New Year New Policies: Strengthening Risk Management

Start the New Year Right: Reviewing and Updating Municipal Policies

The start of a new year is a perfect time to revisit Risk Management Policies and Procedures. Think of it as giving your organization’s Risk Management policies a New Year’s resolution: to be clear, consistent, and ready to tackle the year ahead. After all, if you don’t set the rules, someone might invent their own… and that’s when things can get messy (literally and figuratively).

The Importance of Robust Policies and Procedures

Policies and procedures are the backbone of risk management, providing a foundation to minimize liability risks and promote organizational consistency. While Risk Management policies sometimes get a bad rap for being lengthy or complex, concise, well-drafted policies ensure compliance with federal regulations, protect against legal issues, and create a safer and more productive work environment. For municipalities, these updates are not just administrative tasks but strategic actions to align with your municipality’s values and goals for the year ahead.

Sample Policies and Support from OMAG

OMAG offers a range of comprehensive sample policies to assist municipalities. These include Health & Safety policies supported by the Municipal Accident Prevention Program (MAPP), Sanitary Sewer policies and procedures through the Sanitary Sewer Overflow Reduction Program (SSORP), and numerous Human Resource Policies and Procedures. All these resources are available to members on the OMAG webpage. For additional policies or questions, you can also reach out to the Risk Management and/or Human Resources team for guidance and support.

Sanitary Sewer Claims

The claims linked to Sanitary Sewer Overflow (SSO) incidents in the 2022-2023 fiscal year alone have amounted to an unsettling $3.4 million, which is equivalent to 50% of our reported losses among our member municipalities. The rising costs of SSO incidents serve as a reminder that our risk pool's strength lies not only in its financial reserves but in the public health, safety and welfare of member’s citizens. Considering the escalating costs of SSO claims, OMAG is exploring options to reduce this exposure to the risk pool, including limited coverage, higher deductibles, and/or higher premiums. In the interim, it is imperative that we, as a risk pool community, come together to develop a proactive and strategic approach to mitigate the effects of SSO incidents.   

Here are a few OMAG value added services your municipality can utilize to mitigate this issue: 

Know where the issues with your system are located: 

Acoustic Inspection is a quick, easy to use, and cost-effective method for determining potential blockage locations in your collection system.  OMAG has (7) Sewer Line Rapid Assessment Tools (SL-RAT) units available for members to use free of charge.  SL-RAT assessment information allows OMAG members to better allocate sewer line cleaning, CCTV inspection, and other maintenance operations. 

Pinpoint the cause of collection system blockages/issues: 

Closed-circuit television inspection is used to identify, evaluate, and manage obstruction and mainline defects. The value of CCTV inspection is hard to ignore.  Considering this, OMAG has partnered with local contractors to provide closed-circuit television inspection services for a maximum of 3,000 liner feet of sewer line as well as jetting and vacuuming cleaning as needed.  This grant is provided at no cost to eligible participating members. 

Manage root intrusion: 

Tree root are a stubborn and destructive force once they make their way into sewer main lines.  Chemical root control minimizes damage and service disruption and is one of the most effective methods for removing this costly line obstruction.  OMAG has partnered with Duke’s Root Control Inc to provide guaranteed sewer root control treatments to participating members.  This grant opportunity provides a 1:1 matching funds, with a $5,000 maximum benefit. 

Continuing maintenance, purchasing equipment: 

Maintaining your collection and observing “Best Practices” is of paramount importance.  Having equipment to maintain your sewer collection is costly enterprise.  Recent price increases have further placed owning maintenance equipment further out of many members reach. OMAG recognizes the need and in response, developed a grant to make this equipment more obtainable.  The Sanitary Sewer Equipment Purchase grant, is a 1:1 matching funds grant with a $10,000 maximum benefit.  Equipment eligible for matching funds include but are not limited to new/refurbished jetters, jetter nozzles, CCTV inspection cameras, and other related equipment. 

Maintenance, Budget, and Planning Assistance: 

Developing, budgeting and planning for sewer maintenance and replacement is a daunting task.  It is sometime difficult to know where to start.  Please know that OMAG’s Risk Management professionals are no further than a phone call or email away. If you’re looking for resources or assistance in dealing with your specific sewer collection system issue(s); please feel free to contact us at your convenience at (405) 675-1400. OMAG staff is available to answer your questions and connect your municipality with outside professional resources, if needed. 

The Copper Sulfate solution

After an overflow, when asked what was done, many have answered with, we poured Copper Sulfate down the line after the overflow. What is the effectiveness of this strategy?  

 To be effective the chemical must come in contact with the roots. Roots grow in from above the water level down to the water. Short term results can be achieved when the roots are contacting the water, but once the above the water level, the chemical effect is greatly decreased. If the roots are not touching the water, there is no effect on the roots. It just flows by.

 Coper Sulfate is most effective as a capful flushed down a private septic line. In the case of a septic tank, it is determined the best results is at 2lbs for 300-gallon tank. (Without destroying the good bacteria)

 To be effective in a sewer main, what is the ratio of the amount of water to how many pounds of product are needed? Do you calculate or just pour some down the line? How do you know it works as it should? Is it to diluted to perform properly?

 If the line is holding and slow draining, how does this chemical flow down to reach the obstruction before diluting? After Jetting, then placing the chemical in the flow, the distance downstream to the roots, the amount of water in the pipe, and the flow will dictate how effective this type of treatment is. Once again, it will only affect roots in contact with the water, but that is about it.

 A better alternative is a jetter applied root control chemical. When this is applied through a jetter, it encompasses the entire pipe and coats all the roots protruding in the sewer pipe, not just what is in contact with the flow level.

 Once opened, and only utilizing Copper Sulfate, is this line place on a regular treatment schedule? If using the flow line only and adding this chemical, it will need to be re-treated at least every other month, as this is a nutrient rich source for roots, and they will quickly be back at the water level to get more water and creating obstructions for debris to catch on and build back up.

 When applying into a manhole or sewer system, do you wear gloves or eye protection? When you stand over the manhole dumping it in are you wearing respiratory protection from the dust and fumes or are you potentially inhaling these contaminates? This is an acidic chemical and needs to be treated with care.

 Even with a Jetter applied chemical, you will still need to return yearly, but far less than pouring copper sulfate down the manhole.

 There is also an option for a root control grant available through OMAG. With this grant it will remove the roots for two years, but roots are living and always growing and will be back even with the best chemicals. The question becomes how frequently do you want to come back and retreat to keep from having another backup on the same section?

Do Your Citizens Know to Call the City BEFORE Incurring Plumbing Charges????

Most citizens who file claims for reimbursement of plumbing charges are unaware that they must notify the City before incurring those charges or they will not be reimbursed the plumbing bill even if the issue is with the city’s sewer line.  When should they contact the City/Town to report a sewer issue? 

• If they see, hear, or smell anything that may be a sewage overflow or backup.

• Hear gurgling noises from the toilets or drains

• Notice a strong sewer smell but see no evidence of a sewage backup or overflow

• Experience slow drains throughout the house

These are all signs that the city’s sewer main line may be about to back up or overflow.  Citizens should be advised to call the City’s emergency number or the non-emergency police department number so that the person on call can be contacted.  If the work crew determines there is no issue in the city’s sewer line, the homeowner will then need to contact a plumber to determine if there is an issue in the house line. 

Problem items that contribute to sewer backups and blockages include:

• Disposable or “flushable” wipes

• Condoms, feminine products (tampons), and other personal hygiene products

• FOG – fats, oils and grease.  These materials harden and create blockages both in the house line and the main sewer line.  Running hot water and soap down the drain DOES NOT prevent grease build-up and blockages. 

·         Food scraps.  Anything with a fat content can contribute to grease-clogged pipes.  Wipe all greasy, oily, creamy, or buttery food residue from dishes before you wash them.

The City’s sanitary sewer department cleans miles of sanitary sewer lines each year but they still need the citizens to help in preventing sewer overflows.

OMAG in Action: Volume 2

OMAG in Action - Issue 2

OMAG in Action: Volume 1

OMAG in Action - Issue 1

Hierarchy of Safety Controls

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The hierarchy of control involves the following steps: Elimination – removes the cause of danger completely. Substitution – controls the hazard by replacing it with a less risky way to achieve the same outcome. Engineering Controls protect workers by removing hazardous conditions or by placing a barrier between the worker and the hazard. Administrative Controls are fairly simple: warning alarms, for example, are just that – alarms that let you know when something isn’t right. The last control is PPE, Personal Protective Equipment, which really is exactly what the name implies: protection you use personally. 

Elimination, the top of the hierarchy, is the complete elimination of a hazard, the most effective way to protect workers. For example, bad housekeeping. The best practice would be to eliminate the hazard by picking up or moving what’s in the walking path to prevent a slip, trip or fall. Establish travel paths or walkways through work areas. The concept of elimination isn’t as simple as it sounds. If elimination fixed every hazard, everyone would be doing it. However, if elimination is on the table and is available to an employer, they should use elimination for taking care of the hazard. If elimination doesn’t work, you move on down to the substitution.  

Substitution identifies a hazardous situation and uses a different product or piece of equipment that is not hazardous. An example would be, instead of sandblasting, use a non-silica containing abrasive material. The downfalls of substitution are the quality and cost, such as replacing lead-based paint with titanium white. The product must not produce unintended consequences, such as airborne dust, due to inhalation and accumulation of particles in the lungs that can lead to occupational lung disease. Basically, if you can substitute a smaller product with a larger product, that has a larger particle, then that should be your aim. 

Engineering controls are designed to get as close to eliminating the hazard as possible, without eliminating it completely. This is done by designing something in the facility or a piece of equipment to reduce the hazard or employee’s exposure to the hazard. The design must be used properly and be certified by ANSI. A glove box for handling hazardous material and chemicals is an example of isolation and engineering control. The box allows the employee to do the work while not being exposed to the material/chemical due to the material being in the box. Engineering controls don’t work out for everyone, they must be used perfectly if used. Engineering controls are the best option when the hazard cannot be eliminated.  

Administrative controls (written policies & procedures) are at the point where you identify the hazard and recognize the hazard as one that can be tolerated or lived with as long as there are boundaries and precautions in place, so levels of exposure are not exceeded. Administrative controls can be used in conjunction with engineering controls or PPE such as planning the day job in the evening time in the summer due to heat stress and dehydration of workers.  

Finally, PPE. Of all of the controls in the Hierarchy of Controls, Personal Protective Equipment (PPE) is the one most people are familiar with.  Why?  Well, PPE is quick, easy, often less expensive than other options, and readily available. You should know that PIOSH and OSHA consider PPE a “last resort.” So, while a personal fall arrest system is considered PPE, a guardrail is not. While a respirator is considered PPE, ventilation is not. PPE includes material that must be worn on a job site such as earplugs, gloves, hard hats, safety glasses, steel toe boots, or reflective vests. PPE is not a game of guesswork. You must know what PPE is sufficient and insufficient such as earplugs rated for noise reduction. There must be a noise survey done to determine what kind of earplugs will reduce the noise to acceptable levels. PPE must be taken care of and used properly. A full-body harness could save your life but also could cause serious internal bodily harm if it’s not worn properly. 

In a nutshell, take your time and observe the areas around you. If you see a hazard, go through the steps of the hierarchy of control to see which level will best suit the hazard to prevent the worker from getting injured. Safety is common sense, and we can learn to manage hazards better by using the hierarchy of controls.  

Reducing Firefighters’ Chemical Exposures from Contaminated Skin or Personal Protective Equipment (PPE)

Through direct contact to the skin or off-gassing from PPE, firefighters can be exposed to potentially hazardous chemicals both during and after firefighting activities.  

OMAG is issuing this alert to Oklahoma Fire Departments to raise awareness of this type of chemical exposure and encourage them to train firefighters in ways to minimize it.  

Minimize breathing contaminants:  

• Maintain and test SCBAs routinely to ensure their proper function  

• Use proper respiratory protection from initial attack, overhaul, and investigation  

• Remain upwind of the fire if not directly involved in the response  

• Provide as much natural ventilation as feasible to burned structures before starting investigations and when responders are not wearing respiratory protection  

Minimize skin absorption:  

• Wear long hoods that are unlikely to come untucked during response  

• Keep protective ensembles on during overhaul  

• Do gross field decontamination of PPE to remove as much soot and particulate matter as possible  

• Wash hands immediately and shower as soon as possible after a fire response  

• Use moistened wipes to remove as much soot as possible from head, neck, jaw, throat, underarms, and hands immediately while still on the scene  

• Clean PPE, gloves, hood, and helmet immediately after a fire response  

• Have turnout gear cleaned routinely in accordance with NFPA 1851 or the latest version. 

Minimize inhalation of chemicals released from contaminated gear:  

• Remove SCBA and hood last when doffing gear during decontamination  

• Doff gear before entering the rehab area  

• Consider bagging contaminated PPE and securing it in an apparatus compartment  

• Do not take contaminated clothes or PPE home or store them in your vehicle  

• Decontaminate the interior of fire vehicles after fires 

Training firefighters to adhere to these precautions can save lives, prolong careers, and save thousands of dollars in workers’ compensation claims. 

Fire Extinguisher Basics

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It’s important to help employees understand that with proper training and education, fire extinguishers can save lives and property. Many adults may not know how or when to use fire extinguishers. OMAG encourages our municipalities to hold fire safety training, teaching employees how to use a fire extinguisher, when to use one, and what a particular fire extinguisher’s limit are.  

There are five primary classes of fire extinguishers, each designed to put out different kinds of fires. Class A is for use on ordinary materials like cloth, wood, and paper. Class B is for use on combustible and flammable liquids like grease, gasoline, oil, and oil-based paints. Class C is used on electrical equipment like appliances, tools, computers, or other equipment that is plugged in. Class D extinguishers are for use on flammable metals and are specialized extinguishers usually for factories. Any time an SDS (Safety Data Sheet) recommends a product requiring a Class D extinguisher, there should be one present in the facility. Finally, there are Class K fire extinguishers, which are used for vegetable oils and animal fats used in cooking appliances. Most offices, vehicles, shops, and homes now use multipurpose fire extinguishers that are labeled Classes A, B, & C and can handle almost any type of fire. 

Help employees decide when to use a fire extinguisher: 

Fire extinguishers can be helpful on a small fire that hasn’t left its point of origin. Consider providing a checklist to help people prepare to use a fire extinguisher on a fire. 

• Have I alerted others in the facility that there is a fire? 

• Has someone called the fire department? 

• Am I physically able to use a fire extinguisher? 

• Is the fire small and contained in a single object (frying pan, wastebasket)? 

• Do I have a clear escape route, should my efforts fail? 

Use a fire extinguisher when all these questions are answered “Yes.” If you are unsure about whether or not it is safe to use an extinguisher, alert others, leave the building, and call 911 from a mobile phone. 

Teach employees how to use a fire extinguisher: 

When operating a fire extinguisher, remember the acronym PASS – 

Pull the pin. Hold the extinguisher with the nozzle pointing away from you, don’t grip the squeeze handles, and pull the pin preventing the squeeze handles from closing on themselves. 

Aim low. Point the extinguisher at the base of the fire where the fuel is. 

Squeeze the lever slowly and evenly to disperse the fire repelling agent. Squeeze the lever intermittently to give you more control and fire fighting time. Avoid holding the trigger down and dispersing the agent all at once. 

Sweep the nozzle from side to side, covering the fuel area, and move in on the fire as it recedes. 

Educate employees on the importance of fire extinguisher maintenance: 

Remind employees to inspect fire extinguishers at least monthly. We don’t use them often, but when we need them, we need to be able to get to them and they must be reliable. 

• Easy access in an emergency – nothing is blocking or limiting our ability to get to it. The fire extinguishers are mounted and clearly marked with signage denoting where they are. 

• Inspect the extinguishers monthly – make sure the gauge arrow is in the green showing it is properly pressurized. Make sure all parts (can, hoses, nozzles) are free from damage and not clogged. Shake the extinguisher thoroughly to keep the retardant powder from compacting. 

• Make sure the extinguisher is clean and that there is no dust, oil, or grease on the outside of the extinguisher. 

• Make sure there are basic instructions on the use of the fire extinguisher on the label and that they are legible. 

Hands-on training by a qualified instructor is the best way to teach employees how to properly use a fire extinguisher. The experience will help employees better understand the procedures and processes in fighting a fire and the instructor can point out any concerns, field questions by the participants, and provide encouragement to anyone who doesn’t feel confident in their ability to use the extinguisher. 

Counterfeit Respirators

Be Careful When Purchasing Respirators 

Some supply distributors are selling counterfeit respirators that are falsely being sold as NIOSH- approved and may not be capable of providing appropriate respiratory protection to workers.  

NIOSH-approved respirators have an approval label on or within the packaging of the respirator (i.e. on the box or within the user instructions). Additionally, an abbreviated approval is on the FFR (filtering facepiece respirator) itself. You can verify the approval number on the NIOSH Certified Equipment List or the NIOSH Trusted-Source page to determine if the respirators you are intending to purchase have been approved by NIOSH. NIOSH-approved FFRs will always have one of the following designations: N95, N99, N100, R95, R99, R100, P95, P99, or P100.  

Signs a respirator may be counterfeit:  

• No markings at all on the filtering facepiece respirator  

• No approval number on the filtering facepiece respirator or headband  

• No NIOSH markings  

• NIOSH spelled incorrectly  

• Presence of decorative fabric or other decorative add-ons (e.g. sequins)  

• Claims for the approval for children (NIOSH does not approve any type of respiratory protection for children)  

• Filtering facepiece respirator has ear loops instead of headbands  

Before buying large quantities of respirators from a third-party marketplace or unfamiliar website, look for the following possible warning signs:  

• Third-party marketplaces 

• If a listing claims to be “legitimate” or “genuine,” it probably isn’t  

• Examine transactions history and feedback/comments section if possible  

• Are there fluctuations of items traded over time (high and low periods of transactions)?  

• Are there price deviations and fluctuations (is it too good to be true)?  

• Look at the quantity a seller has in stock (advertising unlimited stock could be an indication the respirators are not approved)  

• Does the seller break marketplace policy and hide their contact information within images to circumvent filters?  

• On websites  

• Is the primary contact email address connected to the website or is it a free email account?  

• Look for bad grammar, typos, and other errors  

• Watch for cookie-cutter websites, where sellers interchange several websites, making mistakes (mixed up logos, site partially unfinished, blank pages, a nonsense privacy policy, misspelling the domain)  

If you are purchasing safety equipment for your employees (like respirators) and you find an incredible deal, do some further research before buying. Don’t put your limited resources and your employees at risk. Make sure the equipment has a proper NIOSH approval.