very little information can be found on the work implemented by local Occupational Health and Safety Practitioners working independently or employed by companies to ensure the health, safety and business continuity at the workplace.

I made contact with a few of my peers to write this blog post about the roles and responsibilities of the health and safety practitioners during the covid-19 pandemic. As such I would like to thank amongst others, Daniel Cassar and Antoine Cutajar for their input and insights.

In multinational companies, work started way before the Covid-19 pandemic started in Malta. The health and safety departments of different countries started meeting beforehand to discuss how covid-19 is impacting the business and health and safety of the companies where the pandemic had already started. By doing so the companies which were in countries where the pandemic had not yet emerged could prepare and implement measures in anticipation of the coming issues. Such measures included a review of the current risk assessments, review of the cleaning regime, increasing the stock of PPE (both for the pandemic and usual business), segregation of shifts to ensure business continuity and the implementation of a Covid-19 Emergency Plan which included all the relevant measures. As guidance and legislation were still missing at this time, all decisions were based on risk assessments and research carried out on international guidance and legislation, by the same practitioners.

Online tools such as NextStrain are helping to track the spread of coronavirus in real time. Image credit - nextstrain.org — *Image credit – nextstrain.org*

Communication was key throughout all the stages of the pandemic. Practitioners in the industry worked with both management and the workforce to ensure that proper information was disseminated throughout the company. This was carried out by implementing training programs, online meetings, information bulletins and distribution of surveys. As a result of these communication campaigns, it was possible to answer questions and doubts from the workforce and prevent mass hysteria arising from false information popping up all over the internet.

Mental health and psychosocial risks were always being considered during the implementation of the emergency plan and the publishing of communication. The practitioners were aware that the way the information may be interpreted may give rise to occupational stress. Furthermore, although it was made sure that the companies were compliant with legislation and guidelines, suggestions put forward by other people which were “holier than the Pope” and other “measures” being implemented by third parties, not in line with research and guidelines, were not put forward to management or implemented. The reasoning for not implementing these suggestions was not always easy to explain, however, if the non-factual measures were implemented, the same may have had unnecessary business implications or negative effects on employees as the pandemic progressed.

File:Quarantine staff screening passengers in Shenzhen 2.jpg - Wikimedia Commons

As part of travelling risk assessments, the measures of different countries where people from multi-national companies were travelling to had to be reviewed. The health and safety practitioner made sure that only necessary travel was allowed, the risk to the country of destination was acceptable and that the travelling employee faced no surprises such as an unexpected quarantine and missed flights.

Later into the pandemic, when the governments started to ease off on restrictions, the health and safety practitioners needed to revise their risk assessments to ensure that such relaxation of measures are implemented accordingly. It was and still is, a top priority for the health and safety practitioners to ensure that the measures ranking high in the hierarchy of controls, such as social distancing, provision of barriers and cleaning, are not taken lightly and are still practised at the workplace.

The work of the health and safety practitioners served as an intermediary between the government who implemented guidelines and legislation, the management and the workforce. Legislation and guidelines were translated into layman’s terms and into different formats so that they can be understood by all the workforce and management.

The health and safety practitioner is not always the person seen in a high visibility vest and a white helmet at construction sites, in bigger companies they are usually the ones working in the background, preparing and implementing policies, drawing up risk assessments, carrying out research and preparing proposals and providing suggestions to the management so that adequate and wise decisions can be taken.

The Heat

June 25, 2021July 24, 2022 Franklin GrimaLeave a comment

‘Is-Sħana’

Following one of Malta’s hottest days when temperatures reached 40.2°C ⁽¹⁾, I felt that this month’s post has to be about heat exposure. How hot is too hot, what do the guidelines and legislation say and how to protect yourself against heat and sun exposure?

The OHSA aimed to answer the latter by publishing guidelines on work carried out in warm weather and in the sun⁽²⁾.

The publication starts off by stating that a comfortable temperature should be in the range of 20°C to 25°C. This range is also cited in the Compliance code – Workplace amenities and work environment issued by WorkSafe Victoria⁽³⁾. However, it is common knowledge that it may be impossible to achieve such temperature for outdoor workspaces in the summer. Working in high temperatures for prolonged periods of time can lead to a lack of alertness, tiredness and other heat-related illnesses such as heat stroke and heat cramps.

The OHSA document goes on to explain good practise which is to be followed by the employers and employees such as the provision of adequate ventilation, an increase of breaks, access to potable water, job rotation, and provision of adequate clothing and training. However, these are only guidelines and it is up to the employer to carry out a risk assessment to determine what is required to be implemented. Furthermore, the guidelines are somewhat vague…what is adequate clothing? The Skin Cancer Foundation states that clothing should cover as much skin as possible, and be loose and dark/bright coloured(4). However, due to lack of information, it is common to see construction workers wearing vests or no shirt at all.

What are other countries doing to combat this risk?

When it comes to temperature, it is very difficult to obtain guidelines and/or legislation from European countries. The biggest problem for EU countries is cold weather. In an approved code of practice published by the Health and Safety Executive a workplace minimum temperature of 16 °C can be found, however since hot weather is not common in the UK, the maximum temperature is not mentioned⁽⁵⁾.

In a document titled “Health and safety – time for change” published by The Trades Union Congress based in the UK, it is stated that 14% of workers’ safety representatives remarked high temperatures as a major concern. One would only imagine what this percentage would be if such a survey is carried out in Malta. In this same document, the TUC is calling for a maximum limit of 30°C to be set for workplaces⁽⁶⁾.

However, more fruitful information can be found if one looks at guidance and legislation published by countries with warmer climates.

The American Conference of Governmental Industrial Hygienists (ACGIH) set the threshold limit value between 25 °C and 34 °C depending on the activity being carried out at the workplace and other environmental conditions such as airflow and humidity⁽⁷⁾.

On March 26th, in the United States of America, the Asuncion Valdivia Heat Illness and Fatality Prevention Act of 2021 was introduced which aims to push forward the development of a safety standard for the prevention of exposure to excessive heat. The aim is to publish this standard within 2 years and is to include, amongst others, action limit values, medical surveillance, paid breaks and exposure monitoring⁽⁸⁾.

A country at the forefront of implementing legislation protecting workers from heat is the United Arab Emirates. A law banning outside work and working in the sun from 12:30 to 15:00 is enforced from June to September. The law is backed up by hefty fines and other administrative penalties for those found to be in breach⁽⁹⁾. In Malta, a ban on construction work is implemented in certain localities to protect tourism. What about protecting the workers from the sun?

In a country where public health warnings targeting high temperatures are common, where heat stress and long sun exposure are acknowledged as a serious problem by the chief of OHSA⁽¹⁰⁾ and where heat exposure was identified as a workers’ main concern in 2002 by the HSE in a report called ‘Perceptions of health and safety in Malta’⁽¹¹⁾ …. shouldn’t specific legislation regulating heat be published? shouldn’t we be at the European forefront in the implementation of innovative arrangements against exposure to heat and sun?

Category: General