In the relatively static and well-defined operational conditions of a wide variety of manufacturing facilities, a broadly-trained Stop Work program can be one of many health and safety policies and procedures. Generally speaking, the Stop Work is applied when the following conditions exist:
- Conditions or the work plan changes
- You “think” a hazard or an unsafe condition may exist
- Others who were not involved in the work planning join the work team
However, in the more dynamic working environment of the emergency response, the misapplication of Stop Work has the potential of seriously compromising the objectives of the Site Specific Safety Plan (SSP) that is developed, administered and implemented by the Safety Officer function. In this setting, according to OSHA’s Hazardous Waste Operations and Emergency Response standard [1910.120(q)(3)(vii)] , “the individual in charge of the ICS shall designate a safety officer, who is knowledgeable in the operations being implemented…, with specific responsibility to identify and evaluate hazards and to provide direction with respect to the safety of operations…”. In addition it states, [1910.120(q)(3)(viii)], “…when activities are judged by the Safety Officer to be an IDLH {Immediately Dangerous to Life or Health} and/or to involve an imminent danger condition, the Safety Officer shall have the authority to alter, suspend, or terminate those activities. The safety official shall immediately inform the individual in charge of the ICS of any actions needed to be taken to correct these hazards at the emergency scene”.
In a recent response, the Stop Work concept was broadly disseminated (response wide) through a training program in which the Responsible Party explained that the Stop Work authority is granted to everyone involved in the effort. The intent of the training program attempted to establish in every responder’s mind that stopping the work should not be seen as a negative but that it may be the last opportunity to prevent an incident.
The consequences of this approach if misapplied can seriously compromise the safety mission as set forth in the ICS system—a management approach fully understood by experienced response personnel at all levels of operational responsibility: management, supervision and technician. Multiple instances of Stop Work situations in the response, not by responders but by Responsible Party personnel not charged with the Safety Officer’s role, can result in a lack of respect for the safety mission and for those charged with implementing the SSP, especially “stops” for inconsequential or minor issues or for issues that do not involve significant consequences or imminent danger. Just as important, it creates unnecessary confusion and delay and portrays safety as a nuisance activity.
Experienced and professional Safety Officers, used to working on spill responses within a clearly defined management system, do not exercise their Stop Work authority to prove a point, show off knowledge, or simply to demonstrate that authority. Behavior of that sort is, in fact, contradictory to the Safety Officer concept OSHA set forth in 1910.120 and the command position of Safety Officer. The Safety Officer has the authority to Stop Work, but only in the context of understanding the job at hand and its potential hazards along with good communications and involvement in the job or job preparation. The Safety Officer represents all—workers, supervisors, the management team and the public. It is a role that requires judicious action taken with deliberation and care.