Safety Health Management System Training Lesson 4

Safety & Health Management System Training Lesson 4 – Hazard Prevention & Control

Safety Health Management System (SHMS) Webinar Series In this series of webinars developed under the Susan Harwood Grant, you will learn: o Lesson 1 - OSHA and the Importance of Having a Safety Health Management System (SHMS) o Lesson 2 – Management Commitment & Leadership o Lesson 3 – Worksite Analysis o Lesson 4 – Hazard Prevention & Control o Lesson 5 – Safety & Health Training

Lesson 4 Contents 1. 2. 3. 4. 5. 6. 7. 8. Objectives Hazard Controls Preventive Maintenance Managing Change Occupational Health Program Emergency Planning Contractor Safety Management Review

Objectives • Learn to implement systems to eliminate or prevent hazards. • Learn about different types of hazard controls: – Preventive maintenance and managing change – Emergency planning, occupational health programs, and contractor safety

Hazard Control • Some control measures are more effective than others at reducing the hazard. • Be aware of the different types of controls available and the benefits and limitations of each. • Each of the SHMS models introduced in Lesson 1 require the implementation and maintenance of hazard controls for risk reduction.

Hazard Control • The first consideration for controlling hazards is to eliminate the hazard or substitute a less hazardous material or process. • An example of this method is utilizing a waterbased paint rather than a solvent-based paint. • This control measure minimizes flammable vapors as well as eliminates health concerns associated with solvent-based paints.

Hazard Control • When it is not possible to eliminate a hazard, you should control the hazard using the following methods (in order): – Engineering controls – Administrative controls – Personal Protective Equipment

Hazard Control • Applying this hierarchy is a systematic approach to identify the most effective method of risk reduction. You want to select the highest-level feasible control.

Hazard Control - Engineering • If hazard elimination or substitution is not feasible, engineering controls should be considered next. • Engineering controls are physical changes to the work area or process that effectively minimize a worker's exposure to hazards.

Hazard Control - Engineering • Enclosed Hazard – Enclosure of the hazard, such as enclosures for noisy equipment. • Isolate Hazard – Isolation of the hazard with interlocks, machine guarding, welding curtains, and other mechanisms. • Remove / Redirect Hazard – Removal or redirection of the hazard such as with local and exhaust ventilation. • Redesign Workplace – Redesign of workstation to minimize ergonomic injuries.

Poll Question #1

Hazard Control • If engineering controls are not feasible you must then consider implementing administrative controls. • Administrative controls – No physical changes – Limits daily exposure to hazards by • Adjusting work tasks or schedules.

Hazard Control - Administrative • Examples of administrative controls include: – Limited time exposure to hazards – Written operating procedures, – Work practices, and – Safety and health rules for employees.

Hazard Control - Administrative – Alarms, signs and warnings – Buddy system – Training – Stretching exercises and break policies

Poll Question #2

Hazard Control - PPE • Personal Protective Equipment (PPE): – Used when hazards cannot be eliminated through engineering or administrative controls, – Must consider personal protective equipment (PPE) necessary for employee protection

Poll Question #3

Hazard Control - PPE • According to OSHA, PPE is acceptable as a control method in the following situations: – Engineering controls do not eliminate hazard – While engineering controls are being developed – Administrative controls and safe work practices are not sufficient protection, and – During emergencies.

Hazard Control • The most effective control measure = all three hazard control types. • For example, consider an operation that generates silica dust. – A ventilation system may be installed to control dust (engineering control), – Employees are trained and a sign is posted to warn employees of dangers (administrative controls) and – Goggles are required to operate the equipment (personal protective equipment).

Hazard Control • Scenario CHC Determines Hazard Control – CHC was awarded a contract to replace an exhaust fan on the roof of a high school. Mary White sends a copy of the JHA that was developed for this task (see Lesson 3) so that the Operations crew can review and develop the appropriate hazard controls. – The Operations Foreman, Jack Mc. Donald, is particularly concerned about the fall protection for the roof where the work will be completed. He proceeds through the hierarchy of controls to ensure adequate protection to prevent falls.

Hazard Control • Hazard Elimination. Can this work be done below 4 feet where fall protection would not be required? The Operations crew agreed that the work cannot be done below 4 feet, and therefore engineering controls must be considered. • Engineering Controls. The Operations crew reviewed the roof area where the work will be conducted. There are no physical barriers such as railings at the roof's edge and it is not feasible to install them for this project alone. Administrative controls were then considered.

Hazard Control • Administrative Controls. Fall protection warning lines could be installed 6 feet from the roof's edge to warn employees when they are close to it. Although this is not a physical barrier, employees will be warned of their proximity to the roof's edge. Additionally, one employee will be stationed near the warning line when work is being done close to it. Employees have been trained in safe work practices to prevent falls. • Personal Protective Equipment. Some of the employees will work in an area with a roof skylight that is not guarded with railings. These workers will be instructed to wear personal fall arrest equipment and lifelines attached to an appropriate anchor point.

Preventive Maintenance • A breakdown of equipment in your facility may cause hazards. • For example, – A pump that fails during the process of delivering hazardous materials through your production facility may create a hazardous condition. – The best way to prevent breakdowns or failures is to monitor and maintain your equipment regularly. Determine what hazards could occur if your equipment is not maintained properly and plan to detect failures before they occur.

Preventive Maintenance • Implement a written preventive maintenance program, • Safety Equipment Examples - A confined space entry gas monitor • Determine the intervals of required maintenance on your equipment

Preventive Maintenance • Non-Safety Equipment Example. – Forklifts in your facility have daily and annual inspection requirements. If there is any deterioration in the hydraulic cylinders or tires the capacity rating reduces and there may be a failure during a lift. Establish a regular inspection on a preventive maintenance schedule to keep these devices operating safely.

Preventive Maintenance • When developing systems, be sure to include one for Disciplinary actions that cover all (employees, and contractors) • Ensure that it is applied consistently • Hazard Correction tracking –hazards that have been identified must be tracked in order to eliminate and implement controls

Poll Question #4

Manage Change • A management of change program ensures that any modifications or additions to your equipment or processes are understood and controlled, and includes: – Updating relevant building or equipment drawings, – Modifying safety procedures, and – Training employees on the changes.

Manage Change • Such a program is required for processes that utilize highly hazardous chemicals that are subject to the OSHA Process Safety Management program (29 CFR 1910. 119). • However, this program is beneficial for all changes in your business, even if OSHA doesn't require it.

Manage Change • Conduct an analysis of new equipment and processes • Develop a system to conduct: – Comprehensive survey, – JHA, or – Other worksite analysis technique on new equipment or processes • Implement appropriate controls before being placed into service

Manage Change • Example - Suppose your business introduces a new raw material into the production process. You must consider the following: – How the material will be stored and handled – What PPE may be required if engineering or administrative controls are not effective at controlling exposures – If appropriate eyewash and safety showers are available, and – How to train your employees. .

Occupational Health Program • An occupational health program allows you to respond effectively to workplace injuries and illnesses and to monitor potential health problems. • Medical Services & First Aid – You must make available physician services, first aid and CPR to your employees. This does not mean that you must provide health care, but you are expected to get medical help when medical conditions arise from work-related events.

Occupational Health Program • Medical Screening – Some OSHA standards require medical screening of employees. Medical screening monitors if exposure to a hazard leads to a potential decline in health. – An example is exposure to noise and the Hearing Conservation Program.

Occupational Health Program • Employee Medical Records – The maintenance and confidentiality of employee medical records are crucial. – According to OSHA, you must maintain an employee's medical records for the duration of employment plus 30 years. – Records include employment medical questionnaires or histories, results of laboratory tests or medical screening, or physicians' opinions from work-related injuries or illnesses. – Develop a system to maintain these records and to ensure that they are kept in confidence.

Occupational Health Program • For more information on employee medical records, see the OSHA standard Access to Employee Exposure and Medical Records (29 CFR 1910. 1020).

Occupational Health Program • Wellness Program – In your occupational health program, consider including health and wellness programs for your employees. – Smoking cessation programs, diet and nutrition education, and physical fitness programs are examples of programs that encourage employees to lead a healthy lifestyle, which helps them be healthy for work

Poll Question #5

Emergency Planning • Effective planning for emergencies and non -routine events is another mechanism of controlling hazards and avoiding employee injuries. You have already learned about the legal requirements for emergency planning.

Emergency Planning • Written Emergency Plan – Determine the actions that employees will take in the event of a fire, chemical release or natural disaster. – Keep in mind those employees with disabilities, language barriers and limited literacy. – Develop the written plan and train your employees prior to an emergency. Don't forget unexpected events such as terrorist acts or workplace violence. – List emergency contacts and ensure the document is updated regularly to reflect current personnel. You can find a template for writing Emergency Action and Fire Prevention Plans on Department of Labor’s website.

Emergency Planning • Emergency Eyewash and Safety Showers – Install emergency eyewash and safety showers where chemicals are used or stored to provide quick flushing if an employee is exposed to the chemical. – Pay close attention to areas such as battery charging stations, maintenance operations, and laboratories where corrosive materials are often used and require prompt flushing to prevent significant skin or eye damage.

Emergency Planning • Emergency Eyewash and Safety Showers – Include these units in your preventive maintenance program. It's important to inspect and flush the units regularly to verify operation and to ensure the water lines are clear of debris prior to emergency use.

Emergency Planning • Emergency Drills – Practice the elements of your emergency action plan by conducting regular fire and/or natural disasters drills. – Ensure that employees know how to evacuate buildings, where to take shelter and who will take headcounts.

Emergency Planning • Emergency Contacts – Post emergency numbers at centrally located bulletin boards and update the list regularly to reflect current personnel. – Ensure that employees who will operate critical equipment following an emergency are properly trained.

Emergency Planning • Local Emergency Responders – Coordinate your emergency planning with the local emergency responders, such as the fire department and/or hazardous materials teams. – Invite them to your facility to teach them your specific worksite hazards and to improve the emergency response time.

Contractor Safety • Most companies hire contractors at some time to perform specific tasks for which their own employees may not have the time or expertise. • It is in your best interest to ensure that contractors at your worksite(s) are appropriately trained and follow all safe work practices.

Contractor Safety • Selection Criteria – Establish selection criteria for hiring contractors. – Consider the contractor's past performance in safety and health during the bid process. – This may include requesting data from their OSHA 300 Log for several years. – Ensure that contractors have an effective safety and health management program in place prior to entering your worksite.

Contractor Safety • Oversight – Establish oversight, coordination and enforcement to ensure the contractor safety and health program is adequate and implemented properly. – Verify that contractors comply with applicable safety and health regulations by conducting regular inspections of the area where the contractors are working.

Contractor Safety • Establishment of Procedures – Develop appropriate entry and exit procedures for the contractors. – If cigarette smoking is allowed on your worksite, establish safe locations for contract employees to smoke, keeping away from storage of flammable or dust-explosive materials.

Contractor Safety • Prompt Control of Hazards – Ensure prompt correction and/or control of any hazards that are identified under the contractor's control. – Consider penalties such as contractor correction and/or contractor dismissal for repeated noncompliance by contractors, vendors or individuals.

Contractor Safety • Injury & Illness Reporting – Develop a system so that all injuries and illnesses that occur during work performed on a contract are reported to you or someone in your company.

Poll Question #6

Contractor Safety – Exercise 1 • CHC Selects a Crane Contractor – Instructions: Evaluate the following data submitted from three different crane contractors. – Each contractor has approximately the same number of employees. – Based on their safety performance alone, which contractor would you select?

Contractor Safety – Exercise 1 Company # of Injuries (Last 3 Years)(a) SHMS in Place? Employee S&H Training Required? A 8 No No B 1 Yes C 3 Yes (a) Injuries that company recorded on OSHA 300 Log.

Contractor Safety – Scenario • CHC’s Welding Contractor – CHC hired a contractor to assist with welding operations while installing an exhaust fan on the roof of the high school. – Mark Rebell was walking the job site when he noticed the welding contractor did not enclose the welding area, where practical, with appropriate welding curtains and did not have a fire extinguisher nearby during the welding operation. – Although no one was injured and there was no building damage, this action clearly violated the standard CHC safe practice

Contractor Safety – Scenario • Mark immediately notified the CHC Operations Foreman. Together, they told the workers of the welding contractor to halt the work. • Then, they called the Foreman of the welding contractor to discuss the correct and safe work practices. • CHC wrote a Near-Miss Report to document the action and reviewed the corrective actions with the welding contractor.

Contractor Safety – Scenario • The welding contractor was told that if another unsafe act was observed, CHC would remove his workers from the job site and his company would be removed from the list of approved contractors. • If the contractor had violated a safety rule that had the potential to cause death or serious physical harm, he would not have been given another chance and would have been removed from the site immediately.

Conclusion • This is the end of Lesson 4, please take the posttest and complete the lesson evaluation form. • Sign up for Lesson 5 or any other sessions. • In order to get your certificate of completion for this series, you must complete all 5 lessons.

• This course, funded by an OSHA-sponsored Susan Harwood grant, is designed to assist small and medium sized businesses in developing and implementing an effective safety and health management system. • This material was produced under grant SH-17814 -08 -60 -F-24 from the Occupational Safety Health Administration, U. S. Department of Labor. It does not necessarily reflect the views and policies of the U. S. Department of Labor, nor does mention of trade names, commercial products, or organizations imply endorsement by the U. S. Government.