There is a crisis in manufacturing that has been slowly but surely coming to a head… with the pace quickening the last few years, especially now with the impact of the COVID-19 pandemic on our workforce. Its impact will be felt for years to come.
Here’s the issue: management at manufacturing facilities is typically on the older side – and many are nearing retirement age. Yet, many facility managers and other key personnel feel that the next generation, the younger workforce under them, isn’t really ready to replace them yet. The senior workforce often contends that the younger workforce does not have the necessary skills and experience.
Millennials and members of Generation Z aren’t ready to step into important management roles, says the older generation, because they lack the necessary knowledge. If we don’t bridge that gap, and they don’t get up to speed quickly, the consequences can be serious.
How did things get this way? They feel like younger workers are entitled, too complacent, and need instant gratification.
But, on the flipside, younger workers feel like their senior colleagues are out of touch and unwilling to embrace much-needed change and technology that could make their facilities more efficient, productive, and profitable.
It’s a generational conflict we often see in many areas of our society. And we’re not going to solve it by ignoring the issues. In fact, I see both sides as having an element of truth.
It has been my experience that senior facility managers often have an “It’s always been done this way” or “If it ain’t broke, don’t fix it” approach to running their facilities, which can lead to issues because regulations change, best practices change, and technology changes.
By only sticking with old school methods you can easily step out of compliance, have an outdated EH&S program that puts people and profits at risk, or be blind to the invisible environmental gorillas in your facility.
Invisible environmental gorillas are those issues in your processes, facility layout or features, or equipment you just don’t recognize – because you’re so familiar with your facility and they have become part of the backdrop or landscape… the normal routine. However, they could quickly turn into expensive liabilities if they are overlooked.
An outsider can often recognize these issues very quickly because they’re looking at the situation with fresh eyes. Some typical invisible environmental gorillas include:
** Floor drains that are assumed to lead to the sewer system… but actually go to on-site septic tanks or off-site retention ponds… or even straight into the soil and groundwater beneath the facility because they are not connected to a sewer system.
** Improper storage of hazardous materials, storing incompatible materials together, containers incorrectly labeled, improper use of containers, and more.
** Outside storage areas not protected from the weather, leading to releases of materials into stormwater retention basins or even into the environment.
** Floor cracks, floor seams, and floor joints that aren’t properly sealed and can serve as pathways to the environmental for released materials to impact underlying soil and groundwater.
** Equipment and machinery not operated or maintained correctly.
Click here to request a free copy of our book on invisible environmental gorillas: OVERLOOKED: Hunting the Invisible Environmental Gorilla
At the same time, there is a knowledge gap among younger workers primarily due to inexperience.
However, these up-and-comers are very comfortable in using the new technology that is always moving manufacturing forward. This has always been the case, but it is especially important as we enter a post-pandemic world where virtual workplaces and remote working, as well as the social distancing requirements, will become more and more commonplace.
Technology can help ensure that a facility manager doesn’t always have to be physically present to do their job, even something as simple as monitoring conditions remotely, rather than with visual inspections.
As the workplace population is starting to change and things are approached differently as far as processes and the tools we use due to COVID-19, don’t forget to integrate EH&S issues with new processes and policies. It’s all too easy to let “routine” EH&S issues fall by the wayside in a rush to implement new policies to make the workplace pandemic-proof.
Keeping this in mind, let the younger generation take a chance on reinventing the workplace they are taking over.
Both sides bring something valuable to the table. The older generation has experience and institutional knowledge that got us to this point and is of great value. The younger generation brings innovation, comfort with new technology, and a willingness to change and adapt – this will allow our businesses to continue to grow and enable us to have a solid future.
Combine both and you have the march of human progress.
Stay tuned for future articles on bridging the generational gap in our workforce.
If you’re interested in learning more about EH&S issues in the age of COVID-19, please get in touch with me, Mark Roman, at 609-208-1885 or via email at firstname.lastname@example.org.
There is a crisis in manufacturing that has been slowly but surely coming to a head… with the pace quickening the last few years, especially now with the impact of the COVID-19 pandemic on our workforce. Its impact will be felt for years to come.
If you’re looking to buy a building or property to open a new facility or expand your existing operations, you have to keep in mind more than just the price. And that’s especially true if you’re looking at former or current manufacturing sites, warehouses, or other commercial/industrial properties.
Otherwise, you could be in for a lot of expensive issues, as we’ve seen countless times in our work as environmental consultants.
We’ve all heard the horror stories that could happen, such as the New Jersey daycare center where many of the children had abnormally high levels of mercury in their systems. It turns out the daycare center was housed in a building on a property that was a former mercury thermometer factory. Even though the former use of the property was known, regulators issued permits and allowed the property to be utilized as a daycare center.
Many people believe that issues like this do not happen anymore because of all the environmental, health and safety regulations in place. Well, this daycare center issue occurred in the mid-2000s – not that long ago! The property operated as a thermometer plant until 1994, and the daycare center opened in 2004 and was shut down in 2006.
This issue led to environmental regulations in New Jersey that require all childcare centers to conduct an environmental assessment of the property before an application to operate a childcare center can be approved.
And how about the site we worked on that had been a lighting manufacturer for decades? The company eventually closed the entire facility down, all 1 million square feet of it. They had worked out a deal to sell it to the local community, which would then convert the building to apartments.
When we arrived at the site to do an environmental assessment, all the equipment had been removed and the place was in good shape. There were even really nice wooden floors, which would look great in the new apartments.
However, a closer look found that the floors were anchored in place with asbestos-containing material called Nailcrete, which was contaminated with mercury. It turns out that there was a storage and handling area in the former manufacturing facility for mercury and when some of the mercury fell on the floor while it was being dispensed to the factory workers, it would penetrate between the wooden floor planks and settle into the Nailcrete. Decades of this occurring resulted in a significant cleanup of asbestos-/mercury-contaminated building materials.
Make sure you do not star in your own horror story! Based on our experience, we always recommend that you develop a thorough understanding of property history and what used to be in the buildings on a property prior to you signing the deal and taking possession. Once you have the keys, so to speak, any contamination or environmental impacts that pop up are your responsibility, even if it’s no fault of your own, unless you establish environmental liability conditions in the Purchase & Sale Agreement or pursue a no doubt expensive and lengthy legal fight against the previous owner.
As the saying goes: Caveat emptor – buyer beware.
This isn’t a simple matter of asking the seller of the property to simply give you the rundown. Memories are short. Perhaps they’ve only owned the property a short time and don’t know what happened on site before they got there. And, of course, there could always be things they know that could spoil the deal, so they don’t disclose them.
That’s why we tell companies considering real estate purchases to fully understand property history and to conduct thorough environmental due diligence on a property of interest. For further information, please read our previous articles on due diligence and property history, including: Why Due Diligence Is So Important and How to Do It the Right Way and What You Must Know About Property History.
As part of due diligence, it is a critical starting point to have an environmental consultant conduct an ASTM-compliant Phase I Environmental Site Assessment (ESA) of the property at a minimum. It’s a standard, cost-effective way to identify existing or potential environmental concerns and associated liabilities based on current and past activities at the property. Results from a Phase I ESA could trigger the need for additional investigations. For further information on Phase I ESAs, please read our previous article Getting Your Money’s Worth With Phase I Environmental Site Assessments.
This article is meant to delve a little bit deeper into some of the issues we often come across when clients purchase older properties.
It’s very important to know what you’re dealing with, especially if you plan to redevelop a site, tear it down, or change how it will be used (such as the daycare center discussed earlier). There could be all sorts of hidden surprises that could halt your plans, put you in the crosshairs of regulators, or compel an expensive cleanup.
With older buildings especially, there are some key things to look out for when these past commercial and industrial sites are being repurposed. Say a warehouse or old factory is being turned into residential housing or, as we’ve seen a lot recently, into storage unit facilities. Even if you are going to continue to use a former commercial/industrial property as a commercial/industrial property, there are some common issues you need to look into during your due diligence activities. Many of these issues are typically not considered as part of a standard ASTM Phase I ESA yet can result in significant and costly liabilities for you in the future if they are not identified and accounted for prior to purchasing the property.
Here are some of the more significant issues to look out for in older commercial/industrial properties:
For decades before its toxic effects were known, asbestos was everybody’s favorite insulation because of its fire-retardant properties. If you see insulation in an old building, you have to assume it’s asbestos and have a properly licensed firm check it out.
Other places asbestos was commonly used were floor tiles and mastic, caulking (for “window putty” and drywall), siding, textured paint, roofing materials, gaskets, fire-proofing materials and friction products. Check those areas as well.
There is another potential asbestos hiding place we discovered on a project a couple of months ago. Take a closer look at stainless steel tubs or sinks that handle liquids, including water. If you run liquids into one of these, it will make a loud sound if there is no insulating material underneath it to deaden the noise. Often, the material used to control the sound contains asbestos.
The height of asbestos use in the US was in the 1970s, but even though we know about the health effects from asbestos exposure, the US continues to import and use asbestos. According to the US Geological Survey, 750 metric tons of asbestos were imported to the US in 2018. In 1989, the USEPA banned the manufacture, import, processing and distribution of some asbestos-containing products. Recently in 2019, the USEPA introduced additional regulation (including a risk evaluation of asbestos) that ensures that discontinued asbestos products cannot be reintroduced into commerce without further evaluation by the USEPA.
When it comes to asbestos, the best approach is to consider suspect asbestos-containing material as containing asbestos and get it tested properly. The USEPA has a wealth of information on asbestos on its website, including responsibilities for building owners and managers: www.epa.gov/asbestos.
2. Lead-Based Paint
Lead-based paint in the US has a long history of use dating back to colonial times due to its durability. While the use of lead-based paint was banned from residential use in 1978, lead-based paint is still sometimes used in industrial applications. However, due to the costs associated with the eventual need to address the lead-based painted structures, many in the US have elected to require lead-free paint and coatings in project and product specifications for such applications.
Exposures to lead-based paint at industrial properties usually occur in the course of applying, disturbing and removing the lead-based paint, which includes when you are removing painted or coated steel equipment or structures, for example, by torching or cutting the materials. Lead-based paint can also contribute to soil and water contamination at the property.
A lead-based paint survey of the suspect lead-based paint on walls, as well as metal items at the property, is cheap and easy… and essential when buying an older building. Make sure the lead-based paint survey is conducted by a properly licensed/certified firm. Visit the USEPA’s website www.epa.gov/lead for further information.
Polychlorinated biphenyls (PCBs) are man-made organic chemicals that were domestically manufactured from 1929 until 1979, when their manufacture was banned in the US. Because PCBs are non-flammable, chemically stable, and have high boiling points and excellent electrical insulating properties, they were used in hundreds of industrial/commercial applications, such as in electrical, heat transfer and hydraulic equipment, among other uses.
According to the USEPA, “Although no longer commercially produced in the United States, PCBs may be present in products and materials produced before the 1979 PCB ban. Products that may contain PCBs include:
As the country starts to get back to work and our returning work force expands, we need to maintain our focus on getting back to basics.
The issue is what I call “workplace fog,” which is leading to many workplace mistakes that result in issues and accidents that can have serious consequences.
It’s been a very stressful time for the last several months, and it looks like these stressful times are not going to let up any time soon. And when confronted with all the economic, health, personal, and social issues we are facing – all at once – we can have a hard time keeping our head in the game.
As we return to work or expand our work force at our facilities, it’s time to refocus on issues we have control over right now – the workplace – and not let stress and a new emphasis on COVID-19-related issues cloud our judgment when it comes to routine EH&S issues.
We have to keep our teams safe and productive in this new reality and avoid simple mistakes, because the safety of our employees is at stake, and regulators are not loosening the reins on complying with EH&S regulations.
We need to regain our focus at the workplace, otherwise we can have issues occurring at our facilities, similar to the following:
I received a call from a client the other day. He forgot to submit a mandatory monthly monitoring report to regulators last month and, because he had never missed filing a report before, needed to know how to remedy the situation. When I asked what happened… he said he had no explanation; he simply forgot - it just didn’t occur to him that he needed to submit the report. That’s the “workplace fog” I’m talking about. We are so focused on the current state of affairs that we are starting to overlook the routine, yet very important issues that we do have control over.
And there are plenty more examples in the Envision Environmental team’s recent experience.
We are starting to get back into facilities to work with clients, wearing PPE and maintaining social/workplace distancing; and as a result, we are seeing more and more facilities experiencing this “workplace fog”. Some facilities that have gone hundreds of days without a workplace accident or incident are now seeing that streak broken.
We’re seeing facilities that have well established EH&S programs and policies in place with a strong compliance history, starting to experience “workplace fog” related issues.
We came across a significant issue when we were walking through one section of a facility recently where the maintenance crew was about to start working on a transfer pump. The crew had on the appropriate PPE and were observing, as best as possible, workplace distancing. However, we noticed that the transfer pump did not appear to be properly de-energized. Turns out the members of the maintenance crew just assumed someone else in the crew de-energized the pump through their Lock Out/Tag Out procedure – but no one had completed that task. Luckily, this issue was identified before an accident occurred and the pump was properly de-energized before the crew continued with their work.
It’s an extreme but not uncommon example of this “workplace fog”. With all of the COVID-19 related extra policies and procedures that have been put into place, it is even more important than ever to pay attention to everything that is happening at your facility.
The following are some common, more easily avoidable issues that we are seeing lately. The easiest way to make sure these routine issues are being addressed and not disappearing in the “workplace fog” is to utilize a written protocol, program or schedule to keep track of your routine tasks.
1. Monitoring and Reporting
Many facilities have permits that have monthly, quarterly, semi-annual, or even annual reporting requirements. Make sure you keep track of when you need to conduct any monitoring and when your reports must be submitted to the regulators to stay in compliance. Keep that schedule front and center on your computer, at your desk or near your workstation.
2. Routine Maintenance and Inspections
We’ve noticed that there has been a noticeable dip in facilities conducting their standard inspection and maintenance of equipment. Revisit your pre-pandemic preventative maintenance schedule and stick to it.
3. Standard Safety Protocols
We’ve also found that some facilities are simply “forgetting” to follow EH&S programs and policies that have been in place for years – and that are industry standard practices to boot. I mentioned the Lock Out/Tag Out issue we found at one facility. At another facility, we found drums full of flammable material that had not been properly grounded, even though all the necessary materials to do so were located next to each drum. It only took a few minutes to safely ground the drums. This facility now posts a checklist in the drum area that must be filled out during every shift. Confirmation that the drums are properly grounded is just one of the key items that must be verified now.
4. Forklift Accidents
People are distracted, thinking about other things. But at work, when lives are on the line, you need to stay focused on the here and now. Forklift operators must pay extra attention these days – so must those who are walking through a facility. Watch where you’re going and what is going on around you.
5. Machine Guarding
Pinch points in moving machinery must be safely guarded to protect employees. We are seeing equipment operators and process line workers getting injured more frequently due to this “workplace fog” when working near pinch points. Many facility workers are simply not paying attention because their focus is elsewhere these days. As a result, we recommend that pinch points be identified more readily so that they are more obvious to workers, and make sure your machine guarding in these areas is in place. Again, revisit basic safety protocols, and remind everyone that their concentration must be directed to the tasks at hand, not elsewhere.
The bottom line is that as a facility manager, you must work with your team to get everybody refocused, including those who stayed at work, as well as those returning to the job (not to mention new people coming in for the first time).
Back to Work With COVID-19
We must also account for pandemic-related safety measures, too, as our teams get back to work in terms of workspace changes, new training, new protective equipment, new procedures, and more.
Social/workplace distancing is one of the biggest “new” challenges that facilities now have to address. It can be something as simple as having separate entrances and exits so people don’t pass too closely to each other or using different stairwells for going up and going down. (Of course, that can be difficult if you only have one stairwell!)
But this also comes into place in workspaces and common areas like the breakroom. You’ll need to mark the floor with visual aids to make sure people don’t stand too close. You might need to remove tables, so people aren’t crowded together while eating lunch. Visit www.seton.com for products to help you with social/workplace distancing efforts.
I was on a webinar recently with a long-time office space designer, and she noted that after 20 years of open office arrangement, companies are now going back to the cubicle approach. We see similar changes on the production line.
Operator-controlled equipment is usually installed to centralize control panels for multiple workers. Now, centralized is not such a good thing. So, facilities are installing plexiglass dividers near these areas to protect workers when social/workplace distancing is not possible. And a lot of control panels are going mobile, so they can be wheeled around to maintain a six-foot distance from a co-worker.
We’re also seeing limits on “multiple touching” of materials. Instead of several workers transporting materials throughout the facility - from receiving, to storage, to the production line, to shipping, for example, some facilities are using the same workers to handle all of these tasks. That expands the responsibilities of the individual worker and requires additional training (see below). There might be safety issues with handling some materials, or it could be something as simple as making sure they’re lifting a heavy item correctly to reduce the chance of injury.
The pandemic is a medical issue, of course, but also in a way you might not expect. Many facilities are now screening you before you go in as a worker or visitor. They ask you where you’ve traveled recently and take your temperature. But because you can’t discuss those health issues in front of others due to privacy concerns, you may need a separate room to have a confidential discussion if some of the answers to those questions, and/or the results of the temperature screening are outside of the acceptable ranges.
PPE and Disposal
In a typical facility, you usually have eye protection, hearing protection, safety shoes, etc. Now you have to expand PPE to include facial masks, face shields, and rubber gloves. That means you have another waste stream you have to deal with, and these items, once used, need to be segregated and disposed of properly.
With COVID-19, there is a wealth of new information we have to convey to people, and we may not be able to rely on normal routine training to do so. We need to make adjustments to our daily behavior in order to ensure that we keep each other safe and well.
Social/workplace distancing and wearing face masks are very important, but you must also convey the importance of frequent hand washing. Just think of how many things you touch from when you get up in the morning, to when you get to work – and then all the things you touch once you get there. Multiply that by all the people in your facility. It’s amazing how many touchpoints there are, and those areas need to be addressed with new sanitization procedures.
I anticipate in-person training to be more difficult, with virtual training taking its place when possible.
Workers are now being confronted with all this information and new policies. How do you make sure they get it? Put up signage explaining social distancing and encouraging handwashing and other safety tips, for example, but keep it simple.
Since we are knee-deep in the winter months, we are thinking a lot about heating oil. Although this is becoming less and less common these days, as most heat now is generated by electricity, propane or natural gas, there are still major environmental hazards related to heating oil, specifically the storage tanks, underground and aboveground.