Environmental Protection

Compliance Issues Arise with Pandemic Fever

The second wave of the H1N1 is spreading across the nation. Projections say that the H1N1 virus could cause 30-40% absenteeism among the workforce. This may make it necessary for co-workers or management to assume unfamiliar or less familiar tasks. Designating replacements and providing cross training can help prevent disruptions in workflow. And this cross training should also cover environmental, health and safety (EHS) training. Preparing replacement employees to cover new tasks without understanding EHS compliance is asking for trouble.

Of course, the first line of defense is training all employees on pandemic preparedness. Overall, the training should include general knowledge as well as prevention and response measures and your organization’s specific plans and protocols. Show employees the simple steps they can take to protect themselves, and if they do become sick, how to prevent spreading the virus to their co-workers. Sending workers home when they are ill will reduce the spread of the virus but increase the need for cross training.

The next step is to determine which operations are most vulnerable to increased absenteeism. For these operations, designate which workers will be cross trained as replacements and make sure they get trained on the specific job skills they will need. And again, don’t forget EHS training.

For example, employees who work with or around oil and oil handling equipment need to be properly trained on correct equipment operation and procedures. They also require SPCC training. So if you identify replacement workers for oil-handling employees, they will also need to be trained on SPCC.

Most employees who work outdoors, either always or occasionally require training on stormwater BMPs. If you name replacements for outdoors workers who have only worked indoors, they will require stormwater training also.

Shifting and training one worker to cover another worker’s tasks is not so difficult to do, but assuring that regulatory requirements are met adds another level to the cross-training process. Implement an EHS cross-training plan in advance so that you can keep your operations and facility running efficiently and safely.

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About the Author

Mike King is a partner of Excal Visual LLP.

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