These are not good reasons for a safety program and are generally just poor excuses. I have never been a "by the book" safety person, but have always explored ways to develop a practical approach. Let's face it - you are not in the safety business, you are in the commercial diving business. Safety should enhance your profitability, not drown it.

As a safety consultant, I have had the opportunity to work with both technical and management personnel in a diverse group of trades. This has permitted me to hear their views and witness their approaches to company safety efforts. The process by which some programs are developed is flawed. Upper management generally decides to implement safety policies and rules and then attempts to enforce them on employees. Some employees never fully understand safety goals of the company because they are conditioned to follow the rules or face some form of punishment. Following this process, good intentions become controversial, confrontational, and ineffective. It takes a long time to develop a culture and even longer to change one.

A working program is a team approach that is supported by management and employees alike. To be successful, there must be open communication and input from all members of the team. And you must start backwards! Don't rip this page out of the magazine yet. I speak plain Southern that is easy to understand. Read on, because there is a method to my madness.

Get Out of The HR Department
Safety programs cannot survive in your diving company as part of the Human Resource Department. This is an old trend from the days of the "brown shoes management" style. Being from the South, I can visualize an old "sweatshop" textile mill along a river, complete with a water wheel and an irate HR director enforcing employee rules and safety.

Sorry, but this dusty approach no longer works. HR personnel are a very necessary part of any company and are to be commended for the work they do. Indeed, we need these "legal eagles" to keep us in compliance with the various employment laws of today. We must have employee handbooks that explain rules about vacations, overtime, medical leave, etc., but safety must be integrated into operations. The individual who facilitates your safety program should report to the operations manager and make all reports available to top management.

I am a firm believer in management by walking around. This is where the backward approach to safety begins. How do you build a safety program if you do not know what goes on in the day-to-day operations of your organization?

When I began working in safety, I was fortunate to have a background in construction and several years of commercial diving experience. Also, being a tall 5-foot, 6-inch giant and weighing in at a whopping 165 pounds, I decided it would be best if I could figure out a way to build a safety culture instead of showing up in the field to enforce rules and regulations!

Getting to know company employees and their daily responsibilities will enable you to tailor a safety program that is a good fit for your company. There are many safety consulting firms that are happy to sell you one of their "canned" programs and attempt to adapt it to your operation. Do not waste your money with consultants who know nothing about commercial diving. Get out into the field and your shop and scope out the operation. Inform employees that a program is being developed and ask for their comments and input. Take interest in their safety concerns but stay focused on the issue of safety. Do not let conversations become general grumbling sessions.

Employee involvement is sometimes difficult for managers to accept. But there are some valuable intangibles gained that can be very effective in your safety program. A safety program, as any other company program, causes change. People are resistant to change, but if they have a part in making changes, they have ownership in the program.

On a daily basis, your employees are in the best position to improve quality, production, and safety in your operations. Develop safety practices, not rules and regulations. Compile them into a working safety manual that will be an aid to your employees. Provide them with the right support. This is true management at its best. Without management support, your safety program is merely arranging deck chairs on the Titanic.

New Titles
When I am developing a safety program for a client, I always inform their employees during a group meeting that each has a new title. They all are now safety directors. I give them this title without consulting their management first.

While working as the safety director for a large general contractor, I traveled by helicopter to distant projects. We had a good pilot. I liked this guy and I trusted him. He made a statement on one of our flights that I have never forgotten. He informed us that if we saw other aircraft in our flight area, to make him aware of it. He said, "I've probably already noticed it, but let me know anyway. Up here, we're all pilots."

Several years ago, in my hometown, two welders were burned to death on a construction project. They were up working from a scaffold when welding sparks ignited waterproofing material on the side of the building at ground level. Unfortunately, they were unable to escape.

I inquired about the tragic project from a friend of mine that worked for a subcontractor on the site.

He stated, "I do not know how it happened. The contractor had a couple of guys wearing red hardhats that walked around the site daily looking for safety problems."

Instantly, it became clear to me that everyone on-site became comfortable with the "redhats" watching their backs and no one posted a fire watch during the welding operation.

Do your employees wait for a safety inspector to get out to their jobs? Do your employees fail to report hazardous situations to their supervisors because they think they do not have authorization to act in that capacity? In commercial diving, we are all safety directors.

The Team
In any business, there are external and internal customers. External customers are your clients, OSHA, the US Coast Guard, and your insurance carrier. The internal customers are employees of your company.

In a successful safety effort, everyone must treat other employees as customers. Are your employees provided with safe and workable equipment that is properly serviced by a maintenance program? Are they provided with instructions for the tasks they are to complete and do they receive necessary safety training? Do you have personnel that are knowledgeable and properly trained to act as competent supervisors? Are your employees instructed about the importance of work quality and safety as it relates to fellow employees and the success of projects?

When you start a safety program by the backward approach, you must make a commitment to your employees and they must make a commitment to you. The program starts with field and shop operations and success will continue with support and encouragement from management. Employees will quickly recognize a safety facade and will question the seriousness of management for safety support and eventually about any other corporate improvement programs.

I recently worked for a small dive contractor on a job where we were to make a penetration from inside a pump station building to videotape pump impellars and remove silt. The company had a safety manual that was copied from another diving contractor. The owner talked a good story and I believe he had good intentions, but some things in the field raised some questions about his safety dedication. I noticed that the regulators on the bail-out bottles were seldom, if ever, removed from the tank valves. I inquired about their methods for assuring the quantity of air in the bottles. I was quickly informed, "We check those tanks before every job." How long does a job last? Weeks? Is it a big problem to gauge the bottles daily?

Since this was a penetration dive, I removed one of the regulators to inspect it. I found the regulator inlet filter clogged with wet mud. When I turned on the tank valve, a large amount of air leaked around the o-ring. I removed the o-ring and it crumbled in my hand. The "dive station" was the compressor trailer parked downstairs outside the building. We were able to bring the dive radio up to the point of diver entry by using a long extension cord, but there was no way for the tender to monitor the air supply delivery pressure. There was no gauge, air console, or volume tank with gauge at the point of diver entry. The umbilical went all the way back to the trailer.

Not my idea of diver safety or teamwork.

I once worked on a potable water project with a company that had a nice equipment trailer complete with generator, heat, air conditioning, a dressing area, and an office with a video console with multiple recorders and monitor screens. Life was good.

Then I walked out of the trailer.

Connected between the compressor and the volume tank was a cheap, plastic, quarter-inch diameter pneumatic tool hose from a home improvement store. This was definitely the place for a good solid hose whip made up of divers hose and heavy brass fittings.

I am not a "knee-jerk" reactionist and I am not surprised by these things. I see them all the time. I just question whether safety is really a priority. We are not judged by what we say as much as by what we do. Enough said.

No Overkill and No Traps
I once reviewed a rather wordy and exhaustive safety manual of an industrial contractor. It had been compiled by their former safety director who was an industrial hygienist. The binder was four inches thick and the contents were mostly copies of the OSHA regulations from the Code of Federal Regulations. There were a few useful sections, but mainly regulatory psychobabble and some safety information that was not pertinent to their operations. My first impression was, "Who reads this stuff?" After reviewing their accident statistics, it was obvious that no one read the manual.

A successful diving safety program requires a manual that is a working volume incorporating the ADCI Consensus Standards for your operations managers and supervisors to use. The contents must be a good fit with your services, operations, and trades. Key contact information must be included for emergencies. Company positions that are to act as competent persons in making decisions concerning safety, supervising certain hazardous operations, and providing training should be identified. Insurance loss control representatives will inquire as to who has these responsibilities.

The safety program and manual must be presented as a process by which the company operates. New-hire training, re-training, and equipment maintenance must be documented. This is a great defense in the event of an inspection by regulatory agencies.

It is very important to keep the program dedicated only to your operations. Developing programs that are not part of your normal operations can turn into a paper trail nightmare that provides no benefit to your company. You must know what is needed for compliance to prevent creating a trap for your company.

Payback Time
I once heard an employee motivational speaker make the comment that we all work for a radio station called WII-FM. This stands for What's In It For Me?

Good question. There are some real benefits for everyone from a backward safety program.

As the plan is developed in the field with the input of employees, the individual charged with safety responsibility can be developing a corporate safety manual for your company. This removes a great deal of work when it is time for supervisors to review the new manual with employees. The manual is a valuable sales tool to provide to potential customers and is good support at insurance renewal time provided that you have good loss statistics (and you will). Documentation of training is beneficial during OSHA and Coast Guard inspections.

When a new program is first established, sometimes employees will ask what the company will do for them if they are safe. I have never been an advocate for rewarding people for doing things that they should be doing anyway. I do not ever remember receiving a bonus check from the highway patrol for being a safe driver. But safe driving sure has helped my insurance rates. I get to spend the money I save for new fishing gear for my eternal search for the elusive King Mackerel!

The obvious rewards for employees are life, health, and the ability to work, not to mention that their employer will be able to bid work at more competitive rates and keep them busy. Savings from lower insurance rates can benefit employees in many ways, such as purchasing new equipment, retirement plans, profit sharing, etc. Employees also benefit from having safe operable equipment that is maintained by a documented program. This is "what's in it" for all of us.

So, there it is, the backward safety program. Forget about enforcing rules and regulations. Start in the field and your shop and develop company practices and integrate them into daily operations and a company safety manual with reference to the ADCI standards. Have realistic expectations as your program develops. Do not expect your safety facilitator to become a walking code book, but rather someone who has knowledge of the safety resources available.

The ADCI has done the homework for you by evaluating the OSHA commercial diving regulations. A tremendous amount of work went into the development of the ADCI Consensus Standards. Build your program on this effort. A culture of safety will begin to grow. Your management and employees will be "talking the same language" and you will be able to identify those who are not. It will be very visible to clients, regulatory agencies, and insurance carriers that you are doing it right.

To my underwater brothers - safe diving! UW

Steve Pfaff graduated from commercial diving school in 1976 and later earned Associate of Arts and Bachelor of Science degrees. He is a US Coast Guard licensed captain and an ATF explosives licensee. His company, Aquatic Technical Services, specializes in providing loss control and safety consultation. Email him at spfaff2@earthlink.net