EVALUATING THE EFFECTIVENESS OF CONTROLS

Sometimes hazard controls do not work as well as expected. Therefore, the commit-tee or representative should monitor the effectiveness of the corrective action taken by the employer during inspections and other activities. Ask these questions:

. Have the controls solved the problem?

. Is the risk posed by the original hazard contained?

. Have any new hazards been created?

. Are new hazards appropriately controlled?

. Are monitoring processes adequate?

. Have workers been adequately informed about the situation?

. Have orientation and training programs been modified to deal with the new situation?

. Are any other measures required?

. Has the effectiveness of hazard controls been documented in your commit-tee minutes?

9.12 SUMMARY

It is important to identify existing or potential safety hazards and take steps to remove or limit their effects on the workforce. This can be accomplished by using many approaches to control, prevent, or remove safety hazards that could cause injury, illness, and death in the workplace.

All identified hazardous conditions should be eliminated or controlled immedi-ately. Where this is not possible, interim control measures are to be implemented immediately to protect workers. Warning signs must be posted at the location of the hazard; all affected employees need to be informed of the location of the hazard and of the required interim controls, and permanent control measures must be implemented as soon as possible.

Once hazards have been identified, assessed, and controlled, the employer and worker representatives should work together to develop training programs for workers, emergency response procedures, and health and safety requirements for contractors. Someone needs to be responsible to monitor these activities to ensure that they are effective.

The employer is responsible for ensuring that workplace hazards are identified, assessed, and appropriately controlled. Workers must be told about the hazards they face and taught how to control them.

The employer is expected to consult and involve occupational safety health professionals or worker representatives in the hazard control process. Helping the employer identify, assess, and control hazards is one of the most important roles of the responsible party in the internal responsibility system. Hazards are broadly divided into two groups: hazards that cause illness (health hazards) and those that cause injury (safety hazards). Hazards can be identified by asking what harm could result if a dangerous tool, process, machine, piece of equipment, and so forth, failed.

Health and safety hazards can be controlled at the source, along the path, or at the level of the worker. Once controls are in place, they must be checked periodically to make sure that they are still working properly. Someone should be responsible to audit the hazard controls in the internal responsibility system and help the employer keep them effective.

Where a supervisor or foreman is not sure how to correct an identified hazard or is not sure if a specific condition presents a hazard, the supervisor or foreman should seek technical assistance from the designated competent person, safety and health officer, or technical authority. Some of the other techniques used to control hazards are as follows.

9.12.1 JOBSAFETY ASSESSMENT

Prior to the start of any task or operation, the designated competent or company authorized person should evaluate the task or operation to identify potential hazards and to determine the necessary controls. This assessment shall focus on actual worksite conditions or procedures that differ from or were not anticipated to the related other hazard analysis. In addition, the competent person shall ensure that each employee involved in the task or operation is aware of the hazards related to the task or operation and of the measures or procedures that they must use to protect themselves. Note that the job safety assessment is not intended to be a formal documented analysis, but instead is more of a quick check of actual site conditions and a review of planned procedures and precautions.

9.12.2 CONTROLS

Controls come in all forms, from engineering, administrative, to PPE. The best controls are those that can be placed on equipment before involving people and thus either preclude or guard the workforce from the hazard. The use of administra-tive controls relies on individuals following policies and procedures to control hazards and exposure to hazards. However, as we all know this certainly provides no guarantees that the protective policies and procedures will be adhered to unless

effective supervision and enforcement exist. Again, this relies on the company having a strong commitment to occupational safety and health. The use of PPE will not control hazards unless the individuals who are exposed to the hazards wear the appropriate PPE. The use of PPE is usually considered the control of last resort since it has always been difficult for companies to ensure that exposed individuals are indeed wearing the required PPE.

9.12.3 ACCIDENTREPORTING

All incidents and accidents resulting in injury or causing illness to employees and events (near-miss accidents) shall be reported to

. Establish a written record of factors that cause injuries and illnesses and occurrences (near misses) that might have resulted in injury or illness, but did not, as well as property and vehicle damage

. Maintain a capability to promptly investigate incidents and events to initiate and support corrective or preventive action

. Provide statistical information for use in analyzing all phases of incidents and events

. Provide the means for complying with the reporting requirements for occupational injuries and illnesses

Incident reporting system requirements apply to all incidences involving company employees, onsite vendors, contractor employees, and visitors, which results in (or might have resulted in) personal injury, illness, and property and vehicle damage.

Injuries and illnesses that require reporting include those injuries and illnesses occurring on the job that result in any of the following: lost work time, restrictions in performing job duties, requirement forfirst aid or outside medical attention, perman-ent physical bodily damages, or death. Examples of reportable injuries and illnesses include, but are not limited to, heat exhaustion from working in hot environments, strained back muscles from moving equipment, acid burns onfingers, etc.

Other incidents requiring reporting include those incidents occurring on the job that result in any of the following: injury or illness, damage to a vehicle, fire=explo-sion, property damage of more than $100, or chemical releases requiring evacuation of at least the immediate spill area.

Examples of nonreportable injuries and illnesses include small paper cuts, common colds, and small bruises not resulting in work restrictions or requiring first aid or medical attention.

Events (near misses) or other incidents (near misses) that, strictly by chance, do not result in actual or observable injury, illness, death, or property damage are required to be reported. The information obtained from such reporting can be extremely useful in identifying and mitigating problems before they result in actual personal or property damage. Examples of near-miss incidences required to be reported include the falling of a compressed-gas cylinder, overexposures to chemical, biological, or physical agents (not resulting in an immediately observable manifestation of illness or injury), and slipping and falling on a wet surface without injury.

9.12.4 INCIDENTREPORTINGPROCEDURES

The following procedures are to be followed by all employees to effectively report occupational injuries and illnesses and other incidents or events. Serious injury or illness posing a life-threatening situation should be reported immediately to the local emergency response medical services (call 911).

Injuries and illnesses shall be reported, by the injured employee, to his or her supervisor in person or by phone soon after any life-threatening situation has been addressed. If the injured employee is unable to report immediately, then the incident should be reported as soon as possible.

Upon notification of an occupational injury or illness, the supervisor should complete the incident=accident report and, if possible, send it with the injured employee to the medical professional involved. The incident=accident report form must be completed and forwarded to the company’s medical department even if the employee receives medical treatment at the hospital or from a private physician.

Incidents not involving injury or illness, but resulting in property damage, must also be reported within 24 h of the incident. In cases of afire or explosion that cannot be controlled by one person, vehicular accident resulting in injury or more than $500 worth of damage, or a chemical release requiring a building evacuation, the involved party must immediately report the incident to the emergency response services in the area (911—police, fire, etc.)

All near-miss incidences also must be reported on the incident=accident report form within 24 h of occurrence. In place of indicating the result of the incident (i.e., actual personal or property damage), the reporting person shall indicate the avoided injury or damage.

Events, hazardous working conditions or situations, and incidents involving contractor personnel must be reported to the supervisor or safety professional immediately.

The safety department will record and maintain injury and illness data on the OSHA 301‘‘Injury and Illness Incident Report.’’ The OSHA 300 log ‘‘Log of Work-Related Injuries and Illnesses’’ and the OSHA 300A ‘‘Summary of Work-Related Injuries and Illnesses’’ must be posted from February 1 to April 30.

9.12.5 TRAINING

To ensure that all employees understand the incident reporting requirements and are aware of their own and other’s responsibilities, annual training sessions will be held with all employees to review procedures and responsibilities. New employee orientation training should include information on incident reporting and procedures.

9.12.6 PROGRAMAUDITS

The effectiveness of a program can only be accomplished if the program is imple-mented. Therefore, periodic reviews and audits shall be conducted to confirm that all employees are familiar with the incident reporting requirements.

The identification of hazards and the controlling of hazards within the workplace are the responsibilities of the employer and their management. Since employers are in control of the workplace, they have the right to set and enforce their own occupational safety and health requirements.