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Safety & Health Management

System Training

Lesson 4 – Hazard Prevention &


Control
Safety Health Management
System (SHMS) Webinar Series
In this series of webinars developed under
the Susan Harwood Grant, you will learn:
o Lesson 1 - OSHA and the Importance of
Having a Safety Health Management System
(SHMS)
o Lesson 2 – Management Commitment &
Leadership
o Lesson 3 – Worksite Analysis
o Lesson 4 – Hazard Prevention & Control
o Lesson 5 – Safety & Health Training
Lesson 4 Contents
1. Objectives
2. Hazard Controls
3. Preventive Maintenance
4. Managing Change
5. Occupational Health Program
6. Emergency Planning
7. Contractor Safety
8. Management Review
Objectives

• Learn to implement systems to


eliminate or prevent hazards.

• Learn about different types of hazard


controls:
– Preventive maintenance and managing
change
– Emergency planning, occupational health
programs, and contractor safety
Hazard Control

• Some control measures are more


effective than others at reducing the
hazard.
• Be aware of the different types of
controls available and the benefits and
limitations of each.
• Each of the SHMS models introduced in
Lesson 1 require the implementation
and maintenance of hazard controls for
risk reduction.
Hazard Control
• The first consideration for controlling
hazards is to eliminate the hazard or
substitute a less hazardous material or
process.
• An example of this method is utilizing a
water-based paint rather than a solvent-
based paint.
• This control measure minimizes flammable
vapors as well as eliminates health
concerns associated with solvent-based
paints.
Hazard Control

• When it is not possible to


eliminate a hazard, you should
control the hazard using the
following methods (in order):
– Engineering controls
– Administrative controls
– Personal Protective Equipment
Hazard Control
• Applying this hierarchy is a
systematic approach to
identify the most effective
method of risk reduction. You
want to select the highest-
level feasible control.
Hazard Control - Engineering

• If hazard elimination or
substitution is not feasible,
engineering controls should be
considered next.
• Engineering controls are physical
changes to the work area or
process that effectively minimize
a worker's exposure to hazards.
Hazard Control - Engineering
• Enclosed Hazard
– Enclosure of the hazard, such as enclosures
for noisy equipment.
• Isolate Hazard
– Isolation of the hazard with interlocks,
machine guarding, welding curtains, and
other mechanisms.
• Remove / Redirect Hazard
– Removal or redirection of the hazard such as
with local and exhaust ventilation.
• Redesign Workplace
– Redesign of workstation to minimize
ergonomic injuries.
Poll Question #1
Hazard Control
• If engineering controls are not feasible
you must then consider implementing
administrative controls.

• Administrative controls
– No physical changes
– Limits daily exposure to hazards by
• Adjusting work tasks or schedules.
Hazard Control - Administrative
• Examples of administrative
controls include:
– Limited time exposure to hazards

– Written operating procedures,

– Work practices, and

– Safety and health rules for employees.


Hazard Control - Administrative

– Alarms, signs and warnings

– Buddy system

– Training

– Stretching exercises and break


policies
Poll Question #2
Hazard Control - PPE

• Personal Protective Equipment


(PPE):
– Used when hazards cannot be
eliminated through engineering or
administrative controls,

– Must consider personal protective


equipment (PPE) necessary for
employee protection
Poll Question #3
Hazard Control - PPE

• According to OSHA, PPE is acceptable


as a control method in the following
situations:
– Engineering controls do not eliminate
hazard
– While engineering controls are being
developed
– Administrative controls and safe work
practices are not sufficient protection, and
– During emergencies.
Hazard Control

• The most effective control measure = all


three hazard control types.
• For example, consider an operation that
generates silica dust.
– A ventilation system may be installed to
control dust (engineering control),
– Employees are trained and a sign is posted to
warn employees of dangers (administrative
controls) and
– Goggles are required to operate the
equipment (personal protective equipment).
Hazard Control

• Scenario CHC Determines Hazard Control


– CHC was awarded a contract to replace an
exhaust fan on the roof of a high school. Mary
White sends a copy of the JHA that was
developed for this task (see Lesson 3) so that
the Operations crew can review and develop
the appropriate hazard controls.
– The Operations Foreman, Jack McDonald, is
particularly concerned about the fall protection
for the roof where the work will be completed.
He proceeds through the hierarchy of controls
to ensure adequate protection to prevent falls.
Hazard Control
• Hazard Elimination. Can this work be done
below 4 feet where fall protection would not
be required? The Operations crew agreed
that the work cannot be done below 4 feet,
and therefore engineering controls must be
considered.
• Engineering Controls. The Operations crew
reviewed the roof area where the work will
be conducted. There are no physical barriers
such as railings at the roof's edge and it is
not feasible to install them for this project
alone. Administrative controls were then
considered.
Hazard Control
• Administrative Controls. Fall protection warning
lines could be installed 6 feet from the roof's edge to
warn employees when they are close to it. Although
this is not a physical barrier, employees will be
warned of their proximity to the roof's edge.
Additionally, one employee will be stationed near the
warning line when work is being done close to it.
Employees have been trained in safe work practices
to prevent falls.
• Personal Protective Equipment. Some of the
employees will work in an area with a roof skylight
that is not guarded with railings. These workers will
be instructed to wear personal fall arrest equipment
and lifelines attached to an appropriate anchor
point.
Preventive Maintenance
• A breakdown of equipment in your
facility may cause hazards.
• For example,
– A pump that fails during the process of
delivering hazardous materials through your
production facility may create a hazardous
condition.
– The best way to prevent breakdowns or
failures is to monitor and maintain your
equipment regularly. Determine what hazards
could occur if your equipment is not
maintained properly and plan to detect
failures before they occur.
Preventive Maintenance
• Implement a written preventive
maintenance program,

• Safety Equipment Examples - A


confined space entry gas monitor

• Determine the intervals of required


maintenance on your equipment
Preventive Maintenance

• Non-Safety Equipment Example.


– Forklifts in your facility have daily and
annual inspection requirements. If there is
any deterioration in the hydraulic cylinders
or tires the capacity rating reduces and
there may be a failure during a lift.
Establish a regular inspection on a
preventive maintenance schedule to keep
these devices operating safely.
Preventive Maintenance

• When developing systems, be sure to


include one for Disciplinary actions that
cover all (employees, and contractors)

• Ensure that it is applied consistently

• Hazard Correction tracking –hazards that


have been identified must be tracked in
order to eliminate and implement controls
Poll Question #4
Manage Change
• A management of change program
ensures that any modifications or
additions to your equipment or
processes are understood and
controlled, and includes:
– Updating relevant building or
equipment drawings,
– Modifying safety procedures, and
– Training employees on the changes.
Manage Change

• Such a program is required for


processes that utilize highly hazardous
chemicals that are subject to the OSHA
Process Safety Management program
(29 CFR 1910.119).

• However, this program is beneficial for


all changes in your business, even if
OSHA doesn't require it.
Manage Change

• Conduct an analysis of new equipment


and processes
• Develop a system to conduct:
– Comprehensive survey,
– JHA, or
– Other worksite analysis technique on new
equipment or processes
• Implement appropriate controls before
being placed into service
Manage Change
• Example - Suppose your business
introduces a new raw material into the
production process. You must consider
the following:
– How the material will be stored and handled
– What PPE may be required if engineering or
administrative controls are not effective at
controlling exposures
– If appropriate eyewash and safety showers
are available, and
– How to train your employees..
Occupational Health Program
• An occupational health program allows
you to respond effectively to workplace
injuries and illnesses and to monitor
potential health problems.
• Medical Services & First Aid
– You must make available physician
services, first aid and CPR to your
employees. This does not mean that you
must provide health care, but you are
expected to get medical help when medical
conditions arise from work-related events.
Occupational Health Program

• Medical Screening
– Some OSHA standards require
medical screening of employees.
Medical screening monitors if
exposure to a hazard leads to a
potential decline in health.
– An example is exposure to noise and
the Hearing Conservation Program.
Occupational Health Program

• Employee Medical Records


– The maintenance and confidentiality of
employee medical records are crucial.
– According to OSHA, you must maintain an
employee's medical records for the duration of
employment plus 30 years.
– Records include employment medical
questionnaires or histories, results of
laboratory tests or medical screening, or
physicians' opinions from work-related injuries
or illnesses.
– Develop a system to maintain these records
and to ensure that they are kept in confidence.
Occupational Health Program

• For more information on employee


medical records, see the OSHA
standard Access to Employee Exposure
and Medical Records (29 CFR
1910.1020).
Occupational Health Program

• Wellness Program
– In your occupational health program,
consider including health and wellness
programs for your employees.
– Smoking cessation programs, diet and
nutrition education, and physical fitness
programs are examples of programs that
encourage employees to lead a healthy
lifestyle, which helps them be healthy for
work
Poll Question #5
Emergency Planning

• Effective planning for emergencies


and non-routine events is another
mechanism of controlling hazards
and avoiding employee injuries.
You have already learned about
the legal requirements for
emergency planning.
Emergency Planning
• Written Emergency Plan
– Determine the actions that employees will take in
the event of a fire, chemical release or natural
disaster.
– Keep in mind those employees with disabilities,
language barriers and limited literacy.
– Develop the written plan and train your employees
prior to an emergency. Don't forget unexpected
events such as terrorist acts or workplace violence.
– List emergency contacts and ensure the document
is updated regularly to reflect current personnel.
You can find a template for writing Emergency
Action and Fire Prevention Plans on Department of
Labor’s website.
Emergency Planning
• Emergency Eyewash and Safety
Showers
– Install emergency eyewash and safety
showers where chemicals are used or
stored to provide quick flushing if an
employee is exposed to the chemical.
– Pay close attention to areas such as
battery charging stations, maintenance
operations, and laboratories where
corrosive materials are often used and
require prompt flushing to prevent
significant skin or eye damage.
Emergency Planning

• Emergency Eyewash and Safety


Showers
– Include these units in your preventive
maintenance program. It's important
to inspect and flush the units
regularly to verify operation and to
ensure the water lines are clear of
debris prior to emergency use.
Emergency Planning
• Emergency Drills
– Practice the elements of your
emergency action plan by
conducting regular fire and/or
natural disasters drills.
– Ensure that employees know
how to evacuate buildings,
where to take shelter and who
will take headcounts.
Emergency Planning
• Emergency Contacts
– Post emergency numbers at centrally
located bulletin boards and update
the list regularly to reflect current
personnel.
– Ensure that employees who will
operate critical equipment following
an emergency are properly trained.
Emergency Planning

• Local Emergency Responders


– Coordinate your emergency planning
with the local emergency responders,
such as the fire department and/or
hazardous materials teams.
– Invite them to your facility to teach
them your specific worksite hazards
and to improve the emergency
response time.
Contractor Safety

• Most companies hire contractors at


some time to perform specific tasks
for which their own employees may
not have the time or expertise.
• It is in your best interest to ensure
that contractors at your worksite(s)
are appropriately trained and follow
all safe work practices.
Contractor Safety
• Selection Criteria
– Establish selection criteria for hiring
contractors.
– Consider the contractor's past performance
in safety and health during the bid process.
– This may include requesting data from their
OSHA 300 Log for several years.
– Ensure that contractors have an effective
safety and health management program in
place prior to entering your worksite.
Contractor Safety
• Oversight
– Establish oversight, coordination and
enforcement to ensure the contractor
safety and health program is
adequate and implemented properly.
– Verify that contractors comply with
applicable safety and health
regulations by conducting regular
inspections of the area where the
contractors are working.
Contractor Safety
• Establishment of Procedures
– Develop appropriate entry and exit
procedures for the contractors.
– If cigarette smoking is allowed on
your worksite, establish safe
locations for contract employees to
smoke, keeping away from storage of
flammable or dust-explosive
materials.
Contractor Safety
• Prompt Control of Hazards
– Ensure prompt correction and/or
control of any hazards that are
identified under the contractor's
control.
– Consider penalties such as
contractor correction and/or
contractor dismissal for repeated
noncompliance by contractors,
vendors or individuals.
Contractor Safety

• Injury & Illness Reporting


– Develop a system so that all injuries
and illnesses that occur during work
performed on a contract are reported
to you or someone in your company.
Poll Question #6
Contractor Safety – Exercise 1

• CHC Selects a Crane Contractor


– Instructions: Evaluate the following
data submitted from three different
crane contractors.
– Each contractor has approximately
the same number of employees.
– Based on their safety performance
alone, which contractor would you
select?
Contractor Safety – Exercise 1

Company # of Injuries Employee


(Last 3 Years)(a) SHMS in Place? S&H Training
Required?

A 8 No No

B 1 Yes Yes

C 3 Yes Yes

(a) Injuries that company recorded on OSHA 300 Log.


Contractor Safety – Scenario

• CHC’s Welding Contractor


– CHC hired a contractor to assist with welding
operations while installing an exhaust fan on
the roof of the high school.
– Mark Rebell was walking the job site when he
noticed the welding contractor did not
enclose the welding area, where practical,
with appropriate welding curtains and did not
have a fire extinguisher nearby during the
welding operation.
– Although no one was injured and there was no
building damage, this action clearly violated
the standard CHC safe practice
Contractor Safety – Scenario
• Mark immediately notified the CHC
Operations Foreman. Together, they told
the workers of the welding contractor
to halt the work.
• Then, they called the Foreman of the
welding contractor to discuss the
correct and safe work practices.
• CHC wrote a Near-Miss Report to
document the action and reviewed the
corrective actions with the welding
contractor.
Contractor Safety – Scenario

• The welding contractor was told that if


another unsafe act was observed, CHC
would remove his workers from the job
site and his company would be removed
from the list of approved contractors.
• If the contractor had violated a safety
rule that had the potential to cause
death or serious physical harm, he
would not have been given another
chance and would have been removed
from the site immediately.
Conclusion

• This is the end of Lesson 4, please take


the post-test and complete the lesson
evaluation form.

• Sign up for Lesson 5 or any other sessions.

• In order to get your certificate of


completion for this series, you must
complete all 5 lessons.
• This course, funded by an OSHA-sponsored
Susan Harwood grant, is designed to assist
small and medium sized businesses in
developing and implementing an effective
safety and health management system.
• This material was produced under grant SH-
17814-08-60-F-24 from the Occupational
Safety Health Administration, U.S. Department
of Labor. It does not necessarily reflect the
views and policies of the U.S. Department of
Labor, nor does mention of trade names,
commercial products, or organizations imply
endorsement by the U.S. Government.

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