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.