We all know that neither people nor management systems are ever perfect. Organizations nevertheless depend upon supervisors and managers to eliminate or control unplanned, undesirable events. When these events do occur, since they were not prevented by policy or practice, something has failed in the process. These are the root failures of the “system.”

Studies have shown that approximately 94 percent of errors in an organization are due to these systemic failures. If so, it follows that accident events and injuries are caused by operational errors, not by failures of individuals. Management has the responsibility of identifying and correcting these errors — not individual workers who have no control over the company’s operating policies or procedures.

Back to the Act

The Williams-Steiger Occupational Safety and Health Act of 1970 says: “To ensure safe and healthful working conditions for working men and women; by authorizing enforcement of the standards developed under the Act; by assisting and encouraging the states in their efforts to assure safe and healthful working conditions; by providing for research, information, education and training in the field of occupational safety and health; and for other purposes.”

Duties of each employer:

  1. shall furnish to each of his/her 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/her employees;
  2. shall comply with occupational safety and health standards promulgated under this Act. Duties of the employee:
  3. each employee shall comply with occupational safety and health standards and all rules, regulations and orders issued pursuant to this Act which are applicable to his/her own actions and conduct.

Getting prepared

In addition to ensuring safe working conditions for employees on an everyday basis, another facet of hazard analysis involves providing information about the kinds of emergencies that may occur naturally or man-made in the facility’s local area and the potential consequences of such events. Analysis assists employers, employees and customers in deciding what steps to take to prevent these possible emergencies and how to respond if an accident/incident occurs.

The best way to begin a hazard analysis is to list the possible risks present at the event. My recommendation here is to keep a paper copy in a notebook. When the power goes out, so goes your plan that is on your computer or server. I also highly recommend the publication Disaster Recovery Journal (DRJ) (www.DRJ.com) for hazard analysis training articles.

Every company, department and individual shop list will differ based on topographical and geographical features, weather patterns and other factors. Identifying hazards also includes considering the possibility of a secondary hazard such as a thunderstorm, whether large or small. (For example, will it lead to power failure, loss of water and/or other hazards?)

Ready for anything?

Being prepared for the worst allows safety professionals to have responders and supplies on hand if an emergency does occur. Employers, employees and customers need to identify characteristics of each possible hazard to determine the risk and consequences. Characteristics to identify are:

  • Frequency of occurrence — the frequency of occurrence (both historical and predicted) for each hazard in the particular jurisdiction.
  • Magnitude and intensity — the projected severity of the hazard’s occurrence.
  • Location — the location of the hazard, if the hazard is associated with a facility or landscape feature.
  • Spatial extent — the geographic area that may be expected to suffer the impact of the hazard (either around the known location of a hazard or as an estimate for non-localized hazards such as natural and man-made events).
  • Duration — the length of time that the hazard may be expected to last.
  • Seasonal pattern — times of the year when the hazard threat exists (based on month-by-month historical occurrence).
  • Speed of onset and availability of warning — the amount of time projected between first warning (if any) and actual occurrence.

Potential consequences

To determine the potential consequences of a hazard, estimate the lives, property and services at risk. Evaluate the extent of the hazard by closely examining your company in terms of:

  • People (employees/customers deaths, injuries and displacement)
  • Critical facilities (days of service loss, repair time)
  • Community functions (disruption)
  • Property (damage, destruction, cost of replacement or repair)
  • Potential secondary hazards (dams, warehousing, chemical processing plants)
  • Loss of revenue
  • Negative public image of jurisdiction.

When evaluating hazards, remember that hazards may occur in multiples and that one hazard may cause a secondary hazard.

  1. Identify the hazards. Determine what kinds of emergencies have occurred or could occur in the jurisdiction.
  2. Weigh and compare the risks. Determine the relative threat posed by the identified hazards, using qualitative and quantitative ratings. This information enables planners to decide which hazards merit special attention in planning and other emergency management efforts.
  3. Profile hazards and their potential consequences. Compile historical and predictive information on each of the hazards, and overlay this information on community data to estimate the hazard’s potential impact on the community.
  4. Create and apply scenarios. For the top-ranked hazards (or those that rate above a certain threshold), develop scenarios that raise the hazard’s development to the level of an emergency. This is a brainstorming activity that tracks the hazard from initial warning (if any) to its impact on a specific part of the jurisdiction and its generation of specific consequences. Brainstorming provides information about what actions and resources might be required for response.

Planning tools

Hazard vulnerability assessment worksheets provide the planning team a starting point to identify specific hazards and risks for the event. This is a vital process to bring stakeholders together to brainstorm potential hazards and begin developing comprehensive planning strategies. There are other, more comprehensive planning tools that are available to address specific needs that the planning team may identify from the “job aid” worksheet. Consult your company or site risk/safety manager, insurance company and local/state emergency management agencies for other planning tools.

Remember this: There are companies and areas that have experienced a major event and there are companies and areas that are going to have a major event in the future. Are you prepared now to act?

General Duty Clause: A catch-all for citations

Section 5 (a)(1) of the OSH Act has become known as the “General Duty Clause.” It is a catch-all for citations if OSHA identifies unsafe conditions for which a regulation does not exist. In practice, OSHA court precedent and the review commission have established that if the following elements are present, a “general duty clause” citation may be issued:

  1. The employers failed to keep the workplace free from a hazard to which employees of that employer were exposed.
  2. The hazard was recognized. Examples might include: through your safety personnel, employees, organization, trade organization or industry customs.
  3. The hazard was causing or was likely to cause death or serious physical harm.
  4. There was a feasible and useful method to correct the hazard (MANCOMM (2005) 29 CFR 1926 OSHA Construction Industry Standards, pg. 449).