I've faced many challenges during my 25+ years of safety experience. There have been new Hazwoper regulations, ergonomics initiatives, DOT hours, OSHA inspections, labor disputes, NRC Licensing, in-house EPA inspectors, fires, explosions, emergency response evaluations, etc., etc., etc. Every step of the way, I was able to find ample resources, expertise and experience to help me succeed. There were regulations, interpretations of regulations, seminars, training programs, and (of course) consultants on every street corner eager to provide any and all needed assistance. There was even an overflowing toolbox of information to help us gain the commitment and support from upper management that we (safety professionals) must have as a core organizational value to be successful. That all changed for me in June, 1998, when I unexpectedly entered a safety "no-man's land". It's a world where there was little regulation, yet huge challenges. There were few available resources, yet endless opportunities. It was outside the day-to-day interests of OSHA, and wasn't a part of the comprehensive DOT control system, either. We call it DSD, or Direct Store Delivery, and it's a safety "no-man's land". This paper will describe some of my experiences, successes (and failures) and rovide a framework of components that can be part of a successful loss control program for route sales, service and delivery. So fasten your seatbelts.. here we go:
Working in the direct delivery and service (let's just call it "DSD") environment presents all traditionally recognized exposures such as slips, trips, & falls, lifting, sprains & strains, and all typical vehicle issues. These are all situations that can be managed using the normal training, coaching, and leadership methods, right? Well, before you make any assumptions, consider these additional factors:
In most cases, employees work unsupervised.
Turnover is usually very high, so a large percentage of new employees are always present.
Work environments change from minute to minute, everything from rain to rats.
The multi-tasking nature of work challenges the disciplines of even the best employee.
Ask the employee to do 16 hours of work in 10.
Add it all up, and you have numerous exposures in difficult environments, an employee in a hurry, and it all spells trouble. And for the most part, OSHA can't help. Their focus is on fixed facilities, manufacturing, warehousing, etc. If there are any doubts, read what they said in the Federal Register:
"When a worker is killed or injured in a motor vehicle accident on a public highway or street, OSHA is only likely to investigate the incident if it occurred in a highway construction zone. Likewise, when a worker is killed or injured in an airplane crash, a train wreck, or a subway accident, OSHA does not investigate, and there is thus no need for the employer to report the incident to OSHA."1