Out of Sight, Never Out of Mind: Keeping Remote & Lone Workers Safe
By: Cindy Pauley, Contributor
Employers have a duty to protect all workers, including those working alone or remotely. OSHA defines a lone worker as “an employee working alone, such as in a confined space or isolated location.” An isolated location doesn’t just include being out of earshot or being on a distant work site. It also includes traveling alone, performing remote office work or being a sole worker on a night shift. Lone work doesn’t always mean working by oneself, either. It can also mean working without direct supervision or working in isolation for periods of time.
Protecting Lone Workers
As with any other worker, lone workers are best protected using a combination of engineering controls, safe work practices and personal protective equipment (PPE). Methods of protection will depend on the level of risk faced by the worker; the location and type of work; and the potential need for emergency response. Decisions about which control measures to implement should be made only after a careful assessment of each separate lone worker situation.
An effective lone worker safety program will incorporate the following:
Performing risk assessments that identify hazards associated with tasks, the environment, emergency response needs and contact with other people. Risk assessments should always involve discussions with lone and remote workers to better understand their challenges and how they feel the challenges can be alleviated.
Disallowing lone work for high-risk tasks or situations.
Scheduling higher risk tasks for normal business hours or when other workers are more available to assist or respond to an emergency.
Implementing accountability procedures that require regular contact with lone workers. These can be verbal or by sight and include alerts, power tool sounds, visual cues or phone calls. Lone workers should especially be checked on immediately following lunch and at the end of a shift, job or specialized task. Documenting contact is always a great practice to ensure workers are accounted for.
Developing “no contact” emergency protocols to ensure visual or verbal follow up is made with lone workers if there is no response during accountability procedures.
Utilizing a buddy system so lone workers have someone regularly checking on them and available to them in an emergency.
Investigating incidents and near misses whereby lone or remote work increased incident severity, so corrective actions can be made to prevent recurrence. And don’t forget to update lone worker policies to include corrective actions.
Educating all workers about the risks associated with lone and remote work, so employees know how to assist when concerns arise. Employers should offer additional training to lone and remote workers to ensure they understand accountability procedures, emergency response requirements, medical and ergonomic hazards, and workspace safety inspections relating to their roles.
As a final layer of protection, employers should implement PPE requirements. “Smart PPE” is on the rise as one of the best methods for ensuring worker protection, especially for lone and remote workers. Joining the ranks of phone tracking, PPE now uses technology and software to read and respond to a worker’s body and interaction with the environment. Wearable technology provides panic alert buttons, lights and buzzers to indicate changes in temperature or exposure to chemicals; as well as lockout devices triggered by body lasers to prevent equipment-related injuries.
Keeping Remote Office Workers Safe
Thanks to the COVID pandemic, working from home has become a popular practice. Many companies and employees have embraced the benefits of remote office work, such as office space and energy cost savings; fuel and drive-time savings; and a flexible work schedule that promotes more productivity through work-life balance. With all the positives, however, employers can’t lose sight of their responsibility for the hazards that workers face in a remote office setting.
In a letter of interpretation, dated November 15, 1999, OSHA explains that regulations apply to any workplace, including home offices, and therefore employers are responsible for regulatory compliance. The letter explains that having a remote work agreement with an employee gives the employer some control over the conditions of the workspace to ensure employees aren’t exposed to “reasonably foreseeable hazards” created by working from home.
That being stated, OSHA also explains that the employer is responsible for a safe workspace, but not a safe home, and therefore wouldn’t be responsible for conditions of the home unless they negatively impact the employee’s work area. A good example of this would be walking-working surfaces. The employer is responsible for protecting from trip hazards, uneven flooring, unsafe stairs, missing handrails, etc., that expose the employee to potential harm during their work.
If an employer is aware of or suspects any safety or health hazards, they must take reasonable action to correct the hazards. And, although OSHA doesn’t perform home office inspections, there’s nothing preventing an employer from implementing their own inspection procedures to ensure the safety of their remote office workers. Depending upon the type of home office work being performed, safety inspections might include:
- Fire hazards: electrical hazards, extension cord and power strip use, laptop charging procedures, combustible and flammable material storage, etc.
- Ergonomic hazards: office and computer layout, lighting, temperature control, ventilation, proper rest and nutrition, bending, lifting, etc.
- Material handling and storage: shelving use and anchorage, manual lifting, chemical exposures, etc.
- Emergency procedures: fire, severe weather, access to emergency healthcare and first aid supplies, emergency egress, etc.
When Should Employees NEVER Work Alone?
OSHA does prohibit working alone in certain situations. These are detailed in the following standards:
- 120 – HAZWOPER
- 134 – Firefighter respiratory protection
- 146 – Permit-required confined space
- 269 – Certain energized work activities
There are other conditions whereby employees should never work alone, including:
- Entering confined spaces (whether permit-required or not)
- Working at heights
- Operating certain heavy machinery
- Handling highly hazardous chemicals or materials
- Working in areas that are potentially violent or volatile
Employers should also consider workers who have known medical conditions, as well as young or apprentice workers. Workers with physical or health concerns, or those that are new to their surroundings, are at greater risk and, therefore, would be better off not working alone.
An Employee’s Right to Refuse Lone Work
It’s important to note that OSHA ensures an employee’s right to refuse lone work, since it’s deemed “dangerous.” The right of an employee to refuse such work is protected when all of the following conditions are met:
- The refusal to work is made in “good faith,” meaning there’s a genuine belief that the work is imminently dangerous.
- If a reasonable person would agree that the work is dangerous and poses a serious threat.
- There isn’t enough time to get an urgent hazard corrected through normal remediation channels, such as a request for an OSHA inspection.
- When the employer has been asked to eliminate the danger but has failed to do so.
OSHA doesn’t have a specific requirement to develop and implement a work alone policy. However, failure to have a policy that protects lone and remote workers could be considered a General Duty OSHA violation. Employers should treat lone and remote workers with the same safety priority as other workers. Implementing procedures for regular communication and accountability is vital for never losing sight of these essential workers.
About the Author:
Cindy Pauley is an Editor for J. J. Keller & Associates, Inc. on the Environmental, Health & Safety (EHS) Publishing Team. She uses her 13+ years of safety program development and management experience in oil and gas, chemical, manufacturing, construction and agricultural industries to develop a wide variety of easily understandable content and to provide regulatory insight for J. J. Keller’s customers and partners. Pauley is both a Certified Occupational Safety Specialist (COSS) and a Certified Occupational Hearing Conservationist (COHC) with an MA and BAA from Central Michigan University.
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