Professional Documents
Culture Documents
Workplace Safety Management
Workplace Safety Management
How to Establish
And Run a Workplace
Safety Program
10030760
Safety 101:
How to Establish and Run
A Workplace Safety Program
6/08 Business & Legal Reports, Inc. (10030760)
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Chapter 1. What Makes a Great Safety Professional? ...........................................................................1
Special Challenges if Safety Is an Added Responsibility ..............................................................................1
What Is Your Role as a Safety Manager?........................................................................................................2
How This Book Will Help ..............................................................................................................................2
Next Steps.........................................................................................................................................................3
Chapter 2. Set the Stage for Safety Success.............................................................................................5
Be a Cheerleader and a Business Advocate for Safety ..................................................................................5
Bottom Line.....................................................................................................................................................5
Safety a Necessity.............................................................................................................................................5
Insist on Top Management Support and Participation ................................................................................6
Clarify Responsibilities: Yours, Managements, Employees.........................................................................6
Encourage Employee Involvement ................................................................................................................6
Create a Safety Culture ...................................................................................................................................7
Next Steps.........................................................................................................................................................7
Chapter 3. Get Familiar with OSHA ....................................................................................................9
What Is OSHA?................................................................................................................................................9
What About State Safety Regulations?...........................................................................................................9
Rights and Responsibilities Under OSHA...................................................................................................10
What OSHA Requires of Employers ............................................................................................................10
What OSHA Requires of Employees .............................................................................................................10
What Rights OSHA Gives Employees ..........................................................................................................11
OSHAs Guidelines for Safety Programs ......................................................................................................11
Should You Follow OSHAs Guidelines? ......................................................................................................11
OSHAs Posting, Recordkeeping, and Notification Requirements............................................................12
OSHA Recordkeeping Requirements ............................................................................................................12
OSHA Posting Requirements........................................................................................................................13
Notification Requirements ............................................................................................................................13
OSHA Inspections, Citations, Penalties.......................................................................................................13
Assistance from OSHA..................................................................................................................................13
Consultation Services for the Employer..........................................................................................................13
Inspection Exemption....................................................................................................................................14
State Consultation Project Directory..............................................................................................................14
OSHA Partnership Programs .......................................................................................................................14
Voluntary Protection Programs (VPP) ...........................................................................................................14
How Does VPP Work? ..................................................................................................................................15
OSHAs Safety and Health Achievement Recognition Program (SHARP) .....................................................15
OSHA Offices .................................................................................................................................................16
Next Steps.......................................................................................................................................................16
Chapter 4. Meet Your Legal Obligations..............................................................................................17
Safety Law ......................................................................................................................................................17
OSH Act and Regulations .............................................................................................................................17
General Duty Clause .....................................................................................................................................17
Requesting Variances from OSHA Regulations..........................................................................................18
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Other Guidelines, Rules, and Laws .............................................................................................................18
Professional and Industrial Association Guidelines ........................................................................................18
Workers Compensation.................................................................................................................................19
DOT..............................................................................................................................................................19
Whistleblower ...............................................................................................................................................19
Other Legal Challenges Related to Safety ....................................................................................................20
Negligence Suits............................................................................................................................................20
Refusals: Its Not Safe and I Wont Do It .......................................................................................................20
Refrain from Retaliation................................................................................................................................20
Next Steps.......................................................................................................................................................21
Chapter 5. Identify Your Workplaces Hazards ....................................................................................23
Quick Tips on Hazard Identification: ..........................................................................................................23
Use a Variety of Hazard Indicators ..............................................................................................................24
Evaluate Written Evidence.............................................................................................................................24
Interview EmployeesNo Reprisal...............................................................................................................24
Perform a Physical Worksite Analysis ........................................................................................................24
General Cleanliness of the Worksite...............................................................................................................24
Actions Governed by Specific Rules...............................................................................................................25
Proper Operation of Equipment.....................................................................................................................25
Environmental Hazards .................................................................................................................................25
Behavioral Hazards ........................................................................................................................................25
Perform Job-by-Job Analysis .......................................................................................................................25
How to Perform an OSHA Job Hazard Analysis............................................................................................25
What Is Job Hazard Analysis? .......................................................................................................................25
Selecting Jobs for Analysis .............................................................................................................................26
Using Internal and External Sources ..............................................................................................................26
Tips for Gathering Information......................................................................................................................26
General Conditions ........................................................................................................................................26
Breaking Down the Job .................................................................................................................................27
Identifying Hazards .......................................................................................................................................27
Recommending Safe Procedures and Protection.............................................................................................28
Revising the Job Hazard Analysis..................................................................................................................28
Dont Forget These Employment Issues ......................................................................................................28
Next Steps.......................................................................................................................................................29
Chapter 6. Look for These Specific Hazards ........................................................................................31
Emergencies....................................................................................................................................................33
Fire Prevention and Control...........................................................................................................................33
Emergencies and Evacuations.........................................................................................................................34
First Aid ........................................................................................................................................................35
Violence .......................................................................................................................................................37
Physical Plant .................................................................................................................................................39
Walking and Working Surfaces .....................................................................................................................39
Sanitation.......................................................................................................................................................40
Security .........................................................................................................................................................42
Environmental Issues: Ventilation, Noise, Radiation .....................................................................................43
Electrical........................................................................................................................................................44
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Machinery and Machine Guarding.................................................................................................................45
Temporary Labor Camps ................................................................................................................................46
Hazardous Materials ......................................................................................................................................47
13 Carcinogens ..............................................................................................................................................47
Air Contaminants ..........................................................................................................................................47
Asbestos.........................................................................................................................................................48
Compressed Gases..........................................................................................................................................48
Dipping and Coating Operations...................................................................................................................48
Explosives and Blasting Agents .....................................................................................................................48
Flammable and Combustible Liquids ............................................................................................................48
Spray Finishing Using Flammable and Combustible Materials......................................................................49
Storage and Handling of Liquefied Petroleum Gases .....................................................................................49
Storage and Handling of Anhydrous Ammonia .............................................................................................49
Process Safety Management of Highly Hazardous Chemicals ...................................................................49
Hazardous Waste Operations and Emergency Response ...........................................................................49
Who is Covered?............................................................................................................................................50
Essential HAZWOPER Components ............................................................................................................50
Written Safety and Health Program...............................................................................................................51
Occupational Exposure to Hazardous Chemicals in Laboratories.............................................................51
Personal Protective Equipment (PPE) .........................................................................................................51
General Protection.........................................................................................................................................51
Hazard Assessment ........................................................................................................................................52
Defective PPE................................................................................................................................................52
Training.........................................................................................................................................................52
Payment for PPE............................................................................................................................................52
Employee-Owned Equipment........................................................................................................................52
Written PPE Program for HAZWOPER......................................................................................................53
Respiratory Protection...................................................................................................................................53
Dress and Grooming......................................................................................................................................54
Hazardous Processes/Activities ....................................................................................................................54
Control of Hazardous Energy (Lockout/Tagout) .............................................................................................54
Permit-Required Confined Spaces..................................................................................................................55
ErgonomicsHow People Interact with Environment..................................................................................57
Hand and Portable Powered Tools and Other Hand-Held Equipment...........................................................58
Materials Handling and Storage.....................................................................................................................58
Powered Platforms, Manlifts, and Vehicle-Mounted Work Platforms ............................................................59
Hot WorkWelding, Cutting, and Brazing.................................................................................................59
Commercial Diving Operations .....................................................................................................................60
Health Issues ..................................................................................................................................................60
Heat and Cold ..............................................................................................................................................60
Dermatitis and Other Skin Problems.............................................................................................................61
Stress Management ........................................................................................................................................62
Safety Issues for Specific Types of Workplaces...........................................................................................62
Office.............................................................................................................................................................62
Manufacturing...............................................................................................................................................63
Maintenance...................................................................................................................................................63
Retail .............................................................................................................................................................63
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Medical Facilities ...........................................................................................................................................63
Food Service...................................................................................................................................................63
Transportation ...............................................................................................................................................64
Schools, Colleges............................................................................................................................................64
OSHAs Special Industries Rules ..................................................................................................................64
Next Steps.......................................................................................................................................................65
Chapter 7. Eliminate or Control Hazards ...........................................................................................67
Preferred Solution: Eliminate the Hazard ..................................................................................................67
Move the Problem Up the Pipeline................................................................................................................67
Use Engineering Controls ..............................................................................................................................67
Try Administrative Controls ..........................................................................................................................68
Protect with PPE ...........................................................................................................................................68
Deal with Behavioral Hazards......................................................................................................................68
Why Was Procedure Not Followed?..............................................................................................................68
Training.........................................................................................................................................................68
Counseling.....................................................................................................................................................68
Discipline ......................................................................................................................................................68
Mandate Start-Up and Daily Inspections ....................................................................................................69
Recognize the Role of Maintenance in Hazard Control..............................................................................69
Develop Policies and Procedures .................................................................................................................69
Policies, Rules, Procedures, Programs, Handbooks........................................................................................69
Consider a Safety Handbook.........................................................................................................................70
Why Have a Safety Handbook? .....................................................................................................................70
Do You Need a Handbook? ...........................................................................................................................70
Weigh the Benefits of an On-Site Medical Facility......................................................................................72
Next Steps.......................................................................................................................................................72
Chapter 8. Train All Employees, Supervisors, and Managers ..............................................................73
Cope with Training Challenges.....................................................................................................................73
Deal with Training a Diverse Workforce........................................................................................................74
Supervisory Training Tips ..............................................................................................................................74
Documenting Training ..................................................................................................................................75
Train After a Change in Equipment or Procedures.........................................................................................75
Conduct Orientation Training ......................................................................................................................75
Typical Orientation Safety Topics...................................................................................................................75
Warnings About Unsuspected Hazards .........................................................................................................76
Specifications for Accident Prevention Signs and Tags ...................................................................................76
Lets Get to It.................................................................................................................................................77
Implement OSHAs Hazard Communication Standard..............................................................................77
Special Rules..................................................................................................................................................77
Exempt Chemicals .........................................................................................................................................77
Hazard Determination...................................................................................................................................78
Written Hazard Communication Program.....................................................................................................79
Trade Secrets ..................................................................................................................................................82
Use OSHAs Seven-Step Voluntary Training Guidelines ............................................................................82
OSHA Step #1: Determine if Training Is Needed.........................................................................................82
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OSHA Step #2: Identifying Training Needs .................................................................................................84
OSHA Step #3: Identifying Goals and Objectives ........................................................................................85
OSHA Step #4: Developing Learning Activities...........................................................................................87
OSHA Step #5: Conducting the Training.....................................................................................................88
OSHA Step #6: Evaluating Program Effectiveness........................................................................................89
OSHA Step #7: Improving the Program.......................................................................................................89
Next Steps.......................................................................................................................................................90
Chapter 9. Motivate Safe Behavior......................................................................................................91
Face the Double Challenge of Safety Management .....................................................................................91
Start with Managers and Supervisors..............................................................................................................91
The Productivity vs. Safety Argument ...........................................................................................................91
Understand Why Accidents Happen...........................................................................................................92
Foster Motivation...........................................................................................................................................92
Try Incentive Programs.................................................................................................................................93
Typical Incentive Programs............................................................................................................................93
Exercise Care..................................................................................................................................................93
Two Observations...........................................................................................................................................93
Discipline for Safety Infractions...................................................................................................................93
Progressive Discipline....................................................................................................................................93
Install a Safety Committee.............................................................................................................................94
Developing and Training the Committee.......................................................................................................96
Job Description of an Effective Safety Committee Member............................................................................97
Next Steps.......................................................................................................................................................97
Chapter 10. Manage Ongoing Safety Responsibilities..........................................................................99
Set Safety Goals, Evaluate, and Update........................................................................................................99
Goal Setting...................................................................................................................................................99
Evaluation......................................................................................................................................................99
Revision and Updating................................................................................................................................100
Perform Safety Audits .................................................................................................................................100
Manage Recordkeeping Requirements .....................................................................................................101
Form 300 Is Just the Beginning ..................................................................................................................101
Other Recordkeeping Requirements............................................................................................................101
Worth the Trouble.......................................................................................................................................102
Right to Access Records ..............................................................................................................................102
Employees Rights to Records......................................................................................................................102
Record Retention.........................................................................................................................................104
Penalties ......................................................................................................................................................104
Reducing Lapses in Recordkeeping..............................................................................................................104
Handle an OSHA Inspection ......................................................................................................................106
OSHA Has the Right to Inspect..................................................................................................................106
Should You Request a Warrant? ..................................................................................................................108
Conduct of the Inspection............................................................................................................................109
Citation, Conference, Contest ......................................................................................................................111
Civil and Criminal Penalties ........................................................................................................................111
Dealing with Inspectors: How to Handle Yourself.......................................................................................111
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Investigate Accidents ..................................................................................................................................113
Employee Cooperation.................................................................................................................................113
Investigation Priority...................................................................................................................................113
Administer Workers Compensation..........................................................................................................116
What Is Workers Compensation? ...............................................................................................................116
What Workers Compensation Covers .........................................................................................................116
Workers Compensation Policy Points to Ponder .........................................................................................117
Consider Light-Duty Programs ..................................................................................................................118
Next Steps.....................................................................................................................................................120
AppendicesSafety Program Resources .............................................................................................121
Appendix A. Safety and Health Resources on the Internet .................................................................123
Whats with the Web? .................................................................................................................................123
Appendix B. State Safety Programs....................................................................................................125
Appendix C. Model Safety Programs..................................................................................................133
Model Safety Program #1 ............................................................................................................................134
B&B Manufacturing Company Safety Program............................................................................................134
B&B Manufacturing Company Safety Training............................................................................................135
Model Safety Program #2 ............................................................................................................................136
TITLE: XYZ COMPANY SAFETY AND HEALTH PROGRAM ..........................................................136
Model Safety Program #3 ..........................................................................................................................138
TITLE: ABC COMPANY SAFETY AND HEALTH PROGRAM ...........................................................138
Appendix D. Model Safety Policies ....................................................................................................141
Safety Policies...............................................................................................................................................142
Points to Cover ............................................................................................................................................142
Things to Consider ......................................................................................................................................143
Sample General Safety Policy.......................................................................................................................144
Exhibit A.....................................................................................................................................................146
Personal Protective Equipment .................................................................................................................148
Background .................................................................................................................................................148
Revised OSHA Regulation..........................................................................................................................148
Points to Cover ............................................................................................................................................151
Legal Points .................................................................................................................................................151
Things to Consider ......................................................................................................................................152
Sample Policies ...........................................................................................................................................152
Subject: Safety/Protection Example of: Standard Policy .............................................................................153
Accident-Reporting Policies .......................................................................................................................155
Points to Cover ............................................................................................................................................155
Legal Points .................................................................................................................................................156
Things to Consider ......................................................................................................................................156
Sample Accident Reporting Policy ..............................................................................................................157
Sample Safety and Accident Prevention Policy.............................................................................................157
Emergency Policies ......................................................................................................................................161
Points to Cover ............................................................................................................................................161
Legal Points .................................................................................................................................................162
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Things to Consider ......................................................................................................................................162
Sample Emergency Policy #1.......................................................................................................................163
Sample Emergency Policy #2.......................................................................................................................164
Fire Prevention Policies ..............................................................................................................................164
Points to Cover ............................................................................................................................................164
Things to Consider ......................................................................................................................................166
Sample Safety Habits/Fire Prevention Policy (Standard) ..............................................................................166
Sample Fire Prevention Policy (Progressive).................................................................................................167
Workers Compensation Policies................................................................................................................172
Points to Cover ............................................................................................................................................172
Legal Points .................................................................................................................................................173
Things to Consider ......................................................................................................................................174
Sample: Workers Compensation Policy (Progressive) Supervisor Guidelines...............................................176
Sample: Workers CompensationTime Frame (Strict) ..............................................................................180
Hazard Communication Policies and Programs .......................................................................................181
Legal Points .................................................................................................................................................181
Points to Cover ............................................................................................................................................181
Things to Consider ......................................................................................................................................182
Sample: Right-to-KnowPlan of Implementation for an End-User of Chemicals ......................................184
Ergonomics Policy........................................................................................................................................187
Sample: Ergonomics Policy..........................................................................................................................187
Return-to-Work Policies .............................................................................................................................189
Sample: Return-to-Work Policy #1 .............................................................................................................189
Sample: Return-to-Work Policy #2 .............................................................................................................189
Appendix E. Master Training Guide for 29 CFR ..............................................................................191
Appendix F. Model Safety Checklists and Training Guides ...............................................................199
Subpart D Walking and Working Surfaces ............................................................................................203
General Housekeeping.................................................................................................................................203
Maintenance ................................................................................................................................................203
Guarding Floor and Wall Openings and Holes............................................................................................203
Stairs............................................................................................................................................................204
Extension Ladders ........................................................................................................................................204
General Ladder Requirements......................................................................................................................204
Ladder Maintenance.....................................................................................................................................205
Portable Rung Ladders ................................................................................................................................205
Portable Wood Ladders................................................................................................................................205
Portable Metal Ladders ................................................................................................................................205
Fixed Ladders...............................................................................................................................................206
Scaffolding...................................................................................................................................................206
Training.......................................................................................................................................................206
Subpart E Exit Routes, Emergency Action Plans, and Fire Prevention Plans.....................................207
Design Requirements for Exit Routes .........................................................................................................207
Maintenance, Safeguards, and Operational Features for Exit Routes ............................................................208
Emergency Action Plans ..............................................................................................................................209
Fire Prevention Plans ...................................................................................................................................209
Training.......................................................................................................................................................210
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Subpart F Powered Platforms, Manlifts, and Vehicle-Mounted Work Platforms ..............................211
Powered Platforms for Building Maintenance..............................................................................................211
Training.......................................................................................................................................................215
Subpart G Occupational Health and Environmental Control...............................................................217
Ventilation...................................................................................................................................................217
Noise ...........................................................................................................................................................217
Nonionizing Radiation................................................................................................................................218
Ventiliation Training ...................................................................................................................................218
Occupational Noise Exposure Training........................................................................................................218
Subpart H Hazardous Materials ..............................................................................................................219
Compressed Gases........................................................................................................................................219
Acetylene.....................................................................................................................................................219
Hydrogen.....................................................................................................................................................220
Oxygen........................................................................................................................................................220
Nitrous Oxide..............................................................................................................................................221
Flammable and Combustible Liquids ..........................................................................................................221
Spray Finishing Using Flammable and Combustible Materials....................................................................221
Explosives and Blasting Agents ...................................................................................................................222
Storage and Handling of Liquefied Petroleum Gases ...................................................................................223
Storage and Handling of Anhydrous Ammonia ...........................................................................................224
Process Safety Management of Highly Hazardous Chemicals.......................................................................224
Hazardous Waste Operations and Emergency Response...............................................................................225
Dipping and Coating Operations.................................................................................................................225
Compressed Gases Training .........................................................................................................................226
Flammable and Combustible Liquids Training............................................................................................227
Explosives and Blasting Agents Training.....................................................................................................229
Storage and Handling of Liquefied Petroleum Gases Training.....................................................................230
Storage and Handling of Anhydrous Ammonia Training.............................................................................231
Process Safety Management of Highly Hazardous Chemicals Training ........................................................232
Hazardous Waste Operations and Emergency Response (HAZWOPER) Training......................................233
Dipping and Coating Operations Training ..................................................................................................236
Subpart I Personal Protective Equipment..............................................................................................237
Assessing Appropriate PPE..........................................................................................................................237
Training.......................................................................................................................................................237
Wearing and Maintaining Equipment .........................................................................................................237
Skin Protection............................................................................................................................................237
Eye and Face Protection...............................................................................................................................238
Respiratory Protection.................................................................................................................................238
Head Protection...........................................................................................................................................240
Foot Protection............................................................................................................................................240
Training.......................................................................................................................................................240
Subpart J General Environmental Controls............................................................................................243
Sanitation.....................................................................................................................................................243
Temporary Labor Camps ..............................................................................................................................244
Permit-Required Confined Spaces................................................................................................................245
Control of Hazardous Energy (Lockout/Tagout) ...........................................................................................249
Temporary Labor Camps Training................................................................................................................250
Specifications for Accident-Prevention Signs and Tags Training..................................................................250
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Permit-Required Confined Spaces Training.................................................................................................251
Control of Hazardous Energy (Lockout/Tagout) Training.............................................................................252
Subpart K Medical and First Aid ............................................................................................................253
Medical and First Aid ..................................................................................................................................253
Training.......................................................................................................................................................253
Subpart L Fire Protection.........................................................................................................................254
Fire Protection Compliance..........................................................................................................................254
Training.......................................................................................................................................................256
Subpart M Compressed Gas and Compressed Air Equipment.............................................................258
Compressed Gas/Air Equipment..................................................................................................................258
Training.......................................................................................................................................................258
Subpart N Materials Handling and Storage............................................................................................258
Materials Handling and Storage...................................................................................................................258
Servicing Rim Wheels .................................................................................................................................258
Overhead and Gantry Cranes .......................................................................................................................258
Crawler Locomotive and Truck Cranes.........................................................................................................259
Derricks .......................................................................................................................................................259
Helicopters ..................................................................................................................................................259
Slings...........................................................................................................................................................259
Powered Industrial Trucks ...........................................................................................................................259
Servicing Multipiece and Single-Piece Rim Wheels Training......................................................................261
Powered Industrial Trucks Training.............................................................................................................262
Subpart O Machinery and Machine Guarding .......................................................................................264
Machinery and Machine Guarding...............................................................................................................264
Training.......................................................................................................................................................265
Subpart P Hand and Portable Powered Tools and Other Hand-Held Equipment.............................266
Portable Tools and Hand-Held Equipment..................................................................................................266
Training.......................................................................................................................................................266
Subpart Q Welding, Cutting, and Brazing .............................................................................................267
Welding, Cutting, and Brazing ...................................................................................................................267
Training.......................................................................................................................................................268
Subpart R Special Industries ...................................................................................................................269
Pulp, Paper, and Paperboard Mills...............................................................................................................269
Textiles ........................................................................................................................................................269
Bakery Equipment.......................................................................................................................................269
Laundry Machinery and Operations .............................................................................................................269
Sawmills ......................................................................................................................................................270
Logging Operations .....................................................................................................................................270
Telecommunications ....................................................................................................................................270
Electric Power Generation, Transmission, and Distribution.........................................................................270
Grain-Handling Facilities............................................................................................................................270
Pulp, Paper, and Paperboard Mills Training ................................................................................................270
Textiles Training..........................................................................................................................................271
Bakery Equipment Training ........................................................................................................................271
Laundry Machinery and Operations Training...............................................................................................271
Sawmills Training........................................................................................................................................272
Logging Operations Training.......................................................................................................................272
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Telecommunications Training......................................................................................................................274
Electric Power Generation, Transmission, and Distribution Training..........................................................276
Grain-Handling Facilities Training .............................................................................................................276
Subpart S Electrical...................................................................................................................................277
Electrical Safety-Related Work Practices .....................................................................................................277
Training.......................................................................................................................................................278
Subpart T Commercial Diving Operations.............................................................................................279
Commercial Diving Operations ...................................................................................................................279
Training.......................................................................................................................................................279
Subpart Z Toxic and Hazardous Substances..........................................................................................280
Air Contaminants ........................................................................................................................................280
Asbestos.......................................................................................................................................................281
Access to Employee Exposure and Medical Records.....................................................................................283
Bloodborne Pathogens .................................................................................................................................284
Ionizing Radiation.......................................................................................................................................287
Hazard Communication Compliance ...........................................................................................................287
Retention of DOT Markings, Placards, and Labels ......................................................................................288
Occupational Exposure to Hazardous Chemicals in Laboratories..................................................................289
Hazardous Substances Training....................................................................................................................289
Access to Records Training..........................................................................................................................291
Bloodborne Pathogens Training...................................................................................................................292
Hazard Communication Training ................................................................................................................293
Occupational Exposure to Hazardous Chemicals in Laboratories Training...................................................294
Appendix G. How to Create a Disaster Plan .....................................................................................295
1
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Chapter 1
What Makes a Great
Safety Professional?
Congratulations! Youre now in charge of safety. Whether safety is your full-time job or an additional
responsibility, you may feel overwhelmed and may not know where to start. However, much about
safety management is training and motivating employeesexpertise that you may already have
In this book, well look at the key elements of successful safety programs and show you how to imple-
ment them in your organization. Well cover:
The role of the safety manager
Setting the stage for safety success
How to identify hazards and neutralize their dangers
How to write policies and a safety handbook
How to assess training needs and develop and deliver training
How to motivate employees toward safe behavior
How to perform the many other aspects of safety management, like audits, inspections, investi-
gations, and so on
Special Challenges if Safety Is an Added Responsibility
Its always tricky to do a tough job like safety management as a part-time responsibility. You may
have to devote some attention to drawing boundaries and setting policies that help you to keep control of
your time. Here are some suggestions.
Spread the load. When safety is a secondary responsibility, you must guard against anyone
thinking you can do a full-time job of it. You need to work hard to clarify responsibilities, and
to make sure that manager and department heads do their share of the safety work
Rely on your safety committee. Your committee can do much to manage the safety program.
Take advantage of the committee. Make sure it meets regularly and often. Have the other
members involved directly in safety management. For example, have each member agree to
take a turn doing the monthly auditsdont you try to do every audit every month. Members
can also be involved in training, accident investigations, and so on.
Bring others into safety business. Perhaps the managers will each take a turn walking
through another managers department. Develop detailed policies and procedures. Make sure
that everyone knows what their responsibilities are.
Use outside resources. Perhaps you will purchase training videos, or hire outside consultants
for some safety tasks. Maybe local fire and police can help with disaster preparations or emer-
gency training.
What Is Your Role as a Safety Manager?
Of course, every worksite is different, with different hazards and different challenges. But most safety
managers are involved with the following:
Be an advocate for safety
Get management backing and participation
Develop general safety policies
Clarify responsibilities
Create a safety focus
Identify and control hazards
Assess workplace hazards
Take steps to eliminate them
Develop and deliver safety training
Orient new employees
Provide new and review training
Train for new equipment and new processes
Motivate safe behavior
Implement incentive programs
Discipline when necessary
Perform special safety responsibilities
Support the safety committee
Perform accident reporting and investigation
Manage workers compensation
How This Book Will Help
Well give you guidelines for meeting all these responsibilities and point you to sources for additional
materials. Since every workplace is different, however, youll need to pick and choose which elements are
most important for you and your work situation.
To get started, heres what we recommend:
1. Skim through this book to get an idea of what safety management is all about.
2. Familiarize yourself with your organizations current safety status:
Review policies on safety, and also any other safety materials such as a safety handbook.
Review safety program activities such as training, incentive programs, etc.
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Review the safety history as found in accident reports, OSHA 300 logs, and workers
compensation claims.
Identify safety equipment used, such as fire protection, eyewash, and personal protective
equipment.
Check schedules for training, audits, committees, etc.
Talk to key managers about safety issues in their departments.
3. Work your way through this book, conducting a hazard identification/hazard control
program, devising a training schedule, and setting up ongoing safety program elements.
4. Chart out how you will approach managing your safety program and improving it. Which
areas need attention (training, compliance, motivation), how badly do they need it, and when
do they need it?
5. Create a safety plan and set goals for your new program.
Next Steps
The next chapter discusses some critical steps that you must take before you start the detailed work
of identifying and controlling hazards and developing your safety program.
What Makes a Great Safety Professional?
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Chapter 2
Set the Stage for Safety Success
To run an effective safety program, you need to be an enthusiastic booster of safety. But enthusiasm
isnt enough to win over managementyou need to make the business case for safety as well.
Be a Cheerleader and a Business Advocate for Safety
Management will readily agree that safety is important, and they know that they have a moral
obligation to maintain a safe workplace. But sometimes its hard to get that concern translated into a
budget for safety products, to get people released for safety training, and to get time allocated for safety
committee meetings, inspections, and investigations.
Bottom Line
While you want to be an enthusiastic cheerleader, remember that management tends to be influenced
most by impact to the bottom line. So enthusiasm and moral arguments arent enough. You need to be
able to justify safety program elements as cost-saving and productivity enhancing. Heres help for
explaining to your management how safety is good for its own sake, and for productivity and profit.
The most important factor is a simple one: An unsafe workplace is unproductive and unprofitable.
Safety a Necessity
Here are some more specific reasons for safety programs.
Injuries and illnesses drop productivity dramatically. Safety problemsaccidents, injuries,
illnessescan shut down production lines for repairs or for investigations. Further, lost-time
accidents mean the loss of skilled workerssubstitutes just cant keep productivity up.
Fines and sanctions for noncompliance with safety rules can be stiff. Organizations have a
legal obligation to keep employees safe. The Occupational Safety and Health Administration
(OSHA) requires organizations to provide a safe workplace.
In spite of workers compensation laws, lawsuits lurk. Even more expensive and time-
consuming than OSHA sanctions are lawsuits that are likely when theres even a hint of
negligence. And dont think juries are going to side with you when an injured employee takes
the stand.
Morale suffers when safety suffers. I told them about the hazard, but they just dont care.
That attitude isnt going to make for eager, productive workers.
When morale suffers, retention suffers. When employees dont feel secure where they work,
and dont think that management cares about their safety, they are much more likely to look
for other work. Thats another expensive problemlost productivity while you hire and train
new workersif you can find them.
Yes there is a modest investment for safety programs, but the return on that investment can be
dramatic.
Insist on Top Management Support and Participation
As with most any organizational project, the first step is to gain management support. And experi-
enced safety people know that management cant just be supportivethey have to show it. They have
to let everyone in the organization know that safety comes before productivity. If top management wont
support that premise, then youll never get anyone else to support it.
Support includes resources, access, and participation.
Resources for safety. This means reasonable budget allocations for safety training materials,
safety signs, posters, lockout equipment, etc. It also means commitment to time for investiga-
tions, safety meetings, and so on.
Access to the top for safety. In addition, safety personnel need to have access to upper
management so that safety concerns can be aired at high levels in the structure.
Frequent and enthusiastic participation. Management must be present at safety awards, at
training, and must take an active role.
OSHA says In an effective program, management regards worker safety and health as a fundamental
value of the organization and applies its commitment to safety and health protection with as much vigor
to other organizational goals.
Clarify Responsibilities: Yours, Managements, Employees
One problem that can easily sidetrack the best safety efforts is lack of clarity about responsibility. Lay
out the safety responsibilities for the following groups:
Top management
Safety officer
Safety committee members
Managers and supervisors
Employees with special responsibilities such as first aid, firefighting, or emergency shutdown
All employees
In each case, try to be specific. Spell out who performs each major safety task and how and where
they get the resources to accomplish it.
Encourage Employee Involvement
Most experts believe that for a safety program to work, employees must be involved. There are two
important aspects to this.
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Build in employee involvement. When planning how to structure and operate your safety
program, and when making decisions that affect employee safety and health, build in
employee participation every step of the way.
Insist that participating employees be supported. Managers and supervisors must be truly
supportive. They do this actively by encouraging participation, but also by their attitudes.
For example, they cant act annoyed when an employee needs time off to attend a safety
meeting. You cant have employees thinking, Being on this safety committee is going to hurt
my career chances.
Create a Safety Culture
Its not enough to have a policy and a program. Safety managers need to think in terms of developing
a safety culturea workplace in which safety is part of the landscape, a routine presence in every
employees work habits. Here are some of the things that will help:
Publicize your commitment. Make sure safety is mentioned at all employee meetings, gather-
ings, training sessions, etc.
Involve employees. As mentioned above, the more employees feel they have had a hand in
creating the program, the more committed they will be to carrying it out.
Have an active safety committee. Safety committees are discussed in more detail in Chapter 9.
Develop a complaint system. Make sure employees know where to go, and make sure to
investigate, take action, and get back to the employee.
Consider incentive programs. Many employers have found that incentive programs help to
focus attention on safe behavior.
Next Steps
Now that you have a feel for your safety role, its time to become familiar with OSHA, the federal
agency that governs safety regulation and enforces safety rules.
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Set the Stage for Safety Success
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9
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Chapter 3
Get Familiar with OSHA
As the person responsible for safety in your organization, you must be familiar with the federal
agency for safety and health and what it requires of your organization.
What Is OSHA?
OSHA is the Occupational Safety and Health Administration, the federal agency charged with
improving and ensuring the safety and health of the nations workers. OSHA was established by the
1970 Occupational Safety and Health Act (OSH Act). OSHA has subsequently set forth regulations for
many types of workplaces and many types of work-related activities. Well cover the requirements of
these regulations in later chapters.
What About State Safety Regulations?
States have two choices when it comes to safety. They may adopt the OSHAs federal regulations, or
they may have a state plan; however, the state plan must have requirements as least as stringent as those
of the federal regulation.
As a result, many states that have chosen to be state plan states have regulations that mimic the
federal regulations in most particulars. Nevertheless, if you operate in a state plan state, you must
familiarize yourself with state requirements.
The following states and jurisdictions have approved state plans:
Alaska Minnesota U.S. Virgin Islands
Arizona Nevada Utah
California New Jersey Vermont
Connecticut New Mexico Virginia
Hawaii New York Washington
Indiana North Carolina Wyoming
Iowa Oregon
Kentucky Puerto Rico
Maryland South Carolina
Michigan Tennessee
Note: The Connecticut, New Jersey, New York, and U.S. Virgin Islands plans cover public sector
(state and local government) employment only.
For more information, See Appendix B.
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Rights and Responsibilities Under OSHA
You must be familiar with what OSHA requires of your organization. In addition to knowing safety
rules for their areas, your managers and supervisors should particularly be aware of employee rights
granted by OSHA.
What OSHA Requires of Employers
Theres a long list of employers OSHA responsibilities. Heres what employers are required to do:
Meet the general duty to provide a workplace free from recognized hazards.
Be familiar with and comply with OSHAs standards, rules, and regulations.
Keep workers informed about OSHA and safety and health matters, and make copies of OSHA
standards available to employees upon request.
Warn employees of potential hazards.
Provide employees with safe and properly maintained tools and equipment, including appro-
priate personal protective equipment, and ensure that they use the equipment.
Evaluate workplace conditions, and minimize or eliminate potential hazards.
Establish operating procedures and communicate them to employees.
Provide required training.
Provide medical exams when required.
Report certain accidents.
Maintain required records of work-related injuries and illnesses, and post a copy of OSHA
300A, Summary of Work-related Injuries and Illnesses, from February 1 to April 30.
Post prominently the OSHA Its the Law poster.
Post OSHA citations and abatement verification notices at or near the worksite involved.
Abate cited violations within the prescribed period.
Provide employees, former employees, and their representatives access to the Log of Work-
related Occupational Injuries and Illnesses (OSHA 300) at a reasonable time and in a
reasonable manner.
Provide access to employee medical records and exposure records to the employee and others.
Cooperate with OSHA compliance officers.
Not discriminate against employees exercising their rights under the OSH Act.
What OSHA Requires of Employees
While OSHA places most of its requirements on employers, it also places responsibilities on
employees. Although OSHA does not cite employees for violations, it does require safe behavior from
them. Specifically, employees should:
Comply with all applicable standards, rules, regulation, and orders issued under the OSH Act.
Follow all employer safety and health rules and regulations, and wear or use prescribed
protective equipment.
Report hazardous conditions and job-related injuries.
What Rights OSHA Gives Employees
OSHA also provides employees with certain rights. Among those are the right to:
A workplace free from recognized hazards.
Review copies of OSHA standards, rules, regulations, and requirements.
Request information from the employer on safety and health hazards, precautions, and emer-
gency procedures.
Receive adequate training and information.
Request an OSHA investigation if they believe hazardous conditions exist.
Have their name withheld from the employer if they file a complaint.
Have an employee representative accompany an OSHA inspector.
Respond to questions from the inspector.
Observe monitoring of hazardous materials and see related records.
Review the OSHA Log and Summary forms.
Submit a written request to the National Institute for Occupational Safety and Health for
information on whether any substance in the workplace has potentially toxic effects in the
concentrations being used.
Report unsafe conditions.
Refuse to work in unsafe conditions if the employee has a good faith belief that the conditions
constitute an imminent threat and where there is insufficient time to contact OSHA, and
where the employee has sought from the employer and been unable to obtain a correction of
the dangerous conditions.
All supervisors and managers must know and respect these rights.
OSHAs Guidelines for Safety Programs
To help employers structure their compliance with its requirements, OSHA has developed Safety and
Health Management Guidelines.
The guidelines are not mandatory (although OSHA would like them to be), but they are a good place
from which to start in designing or revamping your safety program. In fact, youll find that this books
suggestions follow the general outline recommended by the OSHA program.
Should You Follow OSHAs Guidelines?
Most experts recommend it.
First, the guidelines are sensible. You might as well at least start from the guidelines.
Second, when the OSHA compliance officer arrives, it just cant hurt to show that youve designed
your program in line with the OSHA guidelines.
Heres a brief summary of the OSHA program guidelines.
Get Familiar with OSHA
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1. Management Commitment and Employee Involvement
The elements of management commitment and employee involvement are complementary and form
the core of any occupational safety and health program. Managements commitment provides the moti-
vating force and the resources for organizing and controlling activities within an organization. In an
effective program, management regards worker safety and health as a fundamental value of the organiza-
tion and applies its commitment to safety and health protection with as much vigor as to other
organizational goals.
Employee involvement provides the means by which workers develop and/or express their own
commitment to safety and health protection for themselves and for their fellow workers.
2. Worksite Analysis
A practical analysis of the work environment involves a variety of worksite examinations to identify
existing hazards and conditions and operations in which changes might occur to create new hazards.
Ignorance of a hazard stemming from failure to examine the worksite is a sign that safety and health
policies and/or practices are ineffective. Effective management actively analyzes the work and worksite
to anticipate and prevent harmful occurrences.
3. Hazard Prevention and Control
Where feasible, workplace hazards are prevented by effective design of the job site or job. Where it is
not feasible to eliminate such hazards, they must be controlled to prevent unsafe and unhealthful expo-
sure. Elimination or control must be accomplished in a timely manner once a hazard or potential hazard
is recognized. Specifically, as part of the program, employers should establish procedures to correct or
control present or potential hazards in a timely manner.
4. Safety and Health Training
Training is an essential component of an effective safety and health program. Training helps identify
the safety and health responsibilities of both management and employees at the site. Training is often
most effective when incorporated into other education or performance requirements and job practices.
The complexity of training depends on the size and complexity of the worksite as well as the characteris-
tics of the hazards and potential hazards at the site.
Employee Training. Employee training programs should be designed to ensure that all
employees understand and are aware of the hazards to which they may be exposed and the
proper methods for avoiding such hazards.
Supervisory Training. Supervisors should be trained to understand the key role they play in job
site safety and to enable them to carry out their safety and health responsibilities effectively.
See Chapter 8 for details on planning and providing safety training.
OSHAs Posting, Recordkeeping, and Notification Requirements
OSHA mandates certain recordkeeping and posting.
OSHA Recordkeeping Requirements
OSHAs primary recordkeeping requirement concerns the maintenance of the OSHA 300 log in
which you record certain illnesses and injuries. Most employers are required to post an annual summary
of the log, the OSHA 300-A form.
In addition, specific subparts may require special recordkeeping (such as lead exposure and hearing
tests), and youll also want to maintain other records, such as training logs, audits and inspections, and
so on.
Recordkeeping is discussed in detail in Chapter 10.
OSHA Posting Requirements
All employers must post the OSHA poster, Its the Law.
The poster may be downloaded from OSHA at www.osha.gov.
Notification Requirements
When a death or incident that hospitalizes three or more workers occurs, you must notify OSHA
within 8 hours.
OSHA Inspections, Citations, Penalties
While OSHA does devote substantial resources to training and helping employers to comply with
its regulations, it also maintains a large force of compliance officers. Some inspections are randomly
done, some come as a result of employee complaints, and some are the result of an OSHA focus on a
specific industry or on workplaces with a history of safety violations.
When OSHA inspectors arrive, generally unannounced, they will ask for entry and for an initial
conference.
Technically, you dont have to let them in without a warrant, but most employers do, because they
can easily get a warrant, and after they do, theyll probably be a little more sharp-eyed, and less
inclined to accept explanations than they would have been had you let them in first time around.
Inspectors will often want to see your safety program materials, and generally want to talk to
employees. They may quiz employees to see if they understand the hazards with which they work,
where the Material Safety Data Sheets (MSDSs) related to hazards are located, and so on. At the end
of the inspection, there is a closing conference. If OSHA finds violations, they issue citations and
levy fines.
See Chapter 10 for specific information on how to handle an OSHA inspection.
Assistance from OSHA
OSHA doesnt just inspect and issue citations. They provide assistance to employers. In addition to
a number of materials (see www.osha.gov), OSHA offers consultation services.
Consultation Services for the Employer
Employers who want help in recognizing and correcting safety and health hazards and in improving
their safety and health programs can get it from a free consultation service largely funded by OSHA.
The service is delivered by state governments using well-trained, professional staff.
The consultation program not only addresses immediate problems but also offers advice and help in
maintaining continued effective protection.
Get Familiar with OSHA
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Primarily targeted for smaller businesses in higher hazard industries or with especially hazardous oper-
ations, the safety and health consultation program is completely separate from the inspection effort.
The service is also confidential. Your name and firm and any information about your workplace, plus
any unsafe or unhealthful working conditions that the consultant uncovers, will not be reported to the
OSHA inspection staff unless a serious problem is identified and you fail to correct it in the specified
amount of time. In addition, no citations are issued or penalties proposed as a result of a consultation.
Your only obligations are to allow the consultant to confer with employees in the course of the hazard
survey and to correct any imminent dangers and other serious job safety and health hazards in
a timely manner. You make these commitments before the consultants visit.
Comprehensive consultation services include the following:
(1) An appraisal of all mechanical and environmental hazards and physical work practices;
(2) An appraisal of the present job safety and health program or the establishment of one;
(3) A conference with management on findings;
(4) A written report of recommendations and agreements;
(5) Training and assistance with implementing recommendations; and
(6) A follow-up to assure that any required corrections are made.
In rare instances, the consultant may find an imminent danger situation during the walk-through. In
such situations, an employer must take immediate action to protect all affected workers. If the consultant
finds a hazard that is considered to be a serious violation under OSHA criteria, he or she will work with
you to develop a mutually acceptable plan and schedule to eliminate or control that hazard.
Inspection Exemption
Employers who receive a comprehensive consultation visit, correct all identified hazards, and institute
the core elements of an effective safety and health program may be awarded a certificate of recognition
from OSHA, signifying a 1-year exemption from general schedule enforcement inspections. Inspections
prompted by an employee complaint or by a fatality or catastrophe would not be exempted under this
program.
State Consultation Project Directory
You can find addresses, phone numbers, and e-mail addresses for OSHA Consultation Project Offices
for your state at www.osha.gov. Click on OSHA Offices, then follow the links to Consultation Program
Offices.
OSHA Partnership Programs
OSHA has established an interesting set of partnership programs for organizations that demonstrate
the effectiveness of their safety programs.
Voluntary Protection Programs (VPP)
In the VPP, management, labor, and OSHA establish cooperative relationships at workplaces that
have implemented a comprehensive safety and health management system. Approval into VPP is
OSHAs official recognition of the outstanding efforts of employers and employees who have achieved
exemplary occupational safety and health.
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Get Familiar with OSHA
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How Does VPP Work?
VPP sets performance-based criteria for a managed safety and health system, invites sites to apply,
and then assesses applicants against these criteria. OSHAs verification includes a rigorous onsite evalua-
tion by a team of OSHA safety and health experts.
OSHA approves qualified sites to one of three programs:
Star. The Star program recognizes worksites that have outstanding safety programs that have
met all of OSHAs requirements.
Merit. The Merit program is for worksites that are close to achieving Star status but need more
time to fully qualify.
Star Demonstration. This program provides recognition for worksites that address unique
safety and health issues.
OSHA sponsors a VPP mentoring program that matches a potential VPP site with a current
VPP site.
In addition, OSHA has developed a 4-day training course that emphasizes the VPP culture, philos-
ophy, and criteria.
See the OSHA website (www.osha.gov) for information on VPP programs, a current list of VPP
sites, VPP publications, and the VPP Participants Association.
For more information on becoming a VPP member, contact OSHAs Office of Partnerships and
Recognition at 202-693-2213 or the VPP manager at your OSHA regional office.
OSHAs Safety and Health Achievement Recognition Program (SHARP)
OSHA also has a special program for small employers called SHARP (Safety and Health
Achievement Recognition Program). The program recognizes small employers who operate an exem-
plary safety and health management system. Upon receiving SHARP recognition, worksites are exempt
from programmed inspections during the period that the SHARP certification is valid.
To participate in SHARP, you must:
Request a consultation visit that involves a complete hazard identification survey;
Involve employees in the consultation process;
Correct all hazards identified by the consultant;
Implement and maintain a safety and health management system that, at a minimum,
addresses OSHAs Safety and Health Program Management Guidelines
Lower your companys Days Away, Restricted, or Transferred (DART) rate and Total
Recordable Case (TRC) rate below the national average; and
Agree to notify your state Consultation Project Office prior to making any changes in the
working conditions or introducing new hazards into the workplace.
For more information, visit the OSHA website at www.osha.gov or call your regional OSHA office.
OSHA Offices
OSHA maintains area offices and regional offices throughout the country to help employers comply
with all the OSHA regulations. (A listing of all OSHA offices may be found at www.osha.gov.)
Next Steps
Now that you are familiar with OSHA, its time to look more specifically at the agencys regulations
and at other legal obligations for safety management.
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Chapter 4
Meet Your Legal Obligations
As safety manager, you must know the laws and regulations that impact safety management.
Foremost among legal requirements for safety is the set of safety regulations promulgated by OSHA
under the OSH Act. In addition there are other guidelines and regulations that you should know. Heres
a briefing.
Safety Law
Many safety standards are quite specific. Thats very helpful but, of course, it also makes it very hard
for an organization to claim that it didnt understand what was required. However, many standards are
performance-oriented, which gives employers the flexibility to tailor their programs to the characteris-
tics of their workplaces. So as the safety manager, you need to spend some time with the OSHA
regulation and learn which requirements apply to your workplace.
In addition, youll find that some of your safety obligations come from other sources, such as state
laws, and industry association and manufacturer recommendations. Heres what you need to know.
OSH Act and Regulations
OSHAs regulations are a monster in their entiretyover 1,000 pages in printbut depending on
the nature of your business, its likely that only a few of its many subparts apply to your organization.
For example, you probably wont have to spend too much time with Subpart T, which covers commer-
cial diving, unless you happen to be a commercial diver.
General Duty Clause
Where there isnt a specific regulation, OSHA has a catch-all rulethe General Duty Clause
that requires employers to furnish to each of its employees employment and a place of employment
free from recognized hazards that are causing or are likely to cause death or serious physical harm to
its employees.
Some safety managers call the General Duty Clause the right arm of safety enforcementif the
left dont get you then the right one will.
The important message is this: Just because a hazardous substance or a hazardous situation isnt
covered by one of the OSHA regulations specific subparts, that doesnt mean you dont have an OSHA
obligation to protect employees. Because of the general duty clause, you always have the broad respon-
sibility of providing a safe workplace for your workers.
OSHA can and will cite under the General Duty Clause.
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Specific Hazard Subparts
Beyond the General Duty Clause, the OSHA regulations are divided into many specific subparts,
only a few of which usually apply to any particular site.
The subparts deal with
Situations (for example, emergencies and fires);
Procedures (for example, lockout/tagout, confined space entry); and
Substances (for example, lead, 4-Dimethylaminoazobenzene).
For a detailed list of the contents of the subparts see Appendix E.
For detailed guidance on how to comply with the requirements and what training they require, see
Appendix E and Appendix F. For more details on common workplace hazards, see Chapter 6.
Requesting Variances from OSHA Regulations
If an OSHA standard is going to cause you significant problems, dont overlook the possibility of
obtaining a variance. Employers may ask the agency for a variance from a standard or regulation if they
cannot fully comply by its effective date. Among the frequent reasons for a variance is a shortage of
materials, equipment, or professional/technical personnel. Another justification that has been success-
fully employed is that facilities or methods of operation provide employee protection at least as
effective as that required by OSHA.
Other Guidelines, Rules, and Laws
Although the OSHA regulations are the most prominent among your compliance requirements, there
are other laws and guidelines that may impact your safety obligations. Some of these are the following:
Professional and Industrial Association Guidelines
Many professional and industrial associations have developed guidelines for safety issues common in
their industries. Manufacturers and suppliers may also provide guidelines for safe use of their products.
Its generally a good idea to follow these guidelines, even if OSHA doesnt mandate it. If you dont
follow these recommendations and something goes wrong, youll look negligent.
Union Agreements and Rules
Naturally, if you have contracts with your unions, you need to follow any contractual requirements.
Other Laws
Some other laws are part of the safety compliance arena.
ADA
The Americans with Disabilities Act (ADA) contains provisions that bump against safety, often in
difficult ways.
When you have disabled employees, you have an obligation to make reasonable accommodations, but
not when disabled employees may be a danger to themselves or others. Tricky situations such as these
are possible:
Meet Your Legal Obligations
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Operate a vehicle or machinery. You have a difficult situation when you question whether a
disabled employee can, for example, operate a vehicle or piece of machinery without harm to
himself or herself, and without harm to others.
This is most commonly a question when the employee is subject to passing out, for example, if the
person is diabetic or suffers from epilepsy.
Reaction to a substance. Another situation is when the person may be likely to react to a
hazardous substance with an asthma attack, for example, or with a dermatitis problem.
Pregnancy. Another variation involves pregnant employees, when exposure may cause damage
to the fetus.
These cases are all difficult, because typically the employee insists on working the job, either
contending that there is no danger to others or that the job poses no threat to them.
Often these situations may be resolved with a job transfer, but when the employee refuses, or when
there is no other job, and its not abundantly clear that the employee or co-workers are in danger, its
probably best to confer with an attorney.
Workers Compensation
Workers compensation is generally a matter of state law.
Workers compensation can be referred to as the great compromise. For the employee, it provides
immediate paid treatment for job-related illnesses and injuries, as well as payments when the worker is
unable to continue working. In return for this benefit, workers give something up: the right to sue their
employers. Workers compensation is generally the exclusive remedy for workers injured on the job.
Note: In a few states, employers are not required to participate in the workers compensation
program.
For more details on workers compensation, see Chapter 10.
DOT
The U. S. Department of Transportation has many safety roles, including:
Safety for transportation on land, air, and sea
Reporting of oil and chemical spills
Regulations and testing regarding use of drugs and alcohol
Hazardous materials transportation
Whistleblower
In addition to OSHAs protections, many jurisdictions have whistleblower laws, and many federal
laws have whistleblower provisions in them. Managers and supervisors must be trained in how to react
to complaints.
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Other Legal Challenges Related to Safety
In addition to specific compliance issues, safety managers must be aware of other legal threats, in
particular, negligence, refusals, and retaliation.
Negligence Suits
In most workplace situations, when an accident occurs, workers compensation is the sole legal
remedy for employees, so employers dont have to worry about lawsuits.
However, if the employer is guilty of negligence, employees may have an avenue to bring charges in
court. You want to avoid having to face a jury on these issues, because invariably, youll look like the
uncaring company that didnt care about the poor worker and ignored pleas for basic safety protection.
Thats going to get expensive.
To override the presumption that workers compensation is the sole remedy, an employee must have a
strong case. But situations such as these are ripe for negligence suits:
You told an employee that an operation was safe when you knew it wasnt.
You are on notice of a hazard and you did not take action to deal with the problem.
An employee turned violent and you knew of his or her past violent behavior.
The common element is prior knowledge of a risk or hazard.
Refusals: Its Not Safe and I Wont Do It
Managers and supervisors must remember that employees have a right to refuse to work in an unsafe
environment.
What if the employees concerns are just wrong and its safe as can be? This is often the case, espe-
cially since employees often get information from the grapevine and other unofficial sources.
To deal with these situations:
Take the complaints seriously.
Determine exactly what the employee is concerned about.
Explain the companys procedures for evaluating hazards.
Explain why the specific situation does not pose a hazard.
If you cant resolve the issue, you may want to seek another opinion.
Refrain from Retaliation
Every manager and supervisor must be trained to respond properly to safety complaints, and not to
retaliate or appear to retaliate.
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Next Steps
By now, youve got the lay of the land. You know about your OSHA obligations and about other
requirements related to safety. Its time to start working on developing or improving the hazard control
portion of your safety and health program. To do so, youll follow a series of very logical steps:
Identify the hazards.
Take steps to eliminate or minimize the hazards, or to protect employees from them.
Train employees in how to work safely.
Motivate employees to work safely.
Now, you know the rules. The next chapters of this book will help you identify and deal with the
hazards found in your facilities.
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Chapter 5
Identify Your
Workplaces Hazards
Identifying hazards is, of course, the first step in keeping the workplace safe. All employers need to do
this in a regular and systematic way. Some refer to this as a safety scan, while others call it a safety and
health audit. Whatever you name it, this chapter and the next will help you to accomplish this critical task.
This chapter covers general guidance for identifying hazards; the next chapter covers the most
common a specific hazards youll need to look for.
If you are a manager with little experience in safety and health, we suggest that you spend some time
skimming over Chapter 6 and the checklists in the Appendices. That will give you a good idea of the
kinds of hazards for which you will be looking. Remember, although there are a great many potential
hazards, your facility probably only has to worry about a few of them.
Quick Tips on Hazard Identification:
See it in action. If its a process, you want to see it in action. Many activities sound easy and
safe on paper, but when you see employees do them, you see safety problems galore.
Check more than once. Most hazards only present themselves once in a while, so its a good
idea to visit your sites more than once. Also, remember that employees are apt to be on their
best behavior when they know their performance is being observed. If you are frequently in
the work area, employees may forget your presence and go back to business as usual. Then
you may see any unsafe actions or shortcuts they may be taking as they go about their jobs.
Check every shift. Some hazards tend to be present only on one shift, because of staffing, or
lack of supervision on a late night shift, or on the particular manager on duty. Be sure to check
out all shifts.
Beware of undetectables. Some hazards, such as toxic fumes, may not be visible or detectable
without specialized equipment.
Youre going to get dirty. Even in areas with good housekeeping, youre going to get a little
dirty if you crawl around machinery and do what you need to do to get a good look at whats
involved in maintaining safety. Dont do your inspections in a three-piece suit.
Dont forget near misses. Near missessituations in which an accident almost occurredare
important indicators of hazard potential. Always consider near misses along with actual acci-
dents as you evaluate hazards.
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Use a Variety of Hazard Indicators
Dont trust any one source of information about hazards: Try to use as many as you can. Heres
what to do.
Evaluate Written Evidence
Before you start physical inspections, its helpful to evaluate your written records concerning safety.
They will give you some direction to follow. Take a look at the following:
OSHA inspection reports, records of fines or sanctions, etc. These documents help you to
see what safety violations or problems your organization has had in the past.
Workers compensation records. These will help you to pinpoint which departments or areas
have the greatest number of safety problems, and what type of problems they typically have.
Accident and near-miss reports. Similarly, these records should help show safety problem areas.
Safety committee meeting minutes. If you have a safety committee, the minutes will give
you more background on safety concerns and activities at your workplace.
Raw materials. Check other organizations and groups that use the same materials you use
what hazards do they report?
Others using process and equipment. Similarly, look to others who use the same or similar
equipment and manufacturing processes.
Industry groups. Most industrial groups have organizations that serve and represent them.
Find out what materials they have available on hazards and hazard control.
Industry and government safety statistics. OSHA publishes lists of most-commonly cited
violations, and your industry group may be able to provide similar information.
MSDS for hazardous chemicals.
Interview EmployeesNo Reprisal
As you tour your workplace, speak with employees.
Ensure a no-reprisal culturethat is, one where employees are encouraged to raise safety questions
and issues without fear of reprisal.
Perform a Physical Worksite Analysis
Once you have reviewed the safety records, its time to make a physical evaluation of your hazards.
(Appendix F contains many checklists for common workplace situations.) In general, you will check
each area and each workstation for the following:
General Cleanliness of the Worksite
All aisles and exits free of any debris or obstructions.
No wet spots.
No dangerous elements such as potholes or trip hazards.
Actions Governed by Specific Rules
Lockout/tagout.
Bloodborne pathogens.
Confined spaces.
Proper Operation of Equipment
Sometimes operators create problems by how he they perform the job. For example, they might run a
machine beyond its rated capacity, or they might use more raw material than is recommended. Make
sure employees operate equipment within standards. Otherwise, overheating, breakage, and accidents
will result.
Environmental Hazards
Be on the alert for environmental hazards in the workplace. These could be, for instance, air quality
problems, dust or other airborne contaminants, excess heat, or noise, etc.
Behavioral Hazards
Some hazards are of the employees own making. For example, fork truck drivers may try to set a
plant record for how fast they can load a pallet into a railcar, or to set a world record for how many
pounds over rated capacity they can lift.
Perform Job-by-Job Analysis
Some hazards are obviousany observer can tell that workers must exercise care and develop safety
procedures. And, as described above, many hazards will be uncovered as a result of a self-audit. Other
hazards, however, are less obvious, and are uncovered only by conducting a systematic analysis of the
jobs in your worksite, one by one.
Job hazard analysis can be a very important part of your safety and health program. In some organiza-
tions the process is called Job Safety Analysis (JSA) or Job Safety Practices (JSPs).
Because of its importance, OSHA has developed a system to help you.
If hazard analyses have been done before, read them. If not, follow the OSHA system outlined below.
How to Perform an OSHA Job Hazard Analysis
The material that follows was adapted from OSHA publications. It explains what Job Hazard
Analysis is and contains guidelines for conducting your own analysis on a step-by-step basis.
What Is Job Hazard Analysis?
OSHA says that Job Hazard Analysis means carefully studying and recording each step of a job,
identifying existing or potential job hazards (both safety and health) and determining the best way to
perform the job to reduce or eliminate these hazards. Improved job methods can reduce costs resulting
from employee absenteeism and workers compensation, and can often lead to increased productivity.
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Selecting Jobs for Analysis
OSHA suggests that you follow this priority when determining which jobs to analyze first:
1. Jobs with the highest rates of accidents or lost-workday injuries
2. Jobs where close calls have occurred
3. New jobs
4. Jobs where changes have been made in processes and procedures
5. All other jobs. Eventually, a Job Hazard Analysis should be conducted and made available
to employees for all jobs in the workplace.
Using Internal and External Sources
As mentioned above, look to your internal records for indications of hazards and unsafe situations.
Also use external sources for guidance in identifying hazards. In many cases, youll find that someone
has already done the work of analyzing the job for you.
Tips for Gathering Information
Point out that you are studying the job itself, not checking up on the employees job performance.
Involve the employee in all phases of the analysisfrom reviewing the job steps to
discussing potential hazards and recommended solutions.
Talk to other workers who have performed the job.
Use common sense.
Finally, keep your eyes opendont wait for accidents to happen.
General Conditions
OSHA suggests several sample questions you might ask about the general conditions under which
the job is performed. Note that these are just suggestionsyou should add more questions of your own
having to do with your particular environment.
Are there materials on the floor that could trip a worker?
Is lighting adequate?
Are there any electrical hazards that could be accidentally activated at the job site?
Are there any explosive hazards associated with the job, or likely to develop?
Are there tools, including hand tools, machines, and equipment in need of repair?
Is there excessive noise in the work area, hindering worker communication? If so, audiometric
testing may be required.
Is fire protection equipment readily accessible and have employees been trained to use it?
Are emergency exits clearly marked?
Have fire extinguishers been inspected?
Are motorized vehicles properly equipped with working brakes, overhead guards, backup
signals, horns, steering gear, seat belts, and identification, as necessary?
Are all employees who operate vehicles and equipment properly trained and authorized?
Are employees wearing proper personal protective equipment for the jobs they are performing?
Have any employees complained of headaches, breathing problems, dizziness or strong odors?
Is ventilation adequate, especially in confined spaces?
Have tests been made for oxygen deficiency and toxic fumes?
Are there any ergonomic risk factors (lifting, bending, repetitive motions)?
OSHA also mentions the possibility of taking pictures of a worksite for use in making a more
detailed analysis. The OSHA suggestions continue with breaking down the job.
Breaking Down the Job
Nearly every job can be broken down into steps. In the first part of the Job Hazard Analysis, list each
step of the job in order of occurrence as you watch the employee performing the job. Be sure to record
enough information to describe each job action, but do not make the breakdown too detailed. Later, go
over the job steps with the employee.
Identifying Hazards
After you have recorded the job steps, examine each step to determine the hazards that exist or that
might occur. Ask yourself these kinds of questions:
Is the worker wearing protective apparel and equipment, including safety belts or harnesses
that are appropriate for the job?
Are work positions, machinery, pits or holes, and hazardous operations adequately guarded?
Are lockout procedures used for machinery deactivation during maintenance procedures?
Is the worker wearing clothing or jewelry that could get caught in the machinery?
Are there fixed objects that may cause injury, such as sharp machine edges?
Is the flow of work improperly organized (e.g., is the worker required to make movements that
are too rapid)?
Can the worker get caught in or between machine parts?
Can the worker be injured by reaching over moving machinery parts or materials?
Is the worker at any time in an off-balance position?
Is the worker positioned to the machine in a way that is potentially dangerous?
Is the worker required to make movements that could cause hand or foot injuries, or strain
from lifting?
Can the worker be struck by an object or lean against or strike a machine part or object?
Can the worker fall from one level to another?
Can the worker be injured from lifting or pulling objects, or from carrying heavy objects?
Do environmental hazardsdust, chemicals, radiation, welding rays, heat or excessive noise
result from the performance of the job?
Repeat the job observation as often as necessary until all hazards have been identified.
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Recommending Safe Procedures and Protection
After you have listed each hazard or potential hazard and have reviewed them with the employee
performing the job, determine whether the job could be performed in another way to eliminate the
hazards, such as combining steps or changing the sequence, or whether safety equipment and precau-
tions are needed to reduce the hazards.
If safer and better job steps can be used. List each new step, such as describing a new method
for disposing of material. List exactly what the worker needs to know in order to perform the
job using a new method. Do not make general statements about the procedure, such as Be
careful. Be as specific as you can in your recommendations.
If no new procedure can be developed. Determine whether any physical changes, such as
redesigning equipment, changing tools, adding machine guards, personal protective equip-
ment or ventilation, will eliminate or reduce the danger.
If hazards are still present. Try to reduce the necessity for performing the job or the frequency
of performing it.
Go over the recommendations with all employees performing the job. Their ideas about the hazards
and proposed recommendations may be valuable. Be sure that they understand what they are required
to do and the reasons for the changes in the job procedure.
Revising the Job Hazard Analysis
OSHA recommends that the Job Hazard Analysis be reviewed and updated on a regular basis in three
situations:
When an accident or injury occurs
When the job changes
Periodically
Dont Forget These Employment Issues
Some employment matters that influence the safety of your workplace should be considered as you
evaluate hazards. They include:
Drug and alcohol use. Clearly, being under the influence is very dangerous, especially when
working on or with machinery, dangerous substances, or performing other dangerous activities.
Employing minors. The federal government and many states have laws governing the employment
of minors. These regulations often limit the number of hours that may be worked, what time of day,
and the types of jobs that minors may perform. A word to the wise: No judge or magistrate is going to
look favorably on an employer who allowed a minor to get injured.
Employing temporary workers. When temporary workers arrive on your site, remember that all the
rules apply to them. They must be trained before operating equipment, and they must be warned
about hazards.
Hosting third-party workers on your site. Similarly, third-party workers must be briefed on safety
issues before they begin work.
Working in shifts. Shiftwork has its own set of problems, not the least of which is fatiguean
enemy of safety. Make sure all shifts have proper supervision.
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In addition, its often difficult to schedule shift workers for training, safety meetings, and so on. But
dont neglect them just because they are on a midnight shift. They need training, briefings on new
procedures, safety announcements, and their own complaint system.
Another safety issue for shift workers is the pass-off between shifts. For example, briefing arriving
workers about hazards, or about a lockout /tagout or a confined space entry in progress.
Multiple worksites. This is another challengeyou cant be everywhere at once. But its no excuse.
Lean on your supervisors, and get around as often as you can.
Next Steps
This chapter presented an overview of typical hazards and other factors that can lead to unsafe situa-
tions. The next chapter discusses the most common specific hazards found in the workplace.
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Chapter 6
Look for These
Specific Hazards
The last chapter covered general approaches for identifying hazards. This chapter is about specific
hazards that you may face. The chapter presents summary information about the most common hazards
found in workplaces, along with brief information about OSHAs requirements, if any, concerning them.
Some of this material will apply to all employersfor example, fire prevention. Substantial parts of
this section wont apply to you at all.
Use this chapter as a checklist to be sure that you recognize all the hazards your workplace presents.
Suggestion: Skim through the entire chapter.
That should alert you to what you need to check in your facilities. Then go back for some more detail
and delve into the Appendices for practical assistance in the form of checklists and training outlines.
Weve grouped the hazards according to the following scheme:
Emergencies
Fire prevention and control
Emergencies and evacuations
First aid
Violence
Physical plant
Walking and working surfaces
Fall protection
Housekeeping
Aisles and passageways
Stairs and ladders
Scaffolding
Sanitation
Water supply
Toilet facilities
Security
Environmental issues: ventilation, noise, radiation
Electrical
Machinery and machine guarding
Temporary labor camps
Hazardous materials
13 carcinogens
Air contaminants
Asbestos
Compressed gases
Dipping and coating operations
Explosives and blasting agents
Flammable and combustible liquids
Spray finishing using flammable and combustible materials
Storage and handling of liquefied petroleum gases
Storage and handling of anhydrous ammonia
Process safety management of highly hazardous chemicals
Hazardous waste operations and emergency response
Occupational exposure to hazardous chemicals in laboratories
Personal protective equipment (PPE)
General protection
Written PPE program
Respiratory protection
Dress and grooming
Hazardous processes/activities
Control of hazardous energy (lockout/tagout)
Permit-required confined spaces
Ergonomicshow people interact with environment
Hand and portable powered tools and other hand-held equipment
Materials handling and storage
Powered platforms, manlifts, and vehicle-mounted work platforms
Hot workwelding, cutting, and brazing
Driving
Commercial diving operations
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Health issues
Heat and cold
Dermatitis and other skin problems
Stress management
Safety issues for specific types of workplaces
Office
Manufacturing
Maintenance
Retail
Medical facilities
Food service
Transportation
Schools, colleges
OSHAs special industries rules
Pulp, paper, and paperboard mills
Textiles
Bakery equipment
Laundry machinery and operations
Sawmills
Pulpwood logging
Telecommunications
Grain handling facilities
Here are details on the most common hazards found in the workplace.
Emergencies
Preventing fires and dealing with other types of emergencies is the top safety priority for most organ-
izations. All employers need to train employees on their roles in preventing emergencies, and on the
actions to take in the event of an emergency.
Fire Prevention and Control
Not surprisingly, OSHA has very specific requirements in this area.
OSHAs rules for fire protection provide detailed requirements for physical layouts, alarms, evacua-
tion plans, fire prevention, fire brigades, and so on. These sections must be studied in detail and careful
emergency plans and fire prevention plans made, communicated, and practiced.
OSHA regulations require that all employers provide some sort of fire safety device for their facilities.
The size and sophistication of the fire control equipment depends on the size of the facility and the
materials that may be in use there. Furthermore, since no fire detection or firefighting equipment is of
any use if it does not operate properly, the regulation provides for regular testing and maintenance of
smoke detectors, alarms, sprinklers, hoses, portable extinguishers, and fixed extinguishers. OSHA
requires that personnel responsible for maintaining most of this equipment be trained to provide such
servicing.
Fire Brigades
Employers may train and equip some employees to function as a fire brigade for control of small fires.
If an employer chooses to assemble a special team of employees to handle fires, the employer must
comply with the regulations for fire brigades.
These regulations are very specific. There are specifications for personal protective equipment; annual
training; and equipment maintenance requirements. The employer must also write a policy statement
regarding the implementation of the fire brigade.
Emergencies and Evacuations
Employers are responsible for ensuring that employees know what to do in an emergency and know
how to evacuate the workplace if disaster strikes. OSHAs emergency preparedness and response rules are
among the most helpful and practical standards because they provide clear and concise guidance for
preparing for emergency events.
All employers in general industry must comply with OSHAs emergency preparedness and response
rules concerning exit routes, except mobile workplaces, such as vehicles or vessels.
In addition, employers must comply with the requirements for employee emergency and fire prevention
plans whenever a workplace activity or process covered by a specific OSHA standard requires such plans.
Employers must also comply with OSHA rules that support and enhance emergency response efforts
(e.g., medical services and first aid, personal protective equipment, and employee alarm systems).
An Emergency Plan
Your first level of defense is to take measures to try to prevent disasters. Failing that, employers can
take steps to minimize damage and injury or loss of life when a disaster occurs.
A workplace emergency plan may cover natural disasters, fire, violent incidents, terrorist threats,
robberies, bomb threats, and more. The plan should address:
Procedures for calling for outside help and who should do it
Procedures for getting medical assistance and who should do it
Escape procedures and routes
Safe places inside and outside for employees
Identification of personnel who will be called upon for communication, medical, rescue,
escape, other duties
Identification of personnel who will stay in the facility to ensure an orderly shutdown, and
their training
Training programs established for special personnel and training for all workers; emergency drills
Regular evaluation and updating actions
Assessment of procedure each time used (i.e., what went wrong, what went right)
Importance of not locking any exits from the inside
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Bomb Threats
Unfortunately, bomb threats are not uncommon these daysand while they are usually nothing more
than talk, never ignore a bomb threat. Assume it is legitimate. If your workplace gets a bomb threat:
Evacuate. Evacuate the building just the way you would in case of a fire (evacuation should be
well practiced). Executives should evacuate also. Get everybody far away from the threatened area.
Call the police. Give officials as much information as you can about the possible bomb or
bombs and caller.
Note on Liability in the Event of a Disaster
Sooner or later every employer is likely to face a work emergency caused by power outage, hurricane,
earthquake, tornado, flood, fire, riot, robbery, employee violence, explosion, toxic leak, bombing or other
terrorist act.
Of course, all employers want to protect their employees and their businesses. In addition, however,
organizations and individual managers may face liability if they have not taken prudent steps to prepare
for disasters.
In general, liability depends on two issues: foreseeability and negligence. Was the disaster
reasonably predictable? And did the employer take precautions to protect employees, customers, and
the surrounding community? If there was foreseeability and precautions were not adequate, liability
may be found.
What Should you do About Disaster Planning?
How should you go about disaster planning? If you dont have a plan at all, follow the steps outlined
in Appendix G to develop one. If you do have one, use the materials in the appendix as a guideline for
evaluating and improving your plan.
First Aid
Every organization needs some first aid capability. Depending upon the hazards in your workplace,
and the distance from emergency help, you may need a substantial first aid program.
OSHA has several requirements for first aid, including:
Ready availability. Employers must ensure the ready availability of medical personnel for
advice on matters of health in the workplace.
Trained personnel. Unless there is a hospital, clinic, or infirmary for treating injured
employees in close proximity (within 3 to 4 minutes for life-threatening emergencies and
within 15 minutes for injuries that are other than life-threatening), the employer must ensure
that one or more people in the workplace are adequately trained to provide first aid and that
first-aid supplies are available.
Flushing facilities. Employers must make suitable facilities available for immediate quick-
drenching or flushing of the body and eyes where employees may be exposed to corrosive
material. Note: Failure to comply with this requirement is an often-cited violation by OSHA.
Bloodborne pathogens. In addition to standards that govern standard first-aid procedures in
the workplace, OSHA has set strict guidelines for the handling of human blood (to prevent the
spread of disease via bloodborne pathogens). In general, employers would be wise to treat all
human blood as contagious. Any employee designated as a first-aid provider is also covered by
the requirements of the OSHAs bloodborne pathogens standard (29 CFR 1910.1030).
(See the checklist and training guidelines for bloodborne pathogens under Subpart Z in Appendix F.)
First-Aid Kits
Contents. The contents of a first-aid kit will depend on the type of business and the kinds of
injuries commonly experienced. OSHA recommends that generic first-aid kits described in
the American National Standard Z308.1, Minimum Requirements for Industrial Unit-Type
First-aid Kits, are suitable for most small, general industry worksites and offices. For larger
or multi-operation worksites, employers should consult with a medical professional, the local
fire/rescue department, or a local emergency room for advice on stocking first-aid kits appro-
priately.
Responsibility. Give one person responsibility for seeing that the necessary components are
always in the first-aid kit, that what is used is immediately replaced, that the kit is organized
and clean, and that it is always in the proper location.
Location. Inform employees about the location of the first-aid kit. It should be easily accessible.
Additional First Aid Recommendations
Allergies. Maintain a list of employees allergies to specific medications.
Training. The American Red Cross and many municipal fire, ambulance, or police depart-
ments provide first-aid training to employers and employees. Let everyone in the organization
know who the trained first-aid personnel are and make it clear that except in a dire emergency,
these are the only people who should render first-aid assistance. Keep the list and the training
up-to-date.
First-aid log. An employer should maintain a medical or first-aid log to ensure that every use
of the first-aid kit is noted, including date, time, person receiving treatment, person giving
treatment, what injury or symptom was treated, what treatment was given, and first-aid mate-
rials used. Forms for this purpose may be obtained from an insurance carrier, but any simple
record is satisfactory. This record is in addition to the required OSHA log.
Outside contacts. Post the names and telephone numbers of off-site first aid contacts, both
individuals and organizations such as fire departments and poison control centers.
Recordkeeping for First Aid
OSHA does not require employers to record injuries that only require first aid on OSHA injury and
illness forms (OSHA Form 300 and 301 Incident Reports). First-aid treatments that are not considered
medical treatment for OSHA injury reporting purposes include:
Ointments
Salves
Bandages (including elastic and butterfly)
Finger guards
Hot and cold therapies
Eye patches
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Antiseptics
Wraps
Dressings
Temporary immobilization devices (e.g., splints, slings, neck collars, back boards) for trans-
porting accident victims
Removing foreign bodies from the eye using only irrigation or a cotton swab
Cleaning, flushing, or soaking skin surface wounds
Drilling a fingernail or toenail to relieve pressure
Nonprescription medications applied to minor injury
Consider the following in preparing your first aid program:
Good Samaritan Protection
Many state laws state that any person, including licensed physicians and surgeons, who in good faith
provides emergency care or assistance without compensation at the place of an emergency or accident, is
protected from liability for any civil damages for acts they may have performed (or omitted) in
providing emergency care. You may want to check whether your state has such a law.
Violence
Workplace violence is a hazard that is becoming an issue at more and more workplaces. Every organi-
zation should be thinking about its role in preventing violence.
Many people believe violent incidents are random and that there is little to be done to prevent
them. However, this is not true. Although nothing will stop all violence, there are steps that will
prevent much of it, cut down on the number and severity of the incidents, and reduce the associated
lawsuits, and psychologically diminish the impact of a tragedy on survivors of such an attack.
OSHA doesnt have a specific standard covering workplace violence. However, employers need to be
aware that they are liable under the General Duty Clause of the OSH Act. This section of the OSH Act
says: Each employer shall furnish to each of his 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 employees.
Reducing Risk
Consider these steps to prevent violence:
Make violence prevention a priority. Treat the violence issue at the same level you would use
for sexual harassment, discrimination, or for employee theft and sabotage. Develop similar
policies, practices, and training programs.
Start with hiring. Start preventing violence by keeping violent people off your employee rolls.
It is not that hard or that expensive to do an extensive background and criminal records check,
and there are many companies and many Internet sites that will help employers perform an
employee check for earlier incidents of violence perhaps, or some other possible tell-tale signs.
In most cases, it is OK not to hire an applicant with a history of violence or with violent tendencies.
Furthermore, it is less risky from a legal standpoint to refuse to hire than to terminate at some point
after hire.
Zero tolerance. Every workplace, no matter how small, should have a policy outlawing violent
behavior. Employers should not allow bullying, serious aggression (whether verbal or physical),
threats, or serious horseplay. The policy statement should put employees on notice that they
are subject to termination if they violate the policy. Many policies put employees on notice
that all threats are taken as serious. The rules against such behavior must be enforced immedi-
ately, consistently, and seriously.
Are You in a Violence-Prone Business?
Research from federal OSHA and the National Institute for Occupational Safety and Health
(NIOSH) shows a number of factors that may increase a workers risk of being assaulted in the work-
place. These factors include:
Routine contact with the public
Working alone or in small numbers
Exchanging money
Having a mobile workplace such as a taxicab or police cruiser
Delivering passengers, goods, or services
Working late or very early hours
Working in high crime areas
Guarding valuable property or possessions.
Be Alert, but Not Too Alert
Encourage workers to notice and identify behavior that is strange and perhaps alarming. This is not
to say that employers should institute scapegoating, snooping, or profiling, but simply that employees
should be told that if their common sense raises concerns about a co-workers odd or frightening
behavior, they should tell their supervisor or the company doctor.
Train supervisors to spot troubled employees. Obviously, supervisors must keep their eyes and ears
open for threatening behavior or verbal threats directed at another employee.
In addition, consider training HR staff and other supervisors in conflict resolution and nonviolent
response to aggression.
Take Advantage of Employee Assistance Programs
Employee Assistance Programs (EAPs) can help prevent violence in a number of ways.
Individual problems. First, of course, they can help individuals with a variety of problems. If an
employer is aware that an employee is in the midst of family problems or financial difficulties,
offer EAP counseling. Ask about problems if they seem obvious. If the problems are hurting the
employees performance, require counseling as part of a performance warning procedure. As
gently as possible, but insistently, get the employee to EAP or to some form of counseling.
Group training and counseling. EAPs may also run programs on stress reduction, caregiving,
or financial and retirement planning.
Statistical insights. EAP statistics may provide information on problems in certain depart-
ments, shifts, or job categories.
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When to Discipline or Terminate
As soon as an employee shows extremely angry/aggressive behavior, or physically or verbally threatens
to harm another employee, a supervisor, or the company, it is time for the employee to go. It is impor-
tant to terminate the employee carefully and humanely. If a violent reaction is possible, consult your
security team.
Violence and the ADA
An employee who commits a violent act may suffer from a mental impairment that may qualify as a
disability under the Americans with Disabilities Act (ADA). But it is unlikely that the courts will
support a disability discrimination complaint in these instances.
Physical Plant
Many hazards dont have to do with specific jobstheyre part of the physical plant. Sometimes these
are caused by design, but more often they are due to carelessness. Here are the most prevalent hazards.
Walking and Working Surfaces
Perhaps the most commonly encountered hazards are those dealing with what OSHA calls walking
and working surfaces. OSHAs standard (also known as slips, trips, and falls) regulates most areas
where employees may work or travel in the workplace including walking/working surfaces, ladders, wall
and floor openings, aisles, and scaffolds. In addition, the rule covers general housekeeping.
OSHAs walking/working surfaces rules apply to all permanent workplaces, except where only
domestic, mining, or agricultural work is performed.
Slips, trips, and falls constitute a large proportion of general industry accidents, and account for 13
percent of all occupational fatalities.
Particular areas of concern are:
Fall Protection
Although OSHA does not have a specific general industry rule for fall protection like the one for
construction (29 CFR 1926.500), the agency considers the rule that covers protection of open-sided
floors, platforms, and runways (29 CFR 1910.23(c)), and the personal protective equipment rule, to
serve as fall protection guidelines for general industry workplaces.
Floor Openings
All floor openings, including a stairway, ladderway, hatchway, chute, skylight, pit, and manhole must
be guarded by fixed or removable railings, screens, or toeboards.
Housekeeping
Housekeeping is a very basic requirement. All areas where employees work or travel, even infre-
quently, must be kept clear of hazards. Every floor, work area, and passageway must be kept free from
protruding nails, splinters, holes, or loose boards. These surfaces must be clean and free of hazards that
could interfere with normal activities.
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Aisles and Passageways
Where mechanical handling equipment is used, safe clearances must be allowed for aisles, at loading
docks, through doorways, and wherever turns or passage must be made. Aisles and passageways must be
kept clear and in good repair.
Covers and Guardrails
Covers or guardrails must also be used to protect employees.
Floor loads
Employers must not place a load on a floor or roof of a building or other structure that is greater than
that approved by the building official.
Wall Openings
Every wall, window wall, and chute wall opening from which there is a drop of more than 4 feet
must be guarded by one or more protection devices described in the rule. Every temporary wall opening
must have adequate guards but these need not be of standard construction.
Open-Sided Floors, Platforms, and Runways
All open-sided floors, platforms, and runways must be guarded by a railing and, in certain cases, by a
toeboard.
Stairs and Ladders
Specifications for fixed stairs and ladders, and portable wood and metal ladders, are thoroughly
presented in these rules. Fixed ladders and stairs must be constructed according to OSHA specifications.
If any ladders or stairs are altered, the changes must meet the requirements. Portable ladders also must
meet safety specifications.
Scaffolding
The scaffolding rule establishes requirements for the construction, operation, maintenance, and use of
scaffolds for the maintenance of buildings and structures.
Mobile Ladder Stands
The rule for manually propelled mobile ladder stands and scaffolds (towers) establishes requirements
for the design, construction, and use of mobile work platforms (including ladder stands, but not aerial
ladders) and rolling or mobile scaffolds (towers).
Sanitation
Sanitation is another issue that concerns every workplace. OSHA sanitation rules cover general house-
keeping with specific references to the following: Toilets, drinking water, toxic materials, wet processes,
waste disposal, vermin control, nonpotable water, washing facilities, lavatories, showers, changing
rooms, clothes-drying facilities, food consumption, eating areas, food storage, and food handling.
The rules also addresses the basic necessities that employers must provide for employees in the work-
place: potable water, toilets, washing facilities, and any other facilities that are required by a specific
OSHA standard.
Housekeeping
All places of employment must be kept clean and dry to the extent that the nature of the work
allows. Drainage must be maintained where wet processes are used, and dry standing places such as false
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floors, platforms, or mats should be provided or, if not practicable, appropriate waterproof footwear
should be provided. Floors, working places, and passageways must be kept free from protruding nails,
splinters, loose boards, and unnecessary holes and openings.
Waste Disposal
Waste receptacles should not leak and should be kept clean and maintained in a sanitary condition. All
sweepings, solid or liquid wastes, refuse, and garbage should be removed in such a manner and as often as
necessary to avoid creating a health hazard and to maintain the workplace in a sanitary condition.
Vermin Control
All enclosed workplaces should be constructed, equipped, and maintained to prevent the entrance or
harborage of rodents, insects, and other vermin. There should be a continuing and effective extermina-
tion program where their presence has been detected.
Water Supply
Potable water must be provided in all places of employment. Outlets for nonpotable water, such as
water for industrial or firefighting purposes, must be posted or otherwise marked to clearly indicate that
they are not safe for drinking; washing persons, cooking or eating utensils, food, food preparation or
processing premises, personal service rooms, or clothes; food preparation; or cooking.
Toilet Facilities
Separate toilet facilities shall be provided for each sex in accordance with Table J-1 of 1910.141. Each
toilet must be in a separate compartment with a door and walls or partitions between fixtures suffi-
ciently high to assure privacy. Where toilet rooms will be occupied by no more than one person at a
time, can be locked from the inside, and contain at least one water closet, separate toilet rooms for each
sex need not be provided.
Lavatories
Sinks with hot and cold running water must be provided in all workplaces. Soap and towels (paper,
cloth, or warm air blowers) must also be provided.
Showers
Whenever showers are required by a particular standard, there should be one shower with hot and
cold running water for each 10 employees of each sex. Soap and towels should also be provided.
Change Rooms
Whenever employees are required to wear protective clothing because of the possibility of contamina-
tion of toxic materials, changing rooms with storage for street clothes and separate storage for protective
clothing should be provided.
Clothes Drying Facilities
Where working clothes are provided by the employer and become wet or are washed between shifts,
provisions should be made to ensure that the clothes are dry before reuse.
Consumption of Food and Beverages
Food and beverages must not be consumed or stored in toilet rooms or any areas exposed to toxic
materials. Receptacles for food waste must be provided and maintained in a sanitary condition.
Food Handling
Where provided, all employee food service facilities and operations must be carried out in accordance
with sound hygiene principles.
Security
For virtually every employer, security has become a more important issue in recent years. Each
facility has different requirements, but here are some areas to focus on in evaluating or improving your
security systems.
Assess Your Target Potential
The first action employers should take is to thoroughly assess the kinds of crimes that are most likely
to occur in their facilities. For example, a convenience store that stays open late at night faces robbery,
sometimes with violence. If youre a manufacturer, it could be theft of tools, ideas, or processes.
Employers know their own workplace best and should take a careful inventory of where specific
vulnerabilities lie. Anything can happen, but some events are more probable for some workplaces, other
events more likely to happen to others. Here are some ideas to get you thinking.
General Security
Have police numbers publicized and posted; be sure every employee knows whom to call in an
emergency.
Designate certain employees to be in charge of security; make sure everyone knows their phone
numbers and when to call.
Warn employees not to personally confront violent or forceful intruders, but to call security,
the police, or the specially designated employees.
Develop instant communication and/or warning networks among HR, key personnel, and
security. Use intercoms, alarms, or whatever is possible in your workplace.
Outside Areas and Parking Lots
Parking lots and grounds pose a major security risk. Consider the following:
Controlling entry; consider a guarded gate, or at least one that is always visible to employees
inside
Providing active security and frequent patrols
Offering or mandating that security escort employees to their cars after hours
Fencing
Bright lighting
Entry
More and more employers are controlling entry to their facilities, using a variety of recognition
systems.
Consider key card access systems at all entrances.
Issue ID cards with recent photos to all employees, and insist that they be worn.
In all but retail establishments, do not allow outside visitors into the workplace unescorted.
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Ask all repair people, salespeople, or any other visitors for identification, even if they are
wearing a uniform.
In retail establishments late at night, do not let an employee work alone. Set up a silent alarm
system connected to the police.
Background Checks
Most employers have become more careful about background checks in recent years. Its best to have
standard procedures for all new hires. Its much easier to weed out problems before people are hired than
after they have started work.
Be sure to do reference checks and background checks. This is usually accomplished by an outside
firm that specializes in that work.
Policy
A security policy should be accomplished with thought and careit is not an off-the-cuff item.
Broadly, it should consist of:
Rules of behavior for all employees
Procedures to safeguard specific areas or activities, and general security
Procedures to follow if something happens (from a fight in the lunchroom to a violent, armed
customer)
Emergency procedures
Training
Its especially important that supervisors and managers be trained to deal with security and violence
problems. Training should not be a superficial, one-shot session.
Environmental Issues: Ventilation, Noise, Radiation
Industrial workplaces, by the nature of their operations, generate conditions that are beyond the
limits safely tolerated by the human body. OSHA regulations address three specific areas of concern:
ventilation, noise, and nonionizing radiation.
The regulations are very specific in their coverage of the control measures required to control expo-
sures and protect employees. The implementation of engineering controls and administrative programs
is the principal means employers are given to comply with OSHAs regulations.
Ventilation
The regulations for ventilation are activity specific. They cover abrasive blasting, grinding, polishing
and buffing operations, and spray finishing operations.
The use of ventilation systems is stressed as the principal means to reduce the risk of exposure and
flammable concentrations of vapors. There are design, construction, and maintenance requirements also.
In certain situations where ventilation systems or physical arrangements cannot provide adequate
protection, personal protective equipment (PPE) is required. See a detailed discussion of PPE later in
this chapter, and find a checklist and training outline in Appendix F (under Subpart I.)
Noise
According to OSHA, approximately 30 million workers are exposed to hazardous noise in the work-
place each year. The incidence of noise-induced hearing loss can be reduced or eliminated through the
successful application of engineering and administrative controls and hearing conservation programs.
Federal regulations are very specific in their coverage of the control measures required to control noise
exposures and protect the hearing of employees. The implementation of engineering controls and
administrative programs is the principal means employers have to comply with regulations.
Engineering and administrative controls must be implemented before personal protective equipment
(e.g., hearing protectors) is used.
Employers that have workplace operations that produce harmful noise must institute several adminis-
trative programs to protect employees: a hearing conservation program, monitoring, audiometric testing
program, and training program are required.
Noise monitoring is used to determine employee exposure under the hearing conservation program.
Control measures such as hearing protectors would be selected on the basis of the information gathered.
Employee hearing is to be evaluated under an audiometric testing program detailed in the regulations.
Employees are also to be provided with information and training related to the requirements of this
standard. Employees must be provided access to certain information and records maintained by the
employer.
Personal hearing protection. Where required, employers must make hearing protectors available to
all employees, at no cost to them. The employer must ensure proper initial fitting and supervise the
correct use of all hearing protectors. The employer must evaluate hearing protector attenuation for the
specific noise environments in which the protector will be used.
Nonionizing Radiation
OSHA also covers measures required to control exposure and protect employees from nonionizing
radiation, for example, from radio frequency and microwaves. (OSHA also covers ionizing radiation in
its Subpart Z.)
These regulations cover everything from exposure monitoring to emergency actions. An employer
must establish programs or procedures that describe personal monitoring, precautionary signs, emer-
gency procedures and signals, and training, as well as recordkeeping and reporting to OSHA.
Electrical
Electrical safety deals with the reliability and effective maintenance of electrical systems that can be
achieved in part by careful planning and proper design and with safe work practices for persons exposed
or potentially exposed to electrical hazards.
OSHAs electrical safety rules for general industry workplaces (29 CFR 1910, Subpart S) cover elec-
trical safety requirements that are necessary for the practical safeguarding of employees in the
workplace. It includes design safety standards for electric utilization systems (all electric equipment and
installations used to provide electric power for workplaces) and safety-related work practices for both
qualified (those who have a specific level of training) and unqualified (those who have little or no
training) employees.
Electrical equipment grounding, enclosing, covering, and guarding live parts, and conductors all
have specific regulations pertaining to them. Flexible cords are another subject that is addressed by
several regulations.
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Examination, Installation, and Use of Equipment
Electrical equipment must be free from recognized hazards that are likely to cause death or serious
physical harm to employees. Listed or labeled equipment must be used or installed in accordance with
any instructions included in the listing or labeling.
Additional concerns include splices, arcing parts, marking, and working space around electrical
installations.
Safe Work Practice Rules
The electrical safe work practice rules cover work practices for both qualified persons (those who have
training in avoiding the electrical hazards of working on or near exposed energized parts) and unqualified
persons (those with little or no such training) working on, near, or with electrical installations.
Personal Protection Safeguards
Employees working in areas in which there are potential electrical hazards must be provided with,
and must use, electrical protective equipment that is appropriate for the specific parts of the body to be
protected and for the work to be performed.
Risky Occupations
OSHA has compiled the following list of typical occupational categories of employees who face a
higher than normal risk of an electrical accident:
Blue collar-supervisors
Electrical and electronic engineers
Electrical and electronic equipment assemblers
Electrical and electronic technicians
Electricians
Industrial machine operators
Material-handling equipment operators
Mechanics and repairers
Painters
Riggers and roustabouts
Stationary engineers
Welders
Machinery and Machine Guarding
Industry relies on machinery to do much of the work necessary to manufacture a product. Because
most machinery is capable of changing the shape or size of a material, it is also capable of doing the
same to parts of the human body. According to OSHA, any machine part, function, or process that may
cause injury must be safeguarded.
When the operation of a machine or accidental contact with it can injure the operator or others in the
vicinity, the hazards must be either eliminated or controlled.
One or more methods of machine guarding must be provided to protect the operator and other
employees in the machine area from hazards such as those created by point of operation, ingoing nip
points, rotating parts, flying chips and sparks. Examples of guarding methods are barrier guards, two-
hand tripping devices, and electronic safety devices.
Types of Machines
OSHA rules address the safety requirements for many types of machines, including
Woodworking machinery
Abrasive wheel machinery
Mills and calendars in the rubber and plastics industries
Mechanical power presses
Forging machines
Mechanical power-transmission apparatus
OSHA Recommendations
OSHA recommends that all guards:
Prevent workers hands, arms, and other body parts from making contact with dangerous
moving parts.
Ensure that no object will fall into the moving parts.
Permit safe, comfortable, and relatively easy operation of the machine.
Allow the machine to be oiled without removing the guard.
Provide a system for shutting down the machinery before guards are removed.
Manufacturer and Employer Responsibilities
Because many OSHA machine-guarding rules are related to the design and construction of the
machinery, it is up to the manufacturer to meet those specific requirements. Employers must ensure that
the machines and equipment are maintained according to the manufacturers requirements and OSHAs
machine operating and inspection requirements.
Temporary Labor Camps
OSHA has special rules for temporary labor camps, which contain specifications for sites, shelters,
water supply, toilet facilities, laundry facilities, washing facilities, lighting, refuse disposal, feeding facil-
ities, insect and rodent control, first aid, and communicable disease reporting.
The site for a temporary labor camp must meet certain specifications, as must the shelter provided.
There must be an adequate water supply and enough toilets for the camp at full capacity. Laundry, hand
washing, bathing, and sewage-disposal facilities must all be provided, as well as sufficient lighting, the
means for proper refuse disposal, and insect and rodent control. Where centralized dining facilities are
provided, food-handling requirements must comply with Public Health Service specifications. First-aid
treatment must be available for emergencies, and communicable diseases must be reported.
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Hazardous Materials
Most workplaces use at least a few hazardous substances, while some use quite a few. OSHA has many
rules governing handling hazardous materials and protection of employees from hazardous materials.
The regulations also cover the management of hazards associated with processes using highly
hazardous chemicals. They establish procedures for process safety management that will protect
employees by preventing or minimizing the consequences of chemical accidents involving highly
hazardous chemicals. A section on hazardous waste operations and emergency response regulates the
safety and health of employees who are involved in clean-up operations at hazardous waste sites and
persons who participate in emergency response.
In addition, OSHA has rules for hazard communication, also knows as Right to Know. Here are
some brief comments on each of these areas.
13 Carcinogens
OSHA designates a group of 13 hazardous chemicals,carcinogensthat have similar management
and training requirements. Organizations that use these materials must follow strict rules concerning
personal protective equipment, decontamination procedures, and so on.
The 13 chemicals are:
4-Nitrobiphenyl
alpha-Naphthylamine
Methyl chloromethyl ether
3,3-Dichlorobenzidine (and its salts)
bis-Chloromethyl ether
beta-Naphthylamine
Benzidine
4-Aminodiphenyl
Ethyleneimine
beta-Propiolactone
2-Acetylaminofluorene
4-Dimethylaminoazobenzene
N-Nitrosodimethylamine
If you use any of these chemicals, youll be subject to these rules.
Air Contaminants
OSHA lists air contaminants in three tables, the infamous Z TablesZ-1, Z-2, and Z-3. These
tables together contain close to 600 substances, and employee exposure to these substances is strictly
limited. Both the concentration of the substance and the length of time an employee may be exposed to
it are restricted, i.e., there are permissible exposure limits (PELs), ceiling limits, and 8-hour time
weighted averages (TWAs) that must be complied with. If this cannot be accomplished using work
practices or engineering controls, protective equipment must be provided to keep employee exposure
within the prescribed limits.
Mandatory training is associated with many of the sections of the regulation, and attention to this
training is particularly important since the hazards are not always obvious to the untrained employee.
Asbestos
This section deals with the hazards of working with asbestos and gives mandatory means of dealing
with the hazards. Requirements include exposure monitoring, the establishment of regulated areas,
rules for communicating hazards to employees, special housekeeping rules, and rules governing medical
exams and recordkeeping. This is a heavy compliance material. If your employees are exposed to
asbestos, take care to review the myriad requirements carefully.
Compressed Gases
Activities involving compressed gases and cylinders must be in accordance with the Compressed Gas
Association (CGA).
Covered gasses
Specifically covered gasses include:
Acetylene. Acetylene is governed by CGA standards.
Hydrogen. Containers for both gaseous and liquefied hydrogen must comply with the specifi-
cations of either the American Society of Mechanical Engineers (ASME), the Department of
Transportation (DOT), or the American Petroleum Institute (API).
Oxygen. This standard provides specifications for containers for bulk oxygen storage systems,
locations of containers, safety relief devices, piping.
Nitrous Oxide. CGA standards are applicable.
Compressed Air Receivers
This section covers compressed air receivers and other equipment used to provide compressed air for
cleaning, drilling, hoisting, and chipping. Of particular interest are gages and valves for compressed air
receivers and the frequent testing of valves.
Dipping and Coating Operations
OSHA regulates construction, ventilation, and exhaust requirements, first-aid procedures, hygiene
facilities, inspection and maintenance procedures, and requirements for use of flammable and
combustible liquids in dipping and coating operations.
Explosives and Blasting Agents
OSHA issues requirements primarily concerning the storage and transportation of explosives and
related materials such as blasting caps.
Flammable and Combustible Liquids
Specifications are provided for storage tanks, piping systems, containers, underground tanks, above-
ground tanks, portable tanks, industrial plants, bulk plants, service stations, processing plants,
refineries, chemical plants, and similar enterprises.
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Spray Finishing Using Flammable and Combustible Materials
Specifications are provided for spray booths; flames and sparks in spray areas; ventilating systems;
storage of flammable/combustible liquids; water sprinklers.
Storage and Handling of Liquefied Petroleum Gases
Requirements include compliance with Department of Transportation (DOT) regulations; odoriza-
tion; construction repair; storage specifications for containers; and specifications for service stations.
Storage and Handling of Anhydrous Ammonia
This standard includes DOT and ANSI specifications for cylinders and requirements for farm vehicles.
Process Safety Management of Highly Hazardous Chemicals
There is extra danger in processes that use large quantities of hazardous chemicals and other
hazardous materials. For these situations, OSHA has developed a separate set of rules.
Much of the regulation on process safety management is concerned with written documentation,
including the following:
A written action plan concerning employee participation in the development of the process
safety procedures.
A written compilation of process safety information.
An initial process hazard analysis if the processes you use involve highly hazardous chemicals.
These chemicals are listed in Appendix A to 1910.119.
Written operating procedures for each process. You must train your employees in the possible
hazards involved in these processes and in the proper operating procedures.
A pre-startup safety review for all new or modified facilities.
A written procedure for the maintenance of process equipment.
Written guidelines that address changes to process chemicals, technology, equipment, and
procedures.
You must investigate every incident that results in (or might have resulted in) a catastrophic release
of highly hazardous chemicals in the workplace, and you must have in place an emergency action plan
for your entire facility. You must make all pertinent information available to those persons who are
responsible for compliance, disregarding the trade-secret status of that information.
Finally, you must audit your own compliance program at least every 3 years to make sure that your
processes and procedures are in compliance with the standard. Copies of the last two audits must be kept.
Hazardous Waste Operations and Emergency Response
The handling of hazardous wastes has a separate set of rules called Hazardous Waste Operations and
Emergency Response (HAZWOPER). Under the authority of Section 126 of the Superfund
Amendments and Reauthorization Act of 1986, OSHA developed HAZWOPER workplace health and
safety standards.
Who Is Covered?
HAZWOPER standards cover employers with one or more employees and who engage in the
following operations:
Cleanup required by federal, state, or local governments at uncontrolled hazardous waste sites
where an accumulation of hazardous substances creates a threat to the health and safety of
people or the environment
Corrective actions involving cleanup at Resource Conservation and Recovery Act (RCRA)-
regulated sites
Voluntary cleanup at government-recognized uncontrolled hazardous wastesites
Operations involving hazardous wastes at treatment, storage, and disposal facilities (TSDF)
licensed under RCRA
Emergency response operations for release, or substantial threats of release, of hazardous
substances
Note: If the operation is not covered by the operations listed, it must comply with emergency
response requirements only, including training.
Essential HAZWOPER Components
HAZWOPER rules define and require compliance with the following components of a hazardous
wastesite management program:
A written safety and health program
Site characterization and analysis
Site control
Training
Medical surveillance
Engineering controls, work practices, and personal protective equipment (PPE)
Monitoring
Informational programs
Material handling
Decontamination
Emergency response plan
Illumination
Sanitation
New technology program
Operations conducted under RCRA
Emergency response to releases
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Written Safety and Health Program
The required written safety and health program must be developed for operations and cleanup at a
hazardous waste site and must incorporate the following seven elements:
Organizational structure
Comprehensive work plan
Site-Specific Safety and Health Plan (SSAHP)
Safety and health training
Medical surveillance
Standard operating procedures (SOP) for safety and health
Interface between general site conditions and site-specific activities
The written program must be made available to all contractors, subcontractors, or their representa-
tives, employees and their representatives, OSHA personnel, and personnel of any other government
agency with regulatory authority at the worksite.
Occupational Exposure to Hazardous Chemicals in Laboratories
Laboratories have different challenges than routine manufacturing operations, so there is a special rule
governing lab employees exposure to hazardous chemicals if the exposure exceeds certain limits.
The basis for this standard is a determination that laboratories typically differ from industrial opera-
tions in their use and handling of hazardous chemicals and that a different approach than that found in
OSHAs substance-specific health standards is warranted to protect workers.
One of the most important features of this section is the Chemical Hygiene Plan. This paragraph
states that employers in laboratories where there are hazardous chemicals present must develop a
Chemical Hygiene Plan and carry out its provisions in order to protect their employees.
If you have laboratory facilities, familiarize yourself with this regulation.
Personal Protective Equipment (PPE)
As mentioned above, PPE is the last resort for protecting employees from hazards. Nevertheless, it is
frequently the best available method. Not surprisingly, OSHA has detailed regulations concerning PPE.
OSHA regulations cover PPE for eyes, face, head, and extremities; protective clothing, respiratory
devices, and protective shields and barriers.
Training on PPE use is particularly important, since this is an area where employees are likely to
forget to wear their equipment unless carefully trained and monitored.
OSHA requires employers to use PPE to reduce employee exposure to hazards when engineering and
administrative controls are not feasible or effective. Employers are required to determine all exposures to
hazards in the workplace and determine if PPE should be used to protect their workers.
General Protection
PPE must be provided, used, and maintained in a sanitary and reliable condition wherever hazards
exist in the workplace. The hazards of processes, chemical hazards, radiological hazards, or mechanical
irritants capable of causing injury or impairment in the function of any part of the body through
absorption, inhalation, or physical contact must be addressed by the use of PPE.
Hazard Assessment
OSHA requires each employer to assess the workplace to determine if hazards are present, or are
likely to be present, and necessitate the use of PPE. Every job in the workplace must be evaluated. The
employer must certify in writing that the PPE hazard assessment has been performed. The written certi-
fication must identify:
The workplace evaluated
The date of the assessment
The person certifying that the evaluation has been performed
The hazards found
The PPE selected
Employers must determine what types of PPE are appropriate for their workers and ensure that
workers know how to use PPE items properly. The two basic objectives of any PPE program are to:
Protect the wearer from safety and health hazards, and
Prevent the wearer from being injured if there is a malfunction or he or she uses the equip-
ment incorrectly.
Defective PPE
The use of defective or damaged PPE is prohibited.
Training
All employees required to wear PPE must be trained when and how to use it and demonstrate its use
before performing work requiring the use of PPE.
Payment for PPE
Employers are required to pay for PPE with the exception of non-specialty safety-toe protective
footwear (including steel-toe shoes or steel-toe boots) and non-specialty prescription safety eyewear,
provided that the employer permits such items to be worn off the job-site. When the employer provides
metatarsal guards and allows the employee, at his or her request, to use shoes or boots with built-in
metatarsal protection, reimbursement is not required for the shoes or boots.
The employer is also not required to pay for logging boots and everyday clothing, such as long-sleeve
shirts, long pants, street shoes, and normal work boots; or ordinary clothing, skin creams, or other
items, used solely for protection from weather, such as winter coats, jackets, gloves, parkas, rubber
boots, hats, raincoats, ordinary sunglasses, and sunscreen.
The employer must pay for replacement PPE, except when the employee has lost or intentionally
damaged it.
Employee-Owned Equipment
If employees choose to use their own PPE, the employer is responsible for its adequacy, maintenance,
and sanitation. The employer does not have to provide reimbursement for such PPE but may not require
that employees provide or pay for their own PPE.
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Written PPE Program for HAZWOPER
A written PPE program, which is part of the employers safety and health program and part of the
site-specific safety and health plan, must be established by employers engaged in hazardous waste opera-
tions and emergency response. The PPE program must address:
Site hazards
PPE selection
PPE use
Work mission duration
PPE maintenance and storage
PPE decontamination
PPE training and proper fitting
PPE donning and doffing procedures
PPE inspection
PPE in-use monitoring
Evaluation of the effectiveness of the PPE program
Limitations during temperature extremes
The program, including both the written program and implementation, must be reviewed annually.
Respiratory Protection
Certain occupational diseases can be caused by breathing contaminated air in the workplace. Where engi-
neering controls are not in place or are not feasible, appropriate respirators must be used by employees.
In any workplaces in which respirators are required, the employer must establish a written respiratory
protection program with specific procedures for all sites covered by it. That program must be updated as
necessary to reflect changes in conditions and must be administered by a trained administrator.
The program must ensure that:
Respirators are provided to all employees who need protection in the workplace.
All respirators are considered applicable and suitable for the intended purposes.
Training in the use of the respiratory equipment is provided.
Each employee understands how to use and uses the applicable respiratory protection.
Medical evaluations of employees required to use respirators are conducted.
Respirators are fit-tested.
Respirators must be cleaned, inspected, and disinfected in the proper manner.
If respiratory equipment is shared by more than one employee, the equipment must be disin-
fected before each use.
If respirator use is not required in a workplace, the employer may still provide respirators to
employees who want them or permit those workers to use their own. A copy of Appendix D of
1910.134 must be given to all employees who use respirators voluntarily.
Dress and Grooming
Although dress and grooming are not exactly part of personal protective equipment, it is important
to note that some dress and grooming habits can cause hazards, and supervisors must be on the lookout
for these situations. For example:
Loose clothing. Loose clothing and accessories like ties, sashes, and scarves are very hazardous when
working near machinery. Once they catch in the machinery, they may drag the person into the
machine.
Long hair. Similarly, long hair can be a hazard. Employees with long hair who work near machinery
should securely tie or pin the hair up, or cover the hair with a cap.
Anything that interferes with PPE. Many other dress and grooming practices may interfere with
the proper use of PPE, for example:
A beard may prevent a face mask from making a proper seal.
Earrings may prevent noise protection gear from fitting.
Supervisors must be trained to be careful when doing initial fitting and testing, and must be
on the lookout to ensure that employees continue to use PPE effectively.
Hazardous Processes/Activities
Sometimes, an activity itself can be hazardous. This next section presents the most important of
hazards that deal with how employees work and how they perform particular tasks. OSHA has rules
governing many of these processes and activities.
Control of Hazardous Energy (Lockout/Tagout)
The purpose of the lockout/tagout rule is to prevent accidents from happening to employees who are
servicing machines and equipment. The regulation calls for isolating energy-producing devices by
attaching locks (lockout) to prevent the machine from being operated or tags (tagout) that warn people
not to start up the machine.
Program. The employer must set up a program that includes energy-control procedures,
employee training, and periodic inspections. Any machine or equipment that is to be serviced
must have its energy source isolated so that the machine is made inoperable. If it is not
possible to do this with a lockout device, a tagout system must be used.
Inspections. Employers must conduct inspections, at least annually, of the energy-control
procedures to make sure that they are in compliance with all regulations.
Training. Employers must provide training such that employees acquire the knowledge and
skills needed to apply, use, and remove the energy controls safely.
Personnel. All lockouts and tagouts must be performed by the employees who are going to
service the machines. Employees who will be affected by a lockout or tagout must be notified
before and after the controls are applied.
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Lockout/Tagout Compliance Requirements
Some of the key parts of the procedure include:
Before any employee performs any servicing or maintenance on a machine or equipment where
the unexpected energizing, startup, or release of stored energy could occur and cause injury, the
machine or equipment must be isolated from the energy source and rendered inoperative.
The employer must provide the appropriate protective materials and hardware for isolating,
securing, or blocking of machines or equipment from energy sources.
Lockout/tagout devices must be singularly identified, used only for controlling energy, capable
of withstanding the environment in which they are used, constructed so that they will not
deteriorate or become illegible, and be standardized throughout the facility.
Lockout/tagout devices must be identified with the name of the employee who applied them.
Lockout/tagout procedures must be performed only by authorized employees.
Affected employees must be notified of the planned lockout or tagout.
An orderly shutdown must be performed.
The machine or equipment must be isolated from the energy source.
Lockout/tagout devices must be applied by authorized employees.
Stored energy must be removed from the machine.
The machine must be tested to ensure that isolation and de-energization have occurred.
Before lockout/tagout devices are removed and energy is restored, the work area must be
inspected to make sure that all nonessential items have been removed, and that machine
components are operationally intact, and that no employees are in a position to be injured.
Training and Communication
Authorized employees must be trained to recognize and control hazardous energy sources.
Affected employees must be instructed in the purpose and use of the energy-control procedure.
All other employees must be trained never to try to start locked or tagged equipment, and
never to remove or ignore lockout/tagout devices.
Permit-Required Confined Spaces
Confined spaces are particularly dangerous. Its very easy for a toxic atmosphere to develop. If your
organizations employees ever need to enter confined spaces, OSHA requires a comprehensive confined
space entry program.
A confined space is a space such as a tank, silo, hopper, or storage bin. In general, confined spaces are
spaces that:
A person can enter to do work
Have limited or restricted means for entry and exit
Are not intended for continuous work
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Permit-Required Confined Space Program
Key aspects of the program include:
Necessary measures must be implemented to prevent unauthorized entry.
Hazards of permit spaces must be identified and evaluated before employees enter the spaces.
Employees also have certain rights and must be provided with certain information about
confined spaces.
Procedures and practices must be developed to ensure safe permit space entry operations.
A permit has to be obtained to enter a confined space and only those authorized entrants
mentioned on the permit may enter.
Each authorized entrant must be provided with the opportunity to observe any monitoring or
testing of permit spaces.
At least one attendant must be placed outside of a permit space for as long as entry operations take
place, and there must be a communications system set up between the entrant and the attendant.
Rescue and emergency services must be developed and implemented. The permit space super-
visor must know what local emergency rescue services to call should they be needed.
Should a dangerous situation arise, the entrants must be removed from the permit space by the
retrieval system.
The regulations also specify the duties of authorized entrants, attendants, and entry supervisors.
Rescue and Emergency Services
A designated rescue and emergency service must be evaluated to make sure that it can respond to a
rescue summons in a timely manner, perform rescue tasks proficiently, is properly equipped, and can
reach victims within a time frame appropriate for the permit space hazards. In addition:
Each rescue team must be informed of the hazards they may confront when called to perform
rescue at the sight.
Employers must ensure that each member of the rescue team has successfully completed
training in required rescue duties.
Training
Appropriate training must be provided to employees before they are first assigned duties, before their
assigned duties are changed, and whenever there is a change in permit space operations that presents a
hazard about which they have not previously been trained.
Entry Permit
Confined space entry permits must contain the following information:
Identification of permit space
Purpose of entry
Date and authorized duration of permit
Names of authorized entrants
Names of attendants
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Name of entry supervisor
Hazards in the permit space
Measures used to isolate permit space
Means used to reduce hazards in permit space before entry
Acceptable entry conditions.
Results of tests.
Available rescue and emergency services
Communications procedures used between authorized entrants and attendants
Equipment that must be provided
Sad Note, but an Important Warning
A surprising number of confined space incidents result in two deathsthe entrant who gets in
trouble and the buddy who goes in to try to rescue the entrant. Confined spaces are very dangerous;
train everyone involved carefully and take seriously your obligations for rescue and retrieval.
ErgonomicsHow People Interact with Environment
Ergonomics has to do with the way employees physically interact with their equipment and their
workspaces. Ergonomic injuries are most often repetitive motion injuries or musculoskeletal disorders
(MSD). A great many ergonomic injuries involve carpal tunnel syndrome or back injuries.
These injuries are often caused by job tasks that require
Repetitive, forceful exertions;
Frequent, heavy, or overhead lifts;
Awkward work positions; or
Use of vibrating equipment.
If allowed to go on untreated, ergonomic injuries can require surgery and often mean that workers
cannot do their jobs for long periods of time.
Actions taken to reduce ergonomic injuries may include PPE, redesigned workstations, changes in
the manner work is performed, or microbreaks.
Many organizations report that their ergonomic efforts do reduce injuries, lost time, and workers
compensation costs.
Legal Requirements
OSHA does not have a standard governing ergonomic issues, although it would like to, and it does
focus a lot of attention on these injuries. The Agency may cite employers for ergonomics injuries under
the General Duty Clause. Some other entities have weighed in on ergonomics:
States. California has enacted safety laws and published ergonomic standards for employers.
ADA. The Americans with Disabilities Act requires employers to reasonably accommodate
employees with disabilities. Redesigning workstations may be a reasonable accommodation.
FMLA. Employees with ergonomic injuries may be eligible for time off under the Family and
Medical Leave Act or a similar state law.
Workers compensation. Employees injured at work from repetitive motions may file for
workers compensation. Often, employees discharged after filing such claims may be able to
sue for discrimination or retaliation.
Symptoms
Signs and symptoms of MSDs include:
Painful joints
Pain, tingling, cramping, or numbness in hands or feet
Shooting or stabbing pains in arms or legs
Swelling or inflammation
Burning sensations
Pain in wrists, shoulders, forearms, knees
Back or neck pain
Stiffness or decreased range of motion
Deformity
Decreased grip strength
Loss of muscle function that may result from exposure to risk factors
Hand and Portable Powered Tools and Other Hand-Held Equipment
Most every workplace has portable power tools. Many of the tools are also commonly found in the
home. Because many employees may be familiar with power tools, it is easy to assume they will be used
safely. What is more likely to happen is a disregard of safety due to familiarity. Safety with these tools
cannot be taken for granted. Accidents result in loss of fingers and other severe injuries to the employee.
OSHAs rules cover safety requirements for powered hand tools such as saws, belt sanders, grinders, pneu-
matic tools, and fastening tools that are explosive-actuated. Also covered are lawnmowers and jacks.
As with other machines, safety should be designed into powered tools. The OSHA regulations
include design specifications. The employer must assure that the tools are not modified or allowed to be
used in any condition that would increase the risk of injury.
Inspections and maintenance are the primary means of assuring safe use of the tools. OSHA also
includes standard operating procedures for handling and operation of the tools.
Materials Handling and Storage
Manufacturing usually requires the handling of heavy or bulky materials. Depending on their size
and weight, the means available to handle them varies. Regardless of the means used, handling mate-
rials involves risk. For that reason, OSHA has chosen to regulate the way materials are handled.
OSHAs rules include regulations for powered trucks such as:
Forklifts
Cranes
Helicopters
Slings
Derricks
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In addition, specific regulations cover the servicing of rim wheels for these vehicles.
Common to most of the sections in this rule are requirements for standard operating procedures for
equipment operations; personnel training and qualified person requirements; and requirements for
maintenance and inspections.
Because most industries use some type of powered industrial truck to move materials and products,
this section is extremely important. Be award of limitations as to the use of these trucks. For example,
only certain types of trucks can be operated in certain hazardous locations. It is very important to make
sure that you are using the proper truck in the proper location.
Powered Platforms, Manlifts, and Vehicle-Mounted Work Platforms
Many industries use platforms or lifts in their day-to-day operations. Because of the nature of this
equipment, workers may work many feet above the ground. Besides the hazard of working at such
heights, there is also concern that the equipment may contribute to the risk of falling or other injury.
OSHA, in its regulations, has concentrated on defining safety requirements for the design, construction,
installation, operation, maintenance, inspection, and use of these lifts and platforms. If these require-
ments are followed, workers will be able to complete their work without fear of the equipment
malfunctioning.
OSHAs rules deal with three specific types of devices: powered platforms, manlifts, and
vehicle-mounted platforms. The regulations include specific design requirements as well as safety
requirements. Newly purchased equipment should meet these requirements. Your supplier should
provide you verification.
Of particular importance are requirements for:
Emergency communications. Employers are required to acquaint their employees with an
emergency action plan so that in the event of an emergency, the employees will be able to
protect themselves.
The use of safety belts and lifelines. Employee sometimes consider wearing this gear to be
too much trouble, burt you must insist on it.
Equipment inspections. Daily inspections are necessary.
Be sure that your procedures and guidelines cover these requirements.
Hot WorkWelding, Cutting, and Brazing
Among the most common activities in industry are welding, cutting, and brazing. These jobs are
often called hot work for obvious reasons. They are also among the most hazardous activities because
of the many hazards associated with them.
An employer who conducts welding and cutting activities should be very familiar with the OSHAs
requirements. Disregarding these regulations can result in fires, injuries to employees, and adverse
health effects.
Of particular concern are the regulations covering fire protection and personnel protection. Other
regulations involve the design specifications for use of the equipment.
Regulations on welding and related occupations deal primarily with the storage, handling, and
conveyance of acetylene and oxygen. Employers should take particular care in preventing leakage of
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these chemicals from cylinders or hoses, and monitor the environment in which they are stored or used.
Acetylene should not be stored in excessive temperatures or near combustible materials.
The regulations also address safety procedures for:
Arc welding and cutting equipment,
Resistance welding equipment,
Fire prevention and protection,
Protective clothing for welding operators, and
Ventilation of the work area.
Welders in confined spaces should have respiratory protection from air contaminants and trace metals.
To help assure safe activities, systems are to be inspected and maintained according to the regulations.
Operators must be trained, and only qualified persons are allowed to conduct maintenance activities.
Driving
Driving is such a common activity that employers may be tempted to ignore it, assuming that all
employees know how to drive safely, but thats not wise. Employers should consider the following:
Defensive driving training
Inspections before starting out (tires, washer fluid, etc.)
Prohibitions against cell phone use while driving
Rules concerning fatigue and number of hours driven per day
A requirement to follow traffic laws
An admonition against alcohol or drugs
Mandatory seat belt use
Commercial Diving Operations
Sections 1910.401 to 1910.441
Underwater work is extremely hazardous. Divers must depend on equipment and procedures to
assure their safety, and the risk of death is great if any piece of equipment fails or the diver does not
adhere to these procedures. The requirements established in this subpart are detailed because of the
extremely hazardous nature of diving operations.
The safety of divers depends on the diver, the equipment used, and the procedures implemented for
the operation, and OSHA has regulations addressing each of these areas. Such things as the avail-
ability of a first aid manual, resuscitators, and emergency telephone numbers at the dive site are of
major importance.
Health Issues
Most health issues are covered elsewhere in this book, but here are a few that are not mentioned:
Heat and Cold
If your workers must work in extreme environments, either hot or cold, you should take steps to
prevent ailments such as frostbite and heat stroke. This may require protective equipment, frequent
rotation in and out of the worksite, frequent breaks, or some other method.
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Dermatitis and Other Skin Problems
Skin disease is the most common on-the-job illness. Some skin problems are simply minor irritations
that go away quickly. Others are long-lasting and may even get worse if an employee becomes sensi-
tized to a particular substance and can no longer go near it.
Skin Hazards
There are a number of possible skin hazards on the job.
Dermatitis is the name for rashes, itching, swelling, and other irritations that can develop
from exposure to substances ranging from chemicals to paint.
Sensitization is what we call the allergy-like reactions, including rashes, that employees experi-
ence whenever they are in the vicinity of a chemical following frequent or long exposure.
Skin can be burned by a flame, hot surface, electrical exposure, or exposure to a corrosive
substance.
Cuts, bruises, and other wounds from tools or flying objects can let bacteria in to the skin and
lead to infections.
Frostbite is an example of a skin problem that results from exposure to cold.
OSHA Regulations
OSHAs main regulation that applies to skin protection is the Hazard Communication Standard, which
requires you to inform employees about the possible health hazards of the substances with which they
work and what protective actions to take against those hazards. And, of course, the General Duty Clause
applies. There are also regulations requiring protective equipment when working with specific substances.
Identifying Hazards
The quickest way to discover if a substance has the potential to cause skin irritation, skin burns, or
other reactions is to read its label and material safety data sheet (MSDS).
Most other skin hazard identification is common sense. If youre working on a hot job or near hot
equipment, you can safely assume theres a burn hazard. If the job situation involves very low tempera-
tures, you have to protect your skin against cold. If youre working with sharp objects or on a job where
materials could hit your hand or other parts of your body, you need some kind of protection against cuts
or bruises.
Protection Against Hazards
Be sure to select equipment thats designed to protect against the specific hazard your employees face.
A glove that will protect against one kind of hazardous substance might be eaten away by another.
Similarly, a glove designed for protection against chemical exposure would probably be useless as
protection against heat.
Train employees to inspect protective gear carefully before use; any rips or holes should be fixed
before wearing.
Also provide instructions for removing protective clothing and be sure that chemical-protective
clothing and gloves are rinsed and cleaned thoroughly before theyre put away.
Try to use the least hazardous substance that will do the job. For example, you may be able to use
water-based cleaners instead of solvents for some applications.
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Other Skin Protection Tips
When you do use hazardous substances, follow these guidelines:
Follow instructions for handling, storage, and transport.
Keep chemical containers closed when not in use.
Use substances only in areas where theres good ventilation.
Bandage any small scrapes or cuts before putting on gloves or protective clothing.
In some situations, protective creams and lotions may be used to create a barrier to skin
disease.
Stress Management
More and more employers are paying attention to stress as a significant problem in the workplace. It
can have a major impact on individual productivity and can affect the pleasantness of the work environ-
ment. In addition, workplace stress management, particularly in these times of massive reorganizations
and reduced staffing, may be pivotal to successfully keeping violence at bay.
NIOSH and a number of other groups have studied stress at work and ways to reduce it. The agency
notes that while working conditions play a primary role in causing job stress, individual factors, such as
caring for an ill parent, can intensify the effects of stressful working conditions.
Anecdotal evidence from a variety of sources suggests the need to treat employees with respect, in all
actions, especially with regard to disciplinary measures such as discharge. Angry workers often mention
that they feel they have not been treated with respect.
OSHA does not specifically regulate stress.
Safety Issues for Specific Types of Workplaces
Sometimes it is easier to look at safety from the viewpoint of the type of workplace rather than the
type of hazard. Here are many of the most common workplaces and the typical hazards that may be
associated with them.
Office
People often think that offices dont have hazards, but they do, and they need to be addressed.
Consider the following:
Electric. With the proliferation of electronics, computers, monitors, printers, modems, and acces-
sories, its not unusual for a worksite to have strips of receptacles plugged into more strips. This
is, of course, an electrical hazard, and the cords may present a tripping hazard.
Passages, exits. As materials accumulate, its often the case that employees get careless about
keeping exits and passageways clear. With increased security, there is also a possibility of
doors being locked.
Housekeeping and cleanliness. Failure to sanitize work and food preparation areas can help
spread illnesses.
Tripping and falling. Slips and falls are typically caused by wet floors, open drawers, using
boxes and swivel chairs for ladders, etc.
Air quality. Many offices have closed ventilation systems.
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Ergonomics. A lot of carpal tunnel problems and similar aches and pains come from sitting
positions and keyboard and screen issues.
Stress. Dont forget stress, in these days of everyone expected to do more with less time.
Manufacturing
The safety issues for manufacturers are covered above in the sections on hazards in the workplace.
Maintenance
Maintenance workers are often exposed to many more hazards than employees who work all day in
one place. For example:
Hazardous substances. Cleaning and lubricating often involve the use of hazardous
substances. Workers must be aware of storage, handling, and disposal practices.
Lockout/tagout. Many maintenance functions demand lockout/tagout of machinery before
doing the work. Be attentive to the pressure to try to perform the maintenance without
locking out the equipment.
Clearing jams. These are always difficult challenges, because productivity is halted. Again, be
aware of lockout requirements.
Putting it off. If maintenance is done during normal work hours, supervisors may try to put it
off. Dont let maintenance get behind.
Retail
Retail seems a safe operation, but several aspects can be dangerous. For example:
Warehousing. Make sure employees are trained in the use of materials handling equipment.
Train to avoid high stacking. Be wary of cardboard-crushing equipment.
Violence. Some retail establishments are prone to robbery.
Shoplifters. Train employees in how to deal with shoplifting.
Medical Facilities
Sharps and bloodborne pathogens are some of the most obvious problems. Other safety challenges
include:
Oxygen and other gasses. As mentioned above, special rules govern the management of these
substances.
Controlled substances. Many medical facilities maintain stocks of controlled substances.
Employees who work with them regularly may not be as careful as they should be. Supervisors
must be aware of security requirements, and the possibility of theftand useby employees.
Lifting and back stress. Employees with patient care responsibilities are often put in a posi-
tion of trying to lift a patient without help. Lay down strict rules about these situations.
Food Service
Food service workers encounter their own set of hazards.
Hot food, hot stoves, hot cooking gear. Employees often work around hot items in often
crowded conditions, and often in a hurry.
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Slips trips, and falls. These hazards are particularly prevalent in food services facilities because
floors are likely to be slippery.
Knives. Food preparation tools are often sharp, and again, chefs are often in a hurry.
Machinery. Large mixing machines and other food prep equipment can be dangerous, espe-
cially if used by distracted employees.
Transportation
Transportation employers should be concerned about the following issues:
Driving within the laws
Fatigue from long hauls
Drugs and alcohol
Cell phones
Schools, Colleges
In school and university settings, theres clearly an extra pressure to take care of hazardous situations
quickly and to be extra careful concerning basic issues such as:
Fire protection
Housekeeping
Security
Violence prevention
OSHAs Special Industries Rules
OSHA has identified several industries for which it has developed special rules. These industries tend
to use highly specialized tools and procedures that present unique safety problems. These industries
carry the ever-present risk of accidents involving loss of appendages, electrocutions, and explosions. Take
baking, for example: The hazard of inhaling flour in bakeries has added another peril to an industry
that runs on ovens, mixers, cutters, and rollers.
The industries are:
Pulp, paper, and paperboard mills
Textiles
Bakery equipment
Laundry machinery and operations
Sawmills
Logging operations
Telecommunications
Electric power generation, transmission, and distribution
Grain handling facilities
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If you are in one of these industry groups, youll have this extra set of regulations with which to
comply.
Next Steps
By now you have looked at many records, youve conducted physical inspections and done hazard
analyses of individual jobs. And youve reviewed the long list of potential hazards to see which ones are
present in your facilities.
Of course, identifying the hazards is only the beginning. The next step is to work out a plan to elimi-
nate or control the hazards youve identified.
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Chapter 7
Eliminate or Control Hazards
Once you have identified the hazards, the obvious next step is to eliminate them or protect employees
from them. If your inspections have uncovered a large number of hazards, you may need to find a way to
rank them according to how immediate the threat is. Here is guidance on how to go about eliminating
or correcting hazards.
Preferred Solution: Eliminate the Hazard
Eliminating the hazard is generally preferable to using protective measures. Safetywise, its always
preferable, but other factors, such as cost and practicability, may mean that its not feasible. Consider the
following possibilities for eliminating hazards.
Move the Problem Up the Pipeline
Often you may eliminate a hazard by working with a supplier. For example:
Have the vendor do a trimming operation or cut to size before material is sent to your facility.
See if your vendor can supply a less toxic raw material.
Specify safety features on machinery when it is ordered.
Use Engineering Controls
Engineering controls are the next level of protection. Engineering controls manage the problem on-
site without the need for personal protective equipment. For example:
Use a soundproof enclosure or a muffler, or install sound treatment on ceilings or walls, to
eliminate a noise hazard.
Change a production step from a hand operation to an automated one.
Physically isolate the hazard, for example, by building a cage around a piece of machinery.
Install a power lifting device to avoid ergonomic problems.
Use machine mounted hands away systems such as a double activation switch that must be
operated by both hands.
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Try Administrative Controls
Sometimes a hazard may be eliminated through administrative means. For example, if there is a
hazard related to exposure to a certain situation for more than 6 hours a day, rotate employees in and out
of that work situation so that no one employee is subjected to the hazardous situation for that long.
Protect with PPE
If other techniques for controlling a hazard are not possible or not feasible, then protective equipment
is the next best solution. Its not as good a solution as the others because it requires the employees
cooperation to make it work, and employees often dont follow the rules. Why? Because PPE is often
viewed as uncomfortable, it makes it hard to see or manipulate objects, and it interferes with communi-
cation.
So whenever PPE is involved, there is a supervision component and a training component to consider.
See Subpart I in Appendix F for a checklist and training guidelines for PPE.
Deal with Behavioral Hazards
Behavioral hazards, such as the employee who wont wear PPE, and the fork truck driver who tries to
set lifting records, have a different set of solutions.
Why Was Procedure Not Followed?
First of all, when there is a behavioral problem, ask the employee, Is there a reason why the proper
procedure was not followed? Sometimes, its just laziness, but often, the employee has a good work-
related reason for not following a procedurea reason that you can deal with. For example, perhaps
following the rules requires a long trip to the far end of the facility and it takes so long that the
employees cant meet the daily production quota if they follow the rules.
Or perhaps a group of employees wont wear hearing protection because when they wear it they cant
hear each other, and they have to talk to run their operation.
These types of reasons call for a change in the procedure, rather than more training and discipline.
Training
Training is always the first, and a continuing, element.
Counseling
Counseling comes next, along with retraining, if employees do not use required PPE or they tend not
to follow rules.
Discipline
If counseling does not work, discipline must follow, up to and including dismissal. Supervisors must
know that they cannot ignore safety violations. They must consistently enforce safety rules.
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Mandate Start-Up and Daily Inspections
Another step toward identifying hazards is the before-the-shift-starts inspection. Particularly with
machinery and vehicles, this is important. Each workstation should follow a daily checklist so anything
thats going out of balance or loose can be adjusted immediately, before it causes a problem.
Recognize the Role of Maintenance in Hazard Control
Maintenance is another important part of controlling hazards, and its easily overlooked. Often equip-
ment that starts out safe, becomes less so as time goes on. The results of forgotten maintenancefor
instance, dull blades, parts out of alignment, loose belts, lack of lubricationall bring safety problems.
Poorly maintained machines are also more likely to jam, a dangerous situation, and youll also probably
ruin a lot more raw material.
Maintenance is another situation in which the urge for productivity may overshadow the need for
maintenance. Establish regular maintenance schedules and ensure that they are followed.
Develop Policies and Procedures
Policies, rules, and standard operating procedures help to promote safe behaviors. In many cases, a
hazardous task can be made safe by using a standard procedure. Employers working with employees,
and perhaps with outside experts, should develop these routines for hazardous tasks.
Policies, Rules, Procedures, Programs, Handbooks
Before we go on, we should define some terms that are often confused. Heres how we distinguish
between policies, rules, procedures, programs, and handbooks:
Policies. A policy is a general guide to an organizations philosophy on action and decision-
making designed to assure consistency and fairness within the framework of an organizations
objectives and philosophy. A policy may be very generalfor example, a policy calling for
safety first in all activities; or it may be more specificfor example, a policy on accident
reporting, lockout/tagout, or first aid. More specific policies often contain procedures and rules.
Rules. Rules are specific statements about what behavior is allowed (or not allowed) in a given
set of circumstances. A rule might state that safety goggles must be worn to operate a certain
piece of equipment. Rules may be incorporated into policies, procedures, manuals, or hand-
books.
Procedures. A procedure is a sequence of steps or a method for accomplishing an end result.
A procedure may consist of a series of steps or rules. For example, a procedure might detail the
steps for moving a substance from one storage container into another.
Programs. The term program is used to indicate the entire set of activities in the organization
that involve safety. A program might include training, incentive programs, safety meetings,
posters, and many other actions.
Manuals and handbooks. A handbook is a written document that presents the most impor-
tant parts of all the items above. It usually contains the general safety information that most
employees need to know rather than the specific rules that lathe operators, for example, would
need to know.
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Developing policies
A few words of caution for those developing policies and procedures:
Updating. Procedures can easily get out of date as materials and equipment change. You must
have a system for keeping them up to date.
Enforcement. Systems are meaningless unless employees follow them. Supervisors must be
attentive and make sure employees are not taking shortcuts or otherwise circumventing estab-
lished procedures.
Model policies
This book presents a substantial collection of sample policies in Appendix D: Along with the poli-
cies are discussions of considerations and points to cover.
Consider a Safety Handbook
Many organizations have found that a helpful tool in controlling hazards is their safety manual or
safety handbook.
Why Have a Safety Handbook?
In most organizations, the handbook has several roles. The primary role is to present safety rules,
procedures, and standards of conduct.
The role of the safety handbook often goes farther than this, however. In most cases, it also:
Serves as an indication of the importance the organization gives to safety.
Assists employees to remember and understand your safety regulations and procedures.
Gives a clear indication to outsidersjudges, juries, agency representatives, and contract
workersthat you take safety seriously.
Shows that your employees knew of your rules, or should have known of them.
Provides a clear reference if you must disciplineheres the rule, you knew about it,
you broke it.
Do You Need a Handbook?
Be completely sure you know why youre publishing a safety handbook before you proceed with
choosing topics, writing copy, and designing and producing your handbook.
Here are the most important usesthe whysof the handbook:
Present information. Presenting information is perhaps the most obvious and most basic
purpose that handbooks serve. As well see, the kinds of information presented can vary
widely, as can the depth of the treatment of each area. Adapt the handbook specifically to your
organizations needs.
Make employees feel safe. A safety handbook lets employees know that you care about their
safety and makes them feel safer about what they are doing. Handbooks are often taken home
by employees, and this results in further reinforcement with the employees family of your
organizations interest in safety.
Stress the importance of safety. As mentioned above, a lot of the safety job consists of
convincing your employees to act safely. The handbook will help stress that behavior and rein-
force it.
Save you time. Not only will you spend less time handling accidental emergencies and filling
out forms, but youll also save the time thats usually taken up by questions about safety.
Boost morale. Morale generally improves in a safety-conscious facility. Workers feel positive
about managements concerns over safety. They know that unsafe work practices will not be
allowed. When people know the rules, they can more easily see that discipline, if it is neces-
sary, is fair.
Meet legal and procedural needs. Finally, the handbook meets certain legal and procedural
requirements for your organization. The handbook provides a written record that the
employees know what the rules and policies are. This can be very important if you are subject
to suits or complaints about issues covered in your handbook.
What Should You Put in Your Handbook?
What should be included in your organizations safety manual? The answer is different for every
organizationeach has a unique combination of hazards circumstances. Therefore, no two safety hand-
books are the same.
Here are some points to consider:
Volume of material. Beware of trying to include too much. Beyond a certain point, using a
manual can become frustrating or seem like too much trouble to read or consult.
Ease of explaining or understanding. Some items may be so complex that you will decide
that you shouldnt include them in your handbook. In such a case, you might prefer to include
a summary statement that refers the reader to the right source, for instance, an appropriate
technical manual. Gauge your handbook material to the levels of reading and comprehension of
your target audience.
Frequency of change. Another thing to consider is how often the information changes. If
changes are frequent, you may want to include only general statements in the handbook that
tell employees where to go for up-to-date information.
Number of employees to whom it applies. If a safety rule applies to only a few employees, its
inclusion in the handbook may confuse them rather than clarify the issue. Try to cover only
topics that apply to a majority of employees.
Legal issues. Although most organizations would like to think of safety as a employee-oriented
issue, the facts are that in todays society legal problems can cause great difficulties. More
often than not, the onus is on the employer to ensure safe behavior. The handbook is part of
your overall statement about safe work conditions and practices. It shows the importance that
you attach to safety, and it shows that employees have access to safety knowledge. So the
handbook goes a long way to help show your good faith in encouraging safe behavior in your
workplace.
Typical Problems with Handbooks
Changes not recorded. A most difficult problem is to ensure frequent updates of any material
that changes. The original creation of a safety handbook is a project that everyone will support
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and encourage, but it is not as easy to find time and support for keeping it up-to-date. As an
aid, on the inside back cover list the number of copies printed and the date of the printing.
Not specific. Be as firm and definite as you need to be. Avoid phrases such as Employees are
encouraged to wear eye protection in the plant area. Be emphatic. For instance, All
employees will wear approved eye protection when entering the plant leaves little room for
misinterpretation.
Weigh the Benefits of an On-Site Medical Facility
For sites in which it is appropriate, OSHA suggests that a medical program that includes first aid on-
site as well as nearby physician and emergency medical care will help to reduce the risks associated with
any injury or illness that occurs.
Next Steps
Youve identified the hazards and developed ways to eliminate or control them. Next, you need to
train employees in their roles.
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Chapter 8
Train All Employees,
Supervisors, and Managers
Once the systems are in place to allow for a safe work environment, the next step is to train
employees in how to work safely.
In each organization, the content of the training and the extent of the training will depend on the
nature of the work to be performed.
OSHA mandates training for many types of hazards and for many types of situations. In addition,
there are a number of areas in which OSHA does not specifically mandate training, but sensible safety
practice requires it. To help you understand these requirements, this book presents several resources.
This chapter. Immediately below are discussions of general safety training considerations,
OSHAs Hazard Communication Standard, and OSHAs Voluntary Guidelines for developing
training.
Appendix E. In Appendix E you will find a master training guide.
Appendix F. In Appendix F you will find a discussion of training requirements and training
recommendations for many of the most common hazards and hazardous situations.
Cope with Training Challenges
Many of the techniques of safety and health training are just like any other kind of training, but there
are several key characteristics that make safety training a special challenge.
Job analysis is critical. Most trainers recommend a needs analysis before any training, but
with safety and health training this is particularly important. Careful attention must be paid
to finding out just what the employees duties are, and just what hazards are involved in
performing the jobnot only in the regular routine, but also what might happen if the job is
not performed safely.
Careful evaluation and testing is necessary. After training is completed, you must check to
see employees learned their lessons. You cant take a chance that a serious accident will occur
just because you failed to train properly or because an employee didnt understand.
Ongoing evaluation and motivation make it work. Just as important as being sure that your
people learned the lesson is being sure that they are putting it into practice every time they
perform the job.
Some forces work against safety. There are some natural pressures or forces in most work
places that push employees toward unsafe behavior. The most prevalent of these is pressure for
production. The safe way to do a job is often not the quickest one. (Until theres a lost-time
injury, that is.) Responsible managers know that sacrificing safety for speed is never the right
decisionnor, in the long run, is it the most productive. Other negative forces include
employee lack of interest, perhaps better described as lack of motivation, lack of correct
training, and distractions from the job.
Deal with Training a Diverse Workforce
Youre proud of your training youve just delivered, only to discover that many of the attendees dont
speak English.
Or you hand out a new policy, only to discover that many of your employees dont read. Or maybe
one is hearing impaired or blind.
These issues are real, but they are not an excuseyou have to train, no matter what the language or
literacy barriers.
What can you do? Here are some tips.
Speak slowly and clearly. Use simple words and short sentences. This helps those whose
command of English is limited, and also makes it easier for lip-readers to understand. One
example: more of the audience will understand may cause cancer than carcinogenic.
Use posters, videos, and other visual aids. These techniques are much more easily under-
stood by a broader range of audience members.
Demonstrate, demonstrate. Many safety procedures are easily demonstrated. For example,
putting on PPE or performing a lockout of a piece of equipment.
When many languages are present, you have a difficult challenge. To some extent you may be able to
get materials translated, but that gets expensive. Perhaps you have an employee fluent in English and
the other languages. That person may be able to help in preparing and delivering training.
Supervisory Training Tips
Supervisors may be reluctant to step up to be trainers, but its part of their jobtheyve got to do it.
Supervisors should be trained to understand the key role they play in job site safety. They need special
training to enable them to carry out their safety and health responsibilities effectively. Training
programs for supervisors should include the following topics:
How to analyze the work under their supervision to anticipate and identify potential hazards.
How to maintain physical protection in their work areas.
How to reinforce employee training on the nature of potential hazards in their work and on
needed protective measures through continual performance feedback and, if necessary, through
enforcement of safe work practices.
That their safety and health responsibilities are broader than those of workers. Supervisors must
be aware of safety requirements, be swift in enforcing, be alert to new hazards, and take action.
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Documenting Training
All training should be carefully documented. It can be a challenge, as much safety training isnt
conducted in a clean classroom where its easy to maintain records. Dont neglect documentation.
First of all, you want to be sure that each employee has received required training and that you know
when it happened so you can schedule follow-up or refresher training at an appropriate interval.
In addition, if there is ever an issue of liability, you want to be able to prove that employees had
training.
Your documentation should include dates, time, topic, brief description of the training, who deliv-
ered the training, and who attended.
Train After a Change in Equipment or Procedures
The workplace is constantly changing, and the training has to follow. Training is usually necessary
whenever new equipment is installed, when existing equipment is upgraded or changed, or when proce-
dures change. Never assume that employees will know what to do and what new hazards they face in
these situations.
Conduct Orientation Training
All employers should have some sort of immediate basic safety training. Naturally, this will be
different for employees in a New York high-rise, and a Midwest grain storage facility. Tailor your
training to what your employees face.
An important reason for early training: Statistics show that workers are most susceptible to injuries
during their first month on the job.
Typical Orientation Safety Topics
Safe practices and hazards in the new employees immediate work area.
What to do in case of a fire.
What to do if there is an accident or injury.
How to report emergencies.
How to report accidents and near misses.
How to report a workers compensation injury and file a claim.
Location of material safety data sheets (MSDSs).
How to care for and use PPE.
How to use tools and machinery and how to perform hazardous processes.
Housekeeping and personal cleanup rules.
Location of emergency equipment, first-aid supplies, designated smoking areas.
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Warnings About Unsuspected Hazards
It is particularly important to train new employees in hazards that are not apparent. For example:
Grain and sawdust storage. New employees have to know not to walk on top of grain as it
tends to dome, leaving a large open space under the surface. An unsuspecting first-day
worker could fall through and suffocate.
Machinery. Many types of machinery have places where it looks safe to reach in or to touch
some part, but at certain times during the process this is dangerous.
Intermittent actions. Some machinery stops and appears to be off, but its not, and can acti-
vate at any moment.
Naturally you have to figure out the specific hazards presented by your workplace, and develop orien-
tation training to address those hazards.
Specifications for Accident Prevention Signs and Tags
OSHA mandates signs for various purposes, and regulates sign design, the wording on signs, and
accident prevention tags.
Employees need early training to understand the color schemes of safety signs and tags. Although red
is generally associated with danger in nearly everyones mind, the warning intended by the use of other
colors may not be obvious to all workers. It is important to take the time to teach employees what the
different colors you use in your color-coding system mean in terms of the hazards and level of danger
they may face. It is equally important to be sure that your safety orientation program for new employees
covers your color-coding system and that all new employees become thoroughly familiar with the
system during their first few days on the job.
Red = Danger. OSHA recommends danger signs or tags be red or predominantly red, with
lettering or symbols in a contrasting color (usually white against the red background). Red is
also used for fire apparatus and equipment, safety containers for flammables, and safety devices
such as switches for emergency stopping of machinery, stop bars, and buttons.
Yellow = Caution. These signs and tags are all yellow, or predominantly yellow, with lettering
or symbols in a contrasting color (usually black). Yellow is often used for physical dangers such
as slipping, tripping, falling, striking against, and pinch hazards.
Orange = Warning. Orange, or predominantly orange, signs and tags generally have black
lettering or symbols. Orange is often used for potentially dangerous parts of machinery or
equipment that may cut, crush, shock, or otherwise injure a person.
Florescent Orange or Orange-Red = Biological Hazard. These signs and tags have lettering
or symbols in a contrasting color (usually black). This color designates infectious agents and
wastes that pose a risk of death, injury, or illness.
Green = Safety Instructions. These signs usually have white lettering against the green back-
ground. Some part of the sign may also contain black lettering against a white background.
Green is used to designate first-aid equipment, emergency eye wash stations, and so forth.
Florescent yellow-orange triangle with a dark red reflective border = Slow-moving vehicle
triangle.
Lets Get to It
Supervisorsunderstandablyare going to want to get a new employee productive as soon as
possible. Theres probably a backlog of work if someones been missing, and supervisors know the new
worker wont be as fast as the others for a while. So the tendency is to short-change the initial safety
training. Dont let it happen.
Implement OSHAs Hazard Communication Standard
OSHA has promulgated a hazard communication standard (HazCom) that applies to hazardous
chemicals. This is a broad requirement with which you must be familiar. Here is an outline of the
requirements of HazCom.
HazCom applies to almost every organization and employer covered by OSHA regulations.
HazCom applies to any chemical in the workplace to which employees would normally be
exposed under normal conditions or in a foreseeable emergency. Foreseeable emergencies
include control equipment failures and ruptures in containers but do not include chemical
releases resulting from accidental fires. HazCom covers both physical hazards (such as flamma-
bility) and health hazards (such as irritation, lung damage, and cancer). Most chemicals used
in the workplace have some hazard potential, and thus are covered by the rule.
HazCom requires all employers that manufacture, import, distribute, or otherwise use
hazardous substances to transmit the information about hazards to employees who work with
those substances through a written hazard communication program, labels, MSDSs, and an
employee information and training program. Use in this context means to package, handle,
react (such as introduce into a process), or transfer.
Special Rules
Conditions for exempting employees. Employees who handle hazardous substances in non-
routine, isolated instances are not covered for those chemicals. The instance of an office
employee who periodically changes the toner in a copying machine would not need informa-
tion or training under HazCom for the toner.
Laboratories. Laboratories and work operations where workers only handle chemicals in sealed
containers (marine cargo areas and warehouses) are not required to maintain a written hazard
communication program. They must, however, still follow HazCom requirements for
container or package labeling, availability of MSDSs, and provide information and training to
employees concerning chemical substances.
Exempt Chemicals
Hazardous wastes are exempt from the standard because there are special requirements for hazardous
waste workers. Other exempt products are those subject to labeling of FIFRA, TSCA, the Federal Food,
Drug, and Cosmetic Act, and the Consumer Product Safety Act. Chemicals covered under TSCA are
subject to the requirements of EPAs hazard communication rule.
The following specific items are also exempt from HazCom requirements:
Articles (manufactured item formed or shaped in a way that does not release or result in expo-
sure to a hazard under normal use)
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Tobacco or tobacco products
Chemicals in physical objects (e.g., plastic chairs)
Food sold in retail establishments or intended for consumption by workers
Drugs in a form available for retail sale or intended for consumption by workers
Cosmetics for the personal use of employees in the workplace or in a retail organization, pack-
aged for retail sale
Wood products. At one time all wood products were exempt from HazCom; however, now
only wood products that pose no hazard to employees, wood that has the potential for flamma-
bility or combustibility, or lumber that will not be processed are still exempt. Wood that has
been covered by a hazardous chemical or that will be subsequently sawed or cut and generate
any dust are specifically not exempt from HazCom.
Hazard Determination
The quality of the employers hazard communication program depends on the adequacy and accuracy
of the hazard assessmentin other words, employers must know which chemicals or substances in their
workplace are hazardous.
Manufacturers and Importers
Chemical manufacturers and importers must evaluate each chemical they produce for its potential for
adverse health effects or physical risks (such as flammability).
MSDSs and Labels
Manufacturers, importers, or distributors must provide labels and an MSDS to their customers for
each hazardous chemical at the time of the first shipment of the chemical. The MSDS must include the
substances ingredients, its chemical and common names, characteristics, physical and health hazards,
permissible exposure limits, and other factors. They must describe in writing the procedures they used
to determine the hazards of the chemical.
The MSDS is a single or multipage document prepared by the manufacturer or importer of a chem-
ical that describes the physical and chemical properties, physical and health hazards, routes of exposure,
precautions for safe handling and use, emergency and first-aid procedures, and control measures.
Labels
The purpose of labeling is to give employees an immediate warning of hazardous chemicals, and a
reminder that more detailed information is available. Containers of hazardous substances must have the
following information labeled, tagged, or marked on them before they are put into use:
Identity of hazardous substances.
Appropriate hazard warnings (a message, words, pictures, or symbols that state a specific harm
that may result from the chemical or substance, not just a generalized warning).
Name and address of chemical manufacturer, importer, distributor, or other responsible party.
Label descriptions must be in English, and may also be printed in additional languages.
Employers purchasing chemicals can rely on the labels provided by their suppliers.
Secondary containers, in which a substance has been transferred from its original manufacturers bulk
bottle to a smaller container owned by the user, must be labeled in the same way, except the name and
address of the chemical manufacturer, importer, distributor, or other responsible party is not required.
An MSDS may not be used as an alternative to a warning label. An employer must also make sure that:
A person is assigned to make sure all in-plant containers are properly labeled.
An individual is in place to make sure all shipping containers are properly labeled.
There is an alternative in-plant container labeling system in place.
A program is in place that keeps all label information up-to-date, all employees are trained to
read labels, and all labels are properly updated.
Chemical manufacturers, importers, distributors, and employers that become aware of any new
significant information about a chemical must revise existing in-plant labels within 90 days to reflect
the information. All shipments of chemicals to employers after the 90 days must contain new labels.
Labeling Alternatives
As an alternative to labeling all individual containers, employers can:
Substitute various types of standard operating procedures, process sheets, batch tickets, blend
tickets, and similar written materials for container labels on stationary process equipment if
they contain the same information and the written materials are readily accessible to
employees in the work area.
Post signs or placards that convey the hazard information if there are a number of stationary
containers within a work area that have similar contents and hazards.
Labeling Exemptions
Employers are not required to label:
Pipes or piping systems
Portable containers transferred from a labeled container intended only for the immediate
use of the transferring employee
DOT Labeling
Chemical manufacturers, importers, and distributors must ensure that each container of hazardous
chemicals leaving the workplace is labeled, tagged, or marked in a manner that does not conflict with
the requirements of the Hazardous Materials Transportation Act (49 CFR 173), administered by the
U.S. Department of Transportation.
Written Hazard Communication Program
Employers that use any of the hazardous materials identified above must maintain a written
hazard communication program. This program is the blueprint for HazComand it is the first
thing an OSHA compliance officer or inspector will ask to see. It does not have to be long or spell
out your program in detail, but it must be well thought out, clear, and comprehensive, at least
outlining all the parts of the program you are implementing. The written program should be
available to all employees.
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The written program should include the following HazCom components:
Participating personnel.
Methods the employer will use to inform employees of the hazards of nonroutine tasks (such as
cleaning reactor vessels), and hazards associated with chemicals contained in unlabeled pipes in
work areas.
Criteria for labels and other forms of warning:
Designation of person responsible for ensuring labeling of in-plant containers.
Designation of person responsible for ensuring labeling on shipped containers.
Description of labeling system used.
Description of written alternatives to labeling of in-plant containers, where applicable.
Procedures to review and update label information, when necessary.
Criteria for MSDSs:
Designation of persons responsible for obtaining/maintaining the MSDSs.
How the data sheets are to be maintained (e.g., in notebooks in the work area(s), in a pickup
truck at the job site, via telefax), procedures on how to retrieve MSDSs electronically,
including backup systems to be used in the event of failure of the electronic equipment, and
how employees obtain access to the MSDSs.
Procedures to follow when the MSDS is not received at the time of the first shipment.
For chemical manufacturers or importers, procedures for updating the MSDS when new and
significant health information is found.
Criteria for employee training:
Designation of persons responsible for conducting training.
Format of the program to be used (audiovisuals, classroom instruction, etc.).
Elements of the training program-check to see if the written program addresses how the
duties outlined in the regulation (29 CFR 1910.1200(h)(2), and 29 CFR 1910.1200(h)(3))
will be met.
Procedures to train new employees at the time of their initial assignment and to train
employees when a new hazard is introduced into the workplace.
Procedures to train employees regarding new hazards to which they may be exposed when
working on or near another employers worksite (e.g., hazards introduced by other employers).
Availability
The written hazard communication program must be readily available to employees, their designated
representatives, the Assistant Secretary of Labor for Occupational Safety and Health, and the Director of
the National Institute for Occupational Safety and Health (NIOSH).
Multi-Employer Worksites
A multi-employer worksite exists any time employees of different employers are on the same site
(e.g., a cleaning crew comes in to your workplace to do its job, or at a construction site).
Compliance by contractor. Any employer that hires the services of an outside contractor or
vendor is responsible for ensuring compliance by the contractor with the requirements of
HazCom if the contractors employees may be exposed to chemical hazards while working at
the employers facility.
Contractor-supplied substances. Each contractor bringing chemicals on-site must provide
the primary employer with the appropriate hazard information for these substances, including
MSDSs, labels, and precautionary measures to be taken when working with or around such
substances.
Hazardous Chemicals List
Employers must prepare a list of all hazardous chemicals in the workplace as part of the written
hazard communication program and check it against the appropriate MSDS. If an MSDS is missing, the
employer must get it from the manufacturer, distributor, or other source. The list will eventually serve
as an inventory of everything for which an MSDS is required.
Employee Information and Training
Employers must provide employees with effective information and training concerning hazardous
chemicals in their work areas at the time of the initial assignment and whenever a new hazard is intro-
duced into the work area. Giving employees MSDSs to read does not satisfy HAZCOM training
requirements. OSHAs requirements for employee information and training are flexible, allowing a
company to design a program tailored to its needs and operations. But training should at least cover:
An explanation of HazCom and its requirements.
The location of workplace areas where hazardous chemicals are present.
Where the chemical inventory, MSDS descriptions, written hazard evaluation procedures, and
written communications program will be kept.
A description of labeling systems.
How the hazard communication program is implemented, how to read and interpret labels and
MSDSs, and how employees can obtain and use available hazard information.
The hazards of chemicals in the work area.
How workers can detect the presence of a hazardous chemical.
The specific protective procedures the employer is providing, such as engineering controls,
work practices, and personal protective equipment.
The information and training must be specific to the kinds of hazards in the workplace and the
particular protective equipment, control measures, and procedures that are necessary. Training can be
accomplished in various ways, including audiovisuals, classroom instruction, and interactive video.
Training can be conducted or information provided by categories of hazard (such as carcinogens or toxic
agents), rather than by specific chemical. Training is required for new physical or health hazards, not for
every new chemical that enters the workplace. If, however, a newly introduced chemical does not fit
into an existing category, then training for that new chemical must be provided.
A general discussion of hazardous chemicals, for example, is not enough. This is a critical part of
HazCom, and if an inspector concludes the training is inadequate, a more rigorous review of the
companys entire compliance program will probably follow. An employer is responsible for evaluating
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an employees level of knowledge concerning hazards in the workplace and the hazard communication
program. This includes employees who speak a language other than English. According to OSHA
guidelines, if employees receive job instructions in a language other than English, then the training and
information conveyed under HazCom should also be presented in that language.
Trade Secrets
An employer may deny a request for disclosure of a chemical identity on the grounds that it is a trade
secret. However, under emergency situations and some other situations, this protection may be lost.
Use OSHAs Seven-Step Voluntary Training Guidelines
While there are many training systems available, we recommend that for safety and health training,
you follow OSHAs Seven-Step Voluntary Training Guidelines. The voluntary training guidelines are a
good place to start for several reasons.
The Seven-Step Guidelines get you off on the right foot. It cant hurt that you are basing
your training program on the suggestions of the agency that evaluates your compliance.
The Seven-Step Guidelines are sound. Training professionals and others agree that the
OSHA Guidelines are well-conceived and well-executed.
The Seven-Step Guidelines are flexible. In developing its programs, OSHA realized that each
worksite is a separate training challengeeach one has its own set of dangers and hazards.
Therefore, OSHA has left the details of program design to you, knowing that you are in the
best position to make the on-site hazard evaluation that will form the basis of your training
program.
The seven steps are:
Step 1Determining if Training Is Needed
Step 2Identifying Training Needs
Step 3Identifying Goals and Objectives
Step 4Developing Learning Activities
Step 5Conducting the Training
Step 6Evaluating Program Effectiveness
Step 7Improving the Program
OSHA Step #1: Determine if Training Is Needed
Whenever you approach a situation that seems to call for training, be sure to step back and ask your-
self whether training is the best way to handle the situation.
As OSHA says, the first step in the training process is a basic one: to determine whether a problem
can be solved by training. Whenever employees are not performing their jobs properly, it is often
assumed that training will bring them up to standard. However, it is possible that other actions (such
as hazard abatement or the implementation of engineering controls) would enable employees to perform
their jobs properly.
Ideally, safety and health training should be provided before problems or accidents occur. This
training would cover both general safety and health rules and work procedures, and would be repeated if
an accident or near-miss incident occurred.
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Problems that can be addressed effectively by training include those that arise from lack of knowl-
edge of a work process, unfamiliarity with equipment, or incorrect execution of a task. Training is less
effective (but still can be used) for problems arising from an employees lack of motivation or lack of
attention to the job. Whatever its purpose, training is most effective when designed in relation to the
goals of the employers total safety and health program.
Why Training Is Needed
There are three major reasons why training is needed.
Required by law. Some training is required by OSHA or other government agencies, so you
dont have any choice about providing it.
Hazards in your workplace. The first place to start identifying the hazards in your workplace
is with your accident records including near miss reports. Your OSHA Form 300s, your
MSDSs, job hazard analyses, and other records that your organization may maintain will point
clearly to the most common safety problems in your organization.
Dangerous work practices on the job. Finally, your observations may reveal actions and prac-
tices in your workplace that are dangerous.
Problems Training Cant Solve
A simple question to decide whether training will solve a problem: Could the employee do what
should be done if he or she wanted to?
When the answer is Yes, then training is usually not the answer. If the employee can do the job the
right way when he or she wants to, then training in how to do the job wont help.
Alternatives to Training
Any time youre not sure whether training is the appropriate measure to solve a problem, run down
this list to see if any other of these measures might be more effective.
1. Mechanical solutions
Change equipment so the worker has to do it rightmechanical devices can eliminate the
possibility of unsafe operation.
Alter the process or procedureother techniques for doing the same thing may be safer.
2. Motivational solutions
Motivational programcommendation to the employee or other motivational ideas
encourage desired behavior.
Reward for acceptable behaviorreward programs have been shown to be effective in
increasing safe behavior.
3. Supervisory solutions
Closer supervisionthe employee may need to be reminded of the safe practice.
More feedback from supervisorthe employee may not know how to do the job the right
way, or may need specific encouragement.
Training for the supervisorthe supervisor may not know how to get the idea across.
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4. Disciplinary solutions
Disciplinesome employees need to know that you mean business about safety.
Terminationultimately, employees who do not behave safely must be terminated. Their
continued employment is too dangerous to themselves and to their fellow employees.
5. Other solutions
Opportunity to practice skillespecially with new employees or new processes, practice
may be the best training.
OSHA Step #2: Identifying Training Needs
Once you establish that training is needed, identify specific training needs. Heres what the volun-
tary training guidelines suggest:
If the problem is one that can be solved, in whole or in part, by training, then the next step is to
determine what training is needed. For this, it is necessary to identify what the employee is expected to
do and in what ways, if any, the employees performance is deficient. This information can be obtained
by conducting a job analysis that pinpoints what an employee needs to know in order to perform a job.
Designing a Training Program
When designing a new training program, or preparing to instruct an employee in an unfamiliar
procedure or system, a job analysis can be developed by:
Examining engineering data on new equipment or the safety data sheets on unfamiliar
substances.
Analyzing the content of the specific federal or state OSHA standards applicable to a business
can also provide direction in developing training content.
Conducting a Job Hazard Analysis. This is a procedure for studying and recording each step
of a job, identifying existing or potential hazards, and determining the best way to perform
the job in order to reduce or eliminate the risks.
Using company accident and injury records to identify how accidents occur and what can be
done to prevent them from recurring.
Requesting employees to provide, in writing and in their own words, descriptions of their
jobs. These should include the tasks performed and the tools, materials, and equipment used.
Observing employees at the worksite as they perform tasks, asking about the work, and
recording their answers. The employees themselves can provide valuable information on the
training they need. Safety and health hazards can be identified through the employees
responses to such questions as whether anything about their jobs frightens them, if they have
had any near-miss incidents, if they feel they are taking risks, or if they believe that their jobs
involve hazardous operations or substances.
Examining similar programs offered by other companies in the same industry.
Who Should Be Trained?
As the OSHA guidelines point out, you cant train everyone on everything. Thats where the concept
of need-to-know comes into play. To make your training most efficient, train only employees with a
need to know:
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Employees who are required to be trained by regulation
Employees whose positions directly involve the actions the training is about
Employees who may reasonably be expected to be assigned to the job
Supervisors of such employees
Technical supervisors or technicians (maintenance department, quality assurance technicians,
etc., whose work takes them into potentially hazardous areas.
Create a MinimumTraining Requirements Grid
How do you determine what the minimum training requirements are? First, look at the different
groups of employees and the areas where they work. Identify what types of training each of these
groups needs.
Facilitywide. Everyone who works in the facility needs this training. An example might be
basic fire drill training, plant evacuation procedures, or hearing protection training.
Area. Everyone who enters a certain area (which might be a room or a space) needs this
training. This might be hard-hat training, respirator training, or confined space entry
training.
Chemical or substance. Everyone who works with or near this substance needs this training.
This might be for people exposed to lead, acrylonitrile, or working with chemicals that might
cause dermatitis.
Piece of equipment. Everyone who works with this piece of equipment needs this training.
This could range from a forklift to a complex stamping machine.
Next, identify when training is needed. Some is required immediately, while some may be able to be
delayed.
Construct a training grid, listing all the jobs down one side and all the training across the top. If your
organization is very large or very complex, you may not be able to construct one grid for all jobs.
Remember that the point is to get a handle on who needs training in what.
OSHA Step #3: Identifying Goals and Objectives
Next, youll want to identify the specific objectives of your training. Heres what OSHAs guidelines
have to say:
Once the employees training needs have been identified, employers can then prepare objectives for
the training. Instructional objectives, if clearly stated, will tell employers what they want their
employees to do, to do better, or to stop doing.
Learning objectives do not necessarily have to be written, but in order for the training to be as
successful as possible, clear and measurable objectives should be thought out before the training begins.
For an objective to be effective it should identify as precisely as possible what the individuals will do
to demonstrate that they have learned, or that the objective has been reached. They should also describe
the important conditions under which the individual will demonstrate competence and define what
constitutes acceptable performance.
Using specific, action-oriented language, the instructional objectives should describe the preferred
practice or skill and its observable behavior. For example, rather than using the statement: The
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employee will understand how to use a respirator as an instructional objective, it would be better to say
The employee will be able to describe how a respirator works and when it should be used. Objectives
are most effective when worded in sufficient detail that other qualified persons can recognize when the
desired behavior is exhibited.
Objectives are what guide you in your training program design. It pays to spend a little extra time
when you develop them. Consider the ABCD system for creating objectives: Audience, Behavior,
Condition, and Degree. It may help you to write objectives that make for truly effective program design.
Audience. The objective should identify the audiencewho is going to receive the planned
training?
Behavior. The objective should specify improved performancewhat observable action will
the trainee exhibit during the evaluation?
Condition. The conditions of performance should be specified. Under what circumstances
will the desired action be performed? What materials and equipment will be used? For
instance, is the task to be performed with protective equipment on? With power off? Can the
trainee refer to the manual?
Degree. The degree of accuracy or accomplishment should be specified. After training is
completed, how well must a task be accomplished or what score must be achieved?
Audience Analysis
Its important to know about your audience before you design a program. Here are some basic ques-
tions to ask:
What is the average age of the audience?
What is the age range of participants?
What level in the hierarchy do they represent?
What departments are represented?
What do they already know about the subject?
What is their educational background?
What are their expectations?
Will they be eager, hostile, or in between?
Resources Analysis
The other analysis is the resources analysis. This has two branches, the human resources and the
physical resources.
Human Resources
Who are the experts on this topic?
Who will provide administrative and clerical support?
Who will do research and design?
Who will produce materials for training?
Who will conduct training?
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Physical Resources
What rooms or spaces are available?
What audiovisual equipment is needed/available?
What samples or practice pieces are available?
What equipment must be used in place?
OSHA Step #4: Developing Learning Activities
In this step, you select and design the activities that will enable trainees to reach your objectives.
Youll also prepare any materials and training aids you need. Heres what the guidelines suggest:
Once employers have stated precisely what the objectives for the training program are, then learning
activities can be identified and described. Learning activities enable employees to demonstrate that they
have acquired the desired skills and knowledge. To ensure that employees transfer the skills or knowl-
edge from the learning activity to the job, the learning situation should simulate the actual job as
closely as possible.
For instance, if an employee must learn the beginning processes of using a machine, the sequence
might be:
(1) To check that the power source is connected;
(2) To ensure that the safety devices are in place and are operative;
(3) To know when and how to throw the switch; and so on.
What About Packaged Training Programs?
Its good common sense to consider programs that someone else has already developed. There is a
clear appeal to packaged or canned training programs, because it seems on the surface that you just
open the leaders guide, start the videotape and thats that. Its not quite so simple, but there are good
reasons to consider packaged programs.
About Training Methods
There are many training methods from which to choose. You will choose the ones that are appro-
priate for your situation based on your analysis of the audience and the material to be presented. Most
experts recommend that for adult learning, you use a blended approach, using many different methods.
For example, you might start people with a computer or Web-based training program, and then follow
up with a classroom session or individual coaching.
Here are some possible training methods:
Lecture
Role Play
Simulation
Case Study
Self-instructional
On-the-job
Discussion
Hands-on Training
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Choosing the Best Training Method
Here are some questions that you can ask yourself to help decide on the type of training to choose.
How many people need the training? Large groups may suggest lectures and movies rather
than individual training.
Can you duplicate the problem/item to be learned? For instance, a film might be good for
hazardous materials cleanup procedures, since you wouldnt want to create a spill.
How much money is budgeted? Limitation in budget can quickly dictate the type of training
you can afford.
How much time is available? How quickly must people be trained?
Who is going to do the training? Are experienced technical trainers available or are the
supervisors going to do the training?
What types of equipment are required for the training?
Is the training to help someone gain a skill, improve an attitude, or understand a concept?
Select the training that is appropriate for the task.
Audiovisual Materials, DVDs and Videotapes
Audiovisual materials can be used to enhance your presentation (for example, pictures of plant loca-
tions and equipment for a lecture) or they may be used to make the actual presentation of material (as
with a film on hazardous spill response).
Web-Based Training/Computer-Based Training
Whether through the Internet or off a CD-ROM, the computer screen is the featured partner in
many training programs being offered today. Computers are infinitely patient and calm. They work at
the students pace, whenever the student wants to work. With increasingly sophisticated graphics, they
are a more interesting tool than they were in the past. Often featuring built-in testing mechanisms,
they are an interesting possibility for individual training.
Note on PowerPoint
PowerPoint
slides seem to be everywhere, and they can enhance a presentation. However, they
usually cant demonstrate, so dont be fooled into thinking that because you have a file of slides youre
ready to deliver great training.
Lesson Plans
Lesson plans are a critical part of preparation for training. The lesson plan tells the instructor what to
do each step of the way. Your lesson plan will evolve from the activities you select. Its important to
take some time to finalize the lesson plan and to make it detailed. That ensures that you dont forget
any important items. It also means that someone else could deliver the training.
Participants Materials
You will generally want to prepare some sort of handout or takeaway for your training.
OSHA Step #5: Conducting the Training
To the extent possible, the training should be presented so that its organization and meaning are clear
to the employees. Employers or supervisors should:
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Explain the goals and objectives of instruction;
Provide overviews of the material to be learned;
Relate, wherever possible, the new information or skills to the employees goals, interests or
experience;
Point out the benefits of training (e. g., the employee will be better informed, more skilled,
and thus more valuable both on the job and on the labor market; or the employee will, if he or
she applies the skills and knowledge learned, be able to work at reduced risk); and
Reinforce what the employees learned by summarizing the programs objectives and the key
points of information covered.
OSHA Step #6: Evaluating Program Effectiveness
Evaluation of safety training is critical! Remember, the objective of training isnt to have a great
training session. The real objective is safe work practices on the job. Training isnt successful just
because people sit through itits successful if people learn from it and act safely and think safely back
at the worksite.
You know what the goals of the training are; devise a way to measure whether or not they have been
achieved.
Most training can be made more effective if there is a follow-up program. Some organizations check
in with trainees at some future point, while others have refresher courses to help people keep current
and improve on skills.
OSHA Step #7: Improving the Program
Based on your evaluations of the program, you will want to make any improvements that your evalu-
ation shows are necessary. Be on the lookout for changes in the job that require changes in the training.
New equipment, new procedures, new hazards appear every day. Make sure your training program
includes them. Heres what the guidelines say:
If, after evaluation, it is clear that the training did not give the employees the level of knowledge and
skill that was expected, then it may be necessary to revise the training program or provide periodic
retraining. At this point, asking questions of employees and of those who conducted the training may
be of some help.
Evaluation Questions
Were parts of the content already known and, therefore, unnecessary?
What material was confusing or distracting?
Was anything missing from the program?
What did the employees learn, and what did they fail to learn?
If a job analysis was conducted, was it accurate?
Was any critical feature of the job overlooked?
Were the important gaps in knowledge and skill included?
Were the instructional objectives presented clearly and concisely?
When the training was presented, was the organization of the material and its meaning made clear?
Did the objectives state the level of acceptable performance that was expected of employees?
Did the learning activity simulate the actual job?
Was the learning activity appropriate for the kinds of knowledge and skills required on the job?
Were the employees allowed to participate actively in the training process?
Evaluation Instruments
These usually include a pretest and a posttest and sometimes tests in between.
The pretest helps you to know that the training is necessary, and helps the instructor to pinpoint
areas where special help may be required. The posttest helps to determine whether the training was
successful, and identifies areas where training may be improved. Intermediate tests may be required in
longer training programs.
Next Steps
Now employees are trained. They know what to do. But will they do it? They may need motivation,
the subject of the next chapter.
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Chapter 9
Motivate Safe Behavior
It seems like you should be doneyouve identified the hazards, taught employees how to act safely,
and provided the means and methods to do so. All set? Surprisingly, in many cases, employees still act
unsafely. In fact, for many employers, safety motivation is the hardest part of safety management.
Face the Double Challenge of Safety Management
Its hard enough just to get the workplace safe for employees. It hardly seems fair that you also have
to struggle to get them to behave safely. But employees have proven, time and again, that they must be
motivated to have a safety-first attitude.
Start with Managers and Supervisors
Many front line managers and supervisors see safety as interfering with productivity, and so they
ignore, or even encourage, unsafe behavior if it gets the product out. Youll never have a safe workplace
with that attitude.
How can you get managers and supervisors on board for safety? Try the following:
Example. Senior management must support safety and let lower-level managers and supervi-
sors know that safety is important.
Evaluation. Make safety one of the goals of every manager and supervisor, and let them know
that, in part, their compensation depends on their success with safety.
Involvement in safety activities. Get them on committees, have them do investigations, safety
audits, etc.
The Productivity vs. Safety Argument
One expert says theres just one question needed to ascertain whether a company believes in safety:
Can an employee with a safety concern stop the production line? If so, you have a safety-conscious work-
place. If not, youre in a productivity-before-safety workplace.
Heres a typical productivity situation:
Your employee runs a machine that often jams. The safety protocol calls for turning the machine off,
locking it out, and then removing the jam. This takes a lot of time, and ruins all the raw material in
the machine. And, they wont make their quota. Since 99 times out of 100, employees can reach in
quickly and clear the jam without turning off the equipment, thats what they do. But eventually, that
1-out-of-100 accident is going to happen. And thats going to be expensive in many ways.
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Equipment will be sidelined, so any productivity gains will disappear quickly.
The trained specialist employee is going to be sidelined.
You and the supervisor are going to be sidelined with investigations, hospital visits, and insur-
ance agents.
OSHA is going to get involved and, if you were negligent, so will the courts.
Dont let the productivity argument even get started. Safety first.
Understand Why Accidents Happen
Of course, not all accidents are due to productivity issues. And most accidents are not due to a failure
in technical understanding. What does cause them?
Most are due to carelessness, horseplay, or ignorance of rules or ignoring safety rules and procedures.
Carelessness. Supervisors have to stay on top of this one.
Dont know of hazard. This is a failure of training, signage, warnings, or something in that vein.
Horse play. Employees like to have fun at work, and, within reason, in many workplaces,
thats OK. But horseplay has a way of escalating, and pretty quickly, it can be dangerous.
Again, youre counting on your, supervisors to keep this under control.
Tired and Bored. An experienced worker doing something for the 500th time loses
concentration and makes a mistake. How can you avoid it? If theres no flexibility its hard.
Consider rotating duties, quick minibreaks, or changing the activity in some way.
Purposefully ignore safety procedures. As weve mentioned, employees sometimes dont
follow safety rules on purpose. For example, they wont wear protective equipment because its
uncomfortable or interferes with doing the job . Or they wont wear hearing protection because
they cant hear shouted commands or warnings. Or they work without a safety guard because
they cant see their work well enough with the guard in place. Most of these problems can be
solved using new systems or making equipment changes.
Foster Motivation
Whatever the reason, there is a gap between desired behavior and actual behavior, even when people
are well-equipped and trained and disciplined. What works for motivation to close the gap?
Set an example
Talk about safety
Ask about safety
Reward safe behavior
Start meetings with the safety reportfirst thing on the agenda every meeting
Make sure employees know what to do, what are the expected behaviors are
Make sure that they are trained in how to do them
And then, theres the carrot and the stick. Try to motivate through incentive programs, and,
if necessary, with discipline and ultimately with termination.
Try Incentive Programs
Many employers find good success with incentive programs. In fact, there are a number of organiza-
tions in the business of providing incentive program materials.
Incentive programs are helpful because they focus attention on safety in a very direct way.
Typical Incentive Programs
Typical programs offer a reward of some kind for every quarter or year worked without a lost-day
accident.
What type of reward is given and to whom? This gets tricky. Some organizations offer one big
reward, for instance, a car. All the people in the safety pool get into a drawing and the winner gets the
car. However, many experts believe that all participants should get the reward when their unit achieves
the goals. That is, instead of one person getting a car, everyone would get, say, a $250 bonus.
Exercise Care
When implementing incentive programs, one must be careful. If the incentive is too greatvaca-
tions for the entire team in Bermuda or a free car for everyoneit starts to work against safety, because
participants will tend to not report accidents and injuries just so they can get the reward.
Similarly, with any group or team programs, one member of the team may feel peer pressurereal or
imaginedto keep quiet about near misses or accidents so the whole team will qualify for the reward.
Some organizations report success using on-the-spot rewards. Others have used safety buddy
systems, safety traffic tickets, and a host of other systems.
Two Observations
Pay close attention. Because programs can backfire if they are not balanced, its important to keep a
close eye on the effect the program is having.
Change programs often. Many employers report that they have to keep changing their motivation
or incentive systems. A program that works at first tends to get stale and lose its ability to motivate.
Discipline for Safety Infractions
Sometimes training, motivation, and gentle reminders, or even direct orders arent enough to get
workers to follow safety rules and procedures.
Discipline is the next tool, and you shouldnt wait too long to use it. Dont ignore dangerous
behaviorit will seem as though you are condoning it.
Progressive Discipline
Most organizations have some form of progressive discipline program, and this is the best course for
most safety violations.
Typically, progressive discipline programs feature an oral warning, a written warning, a suspension,
and ultimately, termination. Unionized organizations, and others, may have special rules for discipline
that should be followed.
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Document. Always document all disciplinary actions carefully, including the oral warning.
Be specific. Dont say Joe doesnt seem to care about safety. Say On July 12th Joe removed
the machine guard, or entered a confined space, etc.
Always focus on behavior, not attitude or character. This is the policy, this is the procedure,
you knew about it and you didnt follow the rule.
Install a Safety Committee
Safety committees are a key part of safety in the workplace. They accomplish several things.
Central focus. Committees that represent all functions or departments allow the organization
to take an overall look at safety requirements and to foresee problems that might otherwise
cause difficulties.
Sounding board. The committee is a visible and approachable body for safety or health
complaints, suggestions, and the like.
Central coordination. With management direction, much of the coordination of safety
training activities can be accomplished by the safety committee.
Management has the ultimate responsibilities for safety and health. Through its managers and super-
visors it establishes the program and enforces safety rules. But the safety committee can have an
important role in assisting supervisors with the success of that program.
An effective safety committee encourages safety awareness, gets a large number of employees
actively involved in the safety program over time, helps motivate employees to follow sound
safety practices.
An effective employee safety structure provides a feedback mechanism to identify and correct
new safety hazards at the earliest stage.
Once the safety committee structure is in place and working well, it is a natural vehicle for
employee involvement, preparation and introduction of new safety rules, new preventative
practices, and safety procedures on new equipment.
All organizations should think through the role of their safety committee, including:
What the responsibilities and duties of the committee are
How the committee helps management to enforce safety rules
How to report unsafe conditions and acts
How to handle safety suggestions
How to conduct safety inspections or tours
What the committee should not do
Be sure to spend time organizing the committee carefully. A safety committee left to its own devices
will contribute little to the local safety effort. Ideas and good motivation lose luster quickly if the
specific role of the safety committee in the safety and health program is not clearly defined.
What role should your safety committee have? This will vary from company to company or from site
to site. Here are elements to consider.
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Set a good example. Committee members must set a good example! Committee members
must be above average in their safe work habits and their positive attitude about safety.
Be visible. Names of safety committee members should be posted prominently in their
departments. They are the strong right hand to supervisors. Some companies also give safety
committee badges to identify their committee members.
Report unsafe conditions. What will the committees role be in reporting unsafe machinery
and conditions and hazardous acts? This will vary, depending on the size of your location, the
number of departments, and your organizations philosophy and policy.
For some organizations, safety committee members will report unsafe acts and conditions
directly to their immediate supervisor, the most usual and most effective way. At other sites,
the manager may have an open door policy, inviting committee members to come to him or
her with their suggestions. At other places, the committee members write up safety notices or
reports and give them to the safety committee for action by management. Whatever system
you use, train your safety committee members in what you want them to doshow them how
you want them to carry out their duties.
Conduct safety inspections. Many organizations utilize safety committee members to
perform safety inspections or plant safety audits. This is a wise choice, for these are the people
who know the work practices and the jobs on your siteand the inherent hazards in the work.
They know the safeand the unsafeway to perform the jobs. But assigning safety
committee members to do safety tours is only the starttraining them in how to do the
inspection task accurately and thoroughly is the next step.
Organizations that utilize safety committees effectively provide them with a checklist or audit
form, usually sub-divided by department or work unit. The form allows the inspector to focus
very specifically on unsafe conditions or unsafe acts. The best type of safety audit form usually
comes from those organizations who have developed a Job Hazard Analysis (JHA) for each job.
These JHAs, if well done, give your safety auditors the key elements in every jobthe unsafe
practices, the dangerous conditionsyou are likely to encounter on the job.
Investigate accidents. Depending on your safety policy, you may want to utilize the safety
committee to assist you in investigating accidents. At some locations the committee investi-
gates all lost work day accidents and reports the findings and recommendations to
management. For other organizations, safety members work jointly with supervisors to find
the causes of accidents. At still other companies, the safety committee at its regular meetings
reviews the results of supervisors accident reports.
Whatever approach you take, be sure that the role of the committee in investigating accidents
is made clear at the start and instruct the members in their role. Its good practice to investi-
gate both lost work day cases as well as near misses and minor accidents that could have been
more serious.
Hold regular meetings. Safety committees must meet formally (usually at least once a month,
sometimes biweekly), and for their meetings to be effective the following matters must be
considered:
Frequency of meetings
Selection of chairperson and a secretary
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A prepared agenda in advance of the meeting to:
Keep discussions on track
Allow members to prepare for the meeting
Serve as written documentation of efforts
Allow management to track efforts
Conduct safety training activities
Minutes:
Written summary of efforts
Names of attendees
Number of absentees
Responsibilities for implementation assigned
Timing of implementation assigned
Cost of implementation
Any approvals required
Completed recommendations
Uncompleted recommendations
Accident review
Safety training activities
Issued within 48 hours of the meeting
Sounding board. Be a sounding board for safety and health activities. Positive management
groups ask their safety committees to be sounding boards on proposals for new safety rules, devel-
oping the JHA changes or additions to PPE, participate in safety fairs and safety victory days.
Developing and Training the Committee
Who can assist you in your efforts to develop and train the local safety committee? The main respon-
sibility falls to site management who must conduct and set up the program. Yet there are others who
can assist in this responsibility. These include:
Safety consultants, either from outside the firm or from your workers compensation carrier.
They can assist in your safety training by providing talks, slides, filmsand above all his or
her experiences with other effective safety programs.
Vendors who sell products to the company will be interested in enhancing their sales position
by training in the use of their product or service. Typical vendors are forklift truck distributors
who will train employees in the safe operation of their equipment, chemical manufacturers who
will be enthusiastic about training operators and mixers in the safe handling of new chemicals,
and fire-fighting equipment suppliers who welcome the chance to give plant personnel hands
on experience with their fire-fighting equipment.
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Job Description of an Effective Safety Committee Member
The outline of duties for the safety committee in one organization reads like this:
Primary Function
To give your best efforts to make the department free from accidents and occupational health problems.
Duties
Work safely yourselfset the example in the department.
Attend and actively participate in safety committee meetings when on day or second shift. If
you are on third shift, notify your supervisor so that your alternate can attend.
Work with your supervisor to eliminate hazardous conditions and unsafe work practices in the
department. Speak to your fellow employees if you believe that they are engaged in an unsafe
work practice; report things that you feel you cant handle to your supervisor for further action.
Investigate with your supervisor recordable case injuries that occur in your department.
Participate in Plant Review Committee activities on lost work day case accidents or industrial
illnesses in your department.
Listen to employee suggestions about safety and bring those that appear to have merit to the
department supervisor for review.
Coordinate with your alternate to conduct department safety inspections in the first week of
each month, using the preprinted checklist as your guide. Each quarter participate with a
plant management member in a facilitywide safety audit.
Before each plant safety meeting, review minutes and open items affecting your department
and have answers or a progress report on each item for the meeting.
Wear your safety committee button at all times while at work.
Next Steps
By now youve got a safety program thats humming along. Now youve got to keep it humming.
The next chapter will help with that.
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Chapter 10
Manage Ongoing
Safety Responsibilities
Its a major step to get to the point where you believe that youve got a good safety program.
Congratulations. Now youve got to keep it going. Here are some of the important areas on which
youll need to focus.
Set Safety Goals, Evaluate, and Update
As the manager of safety and health, you have to take responsibility for setting goals for your
program and evaluating your progress toward those goals.
Goal Setting
You will probably set different types of goals. For example:
Accidents and lost work days. Some goals will relate directly to your programs success in
reducing or eliminating accidents.
Safety activities. Some goals may relate to the number of activities or their success. For
example:
Number of safety meetings
Number of job hazard analyses
Attendance at safety meetings
Number of training sessions
Percent of attendees rating the session good or better
Evaluation
If you have set good, measurable goals, your evaluation of your progress against the goals shouldnt
be difficult.
Youll find some evaluation also takes place as you perform audits. Youll see how many problems
you find.
Should you have a visit from OSHA (see below), youll experience another form of audit.
Revision and Updating
Sure, your safety program was fantastic when it was first developed. But if that was years ago, and it
hasnt been updated, thats a problem. Have all elements of your plans, policies, procedures, and equip-
ment kept up with changes? You need a regular maintenance schedule for all these safety-related items.
The stakes are too high to let yourself get into a situation where the emergency numbers dont work or
the MSDSs are missing.
Here are some things to check periodically.
Safety Training
Is all required training actually being given?
Are refresher courses given regularly?
Are new employees given training within a reasonable time of start date?
Have training materials been updated to reflect new hazards?
Handbooks, Policies, Procedures
Have they kept pace with any changes, any new equipment, new regulations?
Are all materials consistent?
Goals
Are they still valid?
Are they clear to all?
Agreements
If you have agreements with outside providers (for example, for emergency care), are they still
in effect?
Are outside partners aware of changes, new equipment, etc.?
Contacts
Are all contacts (for example, for emergencies, poison, hazardous spills), both inside and
outside, current?
Are they posted and available?
New Processes, New Equipment, New People
Be constantly on the lookout for changes. When there are new people, new equipment, new proce-
dures, there must be related changes in training, policies, procedures, and so on.
Perform Safety Audits
How often should you perform audits and what form should they take?
Of course each workplace is different. But in a workplace with significant hazards, its important for
workers to see a safety team often.
With this in mind, its probably better to do frequent, shorter audits than to do just one long and
detailed audit.
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Dont forget informal auditing. Whenever youre walking around the facility, keep an eye out for
safety.
The checklists in Appendix F will help you to construct an audit customized to your operations.
Manage Recordkeeping Requirements
Its no secret that OSHA has been cracking down on recordkeeping violations, as many employers
have discovered the hard way, with fines exceeding one million dollars.
Though the fines are often reduced on appeal, OSHA is making its point by coming down hard on
companies that fail to keep complete and accurate records of on-the-job illnesses and injuries.
Form 300 Is Just the Beginning
Most of the fines cited here were levied for illness and injury reporting, but thats not by any means
the extent of your recordkeeping responsibility. Many OSHA regulations require records of such
things as:
Training
Exposure to hazardous substances
Monitoring and testing
Inspections and maintenance
Medical surveillance
Hearing conservation
Recordkeeping is not just a defensive posture. Done correctly, it provides you with concrete proof
that you performed required actions, and it also gives you solid evidence that you are carrying your side
of the burden of trying to keep your workplace safe.
Recordkeeping isnt a way to avoid a fine, its a forecaster of potential safety problemsproblems
that could be very expensive and problems that are usually easy to fix as long as the cure comes in time.
Accidents are, of course, more than statistics. OSHAs point is that recordkeeping is the best way for
the Agency to uncover and deal with the safety violations that create many deaths, injuries, and illnesses
and to improve conditions to prevent future occurrences. Consequently, the Agency makes record-
keeping an important part of its inspection program.
Whether or not you agree with OSHA that recordkeeping compliance is a good way to improve
health and safety on the job, you may as well accept that this is the route the Agency is now taking.
The number of violations uncovered at some of the nations largest companies has increased the pressure
on OSHA to check and ensure compliance by all companies.
You can help your company stay in compliance, and out of trouble, by knowing exactly what has to
be recorded and which of those records OSHA and your workers have a right to use.
Other Recordkeeping Requirements
Although most of OSHAs highly publicized recordkeeping penalties have related to injury and
illness, those are far from the only records companies are required to maintain. You also need complete
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records on almost anything that relates to or proves compliance with occupational safety and health
regulations. For most employers, that includes:
A written hazard communication plan
A written contingency plan for emergencies
MSDSs
Hazardous waste manifests
Training records (who was trained, when, and in what)
Medical surveillance records (for asbestos, lead, and many other substances)
Air sampling or other monitoring results
Equipment testing and maintenance
Inspections of equipment, processes, and procedures
Respirator testing, training, and use
Noise exposure monitoring and hearing conservation program
Forklift operator evaluation and training
Hazard assessment for personal protective equipment
Many other records required by various OSHA regulations
Even when there is no clearly stated requirement, you may want to keep records of your health- and
safety-related activities. These will probably show your good faith in maintaining a safe workplace.
Worth the Trouble
It doesnt take long to keep up most of these records; youre probably gathering the information
anyway. But having them will not only help satisfy an OSHA inspector, but also promote your work-
place safety. The first step in any effective health and safety program is to keep good records and act
quickly on problems. By documenting your efforts, you can be sure that you have taken all the steps
necessary to make a safe workplace.
Right to Access Records
In addition to knowing what records to keep, you should be aware of who can review those records. In
general, any occupational illness and injury records must be presented, on request, to OSHA or other
government inspectors and to employees, former employees, and designated employee representatives.
OSHAs access is not limited to just medical data required by its own regulations. Inspectors can
submit written orders to see any company medical records.
Note: In a few recent cases, courts have required OSHA to produce a warrant for records, but this is
by no means the norm. OSHA will get to see the records eventually, so most employers would be wise
to produce them when asked.
Employees Rights to Records
Employees, their designated representatives, and OSHA have the right of access to relevant exposure
and medical records. Upon request, the employer must provide access to records within 15 working
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days. The employer must also copy, or provide facilities for copying, records at no charge. The records
may also be loaned to the employee or representative for a reasonable time to enable a copy to be made.
Exposure records consist of:
Records of the employees past or present exposure to toxic substances or harmful physical
agents
Exposure records of other employees with past or present job duties or working conditions
related to or similar to those of the employee
Records of exposure information for the employees working conditions or workplace
Exposure records of working conditions or workplaces to which the employee is being assigned
or transferred
If OSHA seeks access to medical information of identifiable employees, it must provide the employer
with a written access order. A copy of the order and OSHAs cover letter must be posted for at least 15
working days.
The employer may delete information constituting trade secrets if the party seeking access to records
is notified that information is deleted. When trade secret information is provided, the employer may
require the party seeking access to sign an agreement restricting the use of trade secret information.
An example of an authorization letter for release of employee medical records to a designated repre-
sentative follows:
I, (Employees Name)_________________________, hereby
authorize (Party Holding Records) _________________________________ to
release to (Designated Representative) ___________________________________________ the
following medical information from my personal medical records: (Give a general description of the
information to be released.)
_______________________________________________________________
I hereby give my permission for this medical information to be used for the following
purpose:______________________________________, but I do not give permission for any other
use or redisclosure of this information.
(NOTE: Several extra lines are provided below so you can place additional restrictions on this author-
ization letter if you want to. You may, if you choose, leave these lines blank. On the other hand, you
may want to 1) specify a particular expiration date for this letter (if less than 1 year), 2) describe
medical information to be created in the future that you intend to be covered by this authorization
letter, 3) describe portions of the medical information in your records that you do not intend to be
released as a result of this letter.)
____________________________________________
Full name of employee or legal
representative: ________________________________
Signature of employee or legal
representative: _________________________________
Date of signature: ______________________________
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Record Retention
Since many job-related illnesses, such as cancer, dont appear for years after exposure, OSHA also
requires companies to maintain records for long periods of time.
Specific records of an occupational injury or illness must be maintained for at least 5 years. Employee
medical records must be kept for 30 years after the employee leaves the company. Employee exposure
records, including records of monitoring in the workplace, must also be kept for 30 years.
Even if the employer goes out of business, the records must live on. If a new company takes over,
that company must keep the records. If the employer ceases to exist entirely, its records will probably
go to the National Institute for Occupational Safety and Health (NIOSH). Companies must notify
NIOSH at least three months in advance if they are going out of business and dont know what to do
with their records.
Penalties
OSHAs penalty for failure to keep injury and illness records, or for falsifying such records, is a fine of
up to $10,000 or up to six months in jail. Since that penalty can be imposed on each violation, the cost
of sloppy recordkeeping can add up fast.
Although many fines are reduced on appeal, they are rarely eliminated. And a company that has
failed a recordkeeping inspection once is likely to get repeat inspections, conducted in great detail.
Reducing Lapses in Recordkeeping
Why do recordkeeping lapses strike so often, even in well-managed organizations? We see five
reasons, and we recommend that you keep them in mind as you review your recordkeeping operations.
Laziness or lack of time. Even the best intentions can get swept up in the rush of production
deadlines. When a serious injury happens, time pressures get worsesomeone has to help the
injured employee, someone has to take over the work, someone has to repair the problem or
clean up the spill. Its easy to put off recording the incident, and then forgetting.
Unclear responsibility. It may not be clear who is supposed to handle recordkeeping responsi-
bilities. Or maybe the person is on vacation.
Poor training. People with responsibility may not be clear what constitutes a reportable inci-
dent or injury.
Desire to preserve a good safety record. This is all too common, even in organizations proud
of their safety records. That very pride makes people reluctant to enter an accident or injury
that will eliminate them from consideration for a reward or will hurt the organizations
chances for bettering an existing record.
Trying to get away with something. In some cases, organizations are flagrantly trying to side-
step the regulations, knowing that they have something to hide from the inspector.
In all of these cases, training and management involvement are the keys to keeping the program on
track.
Documentation Requirements
Following is the illness and incident information you must get in writing:
Employee deaths (no matter how long after the accident or illness they take place)
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Lost workday cases
Injury/illness that results in job transfer
Injury/illness that requires medication or treatment (other than first aid)
Injury/illness that involves unconsciousness or restricted work or motion
Diagnosed occupational illness (even if not diagnosed by a doctor and/or not requiring treatment)
Identity and quantity of a hazardous substance to which an employee was exposed
Identity of exposed employee and body parts affected
Medical treatment given to an exposed or injured employee
Action taken as a result of an injury or illness-causing incident
Conditions in the work area after these actions are taken
Recordkeeping and the Hazard Communication Standard
One of the purposes of a hazard communication program is to improve detection, treatment, and
prevention of occupational disease. To facilitate employees learning about the hazards they work with,
employers must keep certain records. These include:
An inventory of all hazardous chemicals in the workplace
MSDs
Training records (not required, but recommended as proof of training)
All of these records become part of the written hazard communication program, which is one arm of
the Hazard Communication Standard.
Records of Monitoring Exposure
Records of industrial hygiene monitoring must be maintained. These records would include
personal, area, grab, and wipe sampling, for example. They must be retained for 1 year, but the
sampling plan, results, and a description of the methods of analysis must be retained for 30 years.
Any records of biological monitoring to assess absorption of substances by the body must also be
retained for 30 years. Such records might include testing of chemical levels in the blood, urine, breath,
hair, or fingernails, for example.
Annual Reports
Many state right-to-know laws require certain information to be submitted to the state
Department of Labor or emergency response departments. This information may include:
An alphabetized inventory of hazardous substances used in the workplace
An explanation of the hazards these substances present
Plans or blueprints of the workplace showing where hazardous substances are kept and evacua-
tion routes
Manufacturers, importers, and employers should have little problem providing this information if their
inventory, MSDSs, and general safety records are kept up-to-date. If your state requires annual reports to
be submitted, it is a good idea to send them, by registered or certified mail, before they are due.
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Handle an OSHA Inspection
Inspectors usually arrive without advance warning during regular working hours. After identifying
themselves to the employer and explaining the nature and scope of the inspection, they will ask to see
records, machines, equipment, and hazardous materials. They can also privately question any employer
or employee.
If OSHA wants to inspect your workplace, it will. But there are rights that employers can exercise
although, as well see, it may not be to your advantage to do so.
OSHA Has the Right to Inspect
The OSH Act grants representatives of the Department of Labor the right to inspect any place of
employment in order to determine whether an employer is in compliance with the Acts safety and
health standards. However, such inspections must occur at reasonable timesthat is, during regular
work hours, within reasonable limits, and in a reasonable manner.
How OSHA Selects Inspection Sites
When should you expect a visit from a government inspector? Both OSHA and EPA are authorized
to inspect your facility at any time. However, it is likely that an inspection will be carried out for one of
the following four reasons:
1. Imminent danger. Imminent danger inspections are held within 24 hours of OSHAs deter-
mination that an imminent danger exists. Because of the potential hazard involved, employers
are alerted in advance by OSHA about these inspections. All other inspections are usually
unannounced. In fact, Section 17 of the OSH Act provides that individuals who supply
employers with advance notice of an inspection are subject to criminal penalties.
2. Workplace fatalities. A second category of OSHA inspections concerns the investigation of
workplace fatalities. Employers are required to report these to OSHA within eight hours.
3. Employee complaint. Approximately one-third of all inspections belong in this category
inspections OSHA conducts as a result of receiving a written complaint by an employee.
Complaints involving serious hazards are inspected within 5 working days, while complaints
involving other-than-serious conditions are inspected within 30 working days. No inspection
is conducted, however, if OSHA determines from the complaint that no violation threatening
physical harm or imminent danger exists.
Under the OSH Act, the agency is required to furnish the employer with a copy of the
employee complaint. However, the employees identity remains confidential and the employer
is prohibited from taking action against the employee because of the complaint.
4. Programmed inspections. The fourth category of inspections involves routinely scheduled or
programmed inspections of establishments in high-risk industries.
Safety. Facilities selected for programmed safety inspections are chosen according to both
industry and company lost-workday injury rates. OSHA has developed an establishment list,
which sets forth all employers within the jurisdiction of OSHA Regional Offices, listed
according to their Standard Industrial Classification (SIC) code. The various industries are
then ranked according to their lost-workday injury rates.
Health. Programmed health inspections are separately determined by OSHA according to the
agencys Health Inspection Plan (HIP). Under this plan, industries are ranked according to
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OSHAs assessment of the hazardous substances associated with the industry, the number of
employees exposed to the substances, and the severity of the potential adverse health effects
that might result from exposure to the substances. Establishments are then randomly chosen
for inspection from this list. Because OSHA does not believe that illness-incidence rates are an
accurate reflection of exposure to hazardous substances, neither industries nor particular
employers may be exempted from health inspections on the basis of low illness rates.
Prior to scheduling either safety or health inspections, each regional OSHA director modifies
the list by adding or deleting employers based on three criteria.
Number of employees. Employers will not be subject to any programmed inspection if 10 or
fewer employees have been employed during the past 12 months.
Recent safety inspection. Employers will not be subject to a programmed safety inspection if
a safety inspection has been conducted within the current or previous fiscal year.
Recent health inspection. Employers will not be subject to a programmed health inspection
if a health inspection has been conducted within the current or previous three fiscal years with
no serious violation cited or, where serious violations were cited, there has been documented
good-faith efforts to abate all serious hazards.
Your Rights When the Inspector Arrives
Among your rights, you may:
In most cases, refuse to let an inspector in without a warrant
Contest a warrant before or after the inspection
Limit scope of the inspection to complaint or warrant
Accompany inspector
Have an opening and closing conference
Contest a fine
Restricting the Scope of the Inspection
Employers are free to restrict the scope of their consent to the area that is the subject of the inspection
request. For example, if an inspection is based upon an employee complaint about the absence of
guardrails around a machine, the employer may limit a safety inspection to that area, thereby
prohibiting either a general safety or health inspection. Any inspection beyond the scope of the consent
will be considered involuntary and thus grounds for overturning a subsequent citation. Further, an
inspection will be deemed involuntary, even if the employer provided consent, when the employer has
been misled by representations of OSHA officials.
The Plain View Exception
Although the scope of the consent may be limited, employers should be aware that under the plain
view exception, any violations observed in an area for which consent has been given may be the subject
of a citation, even though outside the scope of the consent. Thus, for example, if an OSHA inspector
observes an imminent danger en route to the machine area you consented to have inspected, he may cite
your organization. A corollary of this doctrine is the open fields exception, under which a citation
based upon observations from open terrain will be upheld, even without consent or a warrant.
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Should You Request a Warrant?
When presented with a request for an inspection, an employer may either consent or request that
OSHA obtain a warrant prior to the inspection. According to some experts, a consent inspection is
usually the better choice. It is less troublesome, less costly, and more beneficial to the employer. But
others see it differentlyread on.
Warrant Based on Employee Complaint
An application for a warrant based upon an employee complaint probably will be considered by a
court as probable cause for an inspection. However, the inspection would be limited to the violations
that formed the subject of the complaint. The OSHA Review Commissionthe administrative judicial
bodyand several courts have adopted this position. On the other hand, some courts have permitted a
complete wall-to-wall inspection based upon a single employee complaint.
Warrant Based on Program
A warrant can be issued to support a general inspection based upon OSHA administrative procedures
for programmed inspections as long as both the procedure and its application to the employer are
explained in the warrant application. In addition to specifying the reason for the requested inspection,
an application for a warrant must describe the activities that OSHA intends to perform during the
course of the inspection.
Warrant Hearing
Under OSHA regulations, a warrant may be obtained ex parte, that is, without employer participa-
tion. Nevertheless, employers may request a hearing on a warrant application, because courts have
discretion to grant such a hearing. Moreover, even when an ex parte warrant application is granted, an
employer may challenge the propriety of the warrant before or after the inspection. The employer may
refuse to allow entry into the workplace and may contest the warrant either by moving to quash it or by
defending against the civil contempt motion OSHA will likely file.
Insist on the Warrant, Says One Expert
Heres the viewpoint of an attorney who recommends insisting on the warrant. The attorney, experi-
enced in OSHA inspections both with and without warrants, recognizes legitimate reasons for allowing
the inspector in the door without a warrant.
He suggests, however, that it is often to the benefit of the organization to insist on the warrant. Here
are his countervailing considerations:
1. The inspector may not return. In a good many cases, especially if the inspection is routine,
the inspector may just walk away for good.
2. The warrant may have a narrow scope. Many federal judges draw narrow warrants strictly
limited to the specific complaint alleged in the affidavit put before the judge. This scope may
be narrower than that accorded the OSHA inspector without a warrant.
3. Youll buy some time. The warrant wont be issued right awayin some cases inspectors wait
as long as 30 days. If you know of any existing hazards, youll have time to remedy them and
avoid a fine.
4. The risk is small. Because OSHA has little discretion in fining and citations, and because the
settlement process is the same regardless of whether a warrant has been issued, there is little
risk of greater penalty for those who insist on a warrant.
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So, what should you do? As always, it depends on your situation. We suspect that most organiza-
tions will let the inspector in, but it may someday help to know you dont have to.
Conduct of the Inspection
Once an OSHA inspector has been permitted to enter the workplace, either voluntarily or by means
of a warrant, the employer should carefully ensure that the proper administrative procedures are
followed and that the employers rights under the OSH Act are preserved.
The employer should be aware that any statement made or records provided to the OSHA
inspector may be introduced in a subsequent enforcement proceeding. Accordingly, the employer
should supply only information that is required to be maintained or provided under the OSH Act
or OSHA regulations.
Opening Conference
An OSHA inspector must hold an opening conference with the employer and, if appropriate, with
employee representatives. After presenting credentials, the inspector is required to state the nature and
purpose of the inspection and to supply the employer with a copy of any warrant or employee
complaint, if applicable. The employer should carefully review these documents in order to ensure that
the inspection remains within the limits of the inspectors authority.
Records request. The inspector may request other information concerning, for example, the nature of
the employers operations, or seek to examine safety and health records maintained by the employer. An
employer should provide only those records requested by the inspector and required to be maintained
under the OSH Act. Employee health records should not be disclosed unless adequate safeguards to
protect the privacy of the employee are provided.
Trade secrets. Employers should also be sure to inform the inspector of all areas that contain trade
secret information. Any information obtained by OSHA from an inspection of those designated areas
will be labeled as confidentialtrade secret so that unauthorized disclosure of the information will be
prevented. Following an inspection, an employer should contact OSHA to ensure that the trade secret
information is maintained in a confidential file. Although disclosure of trade secret information gener-
ally will be limited to OSHA employees, the information may, if deemed relevant, have to be produced
in judicial or administrative proceedings.
What Can You Expect?
What can employers expect on-site when an OSHA inspector arrives? Here is what is likely:
OSHA and EPA inspectors usually know what theyre doing and what to look for. They are not only
trained in their jobs, but do homework on your company before they arrive. They will generally have
reviewed your accident and medical records on file with the government, as well as the records of the
hazardous materials you use and previous inspection reports.
In addition, inspectors will look at employer records and reports on work-related deaths, injuries, and
illnesses that resulted in medical treatment or work restriction or transfer.
Records review. Inspectors will review the OSHA 300 form and supplementary forms
including possible workers compensation claim forms and employee medical histories.
They will check records of employee exposure to potentially harmful materials, safety training
programs, manifests, chemical labels, and posted notices of hazards and safety precautions.
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Personal protective equipment. Inspectors will check on the use of PPE at the facility, the
training of employees to wear that equipment, and the enforcement of its use on the job.
Machinery. The inspector will check the machines, equipment, and hazardous materials in
your workplace to see that they are in compliance with the law.
He or she will look at how you store and handle hazardous wastes and materials, and will
check storage containers to see that they meet legal standards.
Workers. Inspectors will observe workers to see that they are following safety procedures and
are wearing and using required PPE. They may also ask the workers questions that directly
relate to the purpose of the inspection.
HazCom check. Inspectors will check on compliance with the principal elements of the
Hazard Communication Standard. To ensure that the employer has an effective hazard
communication program, the inspector will conduct employee interviews and document their
responses. The compliance officer will confirm that a written hazard communication program
does in fact exist, that there is an inventory of hazardous chemicals used at the site, the exis-
tence and availability of MSDSs in the work area, the labeling of in-plant containers and the
labeling of containers received from suppliers. Particular attention will be given to the effec-
tiveness of required training, using the employee interviews as a guide.
Overall safety and health program. The employers overall safety and health program will
also come under review and other specific programs (fire, respiratory equipment, etc.) will also
be reviewed. For example, a respiratory program, if required, and other personal protective
equipment programs may be evaluated. Deficiencies are to be identified and reported.
Walk-through. Both the employer and employee representatives have walk-around rights to
accompany the inspector during an inspection, although employees need not be paid by the
employer for this time.
Note that an employer is not obligated to demonstrate the operation of any machinery or
processes.
The inspector will bring OSHAs own testing equipment and may take photographs of any
relevant plant equipment and procedures. He or she will probably take samples of air, water,
and soil to see that hazardous material exposure levels fall within legal limits.
Employees may be asked to wear air sampling pumps, badges, noise dosimeters, or other
sampling devices for specific periods of time so that the inspector can measure the levels of
harmful substances in the work environment.
Mimic the inspector. During the inspection, an employer should perform the same activities
undertaken by the inspector, for example, conducting both air and personal monitoring, taking
photographs, and taking notes of the types of measuring instruments and procedures utilized by
the inspector.
Closing Conference
After the inspection, the inspector will conduct a closing conference with the employer and employee
representatives. During this conference, the inspector must advise the employer of any violations
observed and explain and provide copies of the regulations allegedly violated.
In addition, the inspector must describe abatement requirements, including suggested methods of
abatement and time periods within which to accomplish abatement of all alleged violations.
The employer should not make any statements during the closing conference that could be consid-
ered an admission of the violations at issue or could be construed as a limitation of the employers right
to contest the citation. Admissions of liability may be used against the employer in later enforcement
proceedings.
Citation, Conference, Contest
After the inspection, the inspector will summarize the findings to the employer, and informally
advise the company of any problems.
If an inspector finds unsafe exposure levels, unsafe equipment, or anything that he feels poses immi-
nent danger to employees, he can, after informing the employer and affected employees, take steps to
eliminate the problemincluding ordering evacuation of the area.
The findings and recommendations of the compliance officer are reviewed at the office of the OSHA
area director, who will issue the citations if they are appropriate.
Penalties will be imposed shortly thereafter. Immediately upon receipt, employers are required to
post citations in the plant, and have 15 working days to contest a citation or penalty.
After the issuance of a citation, the area director of the OSHA region in which the employer is
located will hold an informal settlement conference if requested by the employer. The purpose of the
informal conference is to discuss the citations, including the existence of a hazard and the amount of
proposed penalties and abatement requirements, in the hope of resolving the matter without litigation.
To reach settlement agreement, the area director has the authority to modify penalties, abatement
actions, and dates, and characterizations of violations (willful, serious, etc.). If no settlement can be
worked out, the employer may file a notice of contest with 15 working days of the receipt of the cita-
tion, in order to initiate the administrative litigation process. (Or, of course, pay the fine.)
Civil and Criminal Penalties
Section 17 of the OSH Act provides for the issuance of civil and criminal penalties ranging, for
example, from $7,000 for each violation for a nonserious (other) type of violation to 6 months impris-
onment for falsification of records. Of particular importance is the statutory provision for the issuance
of either a serious or willful violation because these types of violations frequently form the basis of a
citation.
Under the OSH Act, the Agency is instructed to issue a serious violation if there exists a substan-
tial probability that death or serious physical harm could result from a condition and that the
employer did not and could not, exercising reasonable diligence, know of the violation.
As for a willful violation, the OSH Act fails to define the term. OSHA, however, has defined the
term to include circumstances in which the employer committed an intentional and knowing violation
of the Act; was aware that a hazardous condition existed, and did not make a reasonable effort to
eliminate the condition; and/or was aware that a condition violated a standard or other requirement of
the Act and was aware of the standard or other requirement violated.
Dealing with Inspectors: How to Handle Yourself
Dealing with investigators requires balance and common sense. Never lose sight of the fact that they
are professionals, and that they are looking for information that may not make you or your company
look good. On the other hand, inspectors are doing an important job, protecting the health and lives of
your co-workers and neighbors. Keep the following guidelines in mind.
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Call the designated representative. Almost every company has a specific representative desig-
nated to meet and accompany any inspector who might come to your facility. Find out now
who that individual is in your company. Keep his or her name and telephone number where
you can always find it, right with the rest of your contingency-plan materials. When an
inspector arrives, contact your representative immediately.
Never be rude. Even when you think that you should not cooperate, be polite, but firm.
Personal animosity will only make a bad situation worse.
Be cautious. Never volunteer anything. Never grasp at an opportunity to put yourself or
your employer in a good light. Why not? Think about it. How often have you listened to
people talk themselves out of a job by responding too carelessly to your carefully crafted ques-
tions? The same could be true in this case. Choose your words carefully.
If in doubt, you can refuse to answer or cooperate. In most cases, you can ultimately be
compelled to respond, but many times the matter will not be pursued. If it is, youll have
time in the interim to consult with counsel as to the best approach.
What will trigger an expansion to a comprehensive inspection?
The inspection will be expanded from a partial tour to a comprehensive inspection, following consul-
tation with the area director, based on the following factors:
Lack of a comprehensive safety and health program. OSHAs field operations manual guides
compliance officers to evaluate the employers safety and health program, whether written or
not, along the following lines:
the degree to which the employer is aware of potential hazards present in the workplace and
the methods used to control them
plans and schedules the employer has to implement engineering or administrative controls
emergency control and evacuation procedures
programs for the selection, use, and maintenance of personal protective equipment.
Significant deficiencies. The inspector will look for significant deficiencies in specific
programs such as respiratory protection, hazard communication, fire protection, and wire-rope
inspection for cranes.
Serious violations of standards. The inspector will note serious violations of safety and health
standards uncovered during the plant tour.
There are concentrations of injuries or illnesses in specific areas of the plant.
There has been a significant past history of serious safety and health violations at the plant.
Appeals
It is important to remember that should an OSHA inspector issue your firm a citation, all is not lost.
OSHA regulations provide an opportunity for management to negotiate or contest the alleged violations.
Informal Discussion. When issued a citation or notice of a proposed penalty, management
should give careful consideration to the option of requesting an informal meeting with the
OSHA area director to discuss the case. The area director is authorized to enter into settle-
ment agreements that revise citations and penalties to avoid prolonged legal disputes. Area
directors can be more responsive to management arguments than OSHA inspectors since the
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inspectors dont have the authority to settle. Therefore, the informal talk often helps to make
this course of action well worth considering.
Notice of Contest. In addition to an informal meeting with the OSHA area director, manage-
ment can formally contest a citation, the time set for abatement of the alleged hazard, or the
proposed penalty. This so-called Notice of Contest must be submitted to the OSHA area
director in writing within 15 working days from the time the citation and proposed penalty
have been received from the inspector. OSHA officials stress that an oral expression of
disagreement will not suffice.
Involving Your Attorney. You should consult your attorney before proceeding whenever the
stakes are high, or might be, or if you are not experienced in the appeals process.
Investigate Accidents
One of the best ways to prevent accidents is to investigate the causes of the accidents that do occur.
A prompt, thorough investigation of any incident, large or small, including near-misses, is an important
part of any good safety program.
In some ways, a good investigation of a workplace accident resembles a police investigation of a
crime. You try to get in and check the scene before anything has been moved or changed, and you try
to assemble the evidence and interview the witnesses while the experience is still fresh in their minds.
However, youre not looking for a criminal or trying to blame the accident on anyone. You are trying
to find out what happened, why it happened, and how you can prevent another similar accident from
occurring.
Employee Cooperation
As part of routine training, brief employees on your accident investigation policy. They need to
know that their cooperation wont result in discipline or other punishment.
Teach employees to:
1. Always report any accident or near-miss immediately
2. Cooperate with all investigations of any accident in which you were involved, which you
witnessed, or where your knowledge of the situation or procedure could be helpful.
Investigation Priority
Investigate accidents in the order of their seriousness. Obviously, an accident that causes a death is
the first order of priority. After that, the order of seriousness is accidents that result in:
Days away from work
Restricted ability to work
Medical treatment
First aid treatment
Near misses
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Near Misses
Investigate all accidents and near-misses, not just the incidents where people get injured and which
have to be reported to OSHA. Near-misses are warnings that help us identify problems and patterns
that can lead to more serious accidents. By following through on the causes of near misses, we can make
changes or corrections that will prevent injuries, illnesses, or damage to equipment.
Whats a near miss? Just about anything that makes you say whew, that was close. If you slip on
spilled liquid but dont fall, thats a near miss. Its a near miss if a box falls off a high shelf but doesnt
hit anyone. If your sleeve catches in a machine but you get it out without getting hurt, thats a near
miss, too.
Identifying Hazards
A good accident investigation is aimed at discovering what happened, what caused it to happen, and
why, and how to prevent future occurrences. The investigation tries to identify the hazards that led to
the accident and any other related hazards that could lead to accidents in the future.
Investigators approach it like a good detective or investigative journalist, trying to answer these
questions:
What happened?
When did it happen?
Where did it happen?
Who was involved?
How did it happen?
Why did it happen?
How can we keep it from happening again?
Investigate Immediately
To get complete answers to these questions, its best to investigate immediately after an accident.
Often, more than one factor contributes to an accident, so be thorough and not miss anything that could
be important.
Take Care of Medical Treatment First
When theres an accident, the first thing you do, of course, is to make sure that anyone whos injured
or ill gets proper medical treatment. If theres something like a spill or leak, it has to be stopped before
it spreads. In some cases, we may have to barricade or rope off an accident site to keep people from
harm and to preserve the evidence.
Leave the Scene Untouched
But aside from taking necessary actions like these, its best to leave the accident scene untouched so
you can study the evidence. If, for instance, there was a spill, you would want to check the evidence to
find out what spilled, where it spilled from and where it went. If a machine was involved, you want to
be able to check the settings and materials in the area and whatever else might be relevant.
In a more serious accident, you might have to take measurements of the area or even take photos or
videos of the accident scene to be studied later.
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InterviewWitnesses
Another thing to do early in the investigation is to interview people who were present when the inci-
dent occurred or who know something useful about the operation, machine, substance, etc. in question.
One at a time. Usually, witnesses are interviewed one at a time right after the incident, often
at or near the place where it happened so they can point out or show what theyre talking
about.
Right away. Try to get eyewitness reports right away in order to get immediate impressions of
what happened before an eyewitness has a chance to confuse it with other similar incidents or
with what other people say.
Not a trial. These interviews are not intended to put anyone on trial or to find someone to
blame. Theyre strictly for the purpose of getting as many facts and as much information on
what happened as possible. You may be asked to describe what you saw or heard or experi-
enced. You may even be asked to act out how it happenedwithout, of course, repeating the
accident itself.
Typical Questions
What time did the incident occur?
Exactly where did it occur (for instance, at the X machine on the east end of room Y)?
Who was injured or made ill and what was the type and severity of the injury or illness?
How did the accident occur? What were the people involved doing before it happened?
What materials or machinery or substances were involved or in the area? What led up to the
accident, and what exactly happened during the accident?
The answers to these questions will usually involve a sequence of events. For example, a
worker turned on a saw, put in a piece of wood, a blade broke, and pieces of wood flew out and
injured a worker at the next machine.
What task was an injured person performing and was that his or her regular job?
What actions were taken after the accident?
Who witnessed the accident and what were they doing?
Protection Against Hazards
Since the purpose of accident investigation is accident prevention, getting the facts is just the begin-
ning. You have to use the facts to find out why the accident happened and then what can be done to
prevent future accidents.
This can be easier said than done. Many accidents have more than one cause. And sometimes what
seem to be causes are actually symptoms of the real problem. Just like sneezing is a symptom, rather
than the cause, of a cold, an unsafe act that led to an accident may be a symptom of inadequate training.
Or an accident that appears to be caused by a missing machine guard may actually be caused by a
machine thats not working properly or by poor machine design or workplace layout that led someone to
remove the guard. In cases like these, we have to deal with the symptoms and the underlying causes.
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Patterns
When you keep track of all accidents and their causes, you can often identify patterns.
If a number of people injure their backs lifting boxes, you may need more specialized training
on how to lift properly and/or more material handling equipment to reduce the need for
manual lifting and/or boxes of a different size or shape that are easier to handle.
If you have several near misses involving spills from similar containers, you may need to
consider switching to a safer kind of container or finding a new way to remove liquids from
those containers.
Administer Workers Compensation
Even if workers compensation isnt directly under your supervision, its an important part of what
you do, because its often the most important benchmark for safety progress. Its probably the most
dramatic means for showing that a safety program contributes to the bottom line.
What Is Workers Compensation?
Workers compensation is a type of insurance that covers employees who are injured or who become
ill as a result of performing their jobs. Each state has a workers compensation law governing the
amount of the payments made to eligible employees and detailing the circumstances under which cover-
ages become available.
The employer is responsible for paying workers comp premiums, and premiums are often adjusted to
reflect the frequency of the companys claims. It is to every employers advantage, therefore, to publicize
the link between high workers comp premiums and accidents on the job.
Workers compensation can be complex. What happens, for example, if an employee is injured in an
automobile accident after working hours while out of town on company business? What if an employee
is injured while participating in a company-sponsored recreational activity? What if an on-the-job acci-
dent can be traced to employee misconduct? It is vitally important that you study your state workers
comp law carefully before sitting down to hammer out a policy statement for your organization.
What Workers Compensation Covers
Although workers compensation is governed primarily at the state level, states are generally similar
in the type of coverage they offer.
Typically, workers compensation covers the cost of medical care including rehabilitation and
needed medical equipment such as crutches or artificial limbs.
Cash payments are usually made during the period employees are unable to work.
Calculations of this amount, dates, and duration vary from state to state, as does the effect of
other types of payments.
A death benefit is typically paid to survivors of employees whose death is job-related.
In cases of pre-existing injuries or second injuries, former employers or the state fund may pay
part of the cost of treatment.
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Exceptions to Coverage:
In most states, there are certain circumstances in which payments will not be made. Typically not
covered, for example, would be:
Willful acts of the employee
Injuries resulting from intoxication
Injuries resulting from fighting
Going and coming injuries. Typically, injuries sustained while en route to and from work
are not covered, unless the worker is performing some errand related to work.
Generally, when employees are injured, they file for workers compensation and the workers compen-
sation agency pays their bills. Employers pay into the program based on their claims history.
Workers Compensation Policy Points to Ponder
The basic points a policy statement on workers comp might cover are listed below.
Applicable state law. You may want highlight coverages for industrial injuries and occupa-
tional illnesses, waiting period in the state before benefits are paid, and the current amount
of weekly indemnity benefits paid.
Benefits. What are the amounts of workers comp benefits? How are payments calculated?
What are the limitations on the amounts that an employee can receive?
Exceptions. There are exceptions to coverage. For example, injuries incurred in an accident
that is due to an employees intoxication or flagrant abuse of work rules may not be covered.
Claim procedures. What are the procedures that must be followed when an employee is
injured on the job? These can be broken down into two parts: the responsibilities of the
supervisor and the responsibilities of the human resources department or the person in the
company who is in charge of dealing with workers compensation claims. What forms are
required, who completes them, where they go?
Maintenance of other benefits while on leave. If an employee is out of work for an extended
period of time, will the company continue to maintain his or her participation in other benefit
programs? If some of these benefits require an employee contribution (for example, health
insurance), must the employee pay this out of his or her workers comp benefits or will the
company pay the full amount for the duration of the leave? If the employer advances the
employees regular salary while on injury leave, what arrangements are made to turn over
workers compensation payments to the employer?
Procedures governing return to work. If an employee is out of work for an extended period of
time, will his or her old job be kept open? What medical check is required before the
employee is permitted to return to work? What if the employee is able to return to work but
is no longer physically able to handle his or her old job?
See a sample workers compensation policy in Appendix D.
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Consider Light-Duty Programs
Given the variety of state and federal laws that require employers to give employees time off
from work, and given benefits such as short-term disability and workers compensation that provide
compensation to employees who are off from work for certain injuries, many employers are developing
programs that require employees to return to work at light duty jobs. These policies need to be
designed to comply with the Americans with Disabilities Act (ADA) and the Family and Medical Leave
Act (FMLA).
Essentially, employers are requiring employees who are able to work to return to part-time or tempo-
rary positions rather than providing benefits for paid time off under short-term disability, long-term
disability, or workers compensation.
Such policies can be used to reduce the abuse of leave policies by employees. Furthermore, if the
employee truly does not wish to work, a return-to-work policy provides a mechanism to classify the
employee as having abandoned the job. By creating a consistent system of policies regarding return to
work, employers can guard against discrimination claims. The following material will aid you in
designing your policy.
General policy. Employers should require employees on a leave to routinely report their
status. For example, have they been released for light duty?
Definitions. Terms such as light duty should be defined. Does that mean fewer duties?
Fewer hours? Both? You may want to use other terms, such as reduced duties to indicate
the position has fewer duties or restricted duties to indicate that the job entails less stren-
uous duties. Reduced hours can be used to describe fewer hours or intermittent hours.
Physical examinations. The employer should require employees to submit to a medical exam-
ination, paid for by the employer, to confirm that the employee is not available for any type of
work. If an employee is released to light duty and the employees physician refuses to
provide adequate information regarding the work restrictions, the employer should have the
right for its own physician to examine the employeeat the employers costto establish any
work-related restrictions.
Detail restrictions. Your policy should provide that the employee has a duty to advise you of
any restrictions. You may need to give the individuals job description to his or her treating
physician and ask the physician to indicate which activities cannot be performed or if there are
limits on any activity.
Coordination with other policies. The return-to-work policy should be coordinated with
such policies as required by the ADA and FMLA. For example, under FMLA regulations, an
employer cannot require a physical examination more often than every 30 days. Additionally,
the return-to-work policy should be coordinated with any short-term or long-term disability
program, any workers compensation claim, and any rehabilitation program.
Type of work. Your policy should describe what type of work is available for employees who
are able to return to duty on a limited basis. To illustrate, are all positions available for
restricted duty? Are there certain positions that are not available for restricted duty? Does
any law require you to provide certain types of work?
Compensation. What will you pay the person while on leave? The rate the individual is
normally paid? The rate for the job? State or federal law may require you to pay the same rate.
No guarantees. Unless otherwise required by applicable law, employers should not guarantee
that work will be available to any employee on a leave of absence who is now available for
restricted duty work. Employers should avoid the need to create work for an employee. On
the other hand, if employees are being paid for their time off, such as under workers compen-
sation or short-term disability, employers may want to obtain some productivity from that
individual.
Failure to report. If an employee is qualified for a position and has a physicians release to do
that type of work, then your policy should address what occurs if the employee refuses or fails
to report to work. For example, the employer can treat this as job abandonment. However, a
federal or state law may prohibit you from requiring an employee to accept restricted duty.
Maximum time period. Your policy should state a maximum time for which an employee
will be permitted to work in temporary positions or restricted duty positions.
Duration. In addition to a maximum time period for duration of restricted duty assignments,
employers need to consider other aspects. Your policy should provide that once the employee
is available for unrestricted work, the temporary job ends. Similarly, if the employee is subject
to being laid off or discharged for violation of a company policy, the temporary position should
end on such an event.
Eligibility. Employers may not want to provide restricted duty or temporary work to all
employees. Employers may wish to restrict eligibility to those employees who have received
an approval from a physician to return to work. Other potential eligibility criteria are
employees who have sustained an injury in the course of working for the company, employees
eligible for a paid leave of absence, employees receiving short-term disability, employees
receiving long-term disability, or employees receiving other company compensation. Keep in
mind that limiting eligibility for restricted duty could violate a discrimination law.
Procedures. Your policy should detail who will determine the parameters of the temporary
job. Is it the personnel department? Is it the supervisor? Is it a combination of the supervisor
and the personnel department? The issues that need to be addressed are items such as the
employees schedule, performance reviews, salary reviews, and rate of pay.
Benefits. Your policy should state whether employees who are returning to work on a part-
time or temporary basis are entitled to benefits such as the accrual of vacation pay, paid
holidays, the accrual of sick time, etc.
Legal Points
ADA. This federal law or a similar state law may require you to offer light duty. Even when
your policy places a limit on the amount of time that can be spent in light duty, the ADA
may require you, as a reasonable accommodation, to extend that time.
FMLA. This federal law does not allow you to require an employee to accept light duty.
However, when the employee requests intermittent leave, you can transfer the person to a posi-
tion that creates the least disruption for you, the employer. There are restrictions on this
transfer right.
State leave laws. State family or medical leave laws may require you to allow more intermit-
tent leave than under the FMLA or may create other restrictions on light-duty positions.
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Workers compensation. State law may require you to hold the employees job open. It may
reduce the employees benefits if you offer restricted work, reduced hours, or reduced duties
and the employee refuses the position. If you refuse to allow an injured employee to return to
work, you may face a claim of workers compensation discrimination.
State pregnancy laws. State law may require you to allow pregnant employees to take inter-
mittent leave or to reduce duties. Usually, pregnancy is not a disability, so normally the ADA
and state disability discrimination laws do not apply.
Discrimination. If restricted duties or reduced hours are offered only to certain employees,
and if this practice has an adverse impact on protected groups, you may face a charge of
discrimination.
Other Issues to Consider
Cost. As you design your policy for restricted duty or return to work, you should keep in
mind whether it is saving you money or costing you money. For example, if the time spent by
supervisors administering the program is excessive, you may not be gaining any benefit from
the program.
Employee morale. Ideally, a return-to-work program encourages employees to return to work
as soon as they are able and discourages goldbricking. Employee morale is often harmed
when employees begin to perceive that co-workers are taking advantage of the system, i.e.,
being paid for time off when they are capable of working, and the employees at work are
having to bear the added burden of performing the task usually done by the absent employee.
Additionally, the temporary work can be a source of income for those employees who do not
have other sources of income.
Consistency. Care must be taken as you design your policy to write one that can be enforced
consistently.
Next Steps
Safety management is a challenging but very fulfilling responsibility. The materials in this book
and dont forget the helpful appendiceswill get you started in a practical and effective way. Keep these
pointers in mind.
Insist on support and resources from management
Be very careful of your time and make use of your safety committee and other individuals to
help shoulder the safety management load.
Get managers and supervisors on board for safety. They have to be serious about it.
Be your organizations advocate, gadfly, ombuds for safety.
Put safety out front in meetings, publications, discussions, agendas, wherever you can. You
cant emphasize it enough.
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AppendicesSafety
Program Resources
The appendices provide a quantity of field-tested materials that will be a very practical source of
assistance in setting up and improving a safety program.
The following appendices are included in the book. Electronic versions of these materials can be
found in the Managing Safety from the HR Desk CD that accompanies this product.
The CD versions are particularly helpful when you want to customize these materials for use within
your organization.
Appendix A. Safety and Health Resources on the Internet
Appendix B. State Safety Programs
Appendix C. Model Safety Programs
Appendix D. Model Safety Policies
Appendix E. Master Training Guide for 29 CFR
Appendix F. Model Safety Checklists and Training Guides
Appendix G. How to Create a Disaster Plan
122
123
2008 Business & Legal Reports, Inc.
1-55645-634-4-6/08/$.50+$.50 (10030700)
Appendix A
Safety and Health Resources
On the Internet
The Internet is an indispensable source of environmental, health, and safety information, and a major
pipeline for acquiring various agency standards, policies, and contacts. So if your facility is appropriately
equipped, you should be able to tap a rich vein of useful material. In this section we present some of the
tools and features available and a number of specific contacts that should prove helpful.
Whats with the Web?
The World Wide Web (Web) is an endless source of information. Caution: Not everything on the
Web is fully researched or frequently updated.
To keep up-to-date on safety information and breaking news from OSHA, check out the safety and
health section on BLRs website at http://.safety.blr.com. You will find news, items, hot topics,
frequently asked questions, free tools, and much more.
OSHAs home page is www.osha.gov. In addition to the full text of 29 CFR, this site provides links to
Federal Register entries on safety and health issues before they are codified, including the preambles that
go along with the final ruleswhich are worth reviewing because they explain and interpret a lot of
background, such as significant comments received during the review period and why certain decisions
were made. There are also interpretations of most standards and answers to frequently asked questions.
Another very useful site is the Government Printing Office Access Page at http://www.access.gpo.gov.
This site allows you to search databases that include the Code of Federal Regulations, the Federal Register,
the United States Code, and the General Accounting Office blue book reports. The Federal Register can
also be accessed free online at http://www.access.gpo.gov/fr/index.html.
Individual states have their own home pages on the Web. Many of these addresses are relatively
simple, as http://www.hawaii.gov or http://www.state.nj.us. Most also have various subaddresses for
their labor or environmental protection departments.
Because there has been explosive expansion in the use of the Web as an advertising medium,
hundreds of manufacturers also have sites that may showcase products or from which you can download
material such as equipment specifications, MSDSs, or the answers to FAQs.
Here is a list of various sites you might want to try.
EHS Training and Compliance Materials URL Address
Business & Legal Reports, Inc. ............................................................http://safety.blr.com
Federal Bureau of Labor Statistics..........................................................http://stats.bls.gov
Congress Legislative Information (Thomas) ..................................http://thomas.loc.gov
Department of Labor............................................................................http://www.dol.gov
Environmental Protection Agency ......................................................http://www.epa.gov
Government Printing Office ....................................................http://www.access.gpo.gov
National Institute of Occupational Safety and Health................http://www.cdc.gov/niosh
Occupational Safety and Health Administration................................http://www.osha.gov
The White House....................................................................http://www.whitehouse.gov
U.S. House http://www.house.gov
U.S. Senate http://www.senate.gov
State and Other Sources
The following will link you to websites where you can access Web pages for individual states
and more:
http://www.statelocalgov.net
Associations URL Address
American Association of Occupational Health Nurses......................http://www.aaohn.org
American College of Occupational and Environmental Medicine ..http://www.acoem.org
American Industrial Hygiene Association ..........................................http://www.aiha.org
American National Standards Institute ..............................................http://www.ansi.org
American Petroleum Institute ..............................................................http://www.api.org
American Society for Testing and Materials ......................................http://www.astm.org
American Society of Mechanical Engineers ........................................http://www.asme.org
American Society of Safety Engineers ..................................................http://www.asse.org
American Welding Society ..................................................................http://www.aws.org
Compressed Gas Association..........................................................http://www.cganet.com
National Fire Protection Association ..................................................http://www.nfpa.org
National Safety Council........................................................................http://www.nsc.org
Society of Automotive Engineers ..........................................................http://www.sae.org
Voluntary Protection Program Participants Association..................http://www.vpppa.org
2008 Business & Legal Reports, Inc.
1-55645-634-4-6/08/$.50+$.50 (10030700)
Safety 101: How to Establish and Run a Workplace Safety Program
124
125
2008 Business & Legal Reports, Inc.
1-55645-634-4-6/08/$.50+$.50 (10030700)
Appendix B
State Safety Programs
This appendix will help you to assess what state regulations may apply to your workplace.
The following states have approved state plans:
Alaska New Mexico
Arizona North Carolina
California Oregon
Hawaii Puerto Rico
Indiana South Carolina
Iowa Tennessee
Kentucky Utah
Maryland Vermont
Michigan Virginia
Minnesota Washington
Nevada Wyoming
Connecticut, New Jersey, New York, and U.S. Virgin Islands plans cover public sector (state and
local government) employment only. Private sector employment is covered under federal OSHA.
The federal Occupational Safety and Health Act (OSH Act) and the regulations adopted under it
form the basic standards for workplace safety and health in private sector (private businesses and
nonprofit organizations) workplaces. The states are permitted to adopt standards of their own, but they
must have formal approval from the federal Occupational Safety and Health Administration (OSHA) to
do so, and the state standards themselves must be at least as stringent as the corresponding federal
provisions. By gaining federal approval a state earns the right to enact its own requirements, including
standards in areas not covered by the federal laws, and to use its own resources and personnel to enforce
them. States with approved regulatory programs are known as state-plan states.
The provisions of their laws and regulations are summarized here. The prerequisites for federal approval
are that the state designate an agency to administer the program, develop standards that are sufficiently
stringent (some states simply adopt federal standards as soon as they are issued), create a legal right of entry
for state inspectors, agree to develop an effective health and safety program for state and local employees
(who are not covered by OSHA), and ensure that all reporting requirements are satisfied.
This table provides only an outline of the actual standards. There are hundreds of specific require-
ments for particular industries, as well as for particular types of workplaces, work practices, and types of
2008 Business & Legal Reports, Inc.
1-55645-634-4-6/08/$.50+$.50 (10030700)
126
equipment. In addition, every state-plan state has adopted a version of OSHAs general duty clause,
which requires employers to furnish a workplace that is free from recognized hazards that are causing
or are likely to cause death or serious physical harm. In combination with the more specific require-
ments, these general duty provisions extend legal coverage to job hazards that might otherwise escape
regulation.
The table in this section describes the core federal safety and health rules that all private and public
sector employers in state plan states must follow, and descriptions of state rules that are more stringent
than corresponding federal rules. All of the states that are listed are state plan states. Private sector
employers in all other states must follow federal rules.
Note: You will find links to state-plan websites on www.osha.gov. Click on State Partners in the left
navigation bar.
Managing Safety from the HR Desk
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Appendix C
Model Safety Programs
This appendix presents three examples of a model safety program. It should help stimulate your
thinking about what your program should contain. No two safety programs will be alike, because no
two operations are exactly alike. Your program should be developed from a study of your hazards, your
perceptions of likely problems and emergencies, and the types and variety of jobs in your workplace. The
ideas presented below are designed to give you some framework in which to formulate your program.
Model Safety Program #1
B&B Manufacturing Company Safety Program
Model Safety Program #2
TITLE: XYZ COMPANY SAFETY AND HEALTH PROGRAM
Model Safety Program #3
TITLE: ABC COMPANY SAFETY AND HEALTH PROGRAM
Model Safety Program #1
B&B Manufacturing Company Safety Program
Safety at B&B
Safety in all aspects of our work is a top priority at B&B. To ensure that all employees are encouraged
to do their jobs safely, we have established the B&B Manufacturing Company Safety Program.
This program spells out what we do to make this a safe place in which to work.
Remember, though, the most basic rule:
Safety is up to you!
You must observe the rules of safety, every time you come to work, every job you do, every piece of
equipment you handle.
Safety Program
Philosophy. The B&B Manufacturing Company holds safety in all operations and activities to be of
primary importance. Accordingly, employees will be trained in the safe performance of their jobs and
will perform their jobs in a safe manner at all times.
Policy. The safety policy stresses the importance of safety and spells out expected standards of safe
conduct.
Regulations. Regulations from government and other agencies, particularly OSHA, dictate many
standards of performance.
Employee Responsibility. Ultimately, it is the employees responsibility to carry out the job in a safe
manner.
Elements of the Program
Training. Training is given to all employees and covers general safety aspects of the job and work
area, such as fire and evacuation procedures, as well as particular safety aspects of each employees job.
Supervision. Maintenance of our high standards of safety is a top priority of every supervisor in this
organization. Supervisors are trained to observe, inspect, and correct any and all safety violations.
Motivation. The company has several motivation programs designed to encourage safe behavior in
the organization.
Incentives. Monetary and gift incentive programs are offered facilitywide as well as departmentally.
Inspections. Inspections are made frequently by supervisors, members of the safety staff, and
members of the executive office.
Discipline. Instances of unsafe work practices will be dealt with seriously. Discipline according to
company policy (firm and fair) is to be expected for infractions of safety rules.
Safety Committee. The operation of the safety program is under the overall supervision of the plant
management, supervisors, and the safety committee, which draws its membership from all areas of the
facility and all levels of the workforce.
Suggestion Program. Your suggestions for improving safety in the facility are welcome. Please drop
your ideas and suggestions in the box near the time clocks.
Open Door Policy. Managements doors are always open for discussion of safety issues.
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Appendix C: Model Safety Programs
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Problem Program. A special communication network has been established for those who have
concerns or complaints but do not wish to voice them openly.
Safety Meetings. All departments have regular safety meetings.
Safety Newsletter. The newsletter is issued monthly with safety tips, new items of interest, and
status reports concerning safety in the facility.
B&B Manufacturing Company Safety Training
Fire Safety and Evacuation
Basic Training. This is the basic course in which all employees are required to participate. It covers
actions to take in the event of a fire, evacuation procedures for fires, and appropriate fire fighting proce-
dures for small fires.
Fire Marshal. This training is for those individuals appointed as area or department fire marshals. In
the event of a fire, these individuals will have responsibility to direct the evacuation of employees in
certain areas of the facility.
Fire Brigade. Those selected for fire brigade training will be involved in extinguishing small fires on
company property. There are several levels of training for fire brigade members. The training is given
off-site at an approved fire-fighting school.
First Aid
First Aid Basic. This basic course is available to all employees. It covers treatment of minor injuries
and basic emergency procedures for more serious injuries or health problems.
First Aid Advanced. The advanced course equips participants to handle first aid for many types of
injuries and is under the direction of a local physician.
CPR. The organization encourages at least one employee from every department to take the
Cardiopulmonary Resuscitation (CPR) course.
EMT. Training for Emergency Medical Technicians involves extensive coursework off site. Our
organization will sponsor a limited number of employees each year.
Office
General Office Safety. This brief training covers lighting and electrical equipment policies, office
machine operation, musculoskeletal disorders, carrying and lifting, body strains, and back injuries.
This brief training covers plant entrance requirements, visitors to the plant, safety performance of
outside contractors and vendors, and restricted areas.
Plant
General Plant Safety. This orientation training covers lifting, climbing, stacking, housekeeping,
smoking control policies, eye, foot, and other protective equipment requirements, hazards due to
machinery or materials handling equipment, and restricted areas.
Welding. This training applies to those who engage in welding operations.
Materials
Hazard Communication (Right to Know) Basic. This training applies to all employees.
Hazard Communication (Right to Know) Specific. This training applies to those who use or may
be exposed to specific hazardous substances in the course of their work.
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136
Asbestos. This training only applies to those who may come in contact with asbestos in the course of
their duties in the plant.
Acrylonitrile. This training applies to those who use or may be exposed to acrylonitrile.
Liquified Petroleum (LP) Gas. This training applies to those who operate equipment fueled by
LP Gas.
Equipment
Machine Operators General. This training applies to all machine operators. It covers basic
machine safety, tagging and lock-out procedures, electrical operations, safeguards, etc.
Specific Machines. This training is specific to the machine the employee will use.
Forklift. This training is given to anyone who will operate a forklift.
Crane. This training is given to anyone who will operate the gantry crane.
Model Safety Program #2
TITLE: XYZ COMPANY SAFETY AND HEALTH PROGRAM
I. Safety Policy
It is the Companys objective to provide a safe and healthful work environment through the preven-
tion of occupational injuries and illness.
Our objective for the Safety and Health Program will be to reduce injuries and illness to a minimum;
ideally our goal is ZERO accidents and injuries. Our Safety and Health Program will include:
l) Establishment of a Plant Safety Committee to oversee safety and health activities.
2) A program of safety and health inspections to find and eliminate unsafe working conditions or
practices, to control health hazards and to comply fully with the safety and health standards for
every job.
3) Training all employees in good safety and health practices.
4) Providing necessary personal protective equipment and instructions for its use and care.
5) Providing mechanical and physical safeguards to the maximum extent possible.
6) Developing and enforcing safety and health rules; requiring that employees cooperate with
these rules as a condition of employment.
7) Investigating every accident promptly and thoroughly, to find out what caused it and to
correct the problem so it wont happen again.
II. Responsibility
We recognize that the responsibility for safety and health are shared.
1. As your employer we accept the responsibility for leadership of the safety and health program,
and for its effectiveness and improvement, and for providing the safeguards required to ensure
safe conditions.
2. Our supervisors and management personnel are responsible for developing the proper attitudes
toward safety and health, and are responsible for ensuring that all operations are performed
with the utmost regard for the safety and health of all personnel involved.
Appendix C: Model Safety Programs
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3. As employees, you are responsible for wholehearted, genuine cooperation with all aspects of
the safety and health program including compliance with all rules and regulations and for
continuously practicing safety while performing your duties.
III. Plant Safety Committee
The Plant Safety Committee (PSC) will be composed of eight members of management/supervision
and hourly personnel. The recommended make-up of the committee will consist of the following:
3 Salaried supervisory personnel
2 Hourly lead personnel
3 Hourly personnel (shop and/or office)
The activities of the PSC will include, but are not be limited to:
1. Holding, as a minimum, monthly safety meetings.
2. Conducting and overseeing departmental safety inspections.
3. Reviewing accident/injury reports and discussing corrective actions.
4. Directing and monitoring departmental training and safety awareness activities.
5. Discussing and reporting on unfinished business of the previous meeting.
6. Reviewing and discussing new or outstanding recommendations, projects, etc.
7. Maintaining appropriate records of activities.
The membership of the PSC will be rotated at least semi-annually to allow different members of the
Company the opportunity to participate more fully in safety activities.
IV. General Safety Activities
In addition to the previously mentioned safety committee activities, the Company is cognizant of its
responsibilities to focus attention in other areas relating to safety and health to meet appropriate safety
and health standards as established by regulatory and other governmental agencies.
Appropriate members of management will be assigned responsibility for the following:
1. Hazard Communication Program requirements for handling, labeling, and storing of chemi-
cals and hazardous materials.
2. Hazard Communication Program as it applies to employee awareness and required training.
3. Fire Safety protection and plant inspections.
4. Hearing Conservation program activities for areas of the plant where deemed necessary.
5. First Aid and CPR training activities as appropriate.
6. Emergency Response planning.
7. Workers Compensation and OSHA recordkeeping requirements.
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Model Safety Program #3
TITLE: ABC COMPANY SAFETY AND HEALTH PROGRAM
Responsibility
The Employee Relations Manager shall coordinate Division safety activities, establishing procedures
for promoting safe working conditions, conducting safety meetings, reviewing accidents, and recom-
mending measures to reduce accidents and health hazards; he or she shall work with the Workers
Compensation carrier, and with local, state and federal agencies to assure that safety and health stan-
dards fully meet applicable requirements.
Line management, including the Plant Manager, Manufacturing Manager, and all forepersons and
supervisors shall be responsible for incorporating safety and good housekeeping into the daily activities
of their departments, including taking corrective and preventive action on problems within their
departments.
The Safety and Housekeeping Committee shall meet monthly. Consisting of hourly and salaried
employees representing all departments and shifts, the Committee shall bring to managements atten-
tion for corrective action any safety and housekeeping problems noted during the preceding month.
The Committee shall review progress on solving problems previously brought up, recommending solu-
tions wherever possible. Promotion of interest and cooperation on safety and housekeeping matters
shall be a prime concern of the Committee.
Safety Rules
Employees and supervisors have cooperated in the establishment of Division safety rules. Each
foreperson and supervisor is responsible for seeing that the rules are observed within his or her depart-
ment, and for taking corrective or disciplinary action as required to assure work is carried out within
these rules.
Orientation
Forepersons and supervisors shall be responsible for ensuring that new employees know all safety,
health, and housekeeping rules to which his or her job is subject and are capable of performing the
essential functions of the job.
Training and Education
The human resources department shall coordinate the use of meetings, contests, videos, discussion
groups, communications, and other activities to train selected groups and educate all employees on
awareness of safety and housekeeping problems. Line management shall recommend specific areas
where such training and education may be required.
Accidents
The foreperson or supervisor shall report each industrial accident or health problem requiring outside
treatment to the human resources department on the Supervisors Accident Investigation Report. The
forepersons and the human resources department, together with members of management as required,
shall investigate reported accidents, taking corrective action as necessary to prevent recurrence.
Inspections
Together with representatives of the Workers Compensation carrier, with personnel of local, state and
federal agencies, or with other Division personnel, the Employee Relations Manager, Plant Manager,
Manufacturing Manager, and forepersons shall inspect the facility regularly for safety and housekeeping
problems. Such problems as may be found shall be evaluated and corrective action taken as required.
Engineering
Plant, manufacturing, industrial, and product engineering activities shall be carried out so as to elim-
inate hazards involving defective equipment and inadequate facilities on both a preventive and remedial
basis.
Facilities
The Company shall maintain facilities for first aid, fire extinguishers, emergency exits, walkways,
parking lots, control panels, air temperature and cleanliness, lavatories, lighting, and other environ-
mental factors, fully meeting requirements applicable to the Division.
Facilities shall be inspected regularly to ensure compliance with safety standards.
Deficiencies
Such deficiencies as may be found in Division safety and housekeeping procedures by insurance
personnel or representatives of local, state, and federal agencies shall be evaluated and corrected as
required.
Violation of safety rules may result in discipline up to and including discharge.
Safety Rules for all Departments
These safety rules have been established by the Division Safety and Housekeeping Committee and
approved by Division Management for the protection of each employee. All employees are requested to
cooperate in observing these rules, and to help in making the Division a safe and orderly place to work.
1. Never operate any machine or equipment unless you are specifically authorized to do so by
your foreperson.
2. Do not operate defective equipment. Do not use broken hand tools. Report defective or
hazardous equipment to your foreperson.
3. Obtain full instructions from your foreperson before operating a machine with which you are
not familiar.
4. Never start on any hazardous job without being completely familiar with the safety techniques
that apply to it. Check with your foreperson if in doubt.
5. Make sure all safety attachments are in place and properly adjusted before operating any
machine.
6. Do not operate any machine or equipment at unsafe speeds. Shut off equipment that is not in use.
7. Wear all protective garments and equipment necessary to be safe on the job. Wear proper
shoes; sandals or other open-toed or thin-soled shoes should not be worn.
8. Do not wear loose, flowing clothing or loose long hair while operating moving machinery.
9. Never repair or adjust any machine or equipment unless you are specifically authorized to do
so by your foreperson.
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10. Never oil, clean, repair, or adjust any machine while it is in motion.
11. Never repair or adjust any electrically driven machine without opening and properly tagging
the main switch.
12. Put tools and equipment away when they are not in use.
13. Do not lift items that are too bulky or too heavy to be handled by one person. Ask for assis-
tance.
14. Keep all aisles, stairways, and exits clear of skids, boxes, air hoses, equipment, and spillage.
15. Do not place equipment and materials so as to block emergency exit routes, fire boxes, sprin-
kler shutoffs, machine or electrical control panels, or fire extinguishers.
16. Stack all materials neatly and make sure piles are stable.
17. Keep your work area, machinery, and all company facilities that you use clean and neat.
18. Do not participate in horseplay, or tease or otherwise distract fellow workers. Do not run on
company premisesalways walk.
19. Power-truck operators must safeguard other workers at all times; workers must show courtesy
to power-truck operators.
20. Never take chances. If youre unsure, ask your foreperson. Let good common sense be your
guide.
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Appendix D
Model Safety Policies
Safety and health policies form the foundation of your entire safety program. The sections below
present a wide variety of model policies, along with comments on what points should be covered and
what needs to be considered in developing a policy of your own.
Safety Policies
Protective Equipment Policies
Accident-Reporting Policies
Emergency Policies
Fire Prevention Policies
Workers Compensation Policies
Hazard Communication Policies and Programs
Ergonomics Policy
Return-to-Work Policies
Safety Policies
Points to Cover
Assuming that you want to start out with a comprehensive policy statement summarizing the basic
provisions of your companys safety program, here are some of the points you should cover.
The companys commitment to safety. Its a good idea to start out with a sentence or two
affirming the companys commitment to maintaining a safe and healthful place for employees
to work.
Safety committee. If your company has an established safety committee, explain what their
responsibilities are and what authority they have. Employee involvement is invited on the
committees.
Supervisors responsibilities. Supervisors play a vital role in the implementation of safety
policies. State as specifically as you can what supervisors are expected to do in carrying out
these policiesfor example, giving the personal leadership to safety in their department,
conducting safety and housekeeping inspections, completing accident report forms, disci-
plining employees who disobey safety rules, orienting new workers about safety issues,
ensuring that protective equipment is worn, etc.
Employees responsibilities. Even the most vigilant supervisor cannot compensate for an inat-
tentive, careless, or deliberately rebellious employee. While employees may not actually read
the policy manual, it is important to spell out their responsibilities so that supervisors can
remind them from time to time of the role they must play in accident prevention. These
responsibilities include working safely at all times, noting hazards and reporting them to their
supervisors, offering suggestions for improving safety procedures, adhering to all company
safety rules, etc.
Accident investigation and reporting procedures. Supervisors in most firms are required to
report accidents promptly. An investigation may be carried out by the human resources
department, the safety committee, or by the supervisor. In any case, be sure to specify what
information is needed, what forms must be completed, and any tips that might be helpful
either to the person conducting an investigation or the person(s) assisting him or her.
Procedures for correcting or eliminating hazards. Under what circumstances should a super-
visor (or an employee) take immediate action on his or her own to correct a safety hazard? If
immediate action is not warranted, what are the appropriate channels through which correc-
tive measures should be routed?
Safety training and education programs. Many companies have periodic training sessions for
both employees and supervisors to acquaint them with new safety hazards or to refresh their
memories about long-standing hazards and what should be done to avoid them.
Safety inspections. If inspections or safety audits are a routine part of your safety program,
you may want to include either a brief mention of them in your policy or even a copy of the
inspection checklist(s) you use.
Protective equipment. If you dont have a separate policy statement covering personal protec-
tive equipment (safety shoes, safety glasses, ear protection, hair nets, etc.), then be sure to
include a statement here.
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Disciplinary action. Violations of safety rules should carry penalties similar to those for other
rule violations. You can either refer your readers to your policy on Work Rules or
Disciplinary Procedures, or recap the penalties for safety violations here. Start with the
premise that employees will work safely and protect themselves from injury.
Physical exams. If you dont have a policy on physical examinations for newly hired
employees or those returning to work after a long absence, you may want to include this as
part of your safety program. You can also simply refer your readers to the physical examina-
tion policy if it is located elsewhere in the manual.
Workers compensation. If you dont want to establish a special policy statement on workers
compensation, this might be a good place to mention what benefits an injured worker receives
and what documentation is required.
Things to Consider
The first and most obvious consideration here will be the nature of your companys operations. A
manufacturing firm is going to have to put a lot more thought and planning into its safety program
policy than a small white-collar organization, for the simple reason that safety is a more pressing
concern in a manufacturing environment. Here are some other issues to take up with your policy
committee:
1. State and federal law. The provisions of both the Occupational Safety and Health Act of 1970
and relevant state laws should be reviewed thoroughly as they apply to your companys opera-
tions. OSHA regulations are continually being changed, and it may be that some of your
safety rules are already out-of-date. Your companys safety manager should sit in on your
policy committee meetings and offer guidance on what your policy should cover.
2. Your companys safety record. Preparing new or updated safety policies is a good reason for
reviewing your companys safety track record. If its a good one, then perhaps your existing
safety policy is doing its job. But if it leaves room for improvement, then perhaps its time to
come out with a stronger policy statement, backed up by more specific rules and more strin-
gent disciplinary actions. It might even be time to establish a safety committee if you dont
already have one.
3. Supervisory commitment. Supervisors are the key to the success of a companys safety
program. Without their understanding of the issues, cooperation, and commitment, your
safety program is doomed. Your policy committee may be able to give you a more accurate
picture of the status of your current supervisors commitment to safety on the job. If it is
lacking, you may want to incorporate education and training efforts in your policy statement,
or simply use stronger or more emphatic language to convey the value you place on the
concerned supervisors role.
4. Attitudes among employees. Employee attitudes are often a reflection of supervisory commit-
ment to safe work practices. A survey of these attitudes, therefore, may provide evidence of
inadequate supervisory support for the companys safety program. This would be important to
know when you tackle the policy-writing task.
Sample General Safety Policy
A. Supervisors Responsibility
1. Employee safety on the job is the primary responsibility of every foreperson and supervisor.
The Safety Committee acts only as a coordinator. Employee safety cannot succeed without the
supervisors utmost sincerity and effort. The Company has gone to great expense to provide
safe working conditions throughout the plant. It is the supervisors duty to see that there is
complete safety in his or her area at all times.
2. The contributing factor in over 60 percent of all accidents involves both the employee and the
environment. The supervisor must, therefore, be constantly on the alert for incidents of
human error and mechanical failure. Supervisors must take the initiative to make corrections
where they have such authority. And, lacking direct authority, they must report any condition
or employee practice that is likely to cause an accident.
3. Supervisors must be convinced that accidents are caused; they dont just happen. An act of
negligence, disregard for established rules or procedures, being in a hurry, improperly guarded
machinery, lack of or improper maintenance, all can cause an accident.
4. Supervisors must also be convinced that an accident does not affect the employee alone.
Accidents cost money and have a direct impact on Company profitability. Accidents affect
production and directly reflect on the efficiency of the department.
B. Supervisors Action
To make the program effective, every member of management shall ensure that:
1. Work that is hazardous or located in a hazardous area will not be assigned until all steps have
been taken to provide for the safety of the employee.
2. All employees have received proper job instruction and are familiar with pertinent safety and
health rules and regulations. Exhibit A (at the end of this policy) is a guideline that should be
used for this purpose.
3. Work areas are frequently examined to ascertain that the work environment is safe and that
employees are working in a safe manner.
4. All safety and health deficiencies are corrected immediately and not repeated.
5. Accidents are investigated and corrective action is initiated where necessary. Like the super-
visor, every employee has a specific role in our loss-prevention efforts. Each employee is
expected to participate actively in the Safety Program and observe all established precautionary
measures.
C. Reporting Injuries
Injuries, no matter how minor, are to be reported to the Medical Department immediately. If
circumstances permit, the employee should be given a first-aid pass. In no case shall the injured be
moved before examination by Medical or Safety department if the injury is serious. It is equally impor-
tant that all spectators be kept away from the scene of an accident. Supervisors should not permit their
employees to leave their work areas to go to the scene of an accident. A doctors note, etc., brought in
by the employee should be forwarded directly to the Safety Department.
Failure to report injuries or illnesses may result in a delay or denial of workers compensation benefits.
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D. Correcting Deficiencies
The department supervisor or foreperson is responsible for correcting, or causing to be corrected, any
hazard the supervisors found as a result of department inspections or investigation of an accident, or
brought to the supervisors attention by an employee. All corrective action must be followed up to
ensure completion.
Where necessary, assistance should be requested from the Safety Department.
E. Accident Investigation
Upon receipt of an investigation form, the investigation shall be completed as soon as possible and
returned to the Safety Department. Instructions on the form should be followed explicitly.
F. Workers Compensation
Employees who sustain an occupational injury or illness will be compensated in accordance with the
State Workers Compensation Act. In order to receive such benefits, the appropriate notification and
medical reports must be provided by the employee.
Any employee who loses time as a result of a work-related injury shall not be processed for a medical
leave of absence.
G. Physical Examination
Physical examinations are required of all employees:
1. Upon employment or reemployment.
2. Upon return to work after a leave of absence for an illness of 1 month or longer.
3. Upon return to work after an absence from the plant of 6 months or longer.
4. As required by OSHA: blood work, air sample tests, dental checks, urine samples, hearing
tests, physicals, etc.
5. At any other time deemed necessary for the best interests of the employee or the protection of
the Company.
Such physical examinations will be given in strict compliance with the Americans with Disabilities
Act and the Family and Medical Leave Act. Medical records shall be maintained in confidence as
required by applicable law.
H. Personal Protective Equipment
Where necessary, by reason of hazard, the Company will provide the necessary personal protective
equipment to ensure the well-being of the employee. These items include:
1. Safety glasses
2. Gloves
3. Aprons
4. Safety shoes
5. Respiratory equipment
Supervision must review operation and provide or request to be provided (by Safety Department) the
necessary protection. Items such as clothing, gloves, aprons, protective creams, etc., must be supplied
and issued by the department head. Employees are expected to wear such personal protective equip-
ment. Failure to do so may lead to discipline up to and including termination.
Exhibit A
Safety Guidelines
1. General
Safety is a responsibility of each employee.
Report unsafe conditions or equipment.
Follow established procedures.
Report all injuries/illnesses no matter how slight.
Dont perform unsafe acts.
2. Machine Safety
Check guards before turning on machine.
Never remove or bypass a guard.
Do not wear loose clothing or jewelry.
Use lockout/tagout for service or maintenance.
3. Hand Tools
Use the right tool.
Keep tools in good condition.
4. Protective Equipment
Use glasses, gloves, shoes, aprons, etc., where required.
Ask supervision to supply or replace them.
5 Housekeeping
Keep your work area clean.
Do not store material in aisles or passageways.
Be on the lookout for others.
6. Material Handling
Stack material safely.
Use wagon, lift trucks, etc., safely.
Lift properly.
7. Electrical Safety
Do not tamper with or try to service equipment yourself.
Report exposed electrical wires.
8. Fire Safety
Observe No smoking signs.
Handle and store flammable liquids properly.
Know the location and use of fire extinguishers.
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9. Personal Conduct
Horseplay is not allowed.
No running in the plant.
Observe warning and caution signs.
10. Power Trucks
Power truck operators must safeguard other workers at all times.
Only trained personnel are to operate power trucks.
Workers must show courtesy to power truck operators.
11. Ladders
Inspect ladders before use to make sure they are in good condition.
Make sure the ladder is set on a firm, level base.
Set extension ladders against a wall at a one-to-four ratio. (The base should be 1 foot (ft) from
the wall for every 4 ft of height.)
Extend straight ladders 36 inches above the edge when gaining access to a roof.
Allow only one person on a ladder at a time.
Never use metal ladders around electrical lines.
12. Chemicals
Proper care should be used when handling industrial chemicals to avoid damage to your health
or to the environment.
Wear suitable hand, face, and eye protection in well-ventilated areas when handling acid-based
products.
Remove contaminated clothing immediately.
Thoroughly flush area if a spill occurs.
Become familiar with material safety data sheets (MSDSs) that accompany the product.
Government agencies, such as EPA and OSHA, have been formed to regulate the control and
handling of acid and other hazardous chemicals.
13. MSDS
MSDSs and related information concerning hazardous materials in the workplace are main-
tained in each department.
I have reviewed with this employee the specific safety precautions of the job and the precautions
outlined in the Company Safety Handbook.
___________________________________ _________________________________
(supervisor) .................................................................................. (date)
I have received detailed instruction on my specific job and the general precautions outlined in the
Company Safety Handbook.
___________________________________ _________________________________
(employee) ........................................................................ (date)
Personal Protective Equipment
Background
When you look at the statistics on industrial accidents, it isnt hard to see why a policy on the wearing
of personal protective equipment (PPE) is so important. Consider, for example, the following facts:
According to Prevent Blindness America, more than 2,000 people injure their eyes at work
each day. About 1 in 10 injuries require one or more missed workdays to recover. Of the total
amount of work-related injuries, 10 percent to 20 percent will cause temporary or permanent
vision loss.
According to the Bureau of Labor Statistics, about a quarter of a million disabling occupational
foot injuries occur each year, many of which happen to workers who arent wearing safety shoes.
The passage of the Occupational Safety and Health (OSH) Act drew attention to the importance of
safety equipment as a factor in preventing occupational injuries and emphasized managements responsi-
bility for seeing to it that employees regularly wear the necessary protective devices.
Also, revised OSHA regulation 1910.132 now requires employers to pay for most types of PPE, with
a few exceptions (listed below). The rule does not require employers to provide PPE where none has
been previously required.
Improvements in personal protective equipment are occurring on a regular basis, and the list of PPE
available to industrial employers today is almost endless, including various types of safety shoes and
boots, goggles and eyeglasses, earplugs and earmuffs, hard hats, protective gloves, face shields, respira-
tors, and work clothing made out of special protective materials.
While the role played by safety equipment in the achievement of the companys accident-prevention
goals is often covered under the policy on Safety Programs or Safety Rules and Regulations, many
firms feel it is an important enough issue to merit a separate policy statement of its own.
Revised OSHA Regulation
Revised Occupational Safety and Health Administration (OSHA) regulation 1910.132, effective
February 13, 2008 (with a final implementation date of May 15, 2008), requires employers to pay for
almost all types of PPE when used by employees exclusively in the workplace (i.e., not for personal use
at home or other nonworkplace activities).
The final rule does not impose new requirements in terms of what PPE must be provided by
employers. Instead, it clarifies that employers must pay for PPEwith a few exceptions, including ordi-
nary safety-toed footwear, ordinary prescription safety eyewear, logging boots, ordinary clothing, and
weather-related gear.
In addition, the final rule explains that employers do not need to reimburse employees who choose to
use their own PPE. However, employees use of their own PPE must be completely voluntary, and
employers still have an obligation to ensure that the equipment provides sufficient protection.
The agency says the revised regulation will increase safety compliance and potentially avoid thou-
sands of workplace injuries annually.
Covered PPE. Here is a nonexhaustive list of employer pays examples:
Electrical protection
Electrically insulated tools
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Rubber insulating gloves
Chemical-resistant gloves/aprons/clothing
Encapsulating chemical protective suits
Foot protection
Metatarsal foot protection
Special boots for longshoremen working logs on log ships
Rubber boots with steel toes
Shoe covers (toe caps and metatarsal guards)
Eye and face protection
Nonprescription eye protection
Prescription eyewear inserts/lenses for full-face respirators
Prescription eyewear inserts/lenses for welding and diving helmets
Goggles
Face shields
Laser safety goggles
Head protection
Bump caps
Hard hats
Hearing protection
Hand/arm/body protection
Rubber sleeves
Aluminized gloves
Mesh cutproof gloves, mesh or leather aprons
Nonspecialty gloves (Payment is required for PPE to protect from dermatitis, severe cuts/abra-
sions; payment is not required if they are only for keeping clean or for cold weather with no
site-specific hazard consideration.)
Reflective work vests
Respiratory protection
Skin protection
Barrier creams (unless used solely for weather-related protection)
Fall protection devices (e.g. harnesses)
Ladder safety device belts
Climbing ensembles used by linemen (e.g., belts and climbing hooks)
Window cleaners safety straps
Fire-fighting PPE (helmets, gloves, boots, proximity suits, full gear)
Welding PPE
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Face shields and goggles
Fire-resistant shirts, jackets, and sleeves
Leather gloves
Items used in medical/laboratory settings to protect from exposure to infectious agents (e.g.,
aprons, lab coats, goggles, disposable gloves, shoe covers, etc.)
Personal flotation devices (life jackets)
Exceptions. Employers are not required to pay for the following clothes or items that are not worn
by employees exclusively for protection from hazards:
Nonspecialty safety-toe protective footwear (provided that the employer permits such items to
be worn off the jobsite)
Steel-toe shoes
Steel-toe boots
Nonspecialty prescription safety eyewear (provided that the employer permits such items to be
worn off the jobsite)
Shoes or boots with built-in metatarsal protection that the employee chooses instead of
metatarsal guards provided by the employer
Logging boots under the logging standard (29 CFR 1910.266(d))
Everyday clothing
Long-sleeved shirts
Long pants
Street shoes
Normal work boots
Ordinary clothing and skin creams used solely for protection from the weather
Winter coats
Jackets
Gloves
Parkas
Rubber boots
Hats
Raincoats
Ordinary sunglasses
Sunscreen
Back belts
Dust masks and respirators worn under the voluntary-use provisions of the PPE standard
Items worn for product or consumer safety or patient safety and health rather than employee
safety and health (for example, hair nets to prevent food contamination during preparation)
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Uniforms that are not PPE
Items worn to keep clean for purposes not related to safety and health
PPE already owned and used voluntarily by the employee
Flame-resistant clothing for electrical work
Replacements. Unless an employee has lost or intentionally damaged the equipment,
employers are required to pay for replacement PPE used to comply with OSHA standards under the
final rule.
Points to Cover
PPE is often considered to be equipment used to protect the head, eyes, ears, torso, arms, hands, and
feet. No matter what type of protective equipment your employees are required to wear, youll want
your policy to cover the following:
Rationale. You should convey the idea that rules and regulations pertaining to safety equip-
ment are designed both to comply with federal or state law and to protect the employee from
serious injury.
Coverage. To whom does your policy apply? Normally, the answer here is all full- and part-
time employees whose work routinely involves danger to the feet, eyes, face, hands, etc.
Payment. Under the new regulation, the company usually pays all of the cost of protective
equipment, unless it is can be used for work and personal use. See exceptions on previous page.
Suppliers. Where can employees obtain their protective items? Are they stocked by the
company store or must they go to a company-approved supplier in the local area?
Replacements. Will the company provide a replacement if safety equipment is lost, damaged
in use on the job, or worn out? What if PPE is lost or damaged through employee negligence?
What are the procedures for obtaining replacements?
Employee responsibility. You should also emphasize the fact that the employee is responsible
for wearing the equipment while on the job and for keeping it well-maintained and in good
repair. You may want to mention what disciplinary measures will be taken for failure to wear
required PPE.
Supervisors responsibility. This is of vital importance. State unequivocally that it is the
supervisors responsibility to make sure that all of his or her subordinates who are required to
wear PPE do so on designated jobs and in designated areas.
Other relevant safety precautions. You may want to include at the end of your policy a
reminder for supervisors about other safety precautions involving the hands, fingers, feet, eyes,
etc. For example, remind them to check employees for rings, bracelets, or dangling earrings
that could get caught in a machine; for neckties or scarves; and for long hair that isnt tied
back or contained in a cap or hair net.
Legal Points
OSHA. The Occupational Safety and Health Act requires the use of PPE to reduce employee
exposure to hazards when engineering and administrative controls are not feasible or effective
in reducing the exposure to acceptable levels. Employers are required to determine if PPE
should be used to protect their workers.
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State safety laws. State laws may set a stricter standard when PPE is to be used.
Employer payment for PPE. As mentioned, revised OSHA regulation 1910.132 requires
employers to pay for virtually all PPE items.
Wage and hour laws. Generally, employers cannot require employees to pay for tools or equip-
ment if such payments reduces their wages below the minimum wage. Moreover, deductions
for lost or damaged PPE from the pay of a salaried employee may violate the Fair Labor
Standards Act and entitle the employee to overtime.
Disability. The Americans with Disabilities Act or state law may require an employer to
provide PPE as a reasonable accommodation.
Discrimination. Title VII of the Civil Rights Act or state law may require an employer to
provide or allow alternative PPE or alternative safety procedures or other reasonable accommo-
dation for a religious objection to PPE, such as religious tenet that requires wearing a beard,
head covering, or jewelry.
Things to Consider
The most obvious consideration in establishing a policy on PPE, of course, is the nature of your
companys industrial operations and the degree to which such equipment is necessary. Here are some
other issues to be considered:
1. Legal requirements. Federal or state OSHA requirements pertaining to the wearing of PPE
should be reviewed thoroughly. Its important to realize that under the current OSHA rule,
employers share the responsibility for seeing that needed PPE is worn, not just for telling
employees it should be worn.
2. Existing attitudes toward safety equipment. If employees have always resisted wearing the
necessary devices, youll want your policy to stress the rationale behind such safety measures,
the benefits to the employee and the company, and perhaps the disciplinary measures that will
be taken for failure to wear them.
Dont overlook the importance of supervisory attitudes as well. If supervisors take safety regu-
lations lightly, chances are that their employees will never develop positive attitudes toward
wearing protective devices.
3. Integration with other policies. There is often some overlap here with policies on work rules,
disciplinary procedures, and safety programs in general. Be sure that these overlapping areas
serve to reinforcenot undermineyour policy on the wearing of safety equipment.
4. Employee involvement. Employees are more likely to wear personal protective equipment that
they have been involved in selecting. If a new type of PPE is needed, ask a small committee of
employees who will eventually wear the equipment to assist you in selectionsizes available,
protection offered, styles, alternative forms, and the like. Then pilot-test some samples to see
which are most comfortable and offer the best protection.
Sample Policies
Policies in this area will obviously vary according to the industry of which the company is a part,
work exposures, and different types of PPE that are regularly used by the companys employees. The
three that have been selected here deal with protective footwear, safety
eyeglasses, and a combination of eye, ear, foot, and head protection.
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The general PPE policy places a limit on the amount of the companys reimbursement for safety
shoes, and the employee is responsible for the cost of replacing any safety equipment that is lost or
damaged through negligence.
A separate policy for safety eyeglasses can be considerably more comprehensive and detailed. It covers
the types of glasses that the company provides, ordering information, and instructions for obtaining
replacements and repairs. The company assumes all costs, with the exception of the eye examination and
fitting charges for employees needing prescription safety glasses.
Another approach companies may take is to issue a general policy statement on the fact that PPE is
required for certain tasksand the consequences for failing to wear itand then having separate
bulletins for each type of PPE. These would contain the particulars on standards to be met, tips on
proper fitting, maintenance, etc.
Subject: Safety/Protection
Example of: Standard Policy
Needs Assessment
Supervisors will assess their departments and determine what hazards, if any, are present that require
the use of personal protective equipment. Then they will select the types of PPE that will protect against
these hazards. They will document the hazard assessment of their department in writing, indicate the
date(s) of the assessment, the list of employees who attended the training, and sign the document.
It is the supervisors responsibility to assure that employees wear the designated PPE on the job.
Eye and Face Protection
Supervisors may obtain eye protection (safety glasses, goggles, etc.) or face shields for their employees
through Purchasing.
If the eye protection is lost or destroyed due to the employees negligence, the employee will be
responsible for the cost of a replacement pair.
Prescription Safety Glasses
Employees working in potential eye-hazard areas who need prescription glasses may submit a request
through their supervisor to the Purchasing department for prescription safety glasses. After an employee
successfully completes the probationary period, prescription safety glasses can be obtained through a
company-approved source. The company will assume the cost of
the glasses.
If the prescription safety glasses are lost or destroyed due to the employees negligence within
1 year of the date of issue, the employee will be responsible for the cost of a replacement pair.
Ear Protection
Employees working in areas where the noise level is 80 decibels or higher may obtain ear protection
through their supervisor. We provide a variety of types of hearing protection from which the employee
may choose the most effective and best fitting.
Personnel who work regularly in 80-decibel-or-higher areas are given a yearly hearing test.
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Foot Protection
All employees should wear substantial shoes with fully enclosed coverings to protect their feet and
toes. For those employees who work in areas where safety shoes are recommended, the company will pay
for one pair per year, per person. The safety shoes must meet federal standards and can be purchased
through several local suppliers.
Hair/Head Protection
Employees must wear protective helmets supplied by the company when working in areas where
there is potential for injury to the head from falling objects.
Operators of forklifts should wear a hard hat when operating the vehicle.
Employees with long hair (down to the shoulders) should tie their hair back or wear hair nets or caps
when working on drill presses, vertical milling machines, or equipment with rotating spindles or other
moving machinery.
Hand Protection
When employees hands are exposed to hazards, the supervisor must formally evaluate the hazards
present and, if risks exist, arrange to provide appropriate hand protection suitable to the needs of the
job. Hazards may include those from skin absorption of harmful substances, severe cuts or lacerations,
severe abrasions, punctures, chemical or thermal burns, and harmful temperature extremes. Performance
characteristics of the hand protection should be evaluated relative to the tasks to be performed, the
conditions present, duration of the use, and the hazards or potential hazards identified.
Supervisors are responsible to assure that employees wear the designated gloves on the job.
General Rules
Loose clothing must not be worn near moving machinery.
Neckties must be securely clipped to the shirt.
Employees working in areas where chemicals, solvents, other irritants, or caustic acids are used
(i.e., tumbling room) will be supplied with face shields, chemical-resistant boots, aprons,
chemically protective gloves, etc.
Rings and jewelry must not be worn when working on machinery.
Work gloves (leather-palmed) must be worn by anyone handling raw materials other than
chemicals.
Training
Supervisors will arrange to train each employee in the proper and correct use of PPE, proper care and
maintenance of the PPE, useful life of the equipment, and the correct way to dispose of broken or
damaged PPE. The supervisor will certify on the Needs Assessment sheet the names of the employees
who have received the training, date of the training, and that the employee has received and understands
the training.
Accident-Reporting Policies
Points to Cover
Policies on accident-reporting procedures may or may not cover investigatory procedures as well.
Sometimes the responsibility for investigating the accident is assigned to the safety manager or safety
committee and is, therefore, not an appropriate subject for a policy statement aimed at supervisors.
Here are the points covered by most accident-reporting policies.
Purpose or rationale. Supervisors should have a clear understanding of why they must report
accidents promptly and accurately. Stress not only legal compliance but also the value of
reports in reducing future accidents.
Definition of accident. Weve already discussed what OSHA considers to be a recordable
injury. You may want to set up a similar definition for your own purposes. Be as specific as
possible, so that supervisors know exactly what types of accidents must be reported.
Reporting procedures. Some companies require that certain types of accidents (for example,
those involving a fatality) be reported by facsimile, E-mail, or telephone immediately, with a
complete written report following. You might want to include a brief summary of the items
of information that should be reported, where forms can be obtained, how soon the report
must be completed, and other relevant requirements.
Drug-testing. If your drug-testing policy requires tests after certain accidents, then your acci-
dent forms and policies should be coordinated with your drug-testing policy.
Documentation and paperwork. Some companies attach copies of their accident report forms
to the policy statement itself; others simply summarize the various forms that must be
submitted and any special certification required.
Supervisors responsibilities. While most of these will be covered in the items listed, its
usually a good idea to include a paragraph or two stressing the importance of the supervisors
role in investigating the accident, notifying the company doctor or nurse, filling out the report
form, etc.
Confidentiality. Keep in mind that medical information obtained about employees may need
to be maintained in confidence because of applicable laws such as the state workers compensa-
tion laws, the Americans with Disabilities Act, and the Family and Medical Leave Act.
Workers compensation. Accident reports are often required for workers compensation insur-
ance. These forms should also be completed when accidents are reported.
Potential litigation. Your policy should cover the manner in which the report should be
maintained, distributed, and in fact written if there is a potential for litigation. For example,
the report may need to be sent only to your in-house counsel if litigation is suspected. In fact,
if there is potential for a claim, the supervisor may be first instructed to contact your general
counsel before starting any paperwork. You want to avoid a situation in which an accident
report admits liability and is used in future litigation against you.
Separate files. Your policy should probably provide that accident reports are to be kept sepa-
rate from personnel files. The accident report may contain medical information that should be
maintained separately from personnel files under the Americans with Disabilities Act.
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Legal Points
Confidentiality. The information in the report may later be requested in a lawsuit filed
against the company. As you design your policy and form, you should ask your attorney
whether there are different forms for distinct purposes. For example, a workers compensation
form or OSHA log contains information required by law and may be required to be filed with
the government. Other information regarding the accident may be placed on a form to be
submitted to your attorney when you believe that a lawsuit may be filed.
Americans with Disabilities Act. This statute may require that records be maintained in
confidence and that the employer provide a reasonable accommodation.
Workers compensation. Usually these state laws protect employees from retaliation for
reporting accidents or safety violations.
OSHA. In addition to reporting requirements, OSHA also protects employees who report
accidents or report dangerous conditions.
Family and Medical Leave Act. Like the ADA, this law may protect the job of an employee
who takes time off due to a work-related accident. It, too, requires that forms be completed
and records kept when an employee takes such leave.
Drug testing. State laws may govern the manner in which you administer drug tests
following an accident and may require the use of specific notices and forms.
Things to Consider
1. The major consideration here will be whether or not your company is covered by OSHAs
recordkeeping and reporting requirements. If it is, the scope and content of your policy will
probably follow the laws provisions quite closely. If it isnt, and you have developed your own
accident reporting and investigation procedures, you will naturally want your policy to
support these procedures.
2. Your policy should also comply with any workers compensation statute.
3. Another major consideration will be the extent of the responsibility assigned to supervisors in
investigating and reporting accidents.
4. If you already have an established Safety Committee whose task it is investigate a reported
accident, the scope of any policy statement aimed specifically at supervisors will naturally be
limited.
5. You should consider whether different reports are completed when the accident involves a
business visitor. Such accidents may lead to lawsuits and the form in which you record the
events and the persons to whom you give it may become critical issues in litigation.
6. If you have general liability insurance that may cover an accident, you may want to consult
with your insurance carrier when you design your policy and report forms.
7. You may also need to coordinate any short-term and long-term disability or accidental death
policies with your accident reporting policy.
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Sample Accident Reporting Policy
Reporting Accidents and Injuries
All work-related accidents and injuries, no matter how minor, should be reported to your supervisor
immediately. This is for your protection in case medical attention is necessary or in the event of some
future complication caused by the accident.
If first aid is necessary, your supervisor will instruct you to go to one of the occupational health clinics
that we belong to. If needed, transportation will be provided. The proper treatment will be obtained
for all injuries that require professional medical care.
It is the policy of the company to require that all employees submit to a drug and alcohol test after an
on-the-job accident or injury. The tests will be paid for by the company, and the results will be kept
strictly confidential.
The company provides workers compensation insurance for every employee. It protects you for loss
of pay and time and for the cost of medical care for injuries sustained while working. There is a 1-week
waiting period before compensation begins.
If you are involved in an automobile accident, we require that you:
Obtain all information relating to the accident in a professional manner, including the names
and addresses of any witnesses.
Do not negotiate the settlement of any claim, promise payment for any injury or damage, or
admit liability.
You must complete a written report for all accidents and injuries as soon as possible. Forms are avail-
able from both the accounting and the parts departments. Completed accident reports provide necessary
information to the accounting department to allow processing claims with our or the other motorists
insurance companies. Any damage to your vehicle, no matter how slight, must be noted on the accident
report. Failure to complete an accident report will make the cost of all damage the responsibility of the
employee.
Sample Safety and Accident Prevention Policy
Purpose
It is company policy to establish and enforce certain safety and fire prevention regulations to protect
both our physical facilities and the lives of our employees. While it is the human resources managers
responsibility to establish the safety and accident prevention policy, and to provide guidance in meeting
the policys objectives, the responsibility for seeing that specific regulations and procedures are carried
out must be shared by every supervisor and manager in the organization.
Accident and Injury Reports
All corporate facilities are required to submit information on work-related injuries and accidents to
the human resources department on a regular basis. This includes any incidents involving personal
injury to an employee or damage to company property. Specific reporting procedures are as follows:
1. All information pertaining to work-related injuries and accidents must be reported on or
before the third calendar day of each month.
2. Any serious incidents involving personal injury to an employee or damage to buildings, equip-
ment, or property must be reported by facsimile, E-mail, or telephone immediately and
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followed by a written incident report form within 48 hours. If you anticipate litigation
because of the incident, you should first contact the general counsels office and follow its
instructions regarding the preparation of the incident report. This contact with the general
counsel should be made immediately. If litigation is not anticipated, then after contacting the
human resources department, the contact is to be _______________________.
3. Any occupational fatality must be reported by facsimile, E-mail, or telephone immediately and
followed by a written report within 24 hours.
4. Less serious incidents must be reported on a written incident report form within 5 days.
Note: Serious incidents in this context include occurrences of injury, illness, fire, explosion, catas-
trophe, water damage, windstorm, spill, collapse, and any similar event that results in significant
personal injury to an employee or in damage to buildings, equipment, or property.
5. All medical records are to be maintained in confidence in accordance with applicable law.
Reporting Procedures for Serious Incidents
All departments must notify the human resources department by facsimile, E-mail, or telephone as
soon as possible when one of the following events occurs, and a written incident report should follow
within 24 hours:
An accident resulting in the injury or illness of three or more employees
Damage to buildings, equipment, or property amounting to $25,000 or more
Overexposure of an employee to ionizing or nonionizing radiation
Any fire involving radioactive materials
All departments must submit a written incident report to the human resources department within
48 hours of the following incidents:
A fire loss amounting to $1,000 or more
An accident resulting in the total loss of a body member (finger, toe, hand, foot, ear, arm, leg)
An accident resulting in the loss of an employees sight
Damage to buildings, equipment, or property amounting to $5,000 or more
If an occupational fatality occurs, the department manager should notify the human resources manager
by facsimile, E-mail, or telephone as soon as possible (certainly within 1 hour of the incident).
The department manager should initiate an immediate investigation of the accident and submit a
written report of the investigation to the human resources manager within 24 hours of the fatality.
Should circumstances require an extension of time, the human resources manager should be so advised
by telephone, facsimile, or E-mail.
If the department manager or the human resources manager believes litigation is possible, they
should contact the general counsels office for instructions before preparing any written report.
Report Instructions
1. Facsimile, E-mail, or telephone reports must be submitted within 24 hours of an incident and
include all the important details that are available. The following items of information are essential:
Name(s) and job title(s) of employee(s) involved
Date and time of accident
Location of accident
Brief description or summary of what happened
2. Written incident or injury reports:
Should be sent according to timetable previously described.
Should be addressed according to previous instructions.
Should be sent under the designation of System Confidential.
Supervisors are responsible for making sure that an adequate number of these forms are on hand at all
times.
Incident Report
To: _____________________________________
File No. __________________________________
Employees Name ___________________________ Date of employment ___________________
Job Title __________________________________ Department _________________________
Date/Time of Incident _______________________ Date Reported _______________________
Bldg., Rm., Location Where Injury Occurred
_____________________________________________________________________________
Witness Name ____________________________ Job Title _____________________________
Witness Name ____________________________ Job Title _____________________________
Brief description of incident _______________________________________________________
_____________________________________________________________________________
_____________________________________________________________________________
_____________________________________________________________________________
Specific cause of incident __________________________________________________________
Suggestions to prevent recurrence ___________________________________________________
Photographs or sketches of the accident scene with distances, measurements, and significant facts
noted in writing. Photographs should be identified as follows:
Company name and location
Date and time of day
Brief description or caption
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Injury Report
To: ___________________________
File No. _______________________
Employees Name ___________________________ Date of employment ___________________
Job Title __________________________________ Department _________________________
Date/Time of Injury _______________________ Date Reported _________________________
Bldg., Rm., Location Where Injury Occurred
_____________________________________________________________________________
Employees Statement ___________________________________________________________
_____________________________________________________________________________
_____________________________________________________________________________
Medical Diagnosis ______________________________________________________________
_____________________________________________________________________________
_____________________________________________________________________________
Classification [ ] Injury Code_______ [ ] Illness Code______
Results
Back at Work? J Yes J No
Days Away from Work (Count calendar days):
Estimated ______ Actual _____ Time Lost at Later Date ______
Non-Lost Day Cases (Check any that apply)
JMedical treatment other than first aid
JDiagnosis of significant occupational illness or injury
JNeedlestick injury or cut from a sharp object contaminated with another persons blood or other
potentially infectious material
JLoss of consciousness
JRestricted work
JTransfer of job
Record
Employee Social Security Number __________________________________________________
Home Address _________________________________________________________________
_____________________________________________________________________________
Date of Birth____________________ Sex J M J F
Treating Physician/Hospital Address ________________________________________________
_____________________________________________________________________________
_____________________________________________________________________________
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Supervisors Description
Describe what happened and how. Be specific: Name objects, substances, or equipment involved.
_____________________________________________________________________________
_____________________________________________________________________________
_____________________________________________________________________________
How could this accident have been prevented? _________________________________________
_____________________________________________________________________________
_____________________________________________________________________________
Steps taken to prevent recurrence: __________________________________________________
_____________________________________________________________________________
_____________________________________________________________________________
Supervisors Signature ___________________________________________ Date ____________
Dept. Head Review
Comment and Action: ___________________________________________________________
_____________________________________________________________________________
_____________________________________________________________________________
Dept. Heads Signature_____________________ Date_________________
Emergency Policies
Points to Cover
The content of policies on emergencies varies widely, depending on whether the company wants to
group all the different types of emergencies together or treat each one separately. For example, you
might have a policy on accidents, another on what to do in case of fire, and another on violence. The
best approach is the one that will help your supervisors the most. Here are some points to cover:
Definition of emergency. Specify what is considered an emergency situation for the
purposes of your policy statement. Be sure to identify each type clearly on the page if you are
trying to cover more than one. A supervisor who is in a hurry should be able to locate the
information he or she needs without searching unnecessarily.
Procedures to follow. For each type of emergency situation, state clearly and concisely what
the supervisor should do and in what order of priority.
Emergency numbers. You may want to include some useful outside telephone numberssuch
as the local hospital, ambulance service, and police and fire departments. You may also want to
list in-house extensions for people who must be notified; for example, the safety manager,
Human Resources department, company nurse, etc.
First aid. If you dont have a separate policy statement covering the handling of first-aid, this
would be a good place to include them.
Authorized action. Your policy will need to identify who has the authority to make decisions
during the particular emergency. For example, if there is a bomb threat, who has the authority
to order an evacuation of the building?
Follow up. Once the immediate steps have been taken to deal with the emergency, what
should the supervisor do? Are there forms that must be filled out, people that must be noti-
fied, or other follow-up measures that should be taken?
Training. Your policy should state how your employees will be trained to handle emergencies.
For example, will you require that at all times at least four employees be on duty that are
trained in first aid?
Drills. Your policy can state whether, when, and how often you will conduct drills. As an
example, if you are in a high-rise building, you may want to have a fire/evacuation drill several
times a year.
Emergency supplies. Your policy should set forth what supplies are needed and who is respon-
sible to ensure that the supplies are replenished as needed. These lists will vary depending on
the emergencies to which you may be subject.
Review of policy. Because you cannot anticipate the type of every emergency, your policy
should provide for a review of any emergency to determine if you need to make changes to
your procedures or include new ones.
Periodic review of policies. If there are not new emergencies that prompt you to review your
policies, you should require at least an annual review of them. In this fashion, you can set aside
time to anticipate future emergencies.
Media contact. Your policy should indicate what is to occur and who is to be contacted if
there is any media coverage as a result of the emergency.
Continuing operation. Your policy should show who decides if the facility will continue oper-
ation after the emergency or simply close down completely.
Legal Points
Liability. As you draft your policy, you should keep in mind whether you are creating a stan-
dard that is too low or too high. In either event, your written emergency procedure could
become the first exhibit in any trial against your company for negligence.
OSHA. Often, the Occupational Safety and Health Administration (OSHA) requires
employers to be prepared for an emergency, For example, companies are to maintain forms
called material safety data sheets, which detail the steps to take in the event a person is
exposed to a toxic substance.
State occupational health and safety laws. State laws similar to the federal law known as the
Occupational Safety and Health Act may require you to prepare for emergencies.
State safety laws. A state law may require your company to train employees in first-aid proce-
dures. You may also be required to have fire drills.
Wage and hour laws. If you require employees to spend time in emergency training, you
should consider whether you must pay them for such time.
Things to Consider
Here are some topics to be discussed at your policy committee meetings:
1. Authority to act. Do local managers have authority to act in an emergency or will they need to
call the main/home office? Exactly what decisions can onsite management make?
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2. Your companys safety record. What types of emergencies have occurred most frequently in
the past? These should be treated first or featured prominently in your policy statement. A
review of your companys safety record can also reveal how accidents have been improperly
handled in the past, and what you might include in your new policy to avoid similar mishan-
dlings in the future.
3. Supervisory training opportunities. Some companies require all supervisors to complete a
course in first aid and cardio-pulmonary resuscitation. If similar training and educational
opportunities relating to the handling of emergencies are available in your firm, then you can
probably confine your actual policy statement to a few essential points and cover the details in
these training sessions.
4. List of emergencies. As you devise your emergency policy, you should anticipate what emer-
gencies will occur in the future that have not occurred in the past. The following is a list of
possible emergencies which you may need to address: arrest of employee, arrest of customer,
bomb threat, burns, chemical spill, computer failure, demonstrations and civil unrest, earth-
quake, electrical failure, evacuation, fire, flooding, gas leak, removal of records, robbery, severe
winter storm, tornado/sudden storm, violence to or by an employee, violent customer or
intruder, and physical illness and injury.
5. Paying wages for emergency training. If your policy requires that at least four employees who
are trained in emergency procedures always be present, then you need to consider how to
obtain that training for those individuals. Will you simply require that as a condition of
employment? Will you provide training and pay the employee while being trained? Will you
ask for volunteers to be trained during off-duty hours?
6. Emergency audits. You should consider whether there are resources for conducting an audit of
your emergency planning. For example, the local police or fire departments may conduct an
audit of your facility and make suggestions concerning safety. Similarly, your company prop-
erty insurance carrier can advise you as to the safest places to be in your facility in the event of
a tornado.
Sample Emergency Policy #1
Accidents
When an employee in your department is injured, you should see to it that he or she reports to the
company nurse/designated clinic immediately. In cases of serious injury or where an employee has a
seizure, care should be exercised in moving the injured or ailing person. Where there is any doubt, a
stretcher should be utilized.
First Aid
Employees designated as being trained in first aid should be notified if an employee is ill or injured.
The company nurse/local EMTs should be called if the illness or injury is serious.
Fires
Please follow the company fire prevention/evacuation policy. Employees trained in operation of fire
extinguishers can attempt to handle small fires; all other employees should evacuate the building as
previously instructed.
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Sample Emergency Policy #2
In case of a serious accident, call: _____________________
The Human Resources department will make all arrangements to see that the employee/customer
receives immediate attention.
Each employee is responsible to report every work-related injury, no matter how slight, to his or her
supervisor. Failure to do so may cause the employee to lose insurance coverage to which he or she might
otherwise be entitled.
Each supervisor is responsible for seeing that his or her employees report all accidents. The supervisor
is further responsible for seeing that all injuries, no matter how slight, receive immediate treatment.
Minor Injuries
Minor injuries, such as cuts, scratches, bruises, and burns that do not require a doctors treatment,
may be handled using one of the first-aid stations located in the lunch room and throughout the facility.
If a supervisor is treating an injury and is uncertain as to whether a physician is required, he or she
should contact Human Resources for a decision. If someone in Human Resources is not available, the
injured employee should be referred to [local doctor], or to the emergency room at [local hospital].
All injuries or complaints treated at the first-aid stations will be entered into the log book at the
station. Entries shall include the following information:
Date and time of injury
Date and time of treatment
Employees name and clock number
Nature of injury (cut on left ring finger, bruise on right foot, headache, etc.)
Treatment given (washing, use of antibiotic, bandages; employee-requested pain reliever; use
of eyewash; sent to [local hospital], etc.)
Occupational or nonoccupational (Note: If injury happened at home or the employee has a
headache or stomach upset, it is nonoccupational.)
First visit or follow-up (If you are replacing an old bandage, it is a follow-up treatment.)