Management Consultants Specializing in
Occupational Safety & Health
Error Free Performance
Human Resources

Work Examples

Confirmation Letter
Recommendations Page
Survey Report
Custom Hand-out

Example - Confirmation Letter	Back To Top
The Confirmation Letter should be a professional and personalized document which summarizes the results of our consultation meeting with the Insured's management person. If there are recommendations offered, this letter will have them attached. (See next section.) The key here is the personalization, not some form letter format.

July 19, 1996

Mr. Bruce Johnson, Vice President
R. B. Wilcox & Son, Inc.
P.O. Box 239
Tomball, TX 77363

Dear Mr. Johnson:

My meeting with you and Mr. Wilcox on July 9 was productive and, certainly for me, educational. I have seen many businesses and operations over my 27 professional years, but I never thought about chemical tanker linings or how they were installed. I found it very interesting.

More to the point, I found your company's health and safety record impressive, although as I came to know both you and Mr. Wilcox, I began to understand how you have sustained such a good record. It is clear to me that you and Mr. Wilcox, as the top management, are visibly and actively involved with the employees on a regular basis; and that this, in turn, creates clear communications, sets clear performance expectations, and demonstrates your interest in results. I have found that most companies where top management finds ways to clearly demonstrate their interest usually have excellent records in all areas of performance, especially safety.

I was impressed by your attention to safety practices and training, such as the regular training in confined space entry procedures and your diligence in following the procedures; your rules about clothing, respirators, and hearing protection; and your attention to implementing improved work design to enhance safety and efficiency. The primary examples of this latter area are the work platforms for gaining access to the top of the rail cars, the plans to shift from silca-based blasting grit to ferrous grit, and the requirement that workers wear company-supplied uniforms.

We covered many subjects during our meeting. I offered some recommendations based on my observations and our discussion, and I did so recognizing they were enhancements to an already excellent operation and program. You, Mr. Wilcox and I discussed my recommendations and I promised I would try to summarize them for you in a follow-up report. This letter is the follow-up report, so attached you will find the recommendations. I trust I have captured them in the same tone as when we discussed them. I see them as helpful, but you are the final judge of their value.

The nice people at Special Risks Insurance Company would like to know what action, if any, you plan to take on the recommendations, and anything else you may have concerns or questions about. Sometime in the next 30 days, please write to them at the address on this letterhead, attention to the Alternative Risk Department. Thank you.

I really enjoyed meeting you and Mr. Wilcox. I learned more from you than you probably learned from me, and I thank you for that. If you have any questions about the recommendations, our discussions, or if I can help further in any way, please feel free to contact me directly during business hours at (614) 837-0454.

Sincerely,

Walter Pfender
Loss Control Consultant

CC: David S. Bullock, Vice President, Insurance Specialists Agency, Inc.

Attachment

	Example - Recommendations Page	Back To Top
	As with the confirmation letter, there is no "boiler-plate" in our recommendations. It would be highly unprofessional and very impersonal, even insulting to the contact person. If we are really interested in helping the client accomplish his own objectives, we certainly should write any recommendations as personal, not generic.

RECOMMENDATIONS

	R.B.Wilcox & Son, Inc. Highway 310 West PO Box 310 Tomball, TX 77363	Person Contacted: Bruce Johnson Consultant: Walter J. Pfender
	Date of Survey: July 9, 1996 Location: As above.
	The suggestions, advice and recommendations, or the absence of such information, in this document are based on observations and/or interviews at the time of the call. This document does not necessarily recognize all hazards present in your premises or operations and is not intended to assure compliance with any local, state or federal regulations. Maintaining safe premises, operations and equipment is solely yours and your company's legal responsibility. Neither the author nor the company he/she represents assume any liability for the management or control of your safety activities, for the correction of any unsafe conditions or practices which may exist in your operations, or for inaccurate or incomplete information provided by you or your company's representatives.

96-01	While you were showing me around your facilities, we watched an employee who was hand coating hatch sections with adhesive using a brush. The hatch sections were hanging on a rack made of metal bars and the worker was kneeling down to work because the sections were only about 2 feet off the floor and the container of adhesive was on the floor. This working position, while not a major issue, places what appears to me to be unnecessary stress on the worker's legs, lower and upper back and probably reduces his efficiency at completely coating the piece. You should revise the rack used to hold the pieces so the worker can work standing up with the pieces at a height between the worker's upper thighs and his arm pits. This would allow him to maintain relatively neutral body positions and reduce the stresses. The rack should also allow him to walk around the pieces to coat the opposite sides without reaching. The container of adhesive should be placed on a solid, perhaps moveable (such as on casters) table around hip-height so he does not have to stoop over to replenish the brush. I believe this change will improve the worker's results and will remove the potential for injury or discomfort to legs and back that may show up later as an injury, perhaps while he is doing some completely different task.
96-02	The same worker described above was using what appeared to be a fairly standard paint brush. While he was working carefully, even delicately, there is always the potential for splatters from the brush. To help avoid the possibility of splattering the adhesive into his eyes, he should wear safety goggles while performing this task, as should any worker who hand applies adhesive or similar substances with a brush or roller. You should establish a requirement for this form of eye protection and provide appropriate goggles. (I do not believe ordinary safety "glasses" would provide sufficient protection, but even glasses would be better than nothing.)
96-03	The metal-topped tables you use to warm and soften the sheets of rubber lining are heated by kerosene salamanders. The curtain-style sides used to contain the warmed air under the tables are made of plywood. I believe this arrangement creates some risk of fire which, in turn, could cause injury to your employees in a variety of ways, not to mention the property damage and interruption to your business that might result. I realize you are considering, even actively planning, to change these tables to steam heated surfaces rather than using the relatively open flame salamanders. You should move forward with your plan as soon as possible. In the interim, if the steam table approach is some time off, you should line the insides on the plywood curtains with sheet metal or replace them with some other insulated but non-combustible material.
96-04	Since the employees who must, from time to time, wear hearing protection seem to find the new style of disposable plugs you are now using (at the recommendation of the state industrial hygienist) uncomfortable to the point of not using them, I recommend you contact the supplier of the plugs to see if he has different models that have the same attenuation characteristics as the ones you are currently using. If he does, perhaps you should purchase a small quantity of each style and let your employees advise which are most comfortable. If they fit well and reasonably comfortably, your employees will be more inclined to use them. The state hygienist should have provided you with a written report detailing the findings of his noise pressure samples. His report should contain the pressure levels for various frequency bands. Using this information, the safety equipment supplier should be able to help you select the right models of plugs in a design your workers like.

	Example - Survey Report	Back To Top
	The survey report is a narrative report intended for the underwriter only. This document provides the essential information about the Risk, organized in major sections. The selected example below has just enough text to give you a sampling of how our standard reports are formatted and written.

	Insured: R. B. Wilcox & Son, Inc. Address: Highway 310 West P.O. Box 233 Tomball, TX 77363	Company: Special Risks Insurance Co. Requester: Denise Gorham Date of Survey: July 9, 1996 Consultant: Walter Pfender Assignment ID: SRI-131 WC Coverage Policy #: TBB 800-020-00
	Locations: As above Contact: Mr. Bruce Johnson, Vice President; Mr. R. B. Wilcox, President

UNDERWRITING SURVEY REPORT

Description of Operations

R. B. Wilcox & Son, Inc. is a contracting company which repairs and/or replaces linings inside railroad chemical tank cars and semi-trailer chemical tankers. The linings are natural rubber ranging from 3/16" to 1/2" thick, applied in sheets and cemented in place using toluene-based adhesives, and cured after installation using 260 degree steam under 20 psi pressure. The company does no other work and 85% of the work is done on the company's premises, with the balance done on some other remote site.

Normally, the rail cars or semi-trailers are brought to the company's plant site in Tomball, TX. Most are delivered to be re-lined but a few, especially semi-trailers, are new units which will be lined for the first time.

For those delivered to be re-lined, the old lining must first be stripped away. A sub-contractor, who operates on the R. B. Wilcox & Son, Inc. premises, does the removal of the old lining using a special device for which the sub-contractor's owners hold a patent. Once the old lining has been removed, all remaining work is done by R. B. Wilcox & Son, Inc. employees. By contract, the sub-contractor has its own insurance, including WC coverage and R. B. Wilcox & Son, Inc. maintains current certificates from the sub-contractor's carriers to verify coverages.

The re-lining process involves entering the tank to inspect it for obvious damage. If the tank is damaged, it is returned to the owner to be repaired. Neither the sub-contractor nor R. B. Wilcox & Son, Inc. do repairs other than to the actual linings. If there is no visible damage, the tank is sealed and pressurized with steam to determine if the tank leaks under pressure. If it does, the leak points are marked and the tanker is returned to the owner for repairs. If the tank does not leak, the re-lining process begins.

To apply the linings, a R. B. Wilcox & Son, Inc. worker must enter the tank through the entry hatch and blast the remaining old adhesive off the inside walls using a sand blasting gun. This process creates some exposure to free silica dust so the worker wears an air-supplied, positive pressure, loose-fitting leather hood and full coveralls and leather gloves. This process takes about 30 minutes.

After the blasting is completed and the dust and debris are vacuumed out and the tank is wiped clean, another worker must apply the toluene-based adhesive thoroughly to the walls of the tank using an ordinary paint roller and an ordinary paint brush for corners/edges. This process involves constant fresh air ventilation of the interior and requires the worker to wear an air-supplied (type C) respirator. This part of the operation takes about 30 minutes.

The rubber lining comes in long sheets similar to rolls of fabric. It is cut to length, warmed on long metal-topped tables to soften the sticky side of the sheets, then rolled up and passed into the tank through the hatch. The worker, still wearing the type C respirator, applies the sticky side of the sheets of lining to the adhesive coating already applied to the tank, cutting the sheets to fit perfectly and working the edges carefully into the corners. The worker works in sections, starting from first one end of the tank, then the other end until he completes the process right under and around the hatch. The installation of the rubber lining sheets usually takes about 1� to 2 hours.

All of these operations are in clearly defined "confined spaces" so all appropriate confined space entry rules and procedures apply. The air inside the tank is checked by the company-designated person who is trained to use instrumentation to check and measure the air quality inside the tank before work begins and to oversee the general ventilation that must be introduced via blowers and hose ductwork. There must always be an outside safety worker watching while there is a worker inside the confined space. In the case of R. B. Wilcox & Son, Inc., this safety worker/observer also must wear an air-supplied respirator, just like the worker inside. This is a very good practice and I'll explain it in more detail later in this report.

Once the lining is installed, the tank is sealed and pressurized to 20 psi with 260 degree steam for 2 hours to cure the rubber and the adhesive into a permanent bond. There is some potential for burns from the steam and the exterior tank surfaces during this process.

The rail cars are moved around inside the R. B. Wilcox & Son, Inc. yard by a specially equipped farm tractor. They use the same tractor to move the semi-trailers around after a fifth-wheel dolly is attached to the king pin under the nose of the semi-trailer, effectively converting it to a full trailer.

The workers use a portable air pressure tank to supply air to release the brakes to move both the rail cars and the semi-trailers. While these units are being worked on and in, the air pressure is released, thus locking the brakes. The semi-trailers are supported on the front by the landing gears, not the dolly.

Management Organization

R. B. Wilcox & Son, Inc. is a privately held corporation with no subsidiaries and no other locations. It was founded 14 years ago. There was no other, prior entity.

Mr. R. B. Wilcox, the original "& Son" in the corporate name, is the President and, along with his father who is now deceased, was co-founder of the company. Mr. Wilcox (the son) is very active in the daily operation of the business, primarily overseeing the actual processing.

Mr. Bruce Johnson is Vice President and has been a past employee of the company, left for a time, and has recently returned as an officer and part owner. He is a professional engineer and he handles most of the outside communications with clients/customers, including sales. He has some direct controllership responsibilities, as well, including the insurance programs. He also shares operating responsibilities with Mr. Wilcox and seems to be the interim heir-apparent to the top slot while Mr. Wilcox's son gains maturity and business acumen.

Mrs. R. B. Wilcox, widow of the deceased co-founder and mother of the President, is also an officer (Secretary) and serves daily as the primary clerical support person and the receptionist. She must be well into her 70s but I sat and talked with her for almost 20 minutes when I first arrived (I was early) not knowing who she was. I found her to be friendly, relaxed, apparently in good health, spry and intelligent in a rural-Texas sort of way.

Mr. Wilcox's son, Jim, is the "safety coordinator." The title is a bit misleading as his primary role is to test each tank and certify it is safe to enter it under the requirements of the confined space entry program. He is to check all the arrangements and precautions and sign-off on the internal confined space entry permit. He is not an officer and does not have any real management responsibility or authority. We certainly did not discuss it, but I get the impression that perhaps some day, if the son ever shows any talent and desire to run this company, Mr. Wilcox will turn it over to the son. Since it is clearly some way off (the son is about 22 years old and looks and acts 17) Mr. Johnson is aboard as the back-up senior executive to Mr. Wilcox.

The company has one shop foreman who reports primarily to Mr. Johnson but, since the company is small and very open, he also sort of reports to Mr. Wilcox. He has been with the company for 10 years.

There are 12 more full-time employees, including four who are designated as lead (read leed not led) men. The shop is non-union. Most of the workers have been at R. B. Wilcox & Son, Inc. for more than 2 years, some for 10 or more, and two since the beginning of the company.

Management's Approach to Loss Prevention

R. B. Wilcox & Son, Inc. has several programs it follows carefully to protect the safety and health of the workers. Most were the responsibility of Mr. Wilcox back when his father was running the operation. At that time, Mr. Wilcox did most of the procedural implementation and did all the training of new workers.

The company has a very thorough and well followed confined space entry program which is administered by Mr. Wilcox's son. The program calls for careful training of all workers, particularly those who actually enter the confined spaces and those who serve as the safety man on the outside. The program requires a written, internal permit that the administrator must sign before anyone may enter the confined space (tank). The pre-conditions for signing the permit include checking the atmosphere inside the tank for volatile or oxygen depleting vapors or gases, checking the air-supplied respirator system, checking the general tank ventilation system, and briefing the two-man crew (one who will enter and the safety person who remain outside and monitor the activity). It is a standard confined space program but it is well implemented.

The company does annual PFTs on all employees, whether they will normally wear a respirator or not. It also does drug screening, audiometric testing, and a general physical as much as a service to the employees as a safety and health precaution. The two people who routinely do the blasting work inside the tanks (actually, one regular blaster and one who is the back-up and really does very little blasting) have chest x-rays every 6 months, as well.

The blasting to this point has been with silica abrasive (sand) but because of the potential health problems associated with silica dust, and because the sand grit can not be reclaimed, the company has purchased new steel grit blasting equipment. It was in the process of being installed at the time of my visit. This will be a significant improvement.

The company has an excellent respiratory protection program. The workers who serve inside the tanks to apply both the toluene-based adhesive and the rubber linings wear air-supplied (Type C) respirators at all times, plus the tank itself has general ventilation, further reducing the concentration of toluene inside the tank. The safety person outside must also wear a Type C respirator during the entire time his partner is wearing his. This allows the safety person to enter the tank immediately if anything should go wrong and the safety person needed to rescue the person in the tank. Good approach.

Management is very visible in the entire operation and actually conducts many of the safety meetings and briefings. This is an important aspect of this company's excellent safety record. Mr. Wilcox explained, too, that while they are very family-oriented and employee-oriented culturally, they are also very strict about the safety rules and won't hesitate to place a worker on probation for failing to follow the rules once and terminate the worker if it happens too soon again.

Management has a bonus program for all employees based on the profits of the company, it tries to develop and advance people from within, and it provides permanent raises for those who consistently demonstrate skill and reliability.

The company has constructed two fairly new buildings which make the entry and work on the rail tankers far less dangerous and more efficient. The rail cars are pulled in one end of the building and the upper level platforms are right at the catwalk level with the tank hatch. The platforms are wide and solid steel supported with concrete floors � a very substantial arrangement typical to what this company strives to do to improve the processing.

New employees usually come from referrals from existing employees and are known, at least in some fashion, to somebody in the company. This is a rural Texas location and I suspect most everyone in the area knows virtually everyone else. Still, new candidates complete a written application and are interviewed by either Mr. Johnson or Mr. Wilcox, and by the foreman. The good candidate is then sent for a physical, a PFT, an audiometric baseline test, and a drug screen. If all checks out, the new employee is oriented by Mr. Johnson and the foreman on company procedures, policies, and safety practices. The new employee is then on a 90 day probationary period. Turnover is very low and even some of the young people who have left over the years for what they believe to be better jobs down in Houston or some other town often end up coming back to the family environment and reasonable pay at R. B. Wilcox & Son, Inc..

Hazard Assessment

Mr. Johnson does weekly inspections of the entire operations along with the safety coordinator (Mr. Wilcox's son) and looks for both conditions and work practices that meet their rules and requirements.

There have been very few minor cuts or burns over the years, all requiring very little attention and none resulting in medical attention or lost time. When these things happen, however, the foreman submits details to Mr. Johnson and he and the management staff (small as it is) discuss the situation in their weekly meetings to determine what corrective action might be necessary to control the source of the injury or the cause of the accident. I believe this approach in this small company is probably sound and adequate, but I left some material on post accident review anyway since Mr. Wilcox and Mr. Johnson seem interested in any improvements they might find.

Hazard Correction and Control

All workers must wear long sleeved shirts and long pants, so the company provides everyone with uniforms and has them cleaned at company expense.

All workers must wear proper work boots at all times. Eye protection is required during certain operations but I believe it should be required more often than it is. (See recommendations.)

The tilt-down gang planks that connect the raised platforms to the catwalks built onto the top of the rail car hatches are solid and properly equipped with safety chains and railings.

The tractor that they use to move the rail cars and the semi-trailers has a large counter-balance weight built onto it to add stability and prevent the front from coming off the ground. It is not equipped with anything else special nor does it need to be. When a unit is being moved by the tractor operator, there are always three other people assigned to walk along with the unit as safety watches, one behind and two on either side. Great!

Most walking areas are quite clear and clean. The company makes a strong effort to avoid tripping hazards and it shows.

The steam treating process is done outside in the yard. The connecting hoses are well insulated and the fittings are in good repair. The workers place signs on the units being treated to remind other workers that treating in is progress and that the exterior of the tank is hot.

Those connecting and disconnecting steam lines wear protective gloves.

Five of the staff are trained and certified in first-aid/CPR and the company provides blood-borne pathogens training for these people and has a blood-borne pathogens program. Great.

There is some significant exposure to falling off the semi-trailers while on top to access the hatch. Because there is no uniformity to the location of the hatch or the catwalk design among the various tank trailer manufactures, R. B. Wilcox & Son, Inc. has not come up with a solution like the fixed platforms they use for the rail cars (which are made to very standard design specifications). They would like to, but so far they have not. Thus, workers who must climb up on these units must be particularly careful. So far, they have been and the company has never had a worker fall off. (See recommendations.)

The small sections of the hatch assembly are lined in the shop on a rack. I found some improvements possible. (See recommendations.)

Safety and Health Training

Most of the formal on-going training, such as haz-mat, confined space entry, and the fit testing of respirators are done by an outside company that comes to the R. B. Wilcox & Son, Inc. location every 3 months. This is an excellent way to accomplish these functions and the same outside firm has been doing this for R. B. Wilcox & Son, Inc. for over 10 years.

The company (actually, Mr. Johnson and the foreman) conduct new worker orientation training as needed.

The entire company attends safety meetings where special items are refreshed, accidents are discussed, work practices are reviewed, and new processes are taught. These company-wide meetings are conducted quarterly. The foreman conducts weekly meetings for all the workers, and the foreman and managers meet weekly, as well.

Loss History and Analysis

R. B. Wilcox & Son, Inc. has not reported a WC claim for injury for 13 consecutive years. Mr. Wilcox did tell me that they have an occasional minor burn or cut which they treat on site and review, but none of these has ever required professional medical attention or even any follow-up attention. They investigate the causes of even these minor incidents.

Obviously, there has been some luck involved in the exceptionally good loss record and, on that basis, I believe it is possible for something significant to pop up. Still, management gives solid attention to safety issues because it has had such an incredible record for so long, it is now motivated strongly to sustain the record, rather than becoming blas� about accidents. This is a good sign.

Opinion of Risk

Management is quite good and very effective in maintaining R. B. Wilcox & Son, Inc. as a good place to work. The business is very focused and the workers become very skilled at what they do. The State of Texas has visited the company to inspect it several times and it has never been cited. An industrial hygienist from the State has conducted surveys on the air quality in the work areas and the tanks while the work was being done and found the toluene exposure under the company's existing work practices to be well within the PELs.

All this considered, this should be an excellent risk from a loss control standpoint.

Recommendations
(The recommendations in the example above would be pasted into the report here.)

This report is intended for underwriting purposes only and is pertinent to the coverages shown in the header of the report. The content is based only on observations and interviews with the insured's management representatives, and concerns such conditions and practices as were observed or considered at the time of the call. It is not intended to indicate there are no other exposures than reflected in the report. The author does not assume any legal liability due to misinformation provided by the insured or his/her representatives, nor for delayed reports for any cause. The control and management of the insured's operations and premises remains strictly the insured's responsibility. This is a confidential report and must be treated as such.

Example - Customized Hand-out

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Customized handouts are reference materials we create to address issues we find to be of particular intest to the companies insured in the program we represent. The reference material takes the form of hand-out sheets which provide specific information on the subject, usually a subject that is unique (or uniquely presented) for the industry the program is serving. These handouts are used in support of our field visits and provide a summary which may be left behind as a ready reference for the insured. We have created a number of these topical customized handouts for our current clients and would expect to create similar, risk specific, topical handouts for new clients' programs. By the way, we don't charge anything extra for doing these sheets. This service is an excellent example of the "little but essential things" mentioned in our section on Services/Rates under Program Partner Services.

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