Safety & Health Management System Training Lesson 3

Safety & Health Management System Training Lesson 3 – Worksite Analysis

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 3 Contents 1. 2. 3. 4. 5. 6. Objectives Accident Investigation Self-Inspection Comprehensive Survey Legal Requirements Job Hazard Analysis

Objectives Learn the four methods of worksite analysis: – – – – Accident/ Investigation System Routine self-inspections Comprehensive Surveys Job Hazard Analysis, or Other Pre-Use Analysis Learn how to effectively conduct each method within your organization.

Poll Question #1

Accident Investigation Accident is defined as an unplanned event that results in personal injury or property damage. Accident is an indication of a deficiency in the SHMS.

Accident Investigation Incident – An unplanned event that does not result in personal injury but may result in property damage or is worthy of recording. Near-Miss – An event that does not result in an injury or damage. It is important to record and investigate near-misses to identify weaknesses in the SHMS that could possibly lead to an injury or damage.

Accident Investigation The primary goals of an accident investigation are: – To identify the root cause of the accident or incident – To prevent the accident or incident from occurring again. Accident investigations and reports help identify these deficiencies. Must be conducted and written according to your organization's established documented procedures.

Accident Investigation The investigation process is "fact-finding" not "fault-finding". Not to place blame. When interviewing witnesses, ask open-ended questions, listen carefully and be courteous. For more guidance on accident investigation, visit the OSHA website – Accident Investigation.

Accident Investigation Accident history records – Another way to discover potential workplace hazards. – Helps you identify past trends. – To establish focused interventions that will prevent similar accidents from re-occurring. – Also known as loss reports/runs.

Accident Investigation Elements of an accident investigation. – A documented procedure is in place when an employee reports an accident, incident or near miss. – Procedures include instructions for medical treatment of employees for all shifts. – Employees are trained to report accidents immediately to their immediate supervisor. – The investigation process may include a team of employees to ensure that the root cause of the accident or incident is identified.

Poll Question #2

Poll Question #3

Accident Investigation Exercise 1 Identify Cause of CHC Accident – Jim South, the Sales Manager at CHC, was in his office when he received a phone call from Mark Rebell. Mark reported that his hand had been injured and that he needed medical attention. He told Jim that he had been walking onto a job site while calling a client on his cell phone. He failed to notice a pile of debris stored near the sidewalk and accidentally tripped on a broken piece of pallet. He put his hands out to stop his fall and his right hand landed on a corner of the broken pallet, slicing a deep cut into his hand. He wanted to know what he should do next.

Accident Investigation Exercise 1 Answers Question 1 – Answer: Jim South should immediately arrange proper medical care for Mark. While the injury is not life-threatening, it should be evaluated to determine if sutures are needed. Question 2 – Answer: Absolutely. This injury may very likely require sutures, which would make it be recordable on the OSHA Form 300 (discussed on next page). In addition, the root cause of the accident should be identified so that future, similar accidents can be prevented.

Accident Investigation Exercise 1 Answers Question 3 – Answer: Root causes of the accident were: (1) inappropriate storage of debris near sidewalk used by employees to access the job site (poor housekeeping) and (2) distraction of employee as he dialed his cell phone. Preventive measures include (1) an action plan for communicating the importance of contractor housekeeping at all job sites, (2) routine inspection of all job sites for improper storage of debris and (3) prohibition against use of cell phones on job sites unless employees are in a safe place.

Self Inspection Reviewing injury and accident data is important, but visually inspecting your facility is the only way to know for sure if hazardous conditions are: – Present – To determine if they are adequately being controlled. – Self-inspections should be conducted on a regular basis because conditions can change.

Self Inspection Self-inspections promote employee participation by getting many employees involved. Those who conduct self-inspections can include, but are not limited to: – Top management, members of safety committees, departmental employees and safety and health staff. Rotating the employees who participate on the inspection team allows more employees to become involved with the SHMS.

Poll Question #4

Self Inspection – What are you looking for? Keep areas for potential hazards in mind when inspecting the following: Housekeeping – Cleanliness of work area; leakage or spillage; and cleaning methods Building Conditions – Exit lights functional; exits, stairs, and aisles free of obstruction

Self Inspection Electricity – Electrical circuits labeled and unused openings closed. Machinery – Effective guarding of point of operation; and Lockout/tag out Chemicals – Proper storage and labeling; and protective equipment available and used properly.

Self Inspection Fire Protection – Fire extinguishers free of obstruction; fire alarms and sprinklers functional; and evacuations routes posted. Material Handling – Forklifts, cranes, and hoists properly inspected and operated. Personal Protective Equipment – PPE is available and maintained properly; and proper use of PPE.

Self Inspection Personnel – Proper use of equipment; and safe work practices. Examples of Self-Inspection Checklists – OSHA Checklist – OSHA Handbook for small businesses - Provides a good overview of self-inspection techniques. (See p. 24 for Checklist.) – General Safety Audit Checklist (Word Format)

Self Inspection - Assignment Below are ideas to consider when conducting your self-inspection: Train your employees on how to identify hazards prior to starting the self-inspection. Develop and utilize helpful checklists so that you don't forget anything when you're conducting the walk-through. Add extra blank spaces so that you can fill in items that are not yet included on the checklist. Later, you can modify your checklist to accommodate your particular workplace. Wear necessary PPE that may be defined by your organization. The safety inspection team should not be violating safety policies! Have necessary tools such as a tape measure, camera or electrical measuring devices to perform quick measurements of the workplace conditions. Don't forget to communicate and distribute the results of the completed self-inspection to appropriate departments. Similarly, don't forget to assign responsibilities and due dates for completing corrective actions.

Comprehensive Survey A comprehensive survey: thorough investigation of the specific hazards in work environment. Investigates possible harmful conditions, conducts scientific measurements to determine potential personnel exposure, and helps to identify legal requirements where necessary. Different from a self-inspection in that it systematically identifies and documents common hazards common to your work environment

Comprehensive Survey Comparison of Results: Comprehensive Survey vs. Self-Inspection Comprehensive Survey Self-Inspection Asbestos ceiling tiles are present in the building being renovated. Develop a plan to ensure compliance with the OSHA Asbestos standard 29 CFR 1910.1001, which includes but is not limited to: employee training, installation of signs and Labels, and personal protective equipment. The asbestos sign has been removed and must be replaced. The compressor room is a high noise area. Conduct sound level monitoring in the area to determine if employees must wear hearing protection when entering or working in the room according to the requirements of 29 CFR 1910.95. The box of hearing protection is empty and needs to be replaced.

Comprehensive Survey A comprehensive survey should be performed by professionals trained in occupational safety and health, industrial hygiene, ergonomics, or other specific areas. Your workers' compensation insurance carrier, private safety consultants, or even your local OSHA consultation office may be able to serve as resources.

Poll Question #5

Legal Requirements Purpose of your comprehensive survey is to identify and understand the legal requirements with which you must comply

Legal Requirements According to the Occupational Safety and Health (OSH) Act: – employers are subject to the General Duty Clause at Section 5(a)(1), – Employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.

Legal Requirements States are allowed to develop their own OSH plans but they must establish standards that are at least as stringent as those of federal OSHA. To determine if your state has its own plan with which you must comply, see State Occupational Safety and Health Plans (OSHA website).

Legal Requirements Legal requirements are grouped into these categories: – Industrial Hygiene – Workplace Conditions – Emergency Planning We will indicate whether or not the standards associated with the hazards in each category require a written program or training.

Legal Requirements Keep in mind that this section is not exhaustive—many hazards are not covered. What follows are the most commonly found hazards in general industry.

Poll Question #6

Legal Requirements Industrial Hygiene – Chemical Hazards – Do your employees handle chemicals or dusty materials in your workplace? – If so, it is your responsibility to provide information on these hazards and to determine if your employees' exposure exceeds permissible levels.

Poll Question #7

Legal Requirements Industrial Hygiene – Other Hazards – Are your employees exposed to loud noise, repetitive motions or bloodborne pathogens? If so, it is your responsibility to provide information on these hazards and to determine if the exposure to your employees exceeds acceptable levels

Legal Requirements Bloodborne Pathogens (BBP) – Pathogenic microorganisms that are present in human blood and can cause disease in humans. These pathogens include, but are not limited to, Hepatitis B Virus (HBV) and Human Immunodeficiency Virus (HIV). Other Potentially Infectious Materials (OPIM) – The following fluids: semen, vaginal secretions, cerebrospinal fluid (CSF), synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, any body fluid that is visibly contaminated with blood, and all body fluids in situations where it is difficult or impossible to differentiate between body fluids

Poll Question #8

Poll Question #9

Legal Requirements Emergency Planning – OSHA requires you to develop written emergency plans and to train your employees appropriately in case of emergencies, such as fires, chemical spills, medical emergencies and weather events. – Exit Routes – Emergency Action – Fire Safety – Medical and First Aid

Legal Requirements Required Written Programs and Plans Following your comprehensive survey, you may be subject to developing and implementing some written programs. A written program documents how your company will comply with the legal requirement, and OSHA will request to see them if your facility is inspected.

Legal Requirements OSHA has templates for some written plans and programs that you may customize for your specific worksite (check your state too). The following list of plans and programs are often implemented by small businesses (not an exhaustive list).

Legal Requirements Bloodborne Pathogen (BBP) Exposure Control Plan Chemical Hygiene Plan Confined Space Entry Emergency Action Plan Hazard Communication Program Lockout/Tagout - Mechanical and/or Electrical PPE Hazard Assessments Respiratory Protection Program

Legal Requirements The following plans are not required to be written but are certainly recommended: – Forklift Safety – Hearing Conservation – Hot Work Permit (required for Process Safety Management) Templates: http://www.osha.gov/dcsp/compliance assistance/samplepr ograms.html

Poll Question #10

Job Hazard Analysis Job Hazard Analysis (or JHA) is a valuable technique, utilized in companies of all sizes, to routinely examine and analyze safety and health hazards associated with individual jobs or processes. Note: Some companies use the terms "Job Safety Analysis" and "JSA" instead of "Job Hazard Analysis".

Job Hazard Analysis JHA can be used to identify, analyze and record: – the steps involved in performing a specific job. – the existing or potential safety and health hazards associated with each step. – the recommended action(s) / procedure(s) that will eliminate or reduce these hazards and the risk of a workplace injury or illness.

Job Hazard Analysis JHA is useful for jobs that have high injury and illness rates. Jobs with the potential to cause severe or disabling injuries. Jobs that are new to your operation, or complex jobs that require written instructions.

Job Hazard Analysis Tip: How to start a JHA – – – – Select the job to be analyzed. Define the specific steps or tasks to do the job. Define the hazards associated with each task. Make recommendations to minimize or eliminate the hazard. – When conducting a JHA, involve employees whose jobs or tasks are being analyzed.

Job Hazard Analysis – Exercise 1 Conduct a Job Hazard Analysis – To give you practice conducting a JHA, do one for changing the oil in your car. – Identify the steps or tasks in changing the oil in your car. – For each task, identify the associated hazards and then make recommendations to minimize or eliminate the hazard.

Job Hazard Analysis – Assignment Remember to involve your employees when conducting a JHA at your workplace. Review your accident history or jobs that are complex to identify jobs that will benefit from a JHA. Develop a team of employees and/or Supervisors to conduct the JHA and provide training prior to starting the JHA. Outline the job into specific tasks or steps. It may be helpful to observe or videotape the job being analyzed to ensure all tasks or steps are included. Develop and utilize your own form to record the JHA.

Conclusion This is the end of Lesson 3, please take the posttest and complete the lesson evaluation form. Sign up for Lesson 4 and subsequent lessons. 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-17814-0860-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.

Legal Requirements – Reference Specific OSHA Standards and Legal Requirements

Legal Requirements Industrial Hygiene – Chemical Hazards – OSHA STD: 29 CFR 1910.1200. – Hazard Communication standards ensure that the hazards of chemicals are evaluated and that this information is communicated to employers and employees. – Requires the employer to provide chemical labeling, MSDS and employee training. – Written Program Required? Yes. Hazard Communication Program. – Training Required? Yes. Initial training and when a new hazard is introduced – For More Info: Hazard Communication (OSHA site).

Legal Requirements Air Contaminants for Toxic and Hazardous Substances – OSHA STD: 29 CFR 1910.1000. If you have hazardous chemicals in the workplace, you must determine if there is a legal limit of exposure that is allowed for your employees and if the levels in your workplace exceed the legal limit. There are 3 tables in 29 CFR 1910.1000 that list legally enforceable limits for chemical exposure: – Table Z-1 - Limits for Air Contaminants – Table Z-2 - Toxic and Hazardous Substances – Table Z-3 - Mineral Dusts

Legal Requirements Written Program Required? No, but you must document any air monitoring results, even if the monitoring reports that there is no employee exposure. Training Required? No. For More Info: Hazardous & Toxic Substances (OSHA site).

Legal Requirements Hazardous Chemicals in laboratories – OSHA STD: 29 CFR 1910.1450. If you have laboratories in your facility where you handle hazardous chemicals, you may be subject to the regulations of this standard. – Written Program Required? Yes. Chemical Hygiene Plan – Training Required? Yes. Initial training and when a new hazard is introduced. – For More Info: Laboratories (OSHA site)

Legal Requirements Process Safety Management of Highly Hazardous Chemicals – OSHA STD: 29 CFR 1910.119. If your company handles or stores highly hazardous chemicals in a quantity that exceeds the threshold quantity that is defined in this OSHA standard, you may be subject to implementing a Process Safety Management (PSM) Program. This is a comprehensive program that is designed to prevent catastrophic releases of highly hazardous chemicals. – Written Program Required? Yes. This standard actually requires several written documents such as written process safety information, process hazard analysis, written operating procedures, and more. – Training Required? Yes. Initial training and when modifications are made to the system. If your employees respond to emergency releases of hazardous chemicals, initial and annual refresher training is required.

Legal Requirements Noise – OSHA STD: 29 CFR 1910.95. You must provide protection against the effects of noise exposure when the sound levels exceed those indicated by the OSHA standard. Hearing loss can occur if employees are exposed to continuous or intermittent loud noise. If noise levels exceed 85 dBA over a time-weighted average of 8 hours, a hearing conservation program must be implemented that includes engineering and administrative controls, hearing protection, audiometric testing and training. – Written Program Required? No. A written hearing conservation program is not required, although you must document sound level monitoring results and employee audiometric testing. It is certainly beneficial to develop a written program even though it is not required. – Training Required? Yes. Initial and annual training for employees in the hearing conservation program – For More Info: Noise & Hearing Conservation (OSHA site).

Legal Requirements Ergonomics – OSHA STD: None. While there is currently no OSHA Ergonomics standard, OSHA recognizes the value of implementing ergonomics programs to prevent musculoskeletal disorders as well as increase employee comfort and productivity. – Training Required? No, not required but certainly recommended. – For More Info: OSHA has developed numerous industry guidelines and other resources to assist you. – See Ergonomics website.

Legal Requirements Bloodborne Pathogens – OSHA STD: 29 CFR 1910.1030. If your employees have exposure or potential exposure to blood, bloodborne pathogens or other potentially infectious materials, OSHA requires you to implement an Exposure Control Plan. Jobs where this potential exposure may occur include but are not limited to: healthcare professionals (nurses, doctors, surgeons, dentists, etc.), morticians, lifeguards, tattoo and body piercing. – Written Program Required? Yes. Exposure Control Plan. – Training Required? Yes. Initial and annual training. – For More Info: See Bloodborne Pathogens and Needlestick Prevention (OSHA website)

Legal Requirements PPE Hazard Assessment – OSHA STD: OSHA website for PPE Standards. You must assess the hazards in the workplace and properly select the PPE for the hazard and document this in a written PPE Hazard Assessment (see links to sample form below). Employees must be trained on how to use, maintain and replace worn PPE. – Written Program Required? Yes. The PPE Hazard Assessment shall have a written certification. – Training Required? Yes. Initial training on how to properly wear and maintain the PPE

Legal Requirements Industrial Hygiene – PPE – To protect employees against environmental hazards, you must provide personal protective equipment (PPE). – Eye /Face Protection - OSHA STD: 29 CFR 1910.133. – Eye and face protection shall be provided when employees are exposed to hazards such as flying particles, molten metal or liquid chemicals. Examples of eye and face protection include safety glasses, goggles and face shields. – Written Program Required? Yes, included in the PPE Hazard Assessment. – Training Required? Yes. Initial training on how to properly wear and maintain the eye and face protection.

Legal Requirements Respiratory Protection – OSHA STD: 29 CFR 1910.134. Respirators shall be provided when necessary to protect the health of your employees against atmospheric contamination such as harmful dusts, fumes, mists, gases, or vapors. Examples of respiratory protection include dust masks, cartridge respirators and self-contained breathing apparatus (SCBA). – Written Program Required? Yes, Respiratory Protection Program. – Training Required? Yes. Initial training; refresher training is required annually and when a new hazard is introduced.

Legal Requirements Head Protection – OSHA STD: 29 CFR 1910.135. – Head protection is required when working in areas where there is a potential for injury to the head from falling objects. Examples of head protection are hard hats and bump caps. – Written Program Required? Yes, included in the PPE Hazard Assessment. – Training Required? Yes. Initial training on how to properly wear and maintain the head protection.

Legal Requirements Foot Protection – OSHA STD: 29 CFR 1910.136. – Foot protection is required when working in areas where there is a danger of foot injuries. Steel-toed safety shoes are an example of foot protection. – Written Program Required? Yes, included in the PPE Hazard Assessment. – Training Required? Yes. Initial training on how to properly wear and maintain the foot protection.

Legal Requirements Hand / Body Protection – OSHA STD: 29 CFR 1910.138. – Hand and body protection is required when employees are exposed to hazards such as harmful substances, severe cuts or lacerations, chemical or thermal burns, or harmful temperature extremes. Examples of hand protection include gloves and gauntlets. – Written Program Required? Yes, included in the PPE Hazard Assessment. – Training Required? Yes. Initial training on how to properly wear and maintain the hand and/or body protection.

Legal Requirements Work place conditions - What process-related hazards are present in your workplace? – OSHA STD: 29 CFR 1910.22 - 1910.30. Walking / Working Surfaces - Your workplace should be designed to prevent employee slips, trips or falls. This includes your housekeeping practices, the protection provided for floor and wall openings, and the use and design of stairs, ladders, platforms, and other walking or working surfaces. – Written Program Required? No. – Training Required? Not specifically to this OSHA standard, although your employees should know the importance of proper housekeeping, the safe use of ladders and methods of fall protection

Legal Requirements Confined Space – OSHA STD: 29 CFR 1910.146 – Does your workplace contain spaces that are considered "confined" because their configurations hinder the activities of employees who must enter, work in and exit them? – OSHA defines a "confined space" as a space that can be bodily entered, has limited means for entry or exit, and is not designed for employee occupancy.

Legal Requirements Confined Space – When a confined space poses additional hazards, such as entrapment, asphyxiating atmospheres, or the moving parts of machinery, the space is defined by OSHA as a Permit-Required Confined Space. – Ensure safe entry into Permit-Required Confined Spaces by implementing a written permit space program and properly training your employees. – If you decide that you will not train or authorize your employees to enter confined spaces, be sure to label the spaces appropriately to prevent unauthorized entry. – Written Program Required? Yes, for Permit-Required Confined Spaces (the Permit-Required Confined Space Entry Program). – Training Required? Yes. Initial training and when a new hazard is introduced for entrants, attendants and entry supervisors. If employees are trained to perform rescue duties, they must practice permit space rescues at least once every 12 months

Legal Requirements Machine Guarding – OSHA STD: 29 CFR 1910.211 - 1910.219. Moving machine parts have the potential for causing severe workplace injuries, such as crushed fingers or hands, amputations, burns, or blindness. – Any machine part, function or process that may cause injury must be safeguarded. – Types of equipment such as abrasive wheels (grinding wheels), punch presses, woodworking equipment and others must be protected. – Written Program Required? No. – Training Required? Yes, training is required specifically for mechanical power presses; however, all employees should know guards are not to be bypassed

Legal Requirements Electrical Safety – Too many standards to list here. Please see OSHA "Electrical" Employees who service electrical equipment must know how to do so safely. Working with electricity can be dangerous and you should know how to protect your employees against electrical hazards. – Written Program Required? Yes, if your employees work on or near exposed de-energized parts. The Lockout/Tagout Energy Control Program may meet this requirement. – Training Required? Yes. Initial training and when a new hazard is introduced.

Legal Requirements Lockout / Tagout – OSHA STD: 29 CFR 1910.147. If your employees maintain or service equipment, appropriate precautions must be taken to prevent potential exposure to energy. – Energy sources should be isolated, locked out and tagged to ensure that the equipment does not start during the servicing or maintenance. – You must develop a written program and provide training to your employees to protect them from hazardous energy during equipment servicing. – Written Program Required? Yes. Lockout/Tagout Energy Control Program. – Training Required? Yes. Initial training and when a new hazard is introduced. Employees authorized to lock out or tag out machines or equipment must have an annual review of the employee's responsibilities under the energy control procedure and an annual periodic inspection

Legal Requirements Powered Industrial Trucks – OSHA STD: 29 CFR 1910.178. Powered industrial trucks must be maintained and operated safely. – Each year in the U.S., nearly 100 workers are killed and another 20,000 are seriously injured in forklift-related incidents [BLS 1997, 1998]. – Forklift overturns are the leading cause of fatalities involving forklifts; they represent about 25% of all forklift-related deaths – Written Program Required? No. Although not required, it is beneficial to develop a written procedure that describes your internal policies for operating powered industrial trucks in your facility. Therefore, your employees can easily read the rules. – Training Required? Yes. Initial training and an Operator Performance Evaluation every 3 years. Refresher training may be required if an operator operates a vehicle unsafely, is involved in an accident or near-miss or meets other criteria as indicated in the OSHA standard

Legal Requirements Exit Routes – OSHA STD: 29 CFR 1910.34 - 1910.37 You must comply with the requirements for exit routes in the workplace to minimize dangers to employees during an evacuation. – Written Program Required? No. – Training Required? No. Emergency Action – OSHA STD: 29 CFR 1910.38. An Emergency Action Plan is required by some OSHA standards and is generally recommended by OSHA. This plan describes the actions that employees will take to ensure their safety in a fire or other emergency. – Written Program Required? Yes. Emergency Action Plan. – Training Required? Yes. Initial training and when a new plan is introduced

Legal Requirements Fire Safety – OSHA STD: 29 CFR 1910.39. A Fire Prevention Plan is required by some OSHA standards, although it is generally recommended to implement one. In addition, there are several fire safety issues to address in your facility such as the storage of flammable liquids, welding and paint spray finishing. – Written Program Required? Yes. Fire Prevention Plan. – Training Required? Yes, initial training and when a new hazard is introduced.

Legal Requirements Medical and First Aid – OSHA STD: 29 CFR 1910.151. While it is your ultimate goal to keep your workplace free from recognized hazards, it is appropriate to plan for responding to employee injuries. This can include providing access to medical personnel, providing first aid supplies and providing first aid training to employees. – Written Program Required? No. – Training Required? Yes, if you choose to train your employees in CPR and First Aid. Don't forget to include Bloodborne Pathogens training if these employees have exposure to blood or other potentially infectious materials. – For More Info: Medical and First Aid (OSHA site)