In the past, I’ve written about familiarity blindness in terms of missing what I call “invisible environmental gorillas” in your facility.
In a nutshell, these are environmental issues at your facility that you simply don’t see because you’re at the facility every day. We are so focused on our daily tasks, including the demanding details of compliance, that we often overlook many issues at our facilities. Many potentially significant environmental issues are lost in the daily details and can blend into the background. These issues fall outside our daily focus, hidden by the demands of our many routine tasks.
The thing is… this familiarity blindness can also carry over into how you do your job… especially how to do it safely.
That’s why we advise our clients that they must always remember to provide their personnel with reminders relative to job performance with an ongoing focus on how to do each job safely. In other words, training, combined with an effective communications program to get your environmental, health and safety message across.
That’s the purpose of ongoing training – to refresh people on how to do things properly, identify safety issues that are constantly around us, learn how to work safely through them, and evaluate how to continuously improve our EH&S Programs and how we do things.
These refreshers, even for those very experienced, are so important because familiarity blindness takes effect when you’ve done the same job for a long time. Due to familiarity blindness, you, and everybody else in the facility can become complacent at certain job tasks. The next thing you know you’re telling yourself there’s no need to wear a hard hat in your facility because, in all these years you’ve never been hit on the head, so why bother?
That very day something hits you right on the head.
Familiarity Blindness and Top Blind Spots in Your Facility
Because of the many responsibilities that you have at your facility, it’s all too easy for facility managers to lose track of what EH&S requirements you need to keep track of. One issue we see that is quite often overlooked is permit management. It takes a lot of effort to determine if you need any permits at your facility, and after figuring that out, additional effort needs to be made to make certain that you obtain the correct permits. Asa result, we see many facilities “celebrate” after obtaining their permits. Sure, finally obtaining your permits is a reason to “celebrate”, but by no means does that mean your work is done. It is also important to maintain compliance with your permits. The easiest way to do that is to READ your permits. Permits contain a lot of important information and that information needs to be understood and followed in order to maintain permit compliance. We have found that many facilities get into permit compliance trouble simply because no one ever read their permits!
Also remember that your facility is constantly changing, whether it’s the raw materials you use, waste products produced, or processes employed. So, remember to keep track of those changes so that you can determine if any of those changes have an effect on your permits. As a result of facility changes, you need to determine if you have to obtain new permits or modify your existing permits.
Another often overlooked issue we see in facilities due to familiarity blindness is staying on top of storage areas, especially for waste materials and hazardous raw materials. This typically comes in the form of housekeeping issues where we see disorganized storage areas that are not well maintained. Sometimes we observe containers not properly closed and/or properly labeled. In some instances, we observe incompatible materials being stored and handled in common areas, and access to these areas is not restricted to only properly trained employees.
Facilities often let their housekeeping slip in that manner, which often leads to some serious issues. It’s also common to see that they’re not properly managing the waste they’re generating. Waste chemicals are left in containers in the wrong places, and that’s a serious problem even if it’s not a big quantity. Sometimes you simply come upon a drum that has no label or clearly the wrong label, and you can’t tell what’s inside.
Say there is some maintenance guy who’s been at the facility for years and years who, out of habit, collects used oil in an unlabeled bucket in his workshop. He’s not too worried about it. He knows what it is, and he eventually transfers that material to a drum that is properly identified as containing used oil for offsite recycling.
But then when he’s not there somebody sees the bucket and figures they’ll dispose of some gasoline or a solvent they have on hand in that bucket because it’s all waste material that will be recycled, right? Now, what the maintenance guy thought was recyclable oil no longer has the same makeup since the used oil now contains gasoline or solvents, which will cause an issue for the proper management and recycling of that material.
We see facilities get notices of violation for one waste material in particular - universal waste.
Here is something that recently happened at a facility we visited. Maintenance personnel were changing out fluorescent light bulbs, a universal waste. As a result, the spent bulbs are supposed to be placed into properly labelled containers and staged in a universal waste storage area in preparation for offsite disposal.
But in this instance, the maintenance folks figured that they would gather up all the spent bulbs and containerize them once all the changeouts were completed. So, as they moved each bulb, they leaned the spent bulbs against a nearby filing cabinet or against a wall. Well, soon enough, break time came along and they headed out to lunch figuring they’ll just take care of containerizing the spent bulbs when they get back. A regulator happened to show up for a spot compliance inspection while the maintenance folks were at lunch and the spent fluorescent bulbs were scattered throughout the facility. Unfortunately, a violation was issued.
I’ve even been to some facilities and observed a whole stack of bulbs sitting under a stairwell. Turns out they were planning to dispose of them properly after they changed all the bulbs in the building – and actually forgot all about them until I stumbled across them a year later.
It’s easy to overlook things – but frequent, short duration training refreshers help keep these issues top-of-mind.
When Familiarity Blindness Can Turn Deadly
One of the most dangerous familiarity blindness hazards when it comes to proper operations at a facility deals with lockout/tagout.
This is, of course, when you de-energize a piece of equipment before you work on it. It’s Safety 101. It is quite tempting to think, “Ah, I’m just replacing the air filter, no need to shut this machine down.” Accidents happen when we start to think about shortcuts.
As with the example with the hard hat above, the person thinks that they’ve changed this air filter for 10 years, and no accidents have ever happened. They don’t realize that the key reason that no accidents have occurred is because the equipment was properly locked out/tagged out prior to working on it. So, the next time they have to change the filter, they decide to skip that step to save some time. Guess what happens next? Since proper protocol was not followed, you have significantly increased the risk of an accident occurring.
We are always looking for ways to do things “better”; however, as we are well aware, sometimes it is not safe to do things faster by simply eliminating key steps. That’s why these refreshers, this ongoing training, and constant and consistent communication o EH&S principles and best practices, are so important.
In addition to refresher training sessions, you should conduct routine thorough and detailed walkthroughs of your facility as part of your preventive maintenance activities. These refresher training sessions and routine walkthroughs serve two purposes:
1. They allow you to break through familiarity blindness and spot those invisible environmental gorillas that are lurking at your facility.
2. They remind you and your team of their obligations and the requirements to be followed when it comes to EH&S policies and operating a safe and compliant facility.
My team and I are happy to help you with addressing familiarity blindness at your facility. As I like to say, it’s important to get fresh eyes on a site to help hunt for invisible environmental gorillas.
Just call me, Mark Roman, at 609-208-1885 or get in touch via e-mail at firstname.lastname@example.org