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Twas the night before Christmas, when all through the house, not a creature was stirring, not even a…

Hold on a minute, Gertrude! Everyone knows the story, but let’s back up and take a behind-the-scenes look at this annual elfin visit. Has it ever occurred to anyone that this is the largest distribution event of the year and it originates from a facility in the coldest climate on Earth? Has anyone given thought to the last minute hustle and bustle that takes place enabling that jolly old elf to make his run? And has consideration been given to the hazards he himself must face as he delivers the goods?

As part of the company’s sustainability program, gasoline and horsepower have been replaced by pixie dust and reindeer power. Unorthodox? Sure. However, a safe and pollutant-free journey is all that matters.

First of all, the facility is staffed by a population of employees of, shall we say “a smaller stature.” The director of distribution, aka the boss, or “Boss Claus” as some like to call him, considers all employees to be family so he is always watching out for their well-being. For this reason, even though OSHA has no jurisdiction at the facility that far north, he still holds all workers to OSHA standards. That said, all materials handlers who operate forklifts to load that magical sled, are, in accordance with 1910.178(l), Powered Industrial Trucks, properly trained. These elfin workers are so playful and fun-loving that it’s all the boss can do to keep them from racing and stunt driving (1910.178(n)(9)).

Confined Spaces

Once the heaping mountain of packages is securely fastened upon the sled, the boss and his wife, who serves as EHS manager and head baker, go out into the frigid Arctic air for a pre-flight safety inspection. Reaching into the sled’s glove box, they pull out the operator’s manual which contains the pre-flight checklist. Headlights and brake lights…check. Seat belt….check. All signs and warnings legible…check. Then the last step prior to take-off is the matter of fuel. As part of the company’s sustainability program, gasoline and horsepower have been replaced by pixie dust and reindeer power. Unorthodox? Sure. However, a safe and pollutant-free journey is all that matters.

It’s this journey that will have the boss literally traversing the globe….from his Arctic headquarters at the top of the world to the tundra of Antarctica where a handful of geological scientists have been particularly good this year. He will, no doubt, be subject to extreme thermal stress hazards, which, being a recognized hazard, is citable under OSHA’s General Duty Clause (a different kind of Claus). Risks associated with both heat and cold stress are dependent upon several factors including air temperature, relative humidity, air/wind speed, clothing and worker acclimatization to the environment. And you thought that red suit was just for looks.

Although well protected against the elements, the hazards are far from over. There will be cell towers and power lines to dodge (electrical approach distances 1910.333 Table S-5); fall hazards (1910.23(c)); and then of course there is the matter of squeezing that round, little belly through some tight chimneys (confined spaces -1910.146). Our hero to the young (and young at heart) has appointed Rudolph, with his intrinsically safe red nose, to serve as entry supervisor and attendant and notified all local fire departments ahead of time in case an emergency rescue is needed. Let’s just hope the residents have not left a smoldering fire or else he will have to consult his OSHA Pocket Reference Guide to look up emergency response procedures at 1910.38.

The boss is very good at what he does and is always safe because he knows that millions of children will be disappointed if he is disabled, but there is one hazard that he finds as irresistible as a puppy’s own tail…all the milk and cookies he will consume going from house to house. Not necessarily healthy, but he consumes it all with guilt-free gusto knowing there is no OSHA standard on cookies and milk.

So as the boss lifts his sled from the final stop, he bellows into the cold night air…

“Merry Christmas to All and to All a Safe Night!”