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Safety & Health Management

System Training

Lesson 3 – Worksite Analysis


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 3 Contents
1. Objectives
2. Accident Investigation
3. Self-Inspection
4. Comprehensive Survey
5. Legal Requirements
6. Job Hazard Analysis
Objectives

• Learn the four methods of worksite analysis:


– Accident/ Investigation System
– Routine self-inspections
– Comprehensive Surveys
– Job Hazard Analysis, or Other Pre-Use Analysis

• Learn how to effectively conduct each method


within your organization.
Poll Question #1
Accident Investigation

• Accident is defined as an unplanned


event that results in personal injury or
property damage.

• Accident is an indication of a deficiency in


the SHMS.
Accident Investigation

• Incident
– An unplanned event that does not result in personal
injury but may result in property damage or is worthy
of recording.
• Near-Miss
– An event that does not result in an injury or damage. It
is important to record and investigate near-misses to
identify weaknesses in the SHMS that could possibly
lead to an injury or damage.
Accident Investigation
• The primary goals of an accident investigation
are:
– To identify the root cause of the accident or incident
– To prevent the accident or incident from occurring
again.

• Accident investigations and reports help identify


these deficiencies.

• Must be conducted and written according to your


organization's established documented
procedures.
Accident Investigation
• The investigation process is "fact-finding" not
"fault-finding". Not to place blame.

• When interviewing witnesses, ask open-ended


questions, listen carefully and be courteous.

• For more guidance on accident investigation,


visit the OSHA website – Accident Investigation.
Accident Investigation
• Accident history records
– Another way to discover potential workplace
hazards.
– Helps you identify past trends.
– To establish focused interventions that will
prevent similar accidents from re-occurring.
– Also known as loss reports/runs.
Accident Investigation
• Elements of an accident investigation.
– A documented procedure is in place when an
employee reports an accident, incident or near miss.
– Procedures include instructions for medical treatment
of employees for all shifts.
– Employees are trained to report accidents immediately
to their immediate supervisor.
– The investigation process may include a team of
employees to ensure that the root cause of the
accident or incident is identified.
Poll Question #2
Poll Question #3
Accident Investigation Exercise 1
• Identify Cause of CHC Accident
– Jim South, the Sales Manager at CHC, was in his
office when he received a phone call from Mark
Rebell. Mark reported that his hand had been injured
and that he needed medical attention. He told Jim that
he had been walking onto a job site while calling a
client on his cell phone. He failed to notice a pile of
debris stored near the sidewalk and accidentally
tripped on a broken piece of pallet. He put his hands
out to stop his fall and his right hand landed on a
corner of the broken pallet, slicing a deep cut into his
hand. He wanted to know what he should do next.
Accident Investigation Exercise 1
Answers
• Question 1
– Answer:
• Jim South should immediately arrange proper medical
care for Mark. While the injury is not life-threatening, it
should be evaluated to determine if sutures are needed.
• Question 2
– Answer:
• Absolutely. This injury may very likely require sutures,
which would make it be recordable on the OSHA Form
300 (discussed on next page). In addition, the root
cause of the accident should be identified so that future,
similar accidents can be prevented.
Accident Investigation Exercise 1
Answers
• Question 3
– Answer:
• Root causes of the accident were: (1) inappropriate
storage of debris near sidewalk used by employees to
access the job site (poor housekeeping) and (2)
distraction of employee as he dialed his cell phone.

• Preventive measures include (1) an action plan for


communicating the importance of contractor
housekeeping at all job sites, (2) routine inspection of all
job sites for improper storage of debris and (3)
prohibition against use of cell phones on job sites
unless employees are in a safe place.
Self Inspection

• Reviewing injury and accident data is important,


but visually inspecting your facility is the only
way to know for sure if hazardous conditions are:
– Present
– To determine if they are adequately being controlled.
– Self-inspections should be conducted on a regular
basis because conditions can change.
Self Inspection

• Self-inspections promote employee participation


by getting many employees involved.
• Those who conduct self-inspections can include,
but are not limited to:
– Top management, members of safety committees,
departmental employees and safety and health staff.
• Rotating the employees who participate on the
inspection team allows more employees to
become involved with the SHMS.
Poll Question #4
Self Inspection – What are you looking
for?
Keep areas for potential hazards in mind
when inspecting the following:
• Housekeeping
– Cleanliness of work area; leakage or spillage;
and cleaning methods
• Building Conditions
– Exit lights functional; exits, stairs, and aisles
free of obstruction
Self Inspection
• Electricity
– Electrical circuits labeled and unused
openings closed.
• Machinery
– Effective guarding of point of operation; and
Lockout/tag out
• Chemicals
– Proper storage and labeling; and protective equipment
available and used properly.
Self Inspection
• Fire Protection
– Fire extinguishers free of obstruction; fire
alarms and sprinklers functional; and
evacuations routes posted.
• Material Handling
– Forklifts, cranes, and hoists properly inspected
and operated.
• Personal Protective Equipment
– PPE is available and maintained properly; and
proper use of PPE.
Self Inspection
• Personnel
– Proper use of equipment; and safe work practices.
• Examples of Self-Inspection Checklists
– OSHA Checklist
– OSHA Handbook for small businesses - Provides a
good overview of self-inspection techniques. (See p.
24 for Checklist.)
– General Safety Audit Checklist (Word Format)
Self Inspection - Assignment
Below are ideas to consider when conducting your self-inspection:
 Train your employees on how to identify hazards prior to starting
the self-inspection.
 Develop and utilize helpful checklists so that you don't forget
anything when you're conducting the walk-through. Add extra
blank spaces so that you can fill in items that are not yet included
on the checklist. Later, you can modify your checklist to
accommodate your particular workplace.
 Wear necessary PPE that may be defined by your organization.
The safety inspection team should not be violating safety
policies!
 Have necessary tools such as a tape measure, camera or
electrical measuring devices to perform quick measurements of
the workplace conditions.
 Don't forget to communicate and distribute the results of the
completed self-inspection to appropriate departments.
 Similarly, don't forget to assign responsibilities and due dates for
completing corrective actions.
Comprehensive Survey
• A comprehensive survey: thorough
investigation of the specific hazards in work
environment.
• Investigates possible harmful conditions,
conducts scientific measurements to determine
potential personnel exposure, and helps to
identify legal requirements where necessary.
• Different from a self-inspection in that it
systematically identifies and documents common
hazards common to your work environment
Comprehensive Survey
Comparison of Results: Comprehensive Survey vs.
Self-Inspection
Comprehensive Survey Self-Inspection

Asbestos ceiling tiles are present in the building being renovated. The asbestos sign has been removed and must be replaced.
Develop a plan to ensure compliance with the OSHA Asbestos
standard 29 CFR 1910.1001, which includes but is not limited to:
employee training, installation of signs and Labels, and personal
protective equipment.

The compressor room is a high noise area. Conduct sound level The box of hearing protection is empty and needs to be replaced.
monitoring in the area to determine if employees must wear hearing
protection when entering or working in the room according to the
requirements of 29 CFR 1910.95.
Comprehensive Survey

• A comprehensive survey should be performed by


professionals trained in occupational safety and
health, industrial hygiene, ergonomics, or other
specific areas.
• Your workers' compensation insurance carrier,
private safety consultants, or even your local
OSHA consultation office may be able to serve
as resources.
Poll Question #5
Legal Requirements

• Purpose of your comprehensive survey is to


identify and understand the legal requirements
with which you must comply
Legal Requirements

• According to the Occupational Safety and Health


(OSH) Act:
– employers are subject to the General Duty Clause at
Section 5(a)(1),
– 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.
Legal Requirements

• States are allowed to develop their own OSH


plans but they must establish standards that are
at least as stringent as those of federal OSHA.

• To determine if your state has its own plan with


which you must comply, see State Occupational
Safety and Health Plans (OSHA website).
Legal Requirements

• Legal requirements are grouped into these


categories:
– Industrial Hygiene
– Workplace Conditions
– Emergency Planning
• We will indicate whether or not the standards
associated with the hazards in each category
require a written program or training.
Legal Requirements

• Keep in mind that this section is not


exhaustive—many hazards are not
covered. What follows are the most
commonly found hazards in general
industry.
Poll Question #6
Legal Requirements

• Industrial Hygiene – Chemical Hazards


– Do your employees handle chemicals or dusty
materials in your workplace?
– If so, it is your responsibility to provide information on
these hazards and to determine if your employees'
exposure exceeds permissible levels.
Poll Question #7
Legal Requirements

• Industrial Hygiene – Other Hazards


– Are your employees exposed to loud noise, repetitive
motions or bloodborne pathogens? If so, it is your
responsibility to provide information on these hazards
and to determine if the exposure to your employees
exceeds acceptable levels
Legal Requirements
• Bloodborne Pathogens (BBP)
– Pathogenic microorganisms that are present in human blood and
can cause disease in humans. These pathogens include, but are
not limited to, Hepatitis B Virus (HBV) and Human
Immunodeficiency Virus (HIV).
• Other Potentially Infectious Materials (OPIM)
– The following fluids: semen, vaginal secretions, cerebrospinal
fluid (CSF), synovial fluid, pleural fluid, pericardial fluid, peritoneal
fluid, amniotic fluid, saliva in dental procedures, any body fluid
that is visibly contaminated with blood, and all body fluids in
situations where it is difficult or impossible to differentiate
between body fluids
Poll Question #8
Poll Question #9
Legal Requirements

• Emergency Planning
– OSHA requires you to develop written emergency
plans and to train your employees appropriately in
case of emergencies, such as fires, chemical spills,
medical emergencies and weather events.
– Exit Routes
– Emergency Action
– Fire Safety
– Medical and First Aid
Legal Requirements

• Required Written Programs and Plans


• Following your comprehensive survey, you may
be subject to developing and implementing some
written programs.
• A written program documents how your company
will comply with the legal requirement, and
OSHA will request to see them if your facility is
inspected.
Legal Requirements

• OSHA has templates for some written plans and


programs that you may customize for your
specific worksite (check your state too).

• The following list of plans and programs are often


implemented by small businesses (not an
exhaustive list).
Legal Requirements
• Bloodborne Pathogen (BBP) Exposure Control
Plan
• Chemical Hygiene Plan
• Confined Space Entry
• Emergency Action Plan
• Hazard Communication Program
• Lockout/Tagout - Mechanical and/or Electrical
• PPE Hazard Assessments
• Respiratory Protection Program
Legal Requirements

• The following plans are not required to be written


but are certainly recommended:
– Forklift Safety
– Hearing Conservation
– Hot Work Permit (required for Process Safety
Management)
• Templates:
http://www.osha.gov/dcsp/compliance_assistance/samplepr
ograms.html
Poll Question #10
Job Hazard Analysis

• Job Hazard Analysis (or JHA) is a valuable


technique, utilized in companies of all sizes, to
routinely examine and analyze safety and health
hazards associated with individual jobs or
processes.
• Note: Some companies use the terms "Job
Safety Analysis" and "JSA" instead of "Job
Hazard Analysis".
Job Hazard Analysis

• JHA can be used to identify, analyze and record:


– the steps involved in performing a specific job.
– the existing or potential safety and health hazards
associated with each step.
– the recommended action(s) / procedure(s) that will
eliminate or reduce these hazards and the risk of a
workplace injury or illness.
Job Hazard Analysis

• JHA is useful for jobs that have high injury and


illness rates.
• Jobs with the potential to cause severe or
disabling injuries.
• Jobs that are new to your operation, or complex
jobs that require written instructions.
Job Hazard Analysis

• Tip: How to start a JHA


– Select the job to be analyzed.
– Define the specific steps or tasks to do the job.
– Define the hazards associated with each task.
– Make recommendations to minimize or eliminate the
hazard.
– When conducting a JHA, involve employees whose
jobs or tasks are being analyzed.
Job Hazard Analysis – Exercise 1

• Conduct a Job Hazard Analysis


– To give you practice conducting a JHA, do one
for changing the oil in your car.
– Identify the steps or tasks in changing the oil
in your car.
– For each task, identify the associated hazards
and then make recommendations to minimize
or eliminate the hazard.
Job Hazard Analysis – Assignment
Remember to involve your employees when
conducting a JHA at your workplace.
 Review your accident history or jobs that are complex
to identify jobs that will benefit from a JHA.
 Develop a team of employees and/or Supervisors to
conduct the JHA and provide training prior to starting
the JHA.
 Outline the job into specific tasks or steps. It may be
helpful to observe or videotape the job being analyzed
to ensure all tasks or steps are included.
 Develop and utilize your own form to record the JHA.
Conclusion

• This is the end of Lesson 3, please take the post-


test and complete the lesson evaluation form.

• Sign up for Lesson 4 and subsequent lessons.

• 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.
Legal Requirements – Reference

Specific OSHA Standards and


Legal Requirements
Legal Requirements
• Industrial Hygiene – Chemical Hazards
– OSHA STD: 29 CFR 1910.1200.
– Hazard Communication standards ensure that the
hazards of chemicals are evaluated and that this
information is communicated to employers and
employees.
– Requires the employer to provide chemical labeling,
MSDS and employee training.
– Written Program Required? Yes. Hazard
Communication Program.
– Training Required? Yes. Initial training and when a
new hazard is introduced
– For More Info: Hazard Communication (OSHA site).
Legal Requirements
• Air Contaminants for Toxic and Hazardous
Substances
– OSHA STD: 29 CFR 1910.1000.
If you have hazardous chemicals in the workplace,
you must determine if there is a legal limit of exposure
that is allowed for your employees and if the levels in
your workplace exceed the legal limit. There are 3
tables in 29 CFR 1910.1000 that list legally
enforceable limits for chemical exposure:
– Table Z-1 - Limits for Air Contaminants
– Table Z-2 - Toxic and Hazardous Substances
– Table Z-3 - Mineral Dusts
Legal Requirements
• Written Program Required? No, but you must
document any air monitoring results, even if the
monitoring reports that there is no employee
exposure.
• Training Required? No.
• For More Info: Hazardous & Toxic Substances
(OSHA site).
Legal Requirements

• Hazardous Chemicals in laboratories


– OSHA STD: 29 CFR 1910.1450.
If you have laboratories in your facility where you
handle hazardous chemicals, you may be subject to
the regulations of this standard.
– Written Program Required? Yes. Chemical Hygiene
Plan
– Training Required? Yes. Initial training and when a
new hazard is introduced.
– For More Info: Laboratories (OSHA site)
Legal Requirements
• Process Safety Management of Highly Hazardous
Chemicals
– OSHA STD: 29 CFR 1910.119.
If your company handles or stores highly hazardous chemicals in
a quantity that exceeds the threshold quantity that is defined in
this OSHA standard, you may be subject to implementing a
Process Safety Management (PSM) Program. This is a
comprehensive program that is designed to prevent catastrophic
releases of highly hazardous chemicals.
– Written Program Required? Yes. This standard actually
requires several written documents such as written process
safety information, process hazard analysis, written operating
procedures, and more.
– Training Required? Yes. Initial training and when modifications
are made to the system. If your employees respond to
emergency releases of hazardous chemicals, initial and annual
refresher training is required.
Legal Requirements
• Noise
– OSHA STD: 29 CFR 1910.95.
You must provide protection against the effects of noise
exposure when the sound levels exceed those indicated by the
OSHA standard. Hearing loss can occur if employees are
exposed to continuous or intermittent loud noise. If noise levels
exceed 85 dBA over a time-weighted average of 8 hours, a
hearing conservation program must be implemented that
includes engineering and administrative controls, hearing
protection, audiometric testing and training.
– Written Program Required? No. A written hearing conservation
program is not required, although you must document sound
level monitoring results and employee audiometric testing. It is
certainly beneficial to develop a written program even though it is
not required.
– Training Required? Yes. Initial and annual training for
employees in the hearing conservation program
– For More Info: Noise & Hearing Conservation (OSHA site).
Legal Requirements
• Ergonomics
– OSHA STD: None.
While there is currently no OSHA Ergonomics
standard, OSHA recognizes the value of implementing
ergonomics programs to prevent musculoskeletal
disorders as well as increase employee comfort and
productivity.
– Training Required? No, not required but certainly
recommended.
– For More Info: OSHA has developed numerous
industry guidelines and other resources to assist you.
– See Ergonomics website.
Legal Requirements
• Bloodborne Pathogens
– OSHA STD: 29 CFR 1910.1030.
If your employees have exposure or potential exposure to blood,
bloodborne pathogens or other potentially infectious materials,
OSHA requires you to implement an Exposure Control Plan.
Jobs where this potential exposure may occur include but are not
limited to: healthcare professionals (nurses, doctors, surgeons,
dentists, etc.), morticians, lifeguards, tattoo and body piercing.
– Written Program Required? Yes. Exposure Control Plan.
– Training Required? Yes. Initial and annual training.
– For More Info: See Bloodborne Pathogens and Needlestick
Prevention (OSHA website)
Legal Requirements

• PPE Hazard Assessment


– OSHA STD: OSHA website for PPE Standards.
You must assess the hazards in the workplace and
properly select the PPE for the hazard and document
this in a written PPE Hazard Assessment (see links
to sample form below). Employees must be trained on
how to use, maintain and replace worn PPE.
– Written Program Required? Yes. The PPE Hazard
Assessment shall have a written certification.
– Training Required? Yes. Initial training on how to
properly wear and maintain the PPE
Legal Requirements
• Industrial Hygiene – PPE
– To protect employees against environmental hazards,
you must provide personal protective equipment (PPE).
– Eye /Face Protection - OSHA STD: 29 CFR 1910.133.
– Eye and face protection shall be provided when
employees are exposed to hazards such as flying
particles, molten metal or liquid chemicals. Examples of
eye and face protection include safety glasses, goggles
and face shields.
– Written Program Required? Yes, included in the PPE
Hazard Assessment.
– Training Required? Yes. Initial training on how to
properly wear and maintain the eye and face protection.
Legal Requirements
• Respiratory Protection
– OSHA STD: 29 CFR 1910.134.
Respirators shall be provided when necessary to
protect the health of your employees against
atmospheric contamination such as harmful dusts,
fumes, mists, gases, or vapors. Examples of
respiratory protection include dust masks, cartridge
respirators and self-contained breathing apparatus
(SCBA).
– Written Program Required? Yes, Respiratory
Protection Program.
– Training Required? Yes. Initial training; refresher
training is required annually and when a new hazard is
introduced.
Legal Requirements

• Head Protection
– OSHA STD: 29 CFR 1910.135.
– Head protection is required when working in areas
where there is a potential for injury to the head from
falling objects. Examples of head protection are hard
hats and bump caps.
– Written Program Required? Yes, included in the
PPE Hazard Assessment.
– Training Required? Yes. Initial training on how to
properly wear and maintain the head protection.
Legal Requirements

• Foot Protection
– OSHA STD: 29 CFR 1910.136.
– Foot protection is required when working in areas
where there is a danger of foot injuries. Steel-toed
safety shoes are an example of foot protection.
– Written Program Required? Yes, included in the
PPE Hazard Assessment.
– Training Required? Yes. Initial training on how to
properly wear and maintain the foot protection.
Legal Requirements
• Hand / Body Protection
– OSHA STD: 29 CFR 1910.138.
– Hand and body protection is required when employees
are exposed to hazards such as harmful substances,
severe cuts or lacerations, chemical or thermal burns,
or harmful temperature extremes. Examples of hand
protection include gloves and gauntlets.
– Written Program Required? Yes, included in the
PPE Hazard Assessment.
– Training Required? Yes. Initial training on how to
properly wear and maintain the hand and/or body
protection.
Legal Requirements
• Work place conditions - What process-related hazards
are present in your workplace?
– OSHA STD: 29 CFR 1910.22 - 1910.30.
Walking / Working Surfaces - Your workplace should be
designed to prevent employee slips, trips or falls. This
includes your housekeeping practices, the protection provided
for floor and wall openings, and the use and design of stairs,
ladders, platforms, and other walking or working surfaces.
– Written Program Required? No.
– Training Required? Not specifically to this OSHA
standard, although your employees should know the
importance of proper housekeeping, the safe use of
ladders and methods of fall protection
Legal Requirements

• Confined Space
– OSHA STD: 29 CFR 1910.146
– Does your workplace contain spaces that are
considered "confined" because their configurations
hinder the activities of employees who must enter,
work in and exit them?
– OSHA defines a "confined space" as a space that can
be bodily entered, has limited means for entry or exit,
and is not designed for employee occupancy.
Legal Requirements
• Confined Space
– When a confined space poses additional hazards, such as entrapment,
asphyxiating atmospheres, or the moving parts of machinery, the space
is defined by OSHA as a Permit-Required Confined Space.
– Ensure safe entry into Permit-Required Confined Spaces by
implementing a written permit space program and properly training your
employees.
– If you decide that you will not train or authorize your employees to enter
confined spaces, be sure to label the spaces appropriately to prevent
unauthorized entry.
– Written Program Required? Yes, for Permit-Required Confined
Spaces (the Permit-Required Confined Space Entry Program).
– Training Required? Yes. Initial training and when a new hazard
is introduced for entrants, attendants and entry supervisors. If
employees are trained to perform rescue duties, they must
practice permit space rescues at least once every 12 months
Legal Requirements
• Machine Guarding
– OSHA STD: 29 CFR 1910.211 - 1910.219.
Moving machine parts have the potential for causing severe
workplace injuries, such as crushed fingers or hands,
amputations, burns, or blindness.
– Any machine part, function or process that may cause injury must
be safeguarded.
– Types of equipment such as abrasive wheels (grinding wheels),
punch presses, woodworking equipment and others must be
protected.
– Written Program Required? No.
– Training Required? Yes, training is required
specifically for mechanical power presses; however,
all employees should know guards are not to be
bypassed
Legal Requirements
• Electrical Safety
– Too many standards to list here. Please see OSHA
"Electrical" Employees who service electrical
equipment must know how to do so safely. Working
with electricity can be dangerous and you should know
how to protect your employees against electrical
hazards.
– Written Program Required? Yes, if your employees
work on or near exposed de-energized parts. The
Lockout/Tagout Energy Control Program may meet
this requirement.
– Training Required? Yes. Initial training and when a
new hazard is introduced.
Legal Requirements
• Lockout / Tagout
– OSHA STD: 29 CFR 1910.147. If your employees maintain or
service equipment, appropriate precautions must be taken to
prevent potential exposure to energy.
– Energy sources should be isolated, locked out and tagged to
ensure that the equipment does not start during the servicing or
maintenance.
– You must develop a written program and provide training to your
employees to protect them from hazardous energy during
equipment servicing.
– Written Program Required? Yes. Lockout/Tagout Energy
Control Program.
– Training Required? Yes. Initial training and when a new hazard
is introduced. Employees authorized to lock out or tag out
machines or equipment must have an annual review of the
employee's responsibilities under the energy control procedure
and an annual periodic inspection
Legal Requirements
• Powered Industrial Trucks
– OSHA STD: 29 CFR 1910.178. Powered industrial trucks must
be maintained and operated safely.
– Each year in the U.S., nearly 100 workers are killed and another
20,000 are seriously injured in forklift-related incidents [BLS
1997, 1998].
– Forklift overturns are the leading cause of fatalities involving
forklifts; they represent about 25% of all forklift-related deaths
– Written Program Required? No. Although not required, it is
beneficial to develop a written procedure that describes your
internal policies for operating powered industrial trucks in your
facility. Therefore, your employees can easily read the rules.
– Training Required? Yes. Initial training and an Operator
Performance Evaluation every 3 years. Refresher training may
be required if an operator operates a vehicle unsafely, is involved
in an accident or near-miss or meets other criteria as indicated in
the OSHA standard
Legal Requirements
• Exit Routes
– OSHA STD: 29 CFR 1910.34 - 1910.37 You must comply with
the requirements for exit routes in the workplace to minimize
dangers to employees during an evacuation.
– Written Program Required? No.
– Training Required? No.
• Emergency Action
– OSHA STD: 29 CFR 1910.38.
An Emergency Action Plan is required by some OSHA standards
and is generally recommended by OSHA. This plan describes the
actions that employees will take to ensure their safety in a fire or
other emergency.
– Written Program Required? Yes. Emergency Action Plan.
– Training Required? Yes. Initial training and when a new plan is
introduced
Legal Requirements
• Fire Safety
– OSHA STD: 29 CFR 1910.39.
A Fire Prevention Plan is required by some OSHA
standards, although it is generally recommended to
implement one. In addition, there are several fire
safety issues to address in your facility such as the
storage of flammable liquids, welding and paint spray
finishing.
– Written Program Required? Yes. Fire Prevention
Plan.
– Training Required? Yes, initial training and when a
new hazard is introduced.
Legal Requirements
• Medical and First Aid
– OSHA STD: 29 CFR 1910.151.
While it is your ultimate goal to keep your workplace free from
recognized hazards, it is appropriate to plan for responding to
employee injuries. This can include providing access to medical
personnel, providing first aid supplies and providing first aid
training to employees.
– Written Program Required? No.
– Training Required? Yes, if you choose to train your employees
in CPR and First Aid. Don't forget to include Bloodborne
Pathogens training if these employees have exposure to blood or
other potentially infectious materials.
– For More Info: Medical and First Aid (OSHA site)

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