6 Occupational Safety and Health Programs
6.2 EXPLAINING THE REQUIREMENTS AND ELEMENTS OF OSHA GUIDELINES FOR A SAFETY AND HEALTH PROGRAMGUIDELINES FOR A SAFETY AND HEALTH PROGRAM
Although federal regulations do not currently require employers to have a written safety and health program, the best way to satisfy OSHA requirements and reduce accidents is for employers to produce one. In addition, distributing a written safety and health program to employees can increase employee awareness of safety and health hazards while, at the same time, reduce the costs and risks associated with workplace injuries, illnesses, and fatalities.
Federal guidelines for safety and health programs suggest that an effective occupational safety and health program must include evidence of
. Management commitment and leadership
. Assignment of responsibility
. Identification and control of hazards
. Training and education
. Recordkeeping and hazard analysis
. Availability offirst aid and medical assistance
If a representative from OSHA visits a jobsite, he=she will evaluate the safety program using the elements listed above. The compliance officer will review the previous items to assess the effectiveness of the safety and health program.
OSHA has set some guidelines for effective safety and health programs. Their application and description are presented to assist in the development of a written program.
6.2.1 MANAGEMENTCOMMITMENT ANDLEADERSHIP
Management Commitment and Leadership includes a policy statement that should be developed and signed by the senior person in the company. Safety and health goals and objectives should be included to assist with establishing workplace goals and objectives that demonstrate the company’s commitment to safety. An enforcement
Quick review sheet for safety and health programs Communication
. Awritten safety policy exists.
A list of company safety and health rules exist . Frequent safety meetings are conducted.
SafeWork Practices
. Trained individuals perform hazardous tasks.
. Machine and maintenance checklists are used.
. Personal protective equipment is used.
Safety Inspection
. Formal safety inspections are conducted at least weekly.
. Daily visual safety inspection takes place.
. Follow-up occurs on all safety suggestions.
. Job observations are conducted by supervisor.
. Health and safety rules are enforced.
Training
. Have an approved training plan.
. Have outlines for training sessions.
. Have a systematic approach to task training.
. Have job safety analysis or safe operating procedures for job classifications.
Accident Investigation
. All accidents are investigated.
. An accident investigation form is used.
. Accidents are analyzed.
FIGURE 6.2 A quick evaluation of a safety and health program.
policy is provided to outline disciplinary procedures for violations of the company’s safety and health program. This safety and health and the enforcement policy should be communicated to everyone on the construction jobsite. Some of the key aspects found under this section are
. Policy statement: goals established, issued, and communicated to employees.
. Program should be revised annually.
. Participation in safety meetings, inspections, safety items addressed in meetings.
. Commitment of resources is adequate in the form of budgeted dollars.
. Safety rules and procedures incorporated into jobsite operations.
. Procedure for enforcement of safety rules and procedures.
. Statement that management is bound to adhere to safety rules.
A safety and health policy statement clarifies the policy, standardizes safety within the company, provides support for safety, and supports the enforcement of safety and health within the company. It should set forth the purpose and philosophy of the company, delineate the program’s goal, assign responsibility for all company per-sonnel, and be positive in nature. It should be as brief as humanly possible (see the model safety and health program [MS&HP] later in this chapter).
Goals and objectives are very important and should be directly observable and measurable. They should be reasonable and attainable. The following are some examples of goals and objectives and the issues faced by those using them:
. Zero fatalities or serious injuries. (This is usually a pie in the sky or unreachable goal for most contractors. For example, if you had 25 accidents last year, zero is probably not possible.)
. Reduce injuries, lost workday accidents, and workers’ compensation claims by ____%.
. Prevention of damage or destruction to company property or equipment.
. Increase productivity through reduction of injuries by _____%.
. Reduce workers’ compensation costs by decreasing the number of claims to ____ or the cost by _____%.
. Enhance company’s image by working safely. Can you measure this in some way?
. Keep safety a paramount part of workers’ daily activities. What are the indicators of this? Number of near-misses, report of hazards, or number of observable unsafe acts.
. Recognize and reward safe work practices. How is this a goal? What could be the measurable outcome of this objective?
6.2.2 ASSIGNMENT OFRESPONSIBILITY
Assignment of responsibility identifies the responsibilities of management officials, supervisors, and employees. An emphasis on responsibility for safety and health
is more creditable if everyone is held accountable for their safety and health performance as related to established goals.
The company=contractor should designate an individual who knows the site, has knowledge of safety and health, and is accountable for the safety and health function.
In addition, all supervisors=forepersons must be told their responsibilities in job safety and health. All employees should be informed of the exceptions relevant to safety and health on the jobsite.
6.2.3 IDENTIFICATION ANDCONTROL OFHAZARDS
Identification and control of hazards includes those items that can assist you with identifying workplace hazards and determining the corrective action necessary to control them. These items include jobsite safety inspections, accident investigations, safety and health committees, and project safety meetings. Identification and control of hazards should include periodic site safety inspection programs that involve supervisors and, if you have them, joint labor management committees. Safety inspections should ensure that preventive controls are in place (personal protective equipment [PPE], guards, maintenance, engineering controls), that action is taken to quickly address hazards, that technical resources such as OSHA, state agencies, professional organizations, and consultants are used, and that safety and health rules are enforced.
The core of an effective safety and health program is hazard identification and control. Periodic inspections and procedures for correction and control provide methods of identifying existing or potential hazards in the workplace and eliminating or controlling them. The hazard control system provides a basis for developing safe work procedures and injury and illness prevention training. Hazards occurring or recurring reflect a breakdown in the hazard control system.
The written safety and health program establishes procedures and responsibilities for the identification and correction of workplace hazards. The following activities are used by the company=contractor to identify and control workplace hazards:
jobsite inspections, accident investigation, safe operating procedures, and safety and health committees.
As part of this safety and health program, the site contractor responsible for each company project=jobsite needs to identify high hazard areas of operation, determine inspection priorities, establish inspection responsibilities and schedules, and develop a management system to review, analyze, and take corrective action on inspection findings. This is especially true of today’s workplace environment, where OSHA has gone to great lengths to address safety and health responsibilities on multiemployer jobsites=projects.
All accidents should be investigated to determine causal factors and to prevent future recurrences of similar accidents. A written report of investigation findings should be prepared by the injured employee’s immediate supervisor and submitted to the site superintendent for review. In most cases, a standard format should be developed to ensure that each incident information report is consistent and complete.
Whenever an accident is reported, the supervisor of the injured worker(s) should respond to the scene of the accident as soon as possible and complete the super-visor’s accident report. All witnesses should be interviewed privately as soon as possible after the accident. If possible, the supervisor should interview the worker(s) at the scene of the accident so that events leading up to the accident can be reenacted.
Photographs should be taken as soon as possible after the accident and should include the time and date taken. Supervisors are required to submit accident inves-tigation reports that answer the questions: Who? What? When? Where? and How? as denoted earlier in this chapter.
6.2.4 TRAINING ANDEDUCATION
Training and education is one of the most important elements of any safety and health program. Each training item should describe methods for introducing and communicating new ideas into the workplace, reinforcing existing ideas and proce-dures, and implementing your safety and health program. The training needs may range from supervisor training, especially work task training, employee updates, and new worker orientation. The content of new worker or new site training should include at least the following topics:
. Company safety and health program and policy
. Employee and supervisory responsibilities
. Hazard communication training
. Emergency and evacuation procedures
. Location offirst-aid stations, fire extinguishers, and emergency telephone numbers
. Site-specific hazards
. Procedures for reporting injuries
. Use of personal protective equipment
. Hazard identification and reporting procedures
. Review of each safety and health rule applicable to the job
. Site tour or map where appropriate
It is a good idea to have follow-up for all training, which may include working with a more experienced worker, supervisor coaching, job observations, and reinforced good=safe work practices.
Supervisors=forepersons are responsible for the prevention of accidents in tasks under their direction and for thorough accident prevention and safety training for the employees they supervise. Therefore, all supervisors=forepersons will receive training so that they have a sound theoretical and practical understanding of the site-specific safety program, OSHA construction regulations, and the company’s specific safety and health rules. They should also receive training on the OSHA hazard communication standard, site emergency response plans,first aid and CPR, accident and injury reporting and investigation, and procedures for safety communications such as toolbox safety talks. Beyond these training requirements described previously, additional training might cover the implementation and monitoring of a construction safety program,
personnel selection techniques, OSHA recordkeeping requirements, and motivating individuals and groups.
6.2.5 RECORDKEEPING AND HAZARDANALYSIS
Recordkeeping and hazard analysis identifies the types of records that OSHA requires your company to maintain and who is responsible for maintaining these records. Procedures for conducting hazard analyses are provided to enable you to learn from past experiences and to take corrective action to prevent future injuries and illnesses. The records that need to be maintained are employee injuries and illnesses, accident investigations, causes and proposed corrective measures, near-misses, training records, and company-required inspection or maintenance records.
Various types of reports are necessary to meet the recordkeeping requirements of OSHA, insurance carriers, and other government regulatory agencies.
Medical records should be maintained for the length of an employee’s employ-ment plus 30 years, while exposure records should be kept for 30 years. These records are confidential. Information from an employee’s medical record will be released only to the employee or his=her designated representative after written consent from the employee.
Training records should be maintained in each employee’s personnel file and should be available for review upon request.
6.2.6 FIRSTAID ANDMEDICALASSISTANCE
First aid and medical assistance identifies the provisions your company should establish to providefirst aid and medical services on your jobsites. Sample emer-gency procedures are included to respond to various types of emergencies that may occur.
Experience indicates that supervisors=forepersons who receive basic first aid and CPR training are much more safety conscious and usually have better crew safety performance records. Therefore, allfield supervisory personnel should be required to attend basicfirst aid and CPR training. Each jobsite should maintain a first-aid log, which includes the following information:
. Injured employee’s name
. Immediate supervisor
. Date and time of injury
. Nature and cause of the injury
. Injured employee’s craft
. Treatment rendered and disposition of employee (returned to work or sent for medical attention)
All employees should be provided with the location(s) of thefirst-aid stations on each project=jobsite. Instructions for using first-aid equipment should be located at each station. In the event of an emergency, employees are to contact any supervisor or individual who is trained infirst aid.
6.2.7 EMERGENCY ANDFIREFIGHTINGPROCEDURES
Emergency andfirefighting procedures should be an integral part of a good safety and health program. There should be guidelines forfirefighting, such as that all firefighting equipment should be conspicuously located and readily available at all times and inspected and maintained in operating condition; and all fire protection equipment should be inspected no less than once monthly with documentation maintained for each piece of equipment inspected. Discharged extinguishers or damaged equipment should be immediately removed from service and replaced with operable equipment, and all supervisors and employees should search for potential fire hazards and coordinate their abatement as rapidly as possible.
Individuals assigned safety responsibilities should receive the necessary training to properly recognizefire hazards, inspect and maintain fire extinguishers, and know the proper use of each. A trained and equipped firefighting brigade should be established, as warranted by the project, to ensure adequate protection to life.
The emergency procedure should be spelled out as related to response, action, and expectations for workers when such emergencies occur. These may include a standard warning alarm, emergency telephone and communication procedures, and an evacuation plan. These procedures should be practiced by regular drills.
The composition or components of your safety and health program may vary depending on the complexity of your operations. They should at least include
. Management’s commitment and safety and health policy
. Hazard identification and evaluation
. Hazard control and prevention
. Training
Of course, each of these may have many subparts that address the four elements in some detail. The safety and health program that you develop should be tailored to meet your specific needs. The following is a MS & HP and should provide a foundation.
6.3 MODEL SAFETY AND HEALTH PROGRAM