Work Rules and Other Operational Controls
Safety standards are often thought of as technical in nature, taking the form of either performance or design requirements. But technical provisions are only part of safety regulation. Work rules, maintenance schedules, and other operational controls play an important role, especially in the kind of standards written by NFPA. To be effective, technical standards must work in tandem with operational controls. Sometimes, operational controls can even substitute for engineering solutions.
To more fully understand the distinction between engineering standards and operational controls, consider the example of safety standards for a hydraulic system. Safety standards could incorporate any of the following four types of controls. First, a technical performance standard might specify that the bursting strength of hydraulic lines be equal to or greater than four times the working pressure. Second, a technical design standard might require that hydraulic lines be equipped with safety valves to prevent loss of system pressure in the event of a ruptured line. Third, behavioral rules could be adopted instead of these technical solutions. For example, the safety standard might include the following operational control: the hydraulic system must be inspected
for leaks after each one hundred hours of operation. Finally, a work rule could be adopted requiring that hydraulic controls be checked every time the machine is started. These technical and behavioral approaches all provide possible solutions to identified hazards. The prevailing conception of safety regulation in the private sector generally excludes the latter two approaches. In response to pressure from business, ANSI formed a Safe Work Practices Task Group aimed at ensuring that "safe work practices are not included in the body of standards." This philosophy accounts for why the appendix contains important provisions in both NFPA standards studied. It also helps account for the storm of protest over housekeeping. Maintenance procedures (particularly housekeeping practices) clearly have a significant effect on safety, but the prevailing view at NFPA is that housekeeping should be left entirely to managerial discretion. Standards for almost any operational controls, even those intended to complement specific technical requirements, make private standards-setters uncomfortable. We try to avoid "'how to' standards," notes a committee member. The provisions of NFPA 61B that address operating procedures are vague and relegated to the appendix, where all provisions are couched in the disclaimer that "this Appendix is not part of the requirements of this NFPA document but is included for information purposes only." The same is true of NFPA 408 for aviation fire safety. Several committee members agree that training requirements are vitally important to the successful use of Halon extinguishers. The standard even includes a (vague) chapter on flight crew training, something quite unusual for the NFPA. More typical is what was relegated to the appendix: "Although not required by this standard, it is highly recommended that live fire training on representative aircraft fires be conducted for all flight crew members during both initial and recurrent training sessions." In contrast, public standards-setters embrace operational controls. The FAA tells commercial airlines "how to" do all sorts of operations and routine maintenance. The essence of the OSHA standard for grain elevators, the "action level" for housekeeping, is an operational control. So, too, are provisions on safety training, evacuation drills, and hot work permits.