The Occupational Safety and Health Act requires employers to identify "recognized hazards" that employees are exposed to at work. By developing a written list of these hazards you're in a better position to train employees, purchase PPE, safeguard equipment and processes, implement preventive maintenance, and demonstrate "good faith" safety leadership.
Employee inputOne way of developing this list is to have every department work with employees to identify "typical" hazards that could lead to accidents, injuries, illnesses, close calls. Training sessions should teach supervisors, managers, and employees the importance of this mission, and define "recognized hazards" as hazards that are typical to the work being performed. You can also uncover recognized hazards by reviewing accident reports, close calls, workers' compensation reports, injury and illness records, and other data.
This is the third article in a five-part series on auditing your safety efforts based on OSHA's PEP. The charts below are used by OSHA inspectors to assess programs (in field trials). What score would you give your program, based on the activity levels described for each rating? Remember, 1 = absent or ineffective, 2 = developmental, 3 = basic, 4 = superior, and 5 = outstanding. Higher ratings assume that all activity described for lower scores has been accomplished in addition to the activity listed for the performance level most closely matching your own.
Accident and record analysis - Accident investigationAccident investigation:An effective program will provide for investigation of accidents and "near miss" incidents, so that their causes, and the means for their prevention, are identified. [Guidelines, (c)(2)(iv)]
1. No investigation of accidents, injuries, near misses, or other incidents is conducted.
2. Some investigation of incidents takes place, but root cause may not be identified, and correction may be inconsistent. Supervisors prepare injury reports for lost-time cases.
3. OSHA-101 is completed for all recordable incidents. Reports are generally prepared with cause identification and corrective measures prescribed.
4. OSHA-recordable incidents are always investigated, and effective prevention is implemented. Reports and recommendations are available to employees. Quality and completeness of investigations are systematically reviewed by trained safety personnel.
5. All loss-producing accidents and "near misses" are investigated for root causes by teams or individuals that include trained safety personnel and employees.
Workplace analysis - Survey and hazard analysisSurvey and hazard analysis:An effective, proactive safety and health program will seek to identify and analyze all hazards. In large or complex workplaces, components of such analysis are the comprehensive survey and analyses of job hazards and changes in conditions. [Guidelines, (c)(2)(l)]
1. No system or requirement exists for hazard review of planned/changed/new operations. There is no evidence of a comprehensive survey for safety or health hazards or for routine job hazard analysis.
2. Surveys for violations of standards are conducted by knowledgeable person(s), but only in response to accidents or complaints. The employer has identified principal OSHA standards which apply to the worksite.
3. Process, task, and environmental surveys are conducted by knowledgeable person(s) and updated as needed and as required by applicable standards. Current hazard analyses are written (where appropriate) for all high-hazard jobs and processes; analyses are communicated to and understood by affected employees. Hazard analyses are conducted for jobs/tasks/workstations where injury or illnesses have been recorded.
4. Methodical surveys are conducted periodically and drive appropriate corrective action. Initial surveys are conducted by a qualified professional. Current hazard analyses are documented for all work areas and are communicated and available to all the workforce; knowledgeable persons review all planned/changed/new facilities, processes, materials, or equipment.
5. Regular surveys including documented comprehensive workplace hazard evaluations are conducted by certified safety and health professional or professional engineer, etc. Corrective action is documented and hazard inventories are updated. Hazard analysis is integrated into the design, development, implementation, and changing of all processes and work practices.
Accident and record analysis - Data analysisData analysis:An effective program will analyze injury and illness records for indications of sources and locations of hazards, and jobs that experience higher numbers of injuries. By analyzing injury and illness trends over time, patterns with common causes can be identified and prevented. [Guidelines, (c)(2)(v)]
1. Little or no analysis of injury/illness records; records (OSHA 200/101, exposure monitoring) are kept or conducted.
2. Data is collected and analyzed, but not widely used for prevention. OSHA-101 is completed for all recordable cases. Exposure records and analyses are organized and are available to safety personnel.
3. Injury/illness logs and exposure records are kept correctly, are audited by facility personnel, and are essentially accurate and complete. Rates are calculated so as to identify high risk areas and jobs. Workers' compensation claim records are analyzed and the results used in the program. Significant analytical findings are used for prevention.
4. Employer can identify the frequent and most severe problem areas, the high risk areas and job classifications, and any exposures responsible for OSHA recordable cases. Data are fully analyzed and effectively communicated to employees. Illness/injury data are audited and certified by a responsible person.
5. All levels of management and the workforce are aware of results of data analyses and resulting preventive activity. External audits of accuracy of injury and illness data, including review of all available data sources are conducted. Scientific analysis of health information, including non-occupational databases is included where appropriate in the program.
Workplace analysis - InspectionInspection:To identify new or previously missed hazards and failures in hazard controls, an effective safety and health program will include regular site inspections. [Guidelines, (c)(2)(ii)]
1. No routine physical inspection of the workplace and equipment is conducted.
2. Supervisors dedicate time to observing work practices and other safety and health conditions in work areas where they have responsibility.
3. Competent personnel conduct inspections with appropriate involvement of employees. Items in need of correction are documented. Inspections include compliance with relevant OSHA standards. Time periods for correction are set.
4. Inspections are conducted by specifically trained employees, and all items are corrected promptly and appropriately. Workplace inspections are planned, with key observations or check points defined and results documented. Persons conducting inspections have specific training in hazard identification applicable to the facility. Corrections are documented through follow-up inspections. Results are available to workers.
5. Inspections are planned and overseen by certified safety or health professionals. Statistically valid random audits of compliance with all elements of the safety and health program are conducted. Observations are analyzed to evaluate progress.
Workplace analysis - Hazard reportingA reliablehazard reportingsystem enables employees, without fear of reprisal, to notify management of conditions that appear hazardous and to receive timely and appropriate responses. [Guidelines, (c)(2)(iii)]
1. No formal hazard reporting system exists, or employees are reluctant to report hazards.
2. Employees are instructed to report hazards to management. Supervisors are instructed and are aware of a procedure for evaluating and responding to such reports. Employees use the system with no risk of reprisals.
3. A formal system for hazard reporting exists. Employee reports of hazards are documented, corrective action is scheduled, and records maintained.
4. Employees are periodically instructed in hazard identification and reporting procedures. Management conducts surveys of employee observations of hazards to ensure that the system is working. Results are documented.
5. Management responds to reports of hazards in writing within specified time frames. The workforce readily identifies and self-corrects hazards; they are supported by management when they do.