OK, you’re ready to implement an occupational safety and health management system, say OSHA’s Voluntary Protection Program or the new ANSI/AIHA Z10 standard. Element 6.4.C of the Z10 standard requires organizations to “expedite action on inadequately controlled hazards that could cause serious injury and illness.”

How do you comply with this requirement? It’s not enough to say safety hazards are given priority. What do you do? Here are eight key steps to follow:

Building a system

1 — Your top management must define roles, assign responsibilities, establish accountability, and delegate authority to employees who implement and carry out maintenance work orders. Controlling workplace hazards is most often accomplished by initiating and completing these work orders. Make sure to document your process.

2 — Establish and validate your own priority system (time frames) for controlling hazards. It should be based on factors including availability and use of resources (time, personnel, and material) and importance (degree of risk) of the hazard. Time frames usually are categorized as immediate, 24 hours, 48 hours, 72 hours, two weeks, four weeks, and month+.

3 — Originators of maintenance work orders should be required to describe the nature of the hazard, harm that might be expected if the hazard is left uncontrolled, and specify the section of the OSHA or other applicable regulatory standard that the hazard may violate. You need to define what qualifies as a safety and health hazard.

4 — A risk factor will need to be considered to more appropriately assign time frames for controlling hazards. All safety and health hazards are not equal. In the real world “immediate” may not be an appropriate time frame for controlling every safety or health hazard.

5 — Consider using a risk assessment matrix to determine your degree of risk — and timeframe for controlling the risk. In its simplest form, a risk assessment matrix is composed of a table with one axis for probability and the other for severity. (Viewed as an equation: risk = probability x severity.) The table above is an example of a simple risk assessment matrix.

A rarely used pedestal grinder not bolted to the floor might be assigned the number 14, for example. You can then assign time frames for each group of numbers within the risk matrix. Numbers 1-5, for example, might be assigned an “immediate” time frame for correction. Higher numbers will have longer time frames.

Your risk matrix can help quantify risks to people as well as property or the environment. For example, a discharged fire extinguisher mounted in the workplace can be critical to protect property, but might pose no risk to employees — if your organization requires an immediate evacuation if any fire is noticed.

6 — Train originators and other users of maintenance work orders how to properly define (qualify and quantify) a safety and health hazard and risk. If this isn’t done, you should be prepared to approve/disapprove or correct and modify all maintenance work orders with a safety/health-related component. Naturally this can be overwhelming — and unnecessary — if your organization generates many work orders.

7 — Communication should occur during timely control of hazards:

• Communicate with employees on how they can participate, without fear of intimidation or reprisal, in reporting hazards.
• Inform employees and management as to when a hazard will be fixed.
• Alert the safety and health pro to delays in controlling hazards so new or additional precautions can be taken.
• Notify top management when controls are overdue so system improvements can be considered and implemented, as necessary.

8 — Measure your organization’s performance in controlling hazards. You might use audits and management reviews. Use a scorecard to help measure how effective you are at the timely control of hazards. Beyond preventing and limiting employee injury and illness, the eight steps outlined here provide you with a process for continual improvement, which will benefit your organization’s overall operations.

SIDEBAR: More about the matrix

Want to learn more about creating and using a risk matrix?

Industrial Safety and Hygiene News, Managing Best Practices column, “Setting Risk Response Priorities,” August 2004.

American National Standard for Occupational Health and Safety Management Systems, ANSI/AIHA Z10-2005, pages 34-35.

Professional Safety, article “Residual Risk Reduction: Systemically Deciding What is ‘Safe’,” pages 25-33, November 2005.