California's workplace safety program rule: template for a federal standard? (1/27)
“I've long advocated that every employer establish a Comprehensive Workplace Safety and Health Program that features management leadership, worker participation, and structure that fosters continual improvement. While thousands of responsible employers already operate this way with excellent results, many other employers haven't gotten the message,” said OSHA chief Dr. David Michaels in a December speech at a NIOSH meeting, his only public remarks to date.
How might Dr. Michaels’ advocacy turn into action? Safety and health experts always point to California’s workplace safety and health program standard as a possible guiding light.
Here is the California standard, in all its non-controversial, bare-bones glory:
a) Every employer shall establish, implement and maintain an effective Injury and Illness Prevention Program in accordance with section 3203 of the General Industry Safety Orders.
(b) Every employer shall adopt a written Code of Safe Practices which relates to the employer's operations. The Code shall contain language equivalent to the relevant parts of Plate A-3 of the Appendix.
(c) The Code of Safe Practices shall be posted at a conspicuous location at each job site office or be provided to each supervisory employee who shall have it readily available.
(d) Periodic meetings of supervisory employees shall be held under the direction of management for the discussion of safety problems and accidents that have occurred.
(e) Supervisory employees shall conduct "toolbox" or "tailgate" safety meetings, or equivalent, with their crews at least every 10 working days to emphasize safety.
Every California employer must establish, implement and maintain a written Injury and Illness Prevention (IIP) Program and a copy must be maintained at each workplace or at a central worksite if the employer has non-fixed worksites. The requirements for establishing, implementing and maintaining an effective written injury and illness prevention program are contained in Title 8 of the California Code of Regulations, Section 3203 (T8 CCR 3203) and consist of the following eight elements:
A model program has been prepared for use by employers in industries, which have been determined by Cal/OSHA to be high hazard. Employers are not required to use this program. This model program was written for a broad spectrum of employers and it may not match each establishment's exact needs. However, it does provide the essential framework required for an Injury and Illness Prevention Program.
Note that California’s plan substitutes specific requirements for things like PPE and ergonomics by using a checklist approach that poses questions, not mandates.
HAZARD ASSESSMENT CHECKLIST GENERAL WORK ENVIRONMENT Are all worksites clean and orderly? Are work surfaces kept dry or appropriate means taken to assure the surfaces are slip-resistant? Are all spilled materials or liquids cleaned up immediately? Is combustible scrap, debris and waste stored safely and removed from the worksite promptly? Is accumulated combustible dust routinely removed from elevated surfaces, including the overhead structure of buildings? Is combustible dust cleaned up with a vacuum system to prevent the dust going into suspension? Is metallic or conductive dust prevented from entering or accumulation on or around electrical enclosures or equipment? Are covered metal waste cans used for oily and paint-soaked waste? Are all oil and gas fired devices equipped with flame failure controls that will prevent flow of fuel if pilots or main burners are not working? Are paint spray booths, dip tanks and the like cleaned regularly? Are the minimum number of toilets and washing facilities provided? Are all toilets and washing facilities clean and sanitary? Are all work areas adequately illuminated? Are pits and floor openings covered or otherwise guarded? PERSONAL PROTECTIVE EQUIPMENT & CLOTHING Are protective goggles or face shields provided and worn where there is any danger of flying particles or corrosive materials? Are approved safety glasses required to be worn at all times in areas where there is a risk of eye injuries such as punctures, abrasions, contusions or burns? Are employees who need corrective lenses (glasses or contacts lenses) in working environments with harmful exposures, required to wear only approved safety glasses, protective goggles, or use other medically approved precautionary procedures? Are protective gloves, aprons, shields, or other means provided against cuts, corrosive liquids and chemicals? Are hard hats provided and worn where danger of falling objects exists? Are hard hats inspected periodically for damage to the shell and suspension system? Is appropriate foot protection required where there is the risk of foot injuries from hot, corrosive, poisonous substances, falling objects, crushing or penetrating actions? Are approved respirators provided for regular or emergency use where needed? Is all protective equipment maintained in a sanitary condition and ready for use? Do you have eye wash facilities and a quick drench shower within the work area where employees are exposed to injurious corrosive materials? Where special equipment is needed for electrical workers, is it available? When lunches are eaten on the premises, are they eaten in areas where there is no exposure to toxic materials or other health hazards? Is protection against the effects of occupational noise exposure provided when sound levels exceed those of the Cal/OSHA noise standard? ERGONOMICS Can the work be performed without eyestrain or glare to the employees? Does the task require prolonged raising of the arms? Do the neck and shoulders have to be stooped to view the task? Are there pressure points on any parts of the body (wrists, forearms, back of thighs)? Can the work be done using the larger muscles of the body? Can the work be done without twisting or overly bending the lower back? Are there sufficient rest breaks, in addition to the regular rest breaks, to relieve stress from repetitive-motion tasks? Are tools, instruments and machinery shaped, positioned and handled so that tasks can be performed comfortably? Are all pieces of furniture adjusted, positioned and arranged to minimize strain on all parts of the body?
How might Dr. Michaels’ advocacy turn into action? Safety and health experts always point to California’s workplace safety and health program standard as a possible guiding light.
Here is the California standard, in all its non-controversial, bare-bones glory:
a) Every employer shall establish, implement and maintain an effective Injury and Illness Prevention Program in accordance with section 3203 of the General Industry Safety Orders.
(b) Every employer shall adopt a written Code of Safe Practices which relates to the employer's operations. The Code shall contain language equivalent to the relevant parts of Plate A-3 of the Appendix.
(c) The Code of Safe Practices shall be posted at a conspicuous location at each job site office or be provided to each supervisory employee who shall have it readily available.
(d) Periodic meetings of supervisory employees shall be held under the direction of management for the discussion of safety problems and accidents that have occurred.
(e) Supervisory employees shall conduct "toolbox" or "tailgate" safety meetings, or equivalent, with their crews at least every 10 working days to emphasize safety.
Every California employer must establish, implement and maintain a written Injury and Illness Prevention (IIP) Program and a copy must be maintained at each workplace or at a central worksite if the employer has non-fixed worksites. The requirements for establishing, implementing and maintaining an effective written injury and illness prevention program are contained in Title 8 of the California Code of Regulations, Section 3203 (T8 CCR 3203) and consist of the following eight elements:
- Responsibility
- Compliance
- Communication
- Hazard Assessment
- Accident/Exposure Investigation
- Hazard Correction
- Training and Instruction
- Recordkeeping
A model program has been prepared for use by employers in industries, which have been determined by Cal/OSHA to be high hazard. Employers are not required to use this program. This model program was written for a broad spectrum of employers and it may not match each establishment's exact needs. However, it does provide the essential framework required for an Injury and Illness Prevention Program.
Note that California’s plan substitutes specific requirements for things like PPE and ergonomics by using a checklist approach that poses questions, not mandates.
HAZARD ASSESSMENT CHECKLIST GENERAL WORK ENVIRONMENT Are all worksites clean and orderly? Are work surfaces kept dry or appropriate means taken to assure the surfaces are slip-resistant? Are all spilled materials or liquids cleaned up immediately? Is combustible scrap, debris and waste stored safely and removed from the worksite promptly? Is accumulated combustible dust routinely removed from elevated surfaces, including the overhead structure of buildings? Is combustible dust cleaned up with a vacuum system to prevent the dust going into suspension? Is metallic or conductive dust prevented from entering or accumulation on or around electrical enclosures or equipment? Are covered metal waste cans used for oily and paint-soaked waste? Are all oil and gas fired devices equipped with flame failure controls that will prevent flow of fuel if pilots or main burners are not working? Are paint spray booths, dip tanks and the like cleaned regularly? Are the minimum number of toilets and washing facilities provided? Are all toilets and washing facilities clean and sanitary? Are all work areas adequately illuminated? Are pits and floor openings covered or otherwise guarded? PERSONAL PROTECTIVE EQUIPMENT & CLOTHING Are protective goggles or face shields provided and worn where there is any danger of flying particles or corrosive materials? Are approved safety glasses required to be worn at all times in areas where there is a risk of eye injuries such as punctures, abrasions, contusions or burns? Are employees who need corrective lenses (glasses or contacts lenses) in working environments with harmful exposures, required to wear only approved safety glasses, protective goggles, or use other medically approved precautionary procedures? Are protective gloves, aprons, shields, or other means provided against cuts, corrosive liquids and chemicals? Are hard hats provided and worn where danger of falling objects exists? Are hard hats inspected periodically for damage to the shell and suspension system? Is appropriate foot protection required where there is the risk of foot injuries from hot, corrosive, poisonous substances, falling objects, crushing or penetrating actions? Are approved respirators provided for regular or emergency use where needed? Is all protective equipment maintained in a sanitary condition and ready for use? Do you have eye wash facilities and a quick drench shower within the work area where employees are exposed to injurious corrosive materials? Where special equipment is needed for electrical workers, is it available? When lunches are eaten on the premises, are they eaten in areas where there is no exposure to toxic materials or other health hazards? Is protection against the effects of occupational noise exposure provided when sound levels exceed those of the Cal/OSHA noise standard? ERGONOMICS Can the work be performed without eyestrain or glare to the employees? Does the task require prolonged raising of the arms? Do the neck and shoulders have to be stooped to view the task? Are there pressure points on any parts of the body (wrists, forearms, back of thighs)? Can the work be done using the larger muscles of the body? Can the work be done without twisting or overly bending the lower back? Are there sufficient rest breaks, in addition to the regular rest breaks, to relieve stress from repetitive-motion tasks? Are tools, instruments and machinery shaped, positioned and handled so that tasks can be performed comfortably? Are all pieces of furniture adjusted, positioned and arranged to minimize strain on all parts of the body?
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