Remember, this is the criteria OSHA inspectors used in a trial program this fall to assess programs.
Ray Colvin of Safety Training Dynamics in The Woodlands, Texas, our guide to interpreting OSHA's evaluation method, believes engineering controls are usually the way to go to take care of noise, machine dangers, chemical exposures, ergonomic problems, and other hazards.
"Nine times out of ten they are cheaper," he says. "Now there are times when you can't safely engineer out problems, but many times you can avoid the headaches of training, medical surveillance, and fitting and maintaining PPE."
The first stepHe also reiterates the need for a thorough hazard analysis. You can't control dangers you don't know about. "It all goes back to having employees come up with a list of recognized hazards. They know where the hazards really are," he says.
A hazard analysis is also the basis for a good medical program, according to Colvin, helping to target surveillance efforts.
Colvin believes most companies are doing a pretty good job with first aid and emergency planning. "They're cut-and-dried issues," he says. But a medical program, especially one that goes beyond procedures spelled out in specific OSHA standards, is a progressive step for companies to take, he says.
Still, every employer needs to be ready for medical emergencies such as employees with heart attacks. "What arrangements have you made? How long will it take to respond?" he asks.
Whatever your plans are-for controlling hazards, emergency response, or first aid-put them in writing, says Colvin. Be ready to explain to OSHA why you do what you do.
Hazard controlHazard Control Hazard Control: Workforce exposure to all current and potential hazards should be prevented or controlled by using engineering controls wherever feasible and appropriate, work practices and administrative controls, and personal protective equipment (PPE). [Guidelines, (c)(3)(I)]
1. Hazard control is seriously lacking or absent from the facility.
2. Hazard controls are generally in place, but effectiveness and completeness vary. Serious hazards may still exist. Employer has achieved general compliance with applicable OSHA standards regarding hazards with a significant probability of causing serious physical harm. Hazards that have caused past injuries in the facility have been corrected.
3. Appropriate controls (engineering, work practice, and administrative controls, and PPE) are in place for significant hazards. Some serious hazards may exist. Employer is generally in compliance with voluntary standards, industry practices, and manufacturers' and suppliers' safety recommendations. Documented reviews of needs for machine guarding, energy lockout, ergonomics, materials handling, bloodborne pathogens, confined space, hazard communication, and other generally applicable standards have been conducted. The overall program tolerates occasional deviations.
4. Hazard controls are fully in place, and are known and supported by the workforce. Few serious hazards exist. The employer requires strict and complete compliance with all OSHA, consensus, and industry standards and recommendations. All deviations are identified and causes determined.
5. Hazard controls are fully in place and continually improved upon based on workplace experience and general knowledge. Documented reviews of needs are conducted by certified health and safety professionals or professional engineers, etc.
MaintenanceMaintenance Maintenance: An effective safety and health program will provide for facility and equipment maintenance, so that hazardous breakdowns are prevented. [Guidelines, (c)(3)(ii)]
1. No preventive maintenance program is in place; break-down maintenance is the rule.
2. There is a preventive maintenance schedule, but it does not cover everything and may be allowed to slide or performance is not documented. Safety devices on machinery and equipment are generally checked before each production shift.
3. A preventive maintenance schedule is implemented for areas where it is most needed; it is followed under normal circumstances. Manufacturers' and industry recommendations and consensus standards for maintenance frequency are complied with. Breakdown repairs for safety-related items are expedited. Safety device checks are documented. Ventilation system function is observed periodically.
4. The employer has effectively implemented a preventive maintenance schedule that applies to all equipment. Facility experience is used to improve safety-related preventive maintenance scheduling.
5. There is a comprehensive safety and preventive maintenance program that maximizes equipment reliability.
Medical programMedical Program An effective safety and health program will include a suitable medical program where it is appropriate for the size and nature of the workplace and its hazards. [Guidelines, (c)(3)(iv)]
1. Employer is unaware of, or unresponsive to medical needs. Required medical surveillance, monitoring, and reporting are absent or inadequate.
2. Required medical surveillance, monitoring, removal, and reporting responsibilities for applicable standards are assigned and carried out, but results may be incomplete or inadequate.
3. Medical surveillance, removal, monitoring, and reporting comply with applicable standards. Employees report early signs/symptoms of job-related injury or illness and receive appropriate treatment.
4. Health care providers provide follow-up on employee treatment protocols and are involved in hazard identification and control in the workplace. Medical surveillance addresses conditions not covered by specific standards. Employee concerns about medical treatment are documented and responded to.
5. Health care providers are on site for all production shifts and are involved in hazard identification and training. Health care providers periodically observe the work areas and activities and are fully involved in hazard identification and training.
Emergency preparednessEmergency preparedness: There should be appropriate planning, training/drills, and equipment for response to emergencies. Note: In some facilities the employer plan is to evacuate and call the fire department. In such cases, only applicable items listed below should be considered. [Guidelines, (c)(3)(iii) and (iv)]
1. Little or no effective effort to prepare for emergencies.
2. Emergency response plans for fire, chemical, and weather emergencies as required by 29 CFR 1910.38, 1910.120, or 1926.35 are present. Training is conducted as required by the applicable standard. Some deficiencies may exist.
3. Emergency response plans have been prepared by persons with specific training. Appropriate alarm systems are present. Employees are trained in emergency procedures. The emergency response extends to spills and incidents in routine production. Adequate supply of spill control and PPE appropriate to hazards on site is available.
4. Evacuation drills are conducted no less than annually. The plan is reviewed by a qualified safety and health professional.
5. Designated emergency response team with adequate training is on site. All potential emergencies have been identified. Plan is reviewed by the local fire department. Plan and performance are reevaluated at least annually and after each significant incident. Procedures for terminating an emergency response condition are clearly defined.
First aidFirst Aid First aid/emergency care should be readily available to minimize harm if an injury or illness occurs. [Guidelines, (c)(3)(iii) and (iv)]
1. Neither on-site nor nearby community aid (e.g., emergency room) can be ensured.
2. Either on-site or nearby community aid is available on every shift.
3. Personnel with appropriate first aid skills commensurate with likely hazards in the workplace and as required by OSHA standards (e.g., 1910.151, 1926.23) are available. Management documents and evaluates response time on a continuing basis.
4. Personnel with certified first aid skills are always available on site; their level of training is appropriate to the hazards of the work being done. Adequacy of first aid is formally reviewed after significant incidents.
5. Personnel trained in advanced first aid and/or emergency medical care are always available on site. In larger facilities a health care provider is on site for each production shift.