Developing a Safety and Health Program

From: Staffing

---

Professionals in the safety and health industry are concerned with developing what they call a safety culture in the workplace. Basically, this is a pervasive feeling, shared by each employee of an organization, that employees are responsible for their own safety and health and for the safety and health of every other worker in the organization.

This feeling is grounded on each individual’s conviction that he or she has a right to a safe and healthful workplace, a conviction reinforced by the organization’s placing an actual value on safety. Only with sincere commitment from management and serious involvement by employees can safety and health programs be successful.

The key term here is value, defined as a principle, a standard, or belief considered worthwhile and desirable. A safe and healthful workplace should be treated in a way that parallels more familiar values — such as free speech, the right to assembly, and even religion — in that safety and health are permanent parts of the organization’s culture and the environment, not transitory issues that are important at some times but not at others.

The Need for a Safety and Health Program

Every organization needs some sort of a program to prevent injuries and illnesses on its premises. Even complete compliance with OSHA’s guidelines will not eliminate all injuries and illness from the workplace because the workplace is filled with people and people make mistakes.

However, physical safeguards, training, proper maintenance, and good management may help ensure the safety and health of most of an organization’s employees.

Benefits of a Safety and Health Program

Obviously, following OSHA guidelines should result in fewer injuries and illnesses in the workplace, but more rewards will result from a strong safety and health program.

Workers’ compensation costs may be lowered, employee morale and work efficiency may be improved, operating costs will be lowered, and profits will be higher. Accidents are expensive. They add to workers’ compensation and medical costs, they make the organization have to repair or replace equipment, they slow production, and they may require the organization to hire and train new workers. These are just the material costs. The pain and suffering that accidents cause employees and their families can be even more damaging.

Safety and Health Program Requirements

Management Leadership

The National Institute for Occupational Safety and Health (NIOSH) identifies management commitment as the major controlling influence in creating a safe workplace. Managers must lead by using a variety of techniques to demonstrate their commitment to workplace safety and health.

Managers may demonstrate their commitment in a variety of ways, such as:

• Attending safety organization meetings.
• Participating in volunteer groups promoting various safety topics.
• Setting an example by following safety rules and regulations.
• Allowing employees free access to tools and equipment necessary to do a job safely.
• Offering employees training on specific safety issues and attending training programs if appropriate to reinforce employee training.
• Participating in or leading safety and health committees.
• Making presentations on safety and health topics.
• Regularly emphasizing to the community the organization’s concern with safety and health.
• Conducting regular inspections.
• Rewarding the best safety and health suggestions.

Managers should regularly seek employees’ opinions on safety and health issues and especially on how the employees view management’s efforts to achieve a safe and healthful workplace. Managers should be available to hear employees’ concerns about safety and health, and employees should feel free to express their views without fear of reprisal. Any suggestion that management is not totally committed to achieving a safe and healthful workplace will undermine any program in place and reduce an organization’s chances of achieving stated safety and health goals. However, employers must be careful in dealing with employees and having employees acting in a committee actively involved in determining how safety problems and concerns are resolved. The National Labor Relations Board could consider such activity an unfair labor procedure.

Employee Involvement

Since rank-and-file employees are the ones most in contact with potential safety and health hazards in the workplace, it is essential that they be involved in any safety and health program an organization sets up. Since these employees have a vested interest in achieving workplace safety — and have often been demonstrated to be valuable problem-solvers — their suggestions should be encouraged and taken seriously. The wider the field of experience brought to bear on solving safety problems, the better the solution. Additionally, employees are more likely to support a program they have helped develop.

Employees can be involved by allowing them an opportunity to participate in the process of establishing a safety and health program. Employees should have a way to make suggestions and, whenever possible, their suggestions should be implemented, or the employees should be told why their suggestions could not be implemented. When employees’ ideas are implemented, their success should be communicated to other employees. In all instances, employees must be protected against harassment resulting from their involvement in a safety and health program.

Employees may be involved in developing safety and health programs in a number of specific ways beyond simply making suggestions for improvements, such as the following:

• Assisting in conducting site surveys.
• Assessing routine hazards in each step of a job and helping to design safe practices to eliminate or reduce the hazards.
• Participating in the development and revision of site safety and health rules.
• Being involved in training new employees.
• Giving presentations at safety meetings.
• Assisting in conducting accident/incident investigations.
• Participating on committees and other advisory or specific-purpose groups.

Individual Responsibility

Importance of Job Descriptions

Everyone in an organization is responsible for workplace safety and health, but specific responsibilities, authority, and accountability are essential if a safety and health program is going to work. One excellent way to identify an individual’s responsibilities in the program is through clearly detailed job descriptions.

Obviously, job descriptions identify the particular duties and responsibilities of a position, and if these duties and responsibilities include those relating to the organization’s safety and health program a good portion of assigning responsibility for safety and health issues will be accomplished.

Administrator Responsibility

The duties and responsibilities of administrators should be written to include the ultimate responsibility for carrying out the stated company safety and health policy. These individuals should be required to set objectives for the safety and health program, support the program by providing equipment and training, assign clear responsibility for various aspects of the program, and require all employees and visitors — including vendors, subcontractors, and customers — to follow the program.

Supervisor Responsibility

First-line supervisors must be held responsible for supervising and evaluating all safety- and health-related aspects of an employee’s performance. They must encourage and support employee involvement in the safety and health program, and they must recognize and reward outstanding individual and group performance. Additionally, first-line supervisors must maintain up-to-date knowledge of safety procedures and methods of detecting safety and health hazards. They must ensure that good housekeeping, including repair or replacement of equipment, is practiced in their area. They must discourage unsafe or unhealthful shortcuts. Finally, they must make certain that emergency procedures are in place and that everyone under their supervision knows what to do in an emergency.

Employee Responsibility

Employees must know the rules for ensuring safety and health in the workplace and they must observe these rules. Employees must review safety and health materials regularly, get instructions when necessary, and must be fully aware of their responsibilities in an emergency.

Safety and Health Director or Coordinator Responsibility

Safety and health directors must continue to develop their expertise. They must keep informed of new laws and standards dealing with employee risk reduction and with injury and illness record keeping requirements. They must regularly evaluate the company’s safety and health program and practices.

Company safety and health officers must conduct hazard analyses, develop plans for hazard prevention and control, and ensure that any required safety equipment or materials are available. They must help management enforce safety and health practices and help with inspections. Finally, health and safety officers should be responsible for handling investigations of employee reports of hazards and for responding to employee suggestions for improving safety and health.

Importance of Accountability

If a system of accountability is in place, the chances that everyone will fulfill their responsibilities will be enhanced. Individuals will be better able to understand and appreciate the importance of their performance if they are rewarded or punished for their successes or failures in safety and health practices. Accountability here must apply to administrators as well as employees if an organization has any hope of its safety program being followed.

Job descriptions help with accountability as they do with responsibility. Job descriptions detail each individual’s responsibilities in regards to safety and health, for example, “The employee must know how a respirator works and when it must be used.” The individual’s periodic evaluation can include assessment of performance in matters of safety and health. The individual’s safety and health performance must be evaluated in terms of stated safety and health objectives to determine if changes must be made in either the performance or the goals.

If an individual’s safety and health performance is evaluated negatively, for example, a supervisor does not properly investigate an accident, some follow-up monitoring may be necessary to ensure the problem is corrected. Improvement or lack of improvement should be included in later performance evaluations.

Whenever possible, positive reinforcement should be used to get cooperation on safety and health matters. Individuals should want to do well and be recognized verbally, in writing, through awards, or incentives. If, however, positive reinforcement fails, some consequences for poor safety and health performance must follow, ranging from counseling through written reprimand, suspension, demotion, or termination.

Ample Safety and Health Resources

Another essential aspect of any safety and health program is identifying — and subsequently providing — ample resources to ensure compliance with a company’s safety and health program. If safety and health improvements are not made because of costs, an organization may be frustrating its safety and health program through shortsightedness. If only the least expensive measures to improve workplace safety and health are taken, for example, good equipment maintenance and housekeeping, benefits may be limited.

Resources for ensuring safety and health improvements include sufficient funding for improvements and new equipment as well as for training programs and, often, the cost of outside consultants. However, arguments can be made that safety and health improvements will save an organization money in such areas as medical and insurance expenses, workers’ compensation costs, lost productivity, losses due to absenteeism and turnover, costs of equipment damage, and waste of materials.

Existence of a Written Policy Statement

Any worthwhile safety and health program needs a policy statement, a written philosophy underlying the existence of the policy. The policy must be written in the clearest language possible, beginning with an introduction expressing the organization’s real concern for the safety and health of its employees and continuing with detailed descriptions of management and employee responsibilities. Since it is, in fact, the cornerstone of the company’s safety and health program, the policy statement must have the support of management and employees.

By clarifying company safety and health policy, the statement will help ensure consistency and continuity in the application of the policy. It will also provide a checkpoint whenever safety and health concerns appear to conflict with production or other priorities and will support supervisors when they enforce safety and health rules and practices.

Contents of Policy Statement

Policy statements usually have the five parts explained as follows:

• Introductory Statement. This is simply a statement showing concern for employee safety and health and should include a statement such as, “We consider the safety and health of our employees more important than any other aspect of company operations.”
• Purpose/Philosophy. A company’s safety and health program should have a clear purpose or philosophy stated in the written policy so that management and employees are reminded of the program’s intent and value: “Accidents and health hazards have no place in our company. We will involve management and employees in planning, developing, and implementing this safety and health program.”
• Management Responsibilities. A company’s safety and health policy statement should describe exactly who is responsible for ensuring that the safety program works and who has specific responsibilities, duties, and authority, within the program. The safety and health policy should specify all the participating individuals and summarize their responsibilities, perhaps following a general statement such as, “The management representatives who have been assigned the safety and health responsibilities listed below will be held accountable for fulfilling those responsibilities…”
• Employee Responsibilities. The contributions of employees to the company’s safety and health program should be acknowledged and rewarded: “Employees must continue to work to prevent injuries and illnesses. The performance of each employee in this regard will be measured along with that employee’s overall performance.”
• Closing Statement. The written policy’s closing statement should reaffirm the organization’s commitment to providing a safe and healthful workplace and should make a final appeal for management and employee cooperation.

Implementing a Safety and Health Program

Clarifying Goals and Objectives

Underlying any written policy statement describing a company’s health and safety program are, of course, the goals and objectives of the program. Goals can be either numerical — for example, a goal of zero hazards at any time — or descriptive — for example, a program that identifies and attempts to eliminate all potential hazards at a worksite.

To set goals and to identify the steps needed to attain these goals — the short-term objectives — management needs to answer the following key questions:

• Where is the organization currently with regard to safety and health?
• Where does it want to be?
• What must be done to get from where it is to where it wants to be?

Nature of Goals and Objectives

Successful goals and objectives have the following characteristics:

• They are realistic and attainable.
• They are readily understood by everyone seeking them.
• They provide maximum payoff for the time and resources expended to obtain them.
• They are consistent with available resources.
• They are consistent with basic organizational policies and practices.
• They relate directly to the roles of those accountable for attaining them.

For example, an objective such as this one is readily attainable, understandable, requires minimal time and resources, and should lead to the organization’s desired goal of eliminating workplace hazards: “Conduct weekly inspections with emphasis on good housekeeping, proper use of protective equipment, condition of critical parts of equipment, and preventive maintenance.”

Communication of Goals and Objectives

To be effective, safety and health program goals and objectives must be communicated to everyone in the organization. This communication will reinforce the organization’s commitment to safety and health and help ensure that employees know their role in the safety and health program.

Review of Objectives

Management should review its objectives regularly to determine if supervisors and employees are working toward the ultimate goal of a safe and healthful workplace. If too many accidents or near accidents continue to occur, if too many days continue to be missed because of illness caused by workplace conditions, the objectives in place may need to be changed or supplemented.

Providing Safety and Health Training

Once an organization has established and communicated its health and safety goals, training must be provided to ensure that managers, supervisors, and employees can attain these goals. Training can range from simple cautionary warnings given to new workers to elaborate formal training programs.

Although training needs will vary from one job to another, it is likely that all organizations will have to provide some training for new workers, instructing them on how to do a job and how to avoid the hazards associated with the job. Contract workers may need to be trained in the potential hazards of a particular workplace.

The installation of new equipment and changes in certain processes may create a need for training since hazards may be increased or new ones introduced. All employees may require regular refresher training to keep them prepared for potential emergencies. Finally, certain federal and state regulations require training; for example, hazard communication and lockout/tagout.

Training Design

The success of training depends on the commitment of managers, supervisors, and employees to an organization’s safety and health program.

To ensure that this commitment exists, employers must be sure of the following:

• The company’s safety and health policy clearly addresses the organization’s commitment to training.
• Employees were involved in policy development or at least fully understand the policy.
• Management and employees were involved in developing the training program.
• The organization shows its commitment to training by offering paid time for training.
• Ample resources are available to develop the training program.
• The training program will be conducted in such a way that employees will be able to understand it, including alternate languages if necessary.

Note: Training programs need not be complex or lengthy. They may simply be based on a company’s worksite analysis program. Accident and incident reports, including near misses, may be another indicator of training needs. A review of new work practices, new equipment, and new materials would provide a useful starting point for training programs.

Specialized Training Programs

Well-developed training programs, such as the following, focus on certain populations of workers:

• New-Hire Training. New employees and temporary employees may need training in specific potential hazards of their job or the worksite. They also need to learn the organization’s attitude toward safety and health in the workplace. For these individuals, it is essential to communicate the purpose of each instruction in relation to their jobs and to provide them an opportunity to practice their newly learned skills. Errors must be pointed out immediately and successes rewarded. Training methods that use interesting and varied activities work best with this population. Regardless of the length or elaborateness of training, employees must receive instruction in emergency response before they start their jobs.
• Safety and Health Training for Employees. New and experienced employees need regular training on identifying workplace hazards and how to protect themselves and others from these hazards. A common approach here is a combination of classroom and on-the-job training. Often fellow employees can provide useful peer training.

All employees and their supervisors must be taught the proper selection, use, and maintenance of personal protection equipment. Employee training must include motivation to wear personal protective equipment in spite of its awkwardness and the discomfort it may cause.

Employees must be trained to respond to emergency situations. They must learn emergency telephone numbers, evacuation routes, and emergency exits. Trainers should conduct emergency evacuation drills to ensure that every employee is familiar with evacuation signals and procedures.

Note: Such drills should account for visitors, contract workers, and service employees who are frequently overlooked in emergencies.

Employees should also be given periodic training to refresh their memories about safety and health measures and to update them on new measures. Periodic safety meetings are frequently used to keep employees abreast of changing situations.

On-the-job training for employees frequently takes the form of supervisors observing employees at work and then meeting with them to evaluate their work practices, complimenting them on their safe work practices and suggesting changes or providing additional instruction when problems are noted. To ensure that employee training is efficacious, instructors should adhere to the following guidelines:

• Prepare employees for training by putting them at ease.
• Recruit employees who show signs of being good trainers of their colleagues to conduct training sessions.
• Explain the job or training topic.
• Determine how much the employees already know.
• Boost employees’ interest by explaining the benefits of training.
• Pace the instruction to the employees’ learning speed.
• Present the material clearly and patiently.
• Present only as much in one session as the employees can master.
• Have the employees perform each step of specific operations.

Employees should be grouped into practice pairs to work on new skills. They should be closely monitored initially, less as they master the skills. They should be encouraged to build their new skills into their work gradually, ideally under supervision, as follows:

• Safety and Health Training for Supervisors. Since supervisors often conduct on-the-job training, they need to be taught how to train employees. They must also be trained to reward safe working practices and discipline unsafe ones fairly and consistently.
• Safety and Health Training for Managers. Training managers about their responsibilities regarding a safety and health program is essential to their understanding and support of the program and, indeed, to the program’s survival.

Training for managers should emphasize the importance of managers’ visibly showing their support for the safety and health program. They must be taught how to communicate the program’s goals and objectives to employees. They should also be taught the importance of their showing good example by scrupulously following all safety and health rules. Training for managers can be handled in a short time but should be repeated at least annually.

Evaluating Training Programs

Training programs should be evaluated regularly to see if they are actually improving employee safety and health. Programs can be evaluated by testing workers before and after they attend the programs to see if improved performance is evident. Interviews with employees who have attended the programs can show if the employees have understood and can explain appropriate safety and health practices. Based on the evaluation of the program, the employer can decide if it is meeting its goals, should be offered again, or needs to be improved.

Recordkeeping

Organizations should keep records of each employee’s attendance at training sessions, including a brief evaluation of the individual’s participation and success, if appropriate. These records will help ensure that everyone who needs training is receiving it and that refresher courses are provided regularly. They will also provide documentation, when needed, that the appropriate training was conducted.

Identifying Hazards

Identifying workplace hazards is a necessary early step in implementing a safety and health program. Administrators who are not fully aware of existing and potential hazards in their facility must find a way to systematically identify the hazards, using approaches such as the following:

• Conducting regular site inspections.
• Performing periodic comprehensive safety, industrial hygiene, and health surveys.
• Analyzing potential hazards relating to changes such as new or planned facilities, equipment, materials, and processes.
• Performing routine hazard analysis of individual jobs, processes, and production phases.

Workplace Surveys

Note that surveys are not the same as inspections. Employees at the workplace may perform inspections. Surveys should be performed by people who can bring fresh vision and extensive knowledge of safety, health, and industrial hygiene to the workplace. Survey services may be provided by outside experts, although this is not required. Bringing in a person from outside can, however, add a fresh perspective.

Periodic surveys allow an organization to take advantage of any new engineering or scientific knowledge of hazards and their prevention. They will also help identify new hazards that have evolved along with changing work processes and procedures.

Role of the Safety Professional

The role of the safety professional, industrial hygienist, or occupational health professional is to do all of the following:

• Examine the processes in use at the facility.
• Observe each operation.
• Speak with employees.
• Verify the chemical inventory.
• Inspect welding operations.
• Evaluate smoking areas.
• Review respirator maintenance.
• Evaluate personnel training.
• Conduct and shift sampling for air and other hazardous contaminants.
• Measure noise.
• Conduct ergonomic assessments.
• Suggest improvements in the monitoring of health issues.

Because of the important role in developing a workplace safety and health program, individuals selected to conduct the surveys must be well trained, have excellent references, and have relevant experience conducting surveys.

Initiating a Survey

Surveys should start with the OSHA Form 300 Log and Form 300A Summary, in which employers are required to record information about occupational deaths, injuries, and illnesses. The following questions should be asked at the beginning of a survey:

• Have any incidents occurred?
• Do any patterns exist?
• Are applicable written safety programs (for example, hazard communication, hearing conservation) in place?
• Are records of employee visits to clinics or first-aid stations available?
• Are training records maintained?
• Are safety programs communicated to employees?
• Are required posters, warning signs, and tags in use?

Analyzing Potential Hazards

It is usually less expensive to eliminate a problem before it occurs than to correct it after the fact, so individuals conducting surveys should be alert to some frequent causes of workplace problems, such as the following:

• Leased Equipment or Buildings. The age and design of leased buildings — often designed for other purposes — can increase the potential for safety and health problems. Asbestos may be present. Hurried renovations may have omitted some basic considerations, such as repair to loose railings. Safety surveyors should review the facility and any blueprints or renovation plans.
• New Equipment and Materials. Management cannot rely completely on manufacturers of equipment and materials to have analyzed all potential hazards of their products, since they cannot always know exactly how the products will be used at each facility. New materials and equipment can be hazardous and must be inspected carefully to identify potential hazards. Materials and equipment produced outside the United States must be checked for conformity with U.S. standards and laws.
• New Processes. Since new processes require employees to perform new tasks, they may cause new hazards, even if employees are using familiar equipment, materials, and facilities.
• Changes in Workers or Staff. The difference in skill and expertise whenever one employee is replaced by another can lead to greater risk to the new worker and to co-workers.
• Changes in an Individual Worker. Changes in an employee’s health or attitude may affect the employee’s ability to function on the job and can affect workplace safety and health. Organizations must provide orientation and training and reasonable adjustments or accommodations to remove such hazards.

Hazard analysis is usually broken down into routine hazard analysis, which consists of job hazard and process hazard analysis, and complex-process hazard analysis, which involves such areas as failure mode and effect analysis, fault tree analysis, and hazard operability studies. These include mechanical and chemical operations, low- and high-temperature operations, possible radiant energy, and direct contamination of employees and are best left to outside experts.

Job Hazard Analysis

Job hazard analysis breaks down a job into its component steps, listing them in order, and determining if the job can be done without any hazards and what steps can be taken to eliminate existing hazards. Job hazard analysis should be done with the participation of the affected employee and any changes should be reviewed with the employee.

Process Hazard Analysis

Process hazard analysis analyzes any series of actions or operations that convert raw material into a product, from the entrance of the raw material into the factory, through intermediate stages, to the final product and any by-products and waste materials. This form of analysis includes analysis of the use, storage, manufacture, handling, or movement of any chemicals.

Process hazard analysis is usually performed by a team representing different disciplines, opinions, and perspectives, since a single person would usually not have the necessary background to understand all parts of the process. The process hazard analysis team can make use of flow charts to gain a visual and verbal understanding of each step in the process and how each step relates to the next. Additionally, the team can gain information by looking at each employee’s actions and locations throughout the day.

The team must consider the following types of concerns:

• The worker’s potential exposure to hazards.
• The substances and equipment the worker uses.
• The safety implications of the worker’s actions for others.
• Measurements must be made of employee exposure to physical agents (for example, microwave radiation) and air contaminants.

Results of a process hazard analysis may lead to recommendations for preventive measures and controls, including the following:

• Engineering controls.
• New work practices.
• Increased use of personal protective equipment.

Preparing for Emergencies

Another step in implementing a workplace safety and health program is the anticipation of and preparation for the unexpected, a step even harder than identifying potential hazards. Those conducting surveys must analyze the hazards associated with unplanned events, not merely hazards associated with normal operations, such as the following:

• Where in a company’s operations could something go wrong?
• What problems would such aberrations cause?

During emergencies, hazards may appear that are not normally found in the workplace. These may be systems’ hazards caused by failure of one or more hazard control systems or may be natural hazards, such as the following:

• Earthquakes.
• Tornadoes.
• Hurricanes.
• Floods.
• Ice storms.

Regular site inspections — conducted by supervisors and by employees inspecting other employees’ worksites — will help identify some potential emergency situations, especially where dangerous chemicals or volatile explosives are involved, and an effective safety and health program should have procedures in place for handling the unexpected. Beyond inspecting the actual premises for possible emergencies, inspectors should consider hazards beyond the actual workplace. They should, for example, consider the chances for natural disasters likely to occur in the area. They should also consider the potential for human errors beyond the control of anyone in the plant. This might include possible problems from nearby airports or railroad tracks or from potentially dangerous sites in the area. Even political turmoil, such as terrorist activities, might be considered in designing emergency procedures.

As with all aspects of a safety and health program, employee involvement is essential. Employees have special knowledge gained from their close involvement with equipment, materials, and processes. Their involvement in hazard analysis will ensure their cooperation in identifying and correcting existing hazards and in anticipating potential ones. Employees must be trained to cope with emergencies and to contribute to resolving emergency situations by handling emergency equipment.

Once most of the possible emergency situations have been determined, a plan of action must be developed to reduce their potential impact. This would entail the following:

• Informing employees of their roles in potential emergencies.
• Arranging for training in fire prevention and hazardous waste disposal and other dangerous situations.
• Planning for first aid and medical responses required for such emergencies.
• Making plans with outside medical or emergency response providers.
• Conducting regular drills to develop the necessary responses to emergencies.
• Emergency communication systems must be installed and be in working order. Emergency supplies must be available. Fire exits, evacuation maps, and other emergency directions must be installed.

Providing for Hazard Reporting

Another essential step in implementing a safety and health program is developing a hazard reporting system. Employees should be encouraged to report their concerns about safety and health conditions in their workplace, and the written policy detailing aspects of the safety and health program should include information on the procedures to report hazards.

Stating in writing that the organization actively encourages employees to report what they see as hazards reaffirms management’s commitment to the safety and health policy. It also reaffirms management’s intention to protect employees from reprisal for reporting safety or health problems.

Employees should be told to report potentially hazardous conditions or practices in person to a supervisor or in writing through some specific channel. Oral reports should be combined with other methods of reporting hazards. Oral reports do not allow for easy tracking of corrections, do not enable the organization to identify trends and patterns, and are less likely to be followed up than are other forms of hazard reports.

Suggestion programs, which allow employees to report hazards on cards reviewed by management, are frequently used means of increasing employee involvement. Such suggestions must be reviewed as soon as possible, however, to ensure timely action.

There should be a clear distinction between suggestions that are basically improvement ideas and suggestions — or rather hazard notices — indicating a real or perceived workplace hazard. Some companies use hazard cards, which employees fill out and submit to a safety department or similar authority to warn of workplace hazards. Additionally, existing maintenance work orders can log and track unsafe conditions. If the hazard is noted on a work order and a high-priority code is assigned to maintenance requests dealing with safety and health hazards, potential hazards can receive a timely response. Work orders can also be used to document the follow-up and correction of the hazard.

Some organizations have developed anonymous reporting of hazards. Responses to anonymous reports can be through posting of the response in conspicuous areas.

Prompt acknowledgement of receipt of the report and information on management’s assessment of the situation should be given to the employee to eliminate worries about the hazard. Employees should be told what steps, if any, are being taken to correct the identified hazard. If the situation is considered not to be a problem, the employee should be told of this also, but should still be thanked for the report.

Correcting Hazards

Once hazards are identified through inspections, surveys, or reports, they must be corrected; a key step in the safety and health program. If possible, the hazard should be eliminated immediately. If not, interim protection must be provided to temporarily eliminate or control a hazard until more permanent corrections can be made. Temporary measures must be taken no matter how soon complete correction is anticipated. There is no justification for needlessly exposing employees to risk.

Tracking Corrections

When hazards are identified either by inspection or by report, they must be tracked until they are corrected, and tracking corrections becomes another essential step in the effective safety and health program. Tracking ensures that corrective action was implemented and completed, especially in situations where the correction cannot be made immediately. It also keeps reporting employees informed about the organization’s response to the hazard report. Tracking also helps determine where a safety and health program might be improved if the same hazard occurs again.

Investigating and Analyzing Accidents and Incidents

Accidents will occur with the best-designed safety and health program, perhaps because some hazards were not identified or because improvements were inadequate or have not had time to work. Accidents and incidents must be investigated and analyzed to identify their root causes and to prevent their recurring. Even simple mishaps or near misses, where no property was damaged and no injuries occurred, should be investigated if there was the potential for harm.

Selecting the Investigator

Investigators must have proper training and resources. Many companies use trained employees plus a safety supervisor. The trend is to use safety teams with special training.

Seeking Information

Since the purpose of an investigation is to determine the root causes of the accident or incident, assigning blame must be avoided. Investigators should identify facts and opinions as such and be wary of statements laying the blame on others rather than on actual causes.

Fact-finding interviews should be conducted seeking answers to the following questions:

• What happened? This elicits a description of the accident or incident.
• When did it happen? This would include the date and time of day.
• Where did it happen? This includes the rooms, workstations, or other places.
• Who was involved? This could include witnesses, if any.
• How did it happen? This would require a description of the work being done at the time, the condition of the work environment, or other situations.
• Why did the accident or incident occur? This searches for root causes and contributing factors.

Identifying Patterns and Causes

If the same type of accident recurs, the hazard control system may need revision or replacement. Trends or patterns may also identify training needs. Trends may be found by reviewing the OSHA 300 Log, Form 300A Summary, inspection records, employee reports, first-aid logs, and by interviewing employees and first-aid personnel.

After discovering a pattern or root cause, investigators must document the cause and inform management and employees of needed corrections and the time required for completion.

Continuing Hazard Control and Equipment Upkeep

Regular inspections and surveys, along with employee reports, allow organizations to keep hazard information current. With hazards continually identified, they can be controlled or prevented using the following standard methods:

• Safe Work Practices. Implementation of special workplace rules may be necessary to continue to protect employees from hazards. Such special rules include specific procedures regarding the use of potentially hazardous equipment or materials, identification of safe acts or behaviors, lockout or tagout procedures, requirements for personal protective devices, and good housekeeping practices. Special safety and health rules are most effective when they are written, posted, and discussed with affected employees and when employees have a role in formulating the rules. Safe work practices are used in conjunction with engineering controls, not as a substitute for them. Such rules are generally derived from the job hazard analysis.
• Engineering Controls. The work environment and the job itself should be designed to eliminate or reduce employee exposure to hazards. This can be done by completely removing the hazard from facilities, equipment, or processes through design, an ideal solution. When hazards cannot be eliminated or replaced with less-hazardous alternatives, they may be enclosed. For example, moving parts of machinery or heat-producing processes may be enclosed with special materials. Finally, if hazards cannot be removed or enclosed, barriers can be put between employees and the hazards in the form of machine guards, ventilation hoods, or isolation of a process.
• Training. Employees must be taught to identify and avoid hazards. Such training can be achieved through positive reinforcement of employees’ following safe work procedures. Note, however, that reward programs for hours without injury may lead to employees’ not reporting injuries or illnesses and are disfavored by OSHA.
• Enforcement. Safe work practices must be made a condition of employment and violation of workplace safety and health rules must be linked to some sort of corrective action appropriate to the seriousness of the violation. Enforcement must be based on letting employees know what is expected of them regarding workplace safety and health and giving them a chance to correct their own behavior. It should not exist merely to punish employees.
• Personal Protective Equipment. Engineering controls and safe work practices may not completely eliminate hazards. Personal protective equipment — such as face shields, steel-toed boots, safety glasses, or hardhats — may be required, and must be provided at no cost to the employees. Employees must be trained in the need for and proper use of such equipment and the limitations of this equipment must be made clear to the employees.
• Administrative Controls. Administrative controls such as lengthened rest breaks, additional relief workers, exercise breaks to vary body motions, and rotation of workers through different jobs to reduce exposure to hazards may also be employed to help with the continuing control of hazards. Administrative controls should be used in conjunction with other controls that work to eliminate hazards and control exposure more directly.
• Preventive Maintenance. Preventive maintenance is designed to eliminate possible equipment problems and may play a major role in ensuring that hazard controls continue to function effectively and that equipment malfunctions do not cause additional hazards.

An organization should have at least one person who knows the equipment and can schedule the maintenance required to keep the equipment or process operating properly. A preventive maintenance program should include a workplace survey to identify all equipment or processes that may require routine maintenance. This information should be listed and reviewed periodically to ensure its accuracy.

Maintenance should be performed at least as often as the manufacturer recommends. It may be necessary to establish a maintenance timetable for performing maintenance of all equipment listed to ensure that all timetables are being met. Records of all maintenance performed must be maintained, either by a computerized system or simply by dating the posted work schedule. These records can help identify employees who have helped prevent costly repairs and accidents.

Designing a Medical Program

Despite the best planning, injuries and illnesses will occur, and an employer must be ready to provide emergency medical service at the worksite. OSHA requires this for worksites that are not within a five-minute response time of medical facilities. First aid and CPR assistance must be available on every shift. For this discussion, a medical program is any program employers put in place to ensure adequate occupational health expertise within a safety and health program. Medical programs provide occupational health care on site and nearby, making use of varied sources of occupational health expertise. The nature and extent of a medical program depends on the availability of medical expertise in the area, however, the goals of all programs are basically the same — to reduce the impact and severity of injuries and illnesses caused by workplace hazards and accidents.

The size and complexity of a medical program will depend on the following:

• The size and complexity of the worksite.
• The worksite’s location in relation to health care providers.
• The types of hazards that exist at the worksite.

Whichever medical program is put in place, it should use the services of a medical specialist with occupational health/medical training. Not every nurse or doctor is trained to recognize the relationships between the workplace and medical problems. Medical programs work best when they are run by occupational health professionals and especially when a network of occupational health professionals — physicians, nurses, paramedics, and physical therapists — is involved, since one individual usually cannot supply all the service and expertise necessary.

Employers will have to decide, based on the special characteristics of their organization, exactly what services a medical program should provide. Factors such as the type of materials handled, the specific processes in which employees are engaged, the type of facilities, the number of employees, the location of the facility in relation to health care services, and the characteristics of the workforce must be considered. An organization with few employees might find on-site health services impractical, whereas an organization with many employees might find on-site services economical. Some employees might be covered under the Americans with Disabilities Act and be especially vulnerable to illness or injury.

Some companies may find they have employees who fall within the scope of the bloodborne pathogens standard, and the medical program must provide appropriate protections for occupational exposure to infectious diseases, even if there is no obvious risk of such exposure. These are just a few of the many factors employers must consider in designing a medical program.

Medical programs serve three basic functions as follows:

• To work as part of the safety program to prevent hazards that cause injuries and illnesses.
• To recognize and treat work-related injuries and illnesses.
• To limit the severity of work-related injuries and illnesses.

The occupational health professional who runs the medical program should be available to provide expertise to the safety and health committee members, and the medical program should be included as part of any annual review of the organization’s safety and health program.

Occupational health professionals should help decide the basis on which existing or potential hazards are treated at a workplace. They should help determine when employees must be tested for evidence of exposure as required by OSHA standards and perform the testing needed for health surveillance. The occupational health professional should review any employee symptoms and diagnoses to see if patterns appear which indicate an occupational health problem.

Those in charge of the medical program are responsible for coordinating the emergency response duties of all employees and any emergency response organizations — fire departments, paramedics, or other organizations — off the worksite. Occupational health professionals in charge of organizations’ medical programs should ensure that all health care is delivered in accordance with federal and state regulations.

The occupational health professional should also be responsible for keeping confidential records of all accident and health matters involving employees, including visits to first-aid stations, clinics, and hospitals.

Additionally, the occupational health professional should maintain contact with employees who are off work because of occupational illness or injury and with the physicians of these employees. A registered nurse or physician should advise employees off work for an extended time about workers’ compensation rights and benefits.

Finally, those in charge of the medical program are responsible for helping employees who have been off work because of occupational illness or injury return to work, under modified duty positions if necessary.

Program Evaluation

Once a safety and health program is in place and running, evaluate it by periodically asking the following questions — the more “Yes” answers, the better the program:

• Are the program’s goals in writing and understandable by everyone in the workplace?
• Do the goals relate directly to the company’s overall safety and health policy?
• Does senior management support the goals?
• Have achievable objectives related to specific deficiencies been stated?
• Are the objectives clearly assigned to responsible individuals?
• Is there a measurement system to indicate progress toward fulfilling the objectives?
• Can the objectives be explained to everyone in the workplace?
• Does everyone in the workplace know how progress toward fulfilling objectives will be measured?
• Is everyone in the workforce an active participant in reaching safety and health goals?

An organization should review all systems that contribute to the safety and health program — from the program’s initial objectives through the training programs implemented and the emergency procedures set in place to the medical program developed. As a program review identifies weaknesses or needs, the basis for new safety and health objectives emerges.

Regular review of the health program is essential to achieving a safe and healthful workplace. High-quality programs must continuously improve to keep up with the changing nature of the organization and to ensure that an organization’s real commitment to the safety and health of its employees is fulfilled.

Contact Information

Centers for Disease Control and Prevention, Workplace Safety and Health
www.cdc.gov/Workplace

Department of Health and Human Services
www.hhs.gov

National Institute for Occupational Safety and Health
www.cdc.gov/niosh

Occupational Safety and Health Administration
www.osha.gov

Occupational Safety and Health Review Commission
www.oshrc.gov