CREATING A SAFETY PROGRAM for YOUR SMALL BUSINESS HCA
Pre Course Quiz 1. 2. 3. 4. 5. 6. What is an incident? ______________________________ Power tools must be fitted with guards and safety switches. True or False Employees attitude may affect safety. True or False Fall protection is required any time you use a ladder over 6 feet. True or False Employees are must take personal responsibility for their safety, their co-workers and others on a jobsite. True or False MSDS’s are required for most chemicals used at a worksite and should be kept locked up in the supervisor’s office for Safety. True or False 7. Guard rails should be installed along all open sides and ends of platforms. True or False 8. When setting up goals for safety on a worksite the acceptable number of incidents should be set at______. (give a number) 9. If a fatality happens on a jobsite due to negligence, unsafe conditions, etc. Who is usually responsible and held accountable? Owner of company, Supervisor, Co-worker. Circle one 10. Safety rules and guidelines and must always be written. True or False 11. It is OSHA’s responsibility to establish and implement a written hazard communication program. True or False 12. Approximately 32 million workers work with or are potentially exposed to chemical hazards. True or False 13. MSDS’s are printed on a mandatory standard OSHA form. 14. PPE is usually an optional step for employees in dealing with hazardous chemicals. True or False 15. Haz. Com is commonly referred to as Right to know True or False 16. What is a Near Miss? _______________Do these need to be reported and investigated? True or False 17. Employers are responsible to pay for all PPE for their employees. True or False 18. Safety Inspections should be conducted on all sites at least yearly. True or False 19. OSHA mandates First aid and CPR training for workers on sites. True or False 20. AHA stands for “All Hands Attention”. True or False
Four Elements Of a Workplace Safety Program • Element #1 - Management, Leadership and Employee Involvement. • Element #2, 3 – Worksite Analysis and Hazard Prevention and Control. • Element #4 – Safety and Health Training and Education.
ELEMENT #1 Management/Leadership/Employee Involvement • Employer and employee involvement and communication on workplace-safety and health issues are essential. • Post the company’s written safety and health policy for all to see. • Involve all employees in policy making on safety and health issues. • Everyone must take an active part in Safety Activities.
Management/Leadership/Employee Involvement • What is Workplace Safety? • Definition: The process of protecting employees from work related illness and injury. It starts by the development of a company Environmental, Safety and Health Policy statement and implementation of a work place safety plan and program.
Ac-ci-dent (ak-si-duhnt) noun 1. an unexpected unplanned, uncontrollable, and undesirable event.
Ac-ci-dent (ak-si-duhnt) 2. an unexpected unplanned, and undesirable event. accidents can be controlled
Basic Principles of Good Safety Management § § § Management Commitment Documented Safety Philosophy Safety Goals and Objectives Committee Organization for Safety Line Responsibility for Safety Supportive Safety Staff Rules and Procedures Audits Safety Communications Safety Training Accident Investigations Motivation
Management/Leadership/Employee Involvement • We must promote the goal of ZERO INCIDENT PERFORMANCE through planning. • Safety Goals must be Communicated- They must be Realistic and they need to reflect the Safety Culture of your organization. • Your Safety Culture requires strong commitment from the top and Safety must truly be the #1 priority. It must become an integral part of your business and Safety must become EVERYONE’s responsibility.
Basic Safety Philosophy Every Incident can be avoided. No Job is worth getting hurt for. Every job will be done safely. Incidents can be managed. Safety is Everyone’s Responsibility. Safety/Best manufacturing practices Safety standards, procedures and practices must be developed. • Training- Everyone must understand AND meet the requirements. • Working Safely is a Condition of Employment • •
Benefits of a Zero Incident Safety Policy • Safety standards are communicated to all employees. • Responsibilities for implementing standards are understood and accepted • Records will document how standards and Best Management Practices are met. • Internal management control • Cost Avoidance • Improved Quality • Better Productivity • Team Building • Unsafe behavior stands out • Unsafe behavior is Unacceptable • Safe Work is influenced through peer pressure • Consistent planning and task execution
Key Safety Principles • Working Safely is a condition of employment. • Each employee is expected to give consideration to the prevention of injury to self and co-workers. • Involvement and thinking of all people in the safety process is valued and expected. • Continual Improvement is the goal. • Individuals and teams must be recognized for their adherence to and advancement of safety.
Maintaining an Incident Free Environment • • Shared Vision Cultural Alignment Focus on Incident Control Upstream Systems Feedback Maintain the 4 – A’s Cultural Change Commitment
What a Safety Statement might look like (This is an EXERCISE) It is the intent of XYZ Industries to provide a safe work environment for all our workers and the wellness of our people, families and communities. We embrace healthy habits and behaviors. It is also our intent to properly manage any incidents that occur so as to minimize injury and other forms of loss. A well managed workplace safety program can benefit our company in countless ways. In order for XYZ Industries to achieve our goals, we have developed a safety program outlining our policies and procedures regarding employee health and safety. Each and every individual must become familiar with the program, follow and enforce the procedures, and become an active participant in this workplace safety program. While management (workplace safety officer and safety committee) will be responsible for developing and organizing this program, its success will depend on the involvement of each employee. We look forward to your cooperation and participation.
Implementing Your Workplace Safety Program Use of Inspections, surveillances, incident reporting, AHA’s Investigations, corrective actions, provide Safety leadership
Workplace Safety Program • Purpose- To reduce work-related injury & illness • Content- The program should include any policy, procedure, training that protects workers from work-related injury and illness while on the job. • Concerns- Promote & reward safe practices at work, reducing injuries & illnesses at work and eliminating fatalities at work.
Co-Workers Affect Each other’s Safety • Employees’ health and safety are affected not only by their own actions but by those of their coworkers. • Senior management must: Help employees manage hazards associated with their work (tasks or responsibilities). They must determine that employees are fit for work. Fitness involves: drug and alcohol issues, physical and emotional well being, and fatigue and stress.
Create Ownership of the program • Workers need to be involved in the creation and use of the workplace safety program for it to succeed. For Example: • Your company is responsible for supplying appropriate safety equipment, but employees are responsible for wearing personal protective equipment at the appropriate time and place. • Your company should provide training to help employees carry out their assignments, but workers are responsible for attending this training, asking questions and telling supervisors if they do not understand what is being explained.
Allow for Continuous Improvement In workplace safety and health, continuous improvement is about: • Seeking better ways to work • Measuring performance • Reporting against set targets • Evaluating compliance with procedures, standards and regulations • Understanding the causes of incidents and injuries and • Openly acknowledging and promptly correcting deficiencies.
Measuring Performance can be measured by: • Reduction in frequency of lost-time injury • Reduction in frequency of medical treatment (beyond first-aid care) injury. • Reduction in number of sick days used • Lower workers compensation costs • Lower medical benefits payments ( doctor’s visits, prescription drugs)
OSHA (29 CFR, 1970) covers nearly all employees • The general duty clause reads “Each employer shall furnish…a place of employment which is free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees. ” • Need to communicate employees rights under the OSHA Act, including the right to file a complaint free from discrimination and explain the elements of a valid complaint.
Employees Rights under OSHA Act – Get training from your employer on chemicals you are exposed to during your work and information on how to protect yourself from harm. Employers must establish a comprehensive, written hazard communication program (Chemical Hazard Communication) Your employer must label chemical containers, make material safety data sheets with detailed hazard information available to employees, and train you about the health effects of the chemicals you work with and what the employer is doing and what you can do to protect yourself from these hazards. – The program must list the hazardous chemicals in each work area, how the employer will inform employees of the hazards of non-routine tasks (for example, the cleaning of reactor vessels), and hazards associated with chemicals in unlabeled pipes and how the employer will inform other employers at a multi-employer worksite of the hazards to which their employees may be exposed. – Get training from your employer on a variety of other health and safety hazards and standards that your employer must follow. These include lockout-tagout, bloodborne pathogens, confined spaces, construction hazards and a variety of other subjects. – Access relevant exposure and medical records. (29 CFR 1910. 1020)
Employees Rights under OSHA Act – Request information from your employer on safety and health hazards in your workplace, chemicals used in your workplace, tests your employer has done to measure chemical, noise and radiation levels, precautions you should take and procedures to be followed if you or other employees are involved in an incident or are exposed to hazardous chemicals or other toxic substances. – Request copies of appropriate standards, rules, regulations and requirements that your employer should have available at the workplace. – Review the Log and Summary of Occupational Injuries and Illnesses (OSHA 300) at a reasonable time and in a reasonable manner or have an authorized representative do so for you. (29 CFR 1904. 7) – Access relevant exposure and medical records. (29 CFR 1910. 1020) –
Employees Rights under OSHA Act – Employers must inform you of the existence, location and availability of your medical and exposure records when you first begin employment and at least annually thereafter. Employers also must provide these records to you or your designated representatives within 15 working days of your request. When an employer plans to stop doing business and there is no successor employer to receive and maintain these records, the employer must notify you of your right of access to records at least 3 months before the employer ceases to do business. – Observe any monitoring or measuring of toxic materials or chemicals, as well as harmful physical agents, such as noise, and see the resulting records. If the exposure levels are above the OSHA limit, the employer must tell you what will be done to reduce the exposure -- the right to observe monitoring exists only where monitoring is performed pursuant to a standard that provides employees with the right to observe. • REQUEST ACTION FROM YOUR EMPLOYER TO CORRECT HAZARDS OR VIOLATIONS.
Employees Rights under OSHA Act – You may ask your employer to correct hazards even if they are not violations of specific OSHA standards. Be sure to keep copies of any requests you make to your employer to correct hazards. • FILE A COMPLAINT WITH OSHA if you believe that there are either violations of OSHA standards or serious workplace hazards. – File a complaint and request OSHA to conduct an inspection if you believe serious workplace hazards or violations of standards exist in your workplace. You can file a complaint online, in writing, by telephone or fax. If you want an OSHA inspector to come inspect your workplace, put your complaint in writing and send it to the OSHA office nearest you. (OSH Act, Section 8), (29 CFR 1903. 11) – Request in your written complaint that OSHA keep your name confidential if you do not want your employer to know who filed the complaint. (OSH Act, Section 8) • BE INVOLVED IN OSHA'S INSPECTION of your workplace.
Employees Rights under OSHA Act – Have an authorized employee representative (such as a union representative) accompany the OSHA compliance officer during the inspection tour. (OSH Act, Section 8), (29 CFR 1903. 8) The authorized employee representative has a right to accompany an OSHA compliance officer (also referred to as a compliance safety and health officer (CSHO) or inspector) during an inspection. Under no circumstances may the employer choose the workers' representative. Where there is no union or employee representative, the OSHA inspector must talk confidentially with a reasonable number of workers during the course of the investigation. Respond to questions from the compliance officer and tell the compliance officer about workplace hazards, particularly if there is no authorized employee representative accompanying the compliance officer on the inspection "walkaround. " (OSH Act, Section 8)
Employees Rights under OSHA Act – You and your coworkers have a right to talk privately and confidentially to the compliance officer whether or not a workers' representative has been chosen. • You may point out hazards, describe injuries or illnesses or near misses that resulted from those hazards and describe past complaints about hazards. Inform the inspector if working conditions are not normal during the inspection. Make sure that the inspector is aware if equipment has been shut down, windows opened or other conditions changed from normal. FIND OUT RESULTS OF AN OSHA INSPECTION. Find out the results of OSHA inspections and request a review if OSHA decides not to issue a citation. If health hazards are present in your workplace, a special OSHA health inspection may be conducted by an industrial hygienist. This OSHA inspector may take samples to measure levels of chemicals or other hazardous materials. OSHA will let the employee representative know whether your employer is in compliance. The inspector also will gather detailed information about your employer's efforts to control health hazards, including results of tests your employer may have conducted.
Employees Rights under OSHA Act • • GET INVOLVED in any meetings or hearings to discuss any objections your employer has to OSHA's citations or to changes in abatement deadlines. File a discrimination complaint (under Section 11(c) of the OSH Act) within 30 days if you are punished or discriminated against for exercising your safety and health rights or for refusing to work (not guaranteed by the OSH Act) when faced with an imminent danger of death or serious injury and there is insufficient time for OSHA to inspect. REQUEST A RESEARCH INVESTIGATION ON POSSIBLE WORKPLACE HEALTH HAZARDS. – Contact the National Institute for Occupational Safety and Health (NIOSH) to request a health hazard evaluation if you are concerned about toxic effects of a substance in the workplace. PROVIDE COMMENTS AND TESTIMONY TO OSHA during rulemaking on new standards. •
Employees Rights under OSHA Act • • – File an appeal of the deadlines that OSHA sets for your employer to correct any violation in the citation issued to the employer. Write to the OSHA Area Director within 15 working days from the date the employer posts the notice requesting on extension of the abatement deadline if you feel the time is too long. (29 CFR 1903. 17) FILE A DISCRIMINATION COMPLAINT. File a discrimination complaint (under Section 11(c) of the OSH Act) within 30 days if you are punished or discriminated against for exercising your safety and health rights or for refusing to work (not guaranteed by the OSH Act) when faced with an imminent danger of death or serious injury and there is insufficient time for OSHA to inspect. REQUEST A RESEARCH INVESTIGATION ON POSSIBLE WORKPLACE HEALTH HAZARDS. – Contact the National Institute for Occupational Safety and Health (NIOSH) to request a health hazard evaluation if you are concerned about toxic effects of a substance in the workplace. • • PROVIDE COMMENTS AND TESTIMONY TO OSHA during rulemaking on new standards.
Occupational Safety and Health Program Includes • • COMPLIANCE WITH STANDARDS ANNUAL OSH INSPECTIONS ABATEMENT OF HAZARDS PROCEDURES TO REPORT HAZARDS WITHOUT FEAR OF REPRISAL OCCUPATIONAL SAFETY & HEALTH TRAINING ACCIDENT REPORTING & INVESTIGATIONS HEALTH SURVEILLANCE PROGRAMS PERFORMANCE EVALUATIONS
Management Leadership and Employee Involvement in S&H Issues • Your plan should include statements on the value of workplace safety and why management is committed to it. • A list of locations where written safety and health policies are posted for all employees to see. • A schedule of when and where regular meetings are held that address employee safety and health issues. • A stipulation that abiding by all safety and health rules is a condition of employment.
Workplace Safety Training • Staff member training and education about safety rules and their responsibilities in the workplace will pay off in a safer and healthier workforce. Remember: the health and safety of employees are affected not only by their own actions but by those of co-workers. • Ensure that everyone in the workplace is properly trained: managers, supervisors all full and part time and temporary workers. • Make sure no one does any job that appears unsafe.
Workplace Safety Training • Hold emergency preparedness drills for workers. Include nature of drill and expectations for employees during the drill. • Pay close attention to employees learning new operations to make sure they have the proper job skills and awareness of the hazards. Expectations must be provided in the trainings. • Supervisors and managers must be trained to recognize hazards and understand their responsibilities. Provide them with guidelines for reporting and correcting hazards.
Workplace Safety Training Supervisors and managers are: • Responsible for daily monitoring of workplace safety practices. • Accountable for mentoring, advising and counseling staff members who are not performing up to written policies and expectations. • Authorized to recommend a staff member for remedial training in a skill or on a machine or in attitude, as required.
Supervisors Responsibilities • • • SET EXAMPLE KNOW, COMMUNICATE, AND ENFORCE STANDARDS OBSERVE EMPLOYEES WORKING ANALYZE & DISCUSS SAFETY HAZARDS COMMUNICATE WITH YOUR EMPLOYEES FOLLOW UP WITH YOUR EMPLOYEES TRAIN ALL EMPLOYEES ON RULES & PROCEDURES CONDUCT INSPECTIONS ACKNOWLEDGE SAFETY BEHAVIOR INVESTIGATE & REPORT ACCIDENTS CORRECT UNSAFE UNHEALTHFUL CONDITIONS
Supervisors Responsibilities • INFORM ALL EMPLOYEES BEFORE THEIR INITIAL ASSIGNMENT OR WHEN A NEW HAZARDOUS CHEMICAL IS INTRODUCED INTO THEIR WORK AREA- (Hazardous Communication Standard) • TRAIN EMPLOYEES HOW TO: IDENTIFY AND PROTECT THEMSELVES FROM CHEMICAL HAZARDS RECOGNIZE THE PHYSICAL AND HEALTH HAZARDS OF CHEMICALS IN THEIR AREA OBTAIN AND USE THE MSDS DOCUMENT ALL TRAINING!!!!!!!!!!
8 BASIC HAZARD COMMUNICATION REQUIREMENTS • DETERMINE HAZARDS • COMPOSE MSDS • PROVIDE CUSTOMERS WITH MSDS AND WARNING LABELS • KEEP MSDS ON FILE AND ACCESSIBLE • LABEL CONTAINERS • DO NOT REMOVE OR DEFACE LABELS • INFORM AND TRAIN EMPLOYEES • WRITTEN HAZCOM PROGRAM
Take an Active part in Safety Activities • COMPLY WITH Occupational Safety & Health STANDARDS • REPORT WORKPLACE HAZARDS • REPORT TO SUPERVISOR ILLNESSES/ INJURIES OR PROPERTY DAMAGE RESULTING FROM INCIDENT – IMMEDIATELY!!
Take an Active part in Safety Activities • Actively participate in the daily safety meetings. • Supervision should encourage employees to lead in regular safety meetings. • Provide input in the development, review and suggestions of improvements to safe work procedures, AHA’s, SOP’s, and in incident report investigations, corrective actions and lessons learned, safety committee.
Take an Active part in Safety Activities • Safety must be everyone’s concern. In most small companies the role of a workplace safety coordinator can be incorporated into someone’s job description. In larger groups a safety director, officer or manager is usually in charge of the workplace safety program and appoints or sets up a safety committee to assist in implementing the safety program. • Committee’s can be made up of many different people with different resources and abilities.
Take an Active part in Safety Activities • Encourage employees to lead and participate in the Daily Safety Meetings. • Taking personal actions and working directly with supervisors to identify, control, or eliminate potential safety hazards. • Reporting of all injuries, near misses or accidents immediately. • Involvement in incident/accident investigations corrective actions and sharing Lessons Learned.
Accident/Incident Investigations Today we want to look at: • • Goals of Accident Investigation Securing the Accident Scene Root-Cause Analysis The importance of Investigative Interviews Assisting in Accident Investigations Reporting Near Misses The Role of Policies, equipment and training on Accident Prevention.
REVIEW • All injuries can be prevented • Management is responsible for preventing injuries • Working safely is a condition of employment • Training employees to work safely is essential and everyone must be involved. • Prevention of personal injuries is good business (and good science!)
Four Elements Of a Workplace Safety Program • Element 1 - Management, Leadership and Employee Involvement. • Element 2, 3 – Worksite Analysis and Hazard Prevention and Control. • Element 4 – Safety and Health Training and Education
Element #2 - Worksite Analysis • • • Analyze all workplace conditions to identify and eliminate existing or potential hazards. An outline of the procedure for reporting hazards Perform analysis on a regular and timely basis. Make certain all employees know and understand current hazard analysis for all jobs and processes. Focus workplace design on all physical aspects of the work environment, including the following: – – – • • Size and arrangement of work space Physical demands of the tasks to be performed Design of tools and other devices people use The fundamental goal of a workplace design is to improve people’s ability to be productive, without error or accident, for extended time periods. Proper workplace design improves both safety and productivity. We want to eliminate hazards during the design or planning stages of a project Review incident causes, inspection results to help identify trends Knowledge of Emergency Response Plans and procedures and participation in drills
Identifying and Evaluating Potential Hazards SAFETY AUDITS / INSPECTIONS Purpose - Inspection of work areas and audits of safety programs are tools that can be used to identify problems and hazards before these conditions result in accidents or injuries. Audits also help to identify the effectiveness of safety program management and can be used as a guide to assure regulatory compliance and a safe workplace. Responsibilities • • Management Design and schedule audit and inspection procedures for all work areas, processes and procedures. Conduct routine audits and inspections Ensure audits are conducted by employees who understand the various safety programs and policies Supervisors conduct informal daily safety inspections and ensure all unsafe conditions are corrected conduct documented weekly inspections and ensure all unsafe conditions are corrected Corrections • All safety deficiencies found during audits and inspections should be corrected as soon as possible. Documentation of corrections should be made on the audit or inspection sheet. And conditions that present a hazards are to be corrected or controlled immediately.
Identifying and Evaluating Potential Hazards SAFETY AUDITS / INSPECTIONS Types of Inspections • • Supervisor & Management Daily Walk-through: this is an undocumented inspection that is made daily prior to startup and shift change to ensure the facility and equipment are in safe conditions for Employees. All noted unsafe areas are placed in a safe condition prior to Employees working in the area. Weekly Supervisor Inspections are conducted and recorded with a Employee. This documented inspection provides a focus to ensure current hazard controls are still effective, equipment is in safe condition and safe work practices are in use. Discrepancies are listed on the inspection sheet, recorded on work orders for correction. The inspection sheet is forwarded to the Safety Manager for review and logging to track discrepancy correction. Monthly Safety Committee Inspection. Each month members of the Safety Committee will tour the entire facility with the Safety Manager. This tour is to ensure Safety Committee Members are familiar with all areas of the operation. Record of problem areas, committee recommendations and deficiencies will be recorded and provided to management. Noise Surveys are conducted at least annually, or whenever facility modifications are made that impact the ambient or specific work area noise levels, Noise surveys are conducted by qualified persons with calibrated instruments
Identifying and Evaluating Potential Hazards SAFETY AUDITS / INSPECTIONS Equipment Inspections Are conducted to ensure specific safety equipment is in good working order and will function when needed. Examples and frequencies are: • • • All construction equipment - Daily prior to use – (use form and file) Sprinkler Inspection - Monthly Boiler Checks- Daily, Weekly , Monthly, Yearly Emergency Lighting Test - Monthly Fire Extinguisher Inspections - Monthly Safety Equipment Inventories - Monthly Emergency Lighting 90 Min. Test - Semiannually Respirator Inspections- Before / After Use (Monthly at a minimum) Hand tools – Daily Scaffolding – Daily
Regularly and thoroughly maintain equipment and vehicles.
Fire Extinguisher INSPECTIONS
Daily Hand Tool - INSPECTIONS
Identifying and Evaluating Potential Hazards SAFETY AUDITS / INSPECTIONS Program Audits are conducted to check the administration of specific safety and health programs. Program Audits of the following shall be conducted annually. • Accident Prevention • • • • Fire Prevention Material Handling Flammable Material Storage Lockout-Tagout Hazard Communication Personal Protective Equipment Confined Space Entry Asbestos Controls Boiler Safety Bloodborne Pathogens Contractor Safety Electrical Safety Tool Safety Hot Work Respiratory Protection
Site Safety Inspections CONSTRUCTION SUPERVISOR SAFETY INSPECTION CHECKLIST Date: Job No. (s): Location: Crew Member: Supervisor: COMMENTS/CORRECTIVE ACTION ITEM Housekeeping (Garbage, cleanliness, electrical cords, ladders) Drinking water/ sanitation requirements/first aid kit Electrical (such as proper grounding, lock & tag and GFCI [good condition, inspected]) Proper personal protective equipment (PPE) Walking/working surfaces (tripping hazards, slippery surfaces, floor holes) Electrical tools (guards in place; good condition, stored properly) Cranes/ rigging equipment (for example: slings, properly stored and inspected) Excavation (properly sloped or shored; permits; inspections; barricaded daily)
Site Safety Inspections Flammables/combustibles (fire extinguishers, welding and cutting equipment) Hot work (Personal Protective Equipment, permit, combustibles, flammables protected) Material Safety Data Sheets onsite with containers labeled Scaffold system fully assembled; tags; inspections; fully planked guardrails Proper barricading/ warning signs (trenches, fuel areas, storage construction sites) Fire extinguishers (monthly inspection, accessible, on mechanized equipment) COMMENTS:
Identifying and Evaluating Potential Hazards SAFETY AUDITS / INSPECTIONS It is every employees responsibility to be on the lookout for possible hazards. Report Immediately: Ø Slippery floors and walkways – open holes in floors Ø Tripping hazards, such as hose links, piping, extension cords, etc. Ø Missing (or inoperative) entrance and exit signs and lighting Ø Poorly lighted stairs Ø Loose handrails or guard rails Ø Open, loose or broken windows Ø Dangerously piled supplies or equipment (HOUSEKEEPING), OILY RAGS Ø Unlocked doors and gates Ø Electrical equipment left operating, frayed cords, no LOTO, Panel doors left open, blocked access to electrical panels Ø Leaks of steam, water, oil other liquids, Roof leaks Ø Blocked aisles – Blocked fire doors Ø Blocked fire extinguishers, sprinkler heads, Evidence of smoking in non-smoking areas Ø Evidence of any equipment running hot or overheating Ø Safety devices not operating properly – Warning Signs Not In Place Ø Machine, power transmission, or drive guards missing, damaged, loose or improperly placed
Work Place Analysis thru Hazardous Commmunication Identification and Training The OSHA Standard § 32 million workers work with or are exposed to one or more chemical hazards. § Are an estimated 650, 000 existing chemical products and this poses a serious problem for exposed workers. § OSHA issued the Hazard Communication standard 29 CFR 1910. 1200, to address this issue. § Hazardous Communication standard is based on a simple concept; that employees have both a need and a RIGHT TO KNOW the hazards and identities of the chemicals they are exposed to when working.
Hazard Communication Safety Training • OSHA’s Hazard Communication standard gives employees the right to know about chemical hazards in the workplace. Employers have an obligation to provide employees with training, information, Personal Protective Equipment and other safety measures dealing with chemical hazards. • Employees need to remember to: o Take training seriously and pay attention o Read labels and Material Safety Data Sheets o Know where to find the Material Safety Data Sheets o Use appropriate Personal Protective Equipment o Know correct emergency procedures o Use safe work Habits
Element #3 - Hazard Prevention and Control • Regularly and thoroughly maintain equipment and vehicles. (we just looked at equipment Inspections) • Ensure that employees know how to use and maintain personal protective equipment (PPE) • Train employees in proper procedures for handling specific situations • Monitoring for air quality, heat stress, noise, ergonomics and other job hazards • Emergency Action Plans and procedures - Fire, life safety and first aid issues
Standard Operating Procedures
Standard Operating Procedures • • • Drug Free workplace Recognition and Awards Audits and Surveillances Incident Reporting & Investigation Lessons Learned General Safety SOP’s- Lets discuss
Ensure that employees know how to use and maintain personal protective equipment (PPE)
Protecting Employees from Workplace Hazards • Employers must protect employees from hazards such as falling objects, harmful substances, and noise exposures that can cause injury. • Employers must: – Use all feasible engineering and work practice controls to eliminate and reduce hazards. – Use personal protective equipment (PPE) if the controls don’t eliminate the hazards. • PPE is the last level of control!
Engineering Controls If. . . • The work environment can be physically changed to prevent employee exposure to the potential hazard, Then. . . • The hazard can be eliminated with an engineering control.
Work Practice/ Administrative Controls • If. . . • Employees can change the way they do their jobs and the exposure to the potential hazard is removed, • Then. . . • The hazard can be eliminated with a work practice or administrative control. • Remember… PPE is the last level of control!
Examples of PPE Body Part Protection
1926 Subpart E, Personal protective and life saving equipment – 1926. 95, Criteria for personal protective equipment – 1926. 96, Occupational foot protection – 1926. 100, Head protection – 1926. 101, Hearing protection – 1926. 102, Eye and face protection – 1926. 103, Respiratory protection – 1926. 104, Safety belts, lifelines, and lanyards – 1926. 105, Safety nets – 1926. 106, Working over or near water
P. P. E. COMPLIANCE IT IS THE RESPONSIBILITY OF THE EMPLOYEE, SUPERVISOR AND HEALTH AND SAFETY REPRESENTATIVE TO ENSURE THAT PERSONAL PROTECTIVE EQUIPMENT IS CORRECTLY CHECKED, STORED AND MAINTAINED!
P. P. E. COMPLIANCE Employer Assess workplace for hazards – Provide PPE – Determine when to use – Provide PPE training for employees and instruction in proper use Employee - Use PPE in accordance with training received and other instructions. - Inspect daily and maintain in a clean and reliable condition. –
Establishing a PPE Program • Procedures for selecting, providing, training, and using PPE as part of an employer’s routine operation • Assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of PPE • Select the proper PPE • Train employees who are required to use the PPE
Training Employees required to use PPE must be trained to know at least the following: • Why training is necessary? • When PPE is necessary • How will it protect them? • What are its limitations? • What type of PPE is necessary? • How to properly put on, take off, adjust and wear the PPE
Training • Proper care and maintenance of the PPE • How to clean and disinfect? • How to identify signs of wear? • What is its useful life & how is it disposed?
Who Pays for PPE? • On November 14, 2007, OSHA announced a new rule requiring employers to pay for almost all personal protective equipment that is required by OSHA’s general industry, construction, and maritime standards. • Many employers already pay for approximately 95% of the employees PPE.
Who Pays for PPE? Employee-owner PPE and replacement PPE: • When an employee provides his/her own PPE, the employer must ensure that the equipment is adequate to protect the employee from hazards at the workplace. • The employer is required to pay for replacement PPE used to comply with OSHA standards. • However, when an employee has lost or intentionally damaged PPE, the employer is not required to pay for its replacement.
PPE Summary Employers must implement a PPE program where they: • Assess the workplace for hazards. • Use engineering and work practice controls to eliminate or reduce hazards before using PPE. • Select appropriate PPE to protect employees from hazards that cannot be eliminated. • Inform employees why the PPE is necessary, how and when it must be worn. • Train employees how to use and care for their PPE, including how to recognize deterioration and failure. • Require employees to wear selected PPE.
Emergency Action Plans and Procedures - Fire, life safety and first aid issues • • • • CONTIGENCY PLAN FOR SEVERE WEATHER & OTHER EMERGENCY RESPONSE SITUATIONS An emergency response plan is a living document and will be changed as conditions and personnel change. It will be the responsibility of the HS manager to update the Emergency plan and to keep the material current. I. INTRODUCTION This plan provides guidance to employees at the MECT 3&4 site and future buildings concerning emergency actions and provides a clear statement of required employee responses during an emergency. II. REPORTING AN EMERGENCY The person who discovers an emergency should use any of the following methods for prompt notification: 1. Telephone: (554 -4713) or 911 and then (Dave Wells 383 -7051 –ECC H&S) 2. Sound blast horn - 3 blasts to notify evacuation to Rally point by the III. PROTECTIVE ACTIONS 1. Sheltering-in-place is the primary protective action in response to most hazardous material releases. Notification of sheltering-in-place normally will be announced over the emergency notification system. Sheltering-in-place requires employees to: Go indoors immediately. Close all windows and doors. Turn off all sources of outdoor air (fans, air conditioners, ventilation system).
Emergency Action Plans and Procedures - Fire, life safety and first aid issues In addition to Fires, and medical emergencies we also need to address: • Different severe weather conditions – Tornadoes, Hurricanes, lightning, earthquake, floods, etc. • Bomb Threats • Violent Employee or Site Shooter
Four Elements Of a Workplace Safety Program • Element 1 - Management, Leadership and Employee Involvement. • Element 2, 3 – Worksite Analysis and Hazard Prevention and Control. • Element 4 – Safety and Health Training and Education
Establishing a Safety and Health Training Program Today we are going to look at: v New Employee Orientation – View an actual Orientation film v Activity Hazard Analysis for every task performed and how to write them. v A Written Safety Program – What it should look like. v Trade or equipment specific safety training. v OSHA 10 -30 hour Training Classes v First Aid /CPR/AED/Blood Borne Pathogen
New Employee Orientation Needs to include: • • • Emergency Contacts- emergency plan, evacuation procedures, meeting places When & where daily safety meetings are held Deal w/ Harassment, Fighting, Horseplay – Zero Tolerance- Removal from site Firearms, weapons, drugs or alcohol prohibited & site testing policies Hazard Communications • Employee Responsibilities- Report ALL Accidents, no matter how slight - this allows for prompt medical attention, and investigation and elimination of the cause that may place others in harm's way. Accidents must be reported to Employee's immediate supervisor and ECC personnel. Immediately correct or report any unsafe condition or hazard noted in the workplace. Employees must support the Zero Accident philosophy to assist us to provide an injury free workplace. Employees are responsible to ask questions when they do not understand. Lack of knowledge is the greatest cause of accidents in the workplace. Report to work "FIT FOR DUTY" Report the use of prescription medication that may have an effect on their ability to safely perform tasks or operate equipment. • • •
New Employee Orientation Needs to include: • Personal Protective Equipment Requirements • Required Work Clothing • Rigging • Fall Protection – 100% at all times when there is fall potential of 6 feet or more • Scaffolding • Fork Lift, Scissor and Boom Lift Operation requirements • LOCKOUT/TAGOUT PROCEDURES • Ladder Safety • Electrical Safety • Housekeeping • Fire Protection • Floor Openings • Overhead Hazards • Heavy Equipment • Other Hazards & Controls- No cell phones while operating equipment • Activity Hazard Analysis • Quality Control Issues • Any other site specific rules – Smoking, eating, radios, Phones, visitors
What have we learned so far? v Must first establish a Safety Statement, work on developing a Safety Culture by following key safety principles, set goals and maintain a commitment for maintaining an Incident Free Environment. v Implementation of the Safety Program involves all workers, from top management to all workers and Supervisors are a key component to making it work. A supervisor or other individual can be assigned Specific responsibilities and can head up a company safety committee that works on developing the safety plans and programs. The safety committee also reviews all incidents, accidents, near misses to determine contributing factors. While focusing on determining causes, it must always be remembered that the overall GOAL is to prevent similar Accidents from happening again. v Worksite Analysis are frequently needed and Audits and Inspections help us identify issues and corrective actions can be made prior to an incident happening. We must develop Standard Operating Procedures to give workers a plan to guide their work.
What have we learned so far? v. A big part of the work place analysis comes thru education of all workers to the hazards of chemicals and is addressed thru training employees on Hazardous Communication Standards v. Understanding the Hierarchy of controls: Engineering – Management – Personal Protective Equipment. We have learned that when exposure to hazards cannot be engineered out of normal operations and when safe work practices and administrative controls don’t provide sufficient protection …. then Personal Protective Equipment (PPE) may be required to keep our workers safe. v. We just looked at the essential need for New Employee Safety Orientations.
SAFETY on Department of Defense CONSTRUCTION PROJECTS Most government contracts incorporate by reference a number of federal acquisition regulation (FAR) clauses that describe a variety of routine requirements. The clause that is most significant with respect to construction safety is FAR clause 52. 236 -13(c), which states that "if this contract is for construction or dismantling, demolition or removal of improvements with any Department of Defense agency or component, the contractor shall comply with all pertinent provisions of the latest version U. S. Army Corps of Engineers Safety and Health Requirements Manual EM 385 -1 -1 in effect on the date of the
SAFETY on Department of Defense CONSTRUCTION PROJECTS • While many of the requirements of EM 385 closely parallel OSHA's requirements, there are 2 notable differences: 1. Specific requirements for a written site-specific accident prevention plan. 2. The development of activity hazard analyses that identify potential hazards by each phase of a construction project & identify the precautions the contractor will take to control those hazards • These two things will drive and guide all work on a DOD Project.
Written Accident Prevention Plans • The accident prevention plan required by EM 385 is not some vague, generic document typical of many construction companies that lists general safety rules such as prohibiting horseplay, or possession of firearms, alcoholic beverages or illicit drugs on the job, and mandatory wearing of longsleeved shirts, hard hats and safety glasses. • Rather, it must be a detailed, site-specific written plan that describes the management processes that will be used to prevent accidents from occurring on a specific construction project.
Written Accident Prevention Plans It is a written plan that explains how a contractor intends to prevent accidents from occurring on a specific construction project.
Written Accident Prevention Plans • Unlike OSHA requirements, EM 385 requires that company officials responsible for specific aspects of the plan be identified. • For example, note that element 1, the signature sheet, requires the title, signature and phone number of the person who prepared the plan, the person who approved the plan and any individuals who concurred with the plan. • Such information would allow Do. D contracting officers, project managers or safety specialists to identify specific company personnel that could answer questions concerning the plan or, more importantly, discuss problems concerning its implementation.
Written Accident Prevention Plans • Accident reporting, must address who, how and when information will be provided on exposure data such as man hours worked that can be used to evaluate safety performance, how major accidents will be reported, who will conduct accident investigations, and how and when reports and logs will be completed.
Written Accident Prevention Plans Vague generic safety and health programs will not meet the jobspecific requirements of EM 385 1 -1
Conducting An Effective Activity Hazard Analysis An introduction to the “Five Step Process” of Activity Hazard Analysis (AHA)
Activity Hazard Analysis If the accident prevention plan is viewed as the strategic guide for accident prevention…. . Activity Hazard Analysis might be seen as the tactical guide. Section 01. A. 09 of EM 385 1 -1 states that "activity hazard analyses shall be prepared by the contractors performing the work activity. "
Activity Hazard Analysis Activity hazard analysis requires contractors to be proactive in aggressively identifying hazards that can be anticipated and controlling them rather than looking back with 20/20 hindsight.
Activity Hazard Analysis - Key Terms • What’s the Job or Activity? • What are the Hazards? • What’s an exposure? • What is Analysis?
Activity • Workers in their first year with their employer account for more than 50% of disabling claims. Why? • ( list three possible explanations )
AHA Purpose § Effective AHA’s help the employer recognize and control hazards and exposures in the workplace. § How might the employee’s perception of a “hazard” differ from that of the employer or supervisor?
Activity Why is an AHA more effective than walk-around inspections in reducing accidents in the workplace?
Probability is defined as: the chance that a given event will occur. We need to determine if Probability of an accident is low -medium or high and if HIGH- the chances are very likely that an accident could occur.
Activity Hazard Analysis STEP 1 • Step One - Watch the work being done What are some effective methods to watch the work being done?
Activity Hazard Analysis STEP 1 • Step One - Watch the work being done • Why is it important to involve the employee?
AHA Step Two - Break the job down into steps COE EM 385 -1 -1 para 01. A. 13. b: Work will not begin until the hazard analysis for the work activity has been accepted by the Government’s designated authority and discussed with all engaged in the activity, including the contractor, subcontractor(s), and Government on-site representative. “Principle Steps” column identify “Sequences of Work” Distribution, etc. Contractor “Construction Schedule or Construction Progress Chart” is a good guide to identify “Sequences of Work”
AHA Step 3 • Step Three - Describe the hazards in each step of the task. • One of the primary purposes of the AHA is to make the job safer. • The information gathered in this step will be valuable in helping to eliminate and/or reduce hazards associated with the job, and improve the system weaknesses that produced them.
AHA Step 3 RECOMMENDED CONTROLS PRINCIPAL STEPS Slinging, lifting and landing loads • “Potential Hazard” column can have “General Safety” as a potential hazard to include minimal PPE. “General Safety” should be identified for every phase of work. Any power or electrical work POTENTIAL SAFETY / HEALTH HAZARDS (Note: Standard PPE required for this activity includes Hard Hat, Safety glasses with side protection, and safety-toe footwear. Additional PPE requirements are listed in this column depending on the hazard. This constitutes the Workplace Hazard Assessment per 29 CFR 1910. 132. Additional assessments and PPE selection when needed will be documented on a JSA or daily briefing sign-in form and signed by the SSHO in accordance with ECC SOP ESQ 6. 1. Hazard assessment and respirator selection for inhalation hazards are documented in the site Respiratory Protection Plan. ) Load shifts, crushing. Ensure proper rigging is used Ensure employees are clear of load Ensure a tag-line is used Make sure lifting gear (wire rope chokers, nylon straps, shackles) are all of adequate capacity for loads and that slings and attachments are stored correctly. All rigging equipment must be tagged. If not tagged, must be taken out of service. Contact with or GFCI’s are mandatory in the use of any and all electrical tools and/or equipment. Exposure to electricity Electric shock Electrocution Electric power tools and equipment will be grounded or double insulated. Inspect all power tools and electric flexible cords daily prior to use to ensure insulation and plug connections are intact. Do not use damaged or defective power tools. Power tools with spliced or tapped cords will be tagged “Do Not Use” and removed from site immediately. Deck Installation Falls, Pinch Points, Drops 100% Tie off while decking if parapet wall is under 42 inches. Never walk backwards with deck to avoid falling in the hole Always keep hands on decking and set down, no “slinging” of deck Grinding Eye protection, hand protection Use face shield and gloves while grinding to avoid sparks or small pieces of metal from getting in the eye or striking the face or hand Hot work permit required for all spark producing tools daily with fire watch. Operate welding and cutting machines o Injury to eyes o Burns o Shock o o Obtain fire permit-If not already on existing HOT permit, obtain new fire permit. Follow all conditions of permit (fire watch, fire extinguisher, etc. ) Inhalation of fumes o o o Inspect your equipment and ensure it is working properly and in good condition. Use proper PPE (eye shields/welding helmets/clothing/gloves) Ensure enough ventilation. Use smoke extractors if necessary. Use barricades/barricade tape to prevent vehicle or pedestrian traffic through work area Only personnel trained and qualified to operate welding equipment should do so. o Starting fire o Properly dispose of cutting and welding spoils. o Distractions o Pollution to the environment
Identifying types of hazards • Acceleration: When we speed up or slow down too quickly • Toxic: Toxic to skin and internal organs. • Radiation: Non-ionizing - burns, Ionizing - destroys tissue.
Identifying types of hazards • Ergonomics: Eight risk factors – 1. High Frequency; – 2. High Duration; – 3. High Force; – 4. Posture; – 5. Point of Operation; – 6. Mechanical Pressure; – 7. Vibration; – 8. Environmental Exposure.
Identifying types of hazards • Pressure: Increased pressure in hydraulic and pneumatic systems. • Mechanical: Pinch points, sharp points and edges, weight, rotating parts, stability, ejected parts and materials, impact. • Flammability/Fire: In order for combustion to take place, the fuel and oxidizer must be present in gaseous form.
Identifying types of hazards • Biological: Primarily airborne and blood borne viruses. • Violence In The Workplace: Any violent act that occurs in the workplace and creates a hostile work environment that affects employees’ physical or psychological well-being.
Identifying types of hazards • Explosives: Explosions result in large amounts of gas, heat, noise, light and over-pressure. • Electrical Contact: Inadequate insulation, broken electrical lines or equipment, lightning strike, static discharge etc. • Chemical Reactions: Chemical reactions can be violent, can cause explosions, dispersion of materials and emission of heat.
Accident Types • Struck-by: – A person is forcefully struck by an object. The force of contact is provided by the object. • Struck-against: – A person forcefully strikes an object. The person provides the force or energy. • Contact-by: – Contact by a substance or material that, by its very nature, is harmful and causes injury.
Accident Types • Contact-with: – A person comes in contact with a harmful substance or material. The person initiates the contact. • Caught-on: – A person or part of his/her clothing or equipment is caught on an object that is either moving or stationary. This may cause the person to lose his/her balance and fall, be pulled into a machine, or suffer some other harm. • Caught-in: – A person or part of him/her is trapped, or otherwise caught in an opening or enclosure.
Accident Types • Caught-between: – A person is crushed, pinched or otherwise caught between a moving and a stationary object, or between two moving objects. • Fall-to-surface: – A person slips or trips and falls to the surface he/she is standing or walking on. • Fall-to-below: – A person slips or trips and falls to a level below the one he/she was walking or standing on.
Accident Types • Over-exertion: – A person over-extends or strains himself/herself while performing work. • Bodily reaction: – Caused solely from stress imposed by free movement of the body or assumption of a strained or unnatural body position. A leading source of injury. • Over-exposure: – Over a period of time, a person is exposed to harmful energy (noise, heat), lack of energy (cold), or substances (toxic chemicals/atmospheres).
Step 4 – Control Measures To help you come up with ideas for the best solution ask the following: (a) How can the conditions be changed to eliminate the hazard? (b) What can the employee do to prevent an accident or eliminate the hazard? It is now time to identify the desired control Measures for each Hazard. “Recommended Controls” column identify site specific control measures to be implemented to eliminate or reduce each hazard identified in the “Potential Hazard” column to an acceptable level.
Engineering Controls • Consist of substitution, isolation, ventilation, and equipment modification. • These controls focus on the source of the hazard, unlike other types of controls that generally focus on the employee exposed to the hazard. • The basic concept behind engineering controls is that, to the extent feasible, the work environment and the job itself should be designed to eliminate hazards or reduce exposure to hazards
Management Controls Management controls may result in a reduction of exposure through such methods as changing work habits, improving sanitation and hygiene practices, or making other changes in the way the employee performs the job.
Personal Protective Equipment When exposure to hazards cannot be engineered completely out of normal operations or maintenance work, and when safe work practices and administrative controls cannot provide sufficient additional protection from exposure, personal protective clothing and/or equipment may be required.
Step Five – Safe Operating Procedure List the competent person here List equipment to be used for the phase of work such as crane, backhoe, powder actuated tools, electric saws/drill, etc. List training requirements for the phase of work such as fall protection, confined space, HAZCOM, qualified equipment operators, safe use of ladders, HAZWOPER, etc.
LETS BUILD AN AHA
LETS BUILD AN AHA
EM 385 vs. OSHA Requirements • EM 385 includes some more stringent technical provisions than CFR 1926. • In particular, the level of emphasis that EM 385 places on employee training and job site inspections suggests that EM 385 views these two elements as being critical for preventing accidents. • This makes sense because employee training is crucial for informing employees of the potential hazards to which they are exposed and the precautions that should be taken to mitigate those hazards, especially those that are not particularly obvious.
EM 385 vs. OSHA Requirements • EM 385 includes provisions for ongoing training, specifically section 01. B. 03 which requires that "safety meetings shall be conducted to review past activities, plan for new or changed operations, review pertinent aspects of appropriate activity hazards analyses (by trade), establish safe working procedures for anticipated hazards, and provide pertinent safety and health training and motivation. " • Meeting must be held at least once a week……….
EM 385 vs. OSHA Requirements • Some other areas of stricter compliance in EM 385 are in areas such as : * Confined Space procedures * Cumulative Trauma Prevention. * Operations of All- Terrain Vehicles * Lock-out / Tag-out • Each project is different and depending on the USACE QA, some areas of enforcement may be much stricter than on others, but ultimately the EM 385 1 -1 must be your guideline for site H&S compliance in addition to any OSHA, city, state and any other applicable regulations. • An online copy of EM 385 may be found at www. usace. army. mil/inet/usace-docs/eng-manuals/em 385 -1 -1/toc. htm
Four Elements Of a Workplace Safety Program • Element #1 - Management, Leadership and Employee Involvement. • Element #2, 3 – Worksite Analysis and Hazard Prevention and Control. • Element #4 – Safety and Health Training and Education.
REVIEW: What have we learned about developing a Safety Program v A written APP can benefit our bottom line and the end result will depend on how well you implement your APP and manage your programs. v Management must commit to safety and participate if APP is to get results. v Written Safety Policy statement to get employee awareness & involvement. v Displaying the required OSHA posters. v Recordkeeping- Document everything v Safety Analysis – Goal is to Eliminate Hazards - AHAs v Health & Safety Training – Supervisor Key – All must be trained- Orientations v Safety Inspection v Immediate Accident Reporting and Accident Investigations v Program Reviews •
NO IT’S NOT THE END IT’S JUST THE BEGINNING
Abbreviations • AHA – Activity Hazard Analysis • APP – Accident Prevention Plan • BMP - Best management practices • PPE – Personal Protective Equipment • DOD – Department of Defense • OSH – Occupational Safety and Health Program • OSHA – Occupational Safety and Health Administration • 29 CFR – Code of Federal Regulations. Haz. Woper - 29 CFR 1910. 120 - the OSHA / EPA requirement to have all employees trained if they will be handling, managing or shipping hazardous wastes. • USACE – United States Army Corps of Engineers • NFPA – National fire protection axsociation • PEL – Permissable exposure limit • RMP – Risk Management Plan • EPA – Environmental Protection Agency
EXTRAS Power Points – “Creating a Safety program for your small buisness”, Competent person, confined space entry, office safety, lighting plan, safety orientation in Spanish, eye safety, basic Electrical safety, Safety Representatives Training, Safety Supervisor training, Safety Audits, Supervisors and managers responsibilities, Scaffold awareness Training, Lock. Out/Tag. Out standard. Numerous Safety Forms - SOP’s on LOTO, Fire Protection, Hand Power tools, Deficiency tracking log, Assured Grounding Program, ECCO SLIP reporting form, AHA’s, Equipment inspection forms, daily excavation/trench form, Equipment inspection stickers, fire extinguisher inspection forms, Crane inspection forms, Equipment operator qualification forms, Demolition check list, contractors visitor sign in sheet, confined space Pre-entry check list, HASP compliance agreement form, Safety audits and SITE INSPECTION PROGRAM INSTRUCTIONS, Focus on 4 Poster, 1 st aid log in sheet, Tailgate meeting sign in sheet, PLAN OF THE DAY FORM, EM 383 1 -1 crane critical lift ck. List. ALSO, Sub-contractors Prequalification Packet for DOD work, Safety Orientation in English/Spanish, Generic Health and Safety plan, Blank Accident Prevention plan, and A
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