If
you are to protect your employees from workplace
hazards you first must understand just what
those hazards are. Are you sure you know all
of the potential hazards generally associated
with your type of business and your specific
working conditions?
A
means of systematically identifying all workplace
hazards would be useful. OSHA's Safety and Health
Program Management Guidelines address such an
inventory. The Guidelines recommend:
Periodic,
comprehensive safety, industrial hygiene and
health surveys:
Change
analysis of the potential hazards in new facilities,
equipment, materials and processes; and
Routine
hazard analysis, such as job hazard analysis,
process hazard analysis or phase hazard analysis.
These
three major actions -- comprehensive surveys,
change analysis and routine hazard analysis
-- form the basis from which good hazard prevention
and control can develop. After hazards are recognized
and controls are put in place, additional worksite
analysis tools can help ensure that the controls
stay in place and that other hazards do not
appear. For a detailed discussion of these additional
tools, such as inspections, employee reports
of hazards, accident and incident investigations,
and accident pattern analysis, you should refer
to other chapters.
But
first you need to understand the existing and
potential hazards in your workplace.
COMPREHENSIVE
SURVEYS
Comprehensive
surveys are not the same as inspections. An
inspection is often done by employees at the
site. Comprehensive surveys should be performed
by people who can bring to your worksite fresh
vision and extensive knowledge of safety, health
or industrial hygiene. Because there are few
professional consultants equipped to do comprehensive
surveys in all three areas, the best approach
is to use a team consisting of three separate
specialists: a safety professional, an industrial
hygienist and an occupational health professional.
The
occupational health professional can be a physician
or a registered nurse with specialized training
and experience in occupational health. A professional
can assist the safety or industrial hygiene
professional or do a separate health survey,
depending on the circumstances at your site.
For the selection criteria for occupational
health professionals, see Chapter 10.
For
small businesses, safety and industrial hygiene
experts usually can be found in the OSHA-funded,
state-run consultation service. Occupational
health professionals sometimes can be found
at local clinics and hospitals or may be no
farther away than the plant nurse. Larger businesses
can contract for safety and health expertise
or find it at the company or corporate level.
If
you use experts from within your company be
on guard for "tunnel vision," which
can lead to a failure to spot hazards in areas
not directly related to your firm's primary
function. You will want your maintenance shop,
for example, to be just as safe as your production
line. We frequently find unguarded saws and
grinders, non-code electrical wiring and other
basic safety hazards in areas that are outside
the main production process but regularly used
by employees.
For
the industrial hygiene survey you should, at
a minimum, inventory all chemicals and hazardous
materials in the plant and review the hazard
communication program. For many industries a
survey of noise levels and a review of the respirator
program will also be vital.
Questions
to Ask Before Contracting for a Survey
To
ensure that your worksite will receive the comprehensive
survey envisioned by the Guidelines, you may
want to ask potential surveyors certain questions:
What
type of training and experience has your prospective
surveyor had?
How
recent is it?
What
is its scope? Is it limited to your industry
only? Does it consist of only practical
experience, without formal training?
If
certified, is certification still valid
or has it lapsed for lack of recent training
or seminar attendance?
Ask
for references and check those where comprehensive
survey have been done recently.
Ask
references whether any OSHA inspections
occurred after the survey and if so, whether
any serious hazards were found that the
consultant had missed.
Find
out what tools the consultant used and what
was covered.
What
kind of information will consultant need in
advance? A professional who is planning an
in-depth survey will prepare by learning beforehand
as much as possible about your worksite and
its processes.
Both
safety and industrial hygiene professionals
will probably want to see a layout of your
operations.
The
industrial hygienist may ask for a list
of the chemicals you use or the Material
Safety Data Sheets (MSDSs) you have received
from your suppliers and the types of processes
in which you use them.
What
kind of test equipment will the consultant
bring?
You
should expect the safety professional to
bring: a tape measure; a ground loop circuit
tester to test electrical circuits; a multi-meter
or Wiggins (for 220 and/or 440 volts only);
a tic tracer (or similar equipment) to check
wire or electrical equipment to see if they
are energized; and a ground fault circuit
interrupter tester.
The
industrial hygienist should bring noise
testing equipment and, depending upon the
chemicals or other contaminants expected,
sampling pumps or grab sampling devices.
How
long will the survey take?
It
should take several times longer than a
routine inspection of your worksite.
If
the industrial hygienist does sampling,
it should be time-weighted, 8-hour or full-shift
sampling to understand the overall exposure
to employees.
How
Will You Know the Surveyor Has Done a Thorough
Job?
Here
are some signs of a thorough survey:
Safety
professionals, industrial hygienists and occupational
health professionals should start with your
injury and illness logs and look for patterns.
The
safety professional also may want to see
other program documentation.
The
industrial hygienist and occupational health
professional will want to see your hazard
communication program, and if applicable,
your hearing conservation and/or respirator
program.
The
occupational health professionals will want
to see your records of employee visits to
clinics, first aid stations and other sites
where treatment is given for work-related
illness and injury. They will want to examine
records of employee training in first aid,
CPR and EMT. Baseline and follow-up testing
records probably will be reviewed also.
The
safety professional should start at the beginning
of your process, where raw materials are brought
in, and carefully go through all your processes,
watching each operation and talking to employees
until the point where your worksites' product
is shipped out or otherwise completed. The
process should include:
Watch
how materials are handled and stored, checking
the stability of storage racks and the safe
storage of flammable/explosives;
Check
the openings that expose moving parts for
pinch points and other hazards;
Check
hand tools and equipment and wiring in the
maintenance shop;
Arrange
to see operations on every shift and to
observe any after-hours operations, such
as clean-up or forklift battery recharging;
Show
interest in how you manage your hazard prevention
and control program;
Open
every door and look in every corner of your
facility;
Walk
around the outside of buildings to check
on such things as chocks for trucks at the
loading/unloading docks, fork lift ramps,
outdoor storage of flammable/explosives
and any fueling areas;
Suggest
target tasks for job safety analysis, especially
those tasks that might involve ergonomic
hazards; and
Assist
in developing or improving your injury reduction
program.
The
industrial hygienist and occupational health
professional should start at the beginning
of your production operation, observe all
processes, talk to employees and follow the
production flow to the point of shipping.
They will want to:
Check
your inventory of chemicals against what
can be found in the worksite;
Determine
what metals are used in any welding operations;
Check
any production areas where eating or smoking
is allowed;
Check
for the possible presence of asbestos, lead
carcinogens, etc;
If
respirators are used, check whether you
are using each brand properly, how each
employee is fit tested, whether pulmonary
function testing is done and how the respirators
are cleaned, maintained, and stored;
Do
full-shift sampling of contaminants thought
to be present in order to understand the
overall exposure to employees;
Watch
the movements workers make in performing
their jobs to see if there are existing
or potential cumulative trauma disorders
(CTDs) or other ergonomic hazards;
Possibly suggest processes for routine process
hazard analysis; and
Help
set up or improve regular monitoring programs
for any contaminants or other health hazards
found to be present.
Note:
The items above are signs of a thorough survey.
They do not constitute an exhaustive list of
activities you should expect.
The
baseline survey should provide the basic inventory
of hazards and potential hazards of your worksite.
This hazard inventory will be expanded and improved
by what you learn from later periodic surveys,
change analysis and routine hazard analysis.
However, the foundation of your inventory is
the baseline comprehensive survey. Consequently,
it is very important that this initial survey
be done well.
Follow-up
Surveys
You
need periodic follow-up surveys if you are to
apply the rapidly growing scientific and engineering
knowledge about hazards, their prevention and
their control. These follow-ups also help uncover
the hazards that develop as processes and procedures
evolve over time. The necessary frequency of
follow-up surveys will depend upon the size
and complexity of your operations.
CHANGE
ANALYSIS
Before
making changes in the worksite, analyze the
changes to identify potential hazards. Anytime
you bring something new into your worksite,
whether it be an entirely new building, a piece
of equipment, different materials or a new process,
you unintentionally may introduce new hazards.
If you are considering a change for your worksite
you should analyze it thoroughly beforehand.
This change analysis is cost-effective in terms
of the human suffering and the financial loss
it prevents. Moreover, heading off a problem
before it develops usually is less expensive
than attempting to fix it after the fact.
An
important step in preparing for a worksite change
is considering the potential effects on your
employees. Individuals respond differently to
change, and even a clearly beneficial change
can throw a worker temporarily off-balance --
literally as well as figuratively -- and increase
the risk of accidents. You will want to inform
all affected employees of the change, provide
training as needed and pay attention to worker
response until everyone has adapted.
The
nearest state consultation program will look
at plans, blueprints and photographs and will
advise you on health and safety concerns. This
assistance will not trigger an enforcement visit.
Building
or Leasing a New Facility. Even something
as basic as a new facility needs to be reviewed
carefully to identify hazards it might pose.
A design that seems to enhance production of
your product and appears delightful to the architect
may be a harmful or even fatal management decision.
Have safety and health experts take a careful
look beforehand at all the design/building plans.
Leasing
a facility that was built for a different purpose
at an earlier time increases the risk of acquiring
health and safety problems. You should make
a thorough review of the actual facility, plus
the blueprints or plans for any renovations.
One of the most obvious concerns in acquiring
an existing facility is whether asbestos insulation
is present and whether it is friable (flaking
off in tiny particles). But you also may discover
that something as easy to fix as a loose stair
railing has gone unnoticed in the rush to renovate
production areas.
Save
frustration, money and lives: have expert safety
and health professionals involved in the planning
of any facility purchase or lease.
Installing
New Equipment. An equipment manufacturer
does not know how its product will be used at
your worksite. Therefore, you cannot rely totally
on the manufacturer to have completely analyzed
and prepared controls or safe procedures for
the product. Moreover, if the equipment is produced
in a foreign country it may not meet clear requirements
of U.S. standards and laws. Therefore, involve
health and safety professionals in the purchase
decision and in the installation plans.
Many
companies also provide a period to test newly
installed equipment. The company assigns its
most experienced operators to watch for hidden
hazards in the operations before full production
begins. As with new facilities, the sooner flaws
are detected the easier and cheaper corrections
are likely to be.
Using
New Materials. Before introducing new materials
to your production processes research the hazards
that the materials themselves present. Also
try to determine if any hazards can occur due
to the processes you plan to use with the materials.
The
place to start is usually the manufacturer's
Material Safety Data Sheet. An MSDS is required
for all materials containing hazardous ingredients.
It should arrive with each shipment. The MSDS
should provide the information an industrial
hygienist needs in order to analyze an ingredient
which may pose a hazard, as well as the means
to prevent or control it.
Some
traditional materials, such as lead in paint,
are dangerous to use but are replaceable with
less hazardous mixtures. For other materials
you may not be able to find adequate substitutes.
You may need to establish controls for the hazards
these materials present.
Starting
Up New Processes. New processes require
workers to perform differently. Consequently,
new hazards may develop even when your employees
are using familiar materials, equipment and
facilities. Carefully develop safe work procedures
for new processes. After the operators have
become familiar with these procedures, perform
routine hazard analysis (discussed below) to
discover any hidden hazards.
Analyzing
Multiple Changes. Often a big change is
composed of several smaller changes. When you
start up production of a new product chances
are you will have new equipment, materials and
processes to monitor. Make sure each new addition
is analyzed not only individually but also in
relation to the other changes.
Once
you have analyzed the changes at your worksite,
add this information to your basic inventory
of hazards. This inventory is the foundation
from which your hazard prevention and control
program is designed.
When
People Change. Worker changes that have
safety and health ramifications can be divided
into two basic categories. The first is staffing
changes. A task previously done by one worker
now is being performed by someone else. The
new employee may bring to the position a different
level of skill from the previous jobholder.
Almost certainly each will possess a different
degree of experience in performing the tasks,
in following the specific work rules and procedures
of the site, and in interacting with nearby
workers. Especially in high hazard situations,
these differences should be examined and steps
should be taken to minimize any increased risk,
both to the new employee and to anyone affected
by the change. Chapter 10 offers a variety of
training and job orientation methods that will
help you to ensure a safe employee transition.
The
second category of worker change is the sometimes
sudden, sometimes gradual change that can occur
in the individual employee. The change may be
related to temporary or chronic medical problems,
a partially disabling condition, family responsibilities,
family crisis and other personal problems, aging,
or the worker's response to workplace changes.
An analysis of this change, followed by physical
and/or administrative accommodations to ensure
safe and healthful continued performance, sometimes
may be appropriate, as for example when an accident
affects an employee's functioning. At other
times a less formal response will be more suitable.
It
may be useful to remember that workplace hazards
do not exist in a vacuum. The human element
is always present, and the human condition is
one of change. An effective manager will be
sensitive to these changes and their potential
effect on the safety and health of the individual
and the company as a whole.
JOB
HAZARD ANALYSIS
This
is the most basic and widely used tool in routine
hazard analysis. It is sometimes called job
safety analysis. You begin by breaking down
a job into its component steps. This is best
done by listing each step in order of occurrence
as you watch an employee performing the job.
Next you examine each step to determine the
hazards that exist or that might occur. Reviewing
the job steps and hazards with the employee
performing the job will help ensure an accurate
and complete list. Manufacturer's equipment
operating instructions or Material Safety Data
Sheets (MSDSs) should also be considered.
Now
determine whether the job could be performed
differently to eliminate the hazards. Would
it help to combine steps or change the sequence?
Are safety equipment and other precautions needed?
If a safer way of performing the job is possible,
list each new step, being as specific as possible
about the new procedure. If no safer way to
perform the job is feasible, determine whether
any physical changes will eliminate or reduce
the danger. These might include redesigning
equipment, changing tools, adding machine guards,
using personal protective equipment or improving
ventilation. Establishing a personal hygiene
routine may be appropriate where toxic dust
is a hazard.
Review
these new safe work procedures with all employees
performing the job. Obtaining their ideas about
the hazards and proposed changes is an important
part of this process. It will help ensure that
your proposed changes are sensible and are accepted
by the workers you are trying to protect. Many
companies have experienced success in assigning
the workers who perform the tasks to the job
hazard analysis team.
Improvements
in job methods can lead to reduced costs resulting
from employee absenteeism and workers' compensation
and often can lead to increased productivity.
Detailed information on this important tool
can be found in the OSHA Publication 3071, "Job
Hazard Analysis."
PROCESS
HAZARD ANALYSIS
A
process can be defined as any series of actions
or operations that convert raw material into
a product. The process can terminate in a finished
product ready for consumption or in a product
that is the raw material for subsequent processes.
OSHA's
Process Safety Management of Highly Hazardous
Chemicals standard (Part 1910.119 of Title 29
of the Code of Federal Regulations) defines
process for the purpose of the standard as any
activity involving a highly hazardous chemical,
including any use, storage, manufacturing, handling
or on site movement of such chemicals, or a
combination of these activities. This standard
aims to protect employees by preventing or minimizing
the consequences of chemical accidents involving
highly hazardous chemicals.
Two
useful booklets dealing with the standard are
OSHA Publication 3131, "Process Safety
Management," and OSHA Publication 3132,
"Process Safety Management - Guidelines
for Compliance."
Employers
should refer to the standard and its appendices
to determine if they have processes covered
by the standard and to take advantage of the
standard's greater detail regarding requirement
for establishing a process safety management
program. Such a program includes conducting
process hazard analyses. However, the concept
of process safety management is relevant and
useful to the full range of workplaces, not
only those subject to the standard's requirements.
We believe that any business aiming for a comprehensive
safety and health program will benefit from
conducting a process hazard analysis.
A
process hazard analysis is a detailed study
of a process to identify every possible hazard
presented to employees. Every element of the
process must be studied. Each action of every
piece of equipment, each substance present,
and every move made by an employee must be assumed
initially to pose a hazard to employees. Process
hazard analysis then is applied to show that
the element either poses no hazard, poses an
uncontrolled hazard, or poses a hazard that
is controlled in every foreseeable circumstance.
Often
the process hazard analysis will concentrate
on the specialized equipment used in the process.
The equipment may be used to:
Move
materials;
Apply
mechanical forces or concentrations of energy
to materials (e.g., ionizing radiation, magnetic
or electric fields, and lasers);
Mix
materials; or
Bring
the hold materials together and contain them,
under either ambient or special conditions,
for chemical or biological reactions, etc.
Processes
may be either batch or continuous. Some operations
may be conducted remotely. There may be special
instrumentation to monitor conditions at various
stages in the process. These instruments will
keep the operator informed and perhaps also
directly control the process or shut down operations
if a hazardous or otherwise undesirable condition
is approaching.
The
best time for an employer to conduct a process
hazard analysis is when the process is first
being designed, before equipment is selected.
This review, in turn, will assist you in choosing
process equipment for its effective, efficient,
and safe operation. Be sure to consider the
equipment's capacity for confining the process
within predetermined safe limits. The type,
number, and location of detectors you select
for monitoring the process should ensure not
only productive operation but also safe operation.
Remember to take into account any substance
or mixture of substances that could present
fire and explosion hazards.
When
you have selected your equipment, the information
from the process hazard analysis will help you
to develop an appropriate inspection and maintenance
schedule.
Remember,
even when a process initially appears to be
so simple that hazard analysis during the design
phase seems unnecessary, it needs to be done
anyway. If the process is simple, and there
are no known potential hazards, then the process
hazard analysis likewise will be simple and
will require very little time and expense. On
the other hand, if things are not as simple
as they seem the analysis may reveal potential
problems that might have been overlooked otherwise.
Correction at this early stage will save time,
money, and possible injuries and grief.
Process
hazard analysis will include hazards associated
with:
Mechanical
and chemical operations,
Low
and high temperature and pressure operations,
Possible
high levels of radiant energy,
Direct
contamination of employees, and
Contamination
of the air with toxic substances.
Remember
that toxic substances may be the raw materials
entering the process, the intermediate products,
the final products, or the by-products or waste
products.
Who
Should Do the Process Hazard Analysis? A
team approach is the best approach for performing
a process hazard analysis because no one person
will possess all of the necessary knowledge
and experience. Additionally, when more than
one person is performing the analysis, different
disciplines, opinions, and perspectives will
be represented and additional knowledge and
expertise will be contributed to the analysis.
At least one member of the team should be an
employee who has experience and knowledge of
the process being evaluated. (See the standard
at 1910.119(e) concerning makeup of the process
hazard analysis team.)
Small
businesses may need to hire expert consultants
to assist in the development of the analysis.
If you have a small business and you do not
know whether your process requires a high degree
of expertise, call for advice from your local
office of the OSHA-funded, state-run consultation
service.
OVERVIEW
OF THE PROCESS
Start
by writing down answers to the questions contained
in the Appendix 7-1 worksheet. With the answers
to these questions, combined with any additional
information pertinent to your operation, prepare
a detailed narrative report. Your report should
be clear enough to be understood even to persons
unfamiliar with the process.
Process
Flow Chart. Unless your process is very
simple, with only one or two steps, you should
now prepare a diagram or flow chart of the process.
The flow chart is a detailed expansion of the
overview. It is prepared as a visual and verbal
description of each step in the process, clearly
relating each step to the others. A careful
review of the flow chart should reveal any elements
not considered in the overview. For an example
of a process flow chart, see Appendix 8-2.
Hazardous
Substances. Examine each substance in the
process: raw materials, intermediate products,
final product, by-products and wastes.
Be
sure to look at all activity involving substances
that could produce hazardous conditions or products.
Consider the potential for the air's oxygen
content being reduced in any inhabited space,
especially confined spaces. Study the potential
hazards of each substance -- toxicity, fire
or explosive hazard, and others. (This is a
requirement of 29 CFR 1910.1200(d).) See how
each substance appears in the process and in
what quantity. Is each hazardous substance being
handled in a way that minimizes its hazard?
Could a less hazardous material be substituted?
With
these answers you can plan your program of prevention
and control. Take the precautions necessary
to protect your workers, beginning with substitutions
and engineering controls. Establish work practices
and use personal protective equipment (PPE)
as necessary. The topic of hazard prevention
and control is covered in Chapter 8.
Equipment.
Look at all the equipment, from that used to
bring in the raw materials at the beginning
of the process to the equipment used to move
out the products, by-products and waste products
at the end of the process. It must be safe not
only for the operator but also for other workers
nearby.
Look
at the materials handling equipment throughout
the process. Examine all the machines used to
bend, form, cut, grind, mill, smooth, or otherwise
change the surface or contours of solid materials.
Look at equipment used to weld, crimp, rivet
or otherwise fasten one solid piece to another.
For
liquids and gases there will be enclosed systems
for transfer and storage, vessels for mixing,
and reactor vessels that may be subjected to
high or low temperatures and/or pressures. If
there are exothermic reactions, reactions that
release heat, are there adequate provisions
for removing the heat? Look at any special equipment
capable of producing hazardous levels of radiant
energy.
Once
you have determined the potential hazards you
can plan your prevention/control by using the
safest equipment, implementing engineering controls
and work practices, and providing and ensuring
the use of PPE as necessary.
Worker
Exposure. Look at each worker's locations
and actions throughout the workday. With what
substances and equipment does the worker interact?
Does the worker perform actions that result
in a hazard for the worker or others?
Employee
exposures to physical agents such as microwave
radiation will have to be measured with special
instrumentation. Air contaminants will have
to be measured to determine exposure levels.
Will air contaminant levels and worker exposure
rise when outside doors and windows are closed
at the end of summer?
Once
you know the exposures you can plan you prevention/control
employing engineering controls, work practices
and PPE as necessary.
See
Appendix 8-3 for a process hazard analysis worksheet.
PREPARING
FOR THE UNPLANNED EVENT
When
dealing with high hazard chemicals or volatile
explosives it is not enough to analyze only
those hazards associated with normal operations,
i.e., those times when the process works as
expected. Using analytical tools such as "what
if," "checklist," hazard and
operability study (HAZOP), failure mode and
effect analysis (FMEA), or "fault-tree"
analysis can determine most of the possible
process breakdowns. You then can design prevention/controls
for the likely causes of these unwanted events.
"What
if" analysis, appropriate for relatively
uncomplicated processes, starts with points
in the process where something could go wrong.
You should then determine what else could happen
and what all possible outcomes would be. You
must plan additional prevention and controls
for those possible unplanned events that could
contribute to an undesirable outcome.
For
more complex processes, the "what if"
study can best be organized through the use
of a "checklist." Aspects of the process
are assigned to analysis team members with the
greatest experience or skill in those areas.
Operator practices and job knowledge are audited,
the suitability of equipment and materials of
construction is studied, the chemistry of the
process and the control systems are reviewed,
and the operating and maintenance records are
audited.
Hazard
and operability study is a method for systematically
investigating each element of a system to uncover
ways in which important parameters can deviate
from the intended design conditions, and as
a result, can create hazards and operability
problems. Typically, an analysis team studies
the piping and instrument diagrams (or plant
model). The team analyzes the effects of potential
deviations from design conditions in, for example,
flow, temperature, pressure and time. The team
then assesses the system's existing safeguards,
the causes of a potential for system failure
and the requirements for protection.
Failure
mode and effect analysis is a methodical study
of component failures. This review starts with
a diagram of the process and includes all components
that could fail and conceivably affect the safety
of the operation. Typical examples are instrument
transmitters, controllers, valves, pumps and
rotometers. The components are listed on a data
tabulation sheet and individually analyzed for
their potential mode of failure, the effects
of failure, detection methods and other factors.
The last step in the analysis is to analyze
the component data and develop recommendations
for risk management.
In
"fault-tree" analysis you start with
an undesirable outcome that is possible, even
if highly unlikely, given the potential hazards
involved in your process. Then you trace back
into the process to identify all possible events
or combinations of events that would have to
occur to produce that outcome. Since this information
is graphically represented using logic symbols
in a determined sequence of events, you then
can design prevention/controls to make it impossible
or nearly impossible for them to occur.
For
additional information on methodologies, see
OSHA's Process Safety Management of Highly Hazardous
Chemicals standard at 1910.119(e) and OSHA Publication
3133, "Process Safety Management - Guidelines
for Compliance."
UPDATING
THE PROCESS HAZARD ANALYSIS
After
completion of the initial process hazard analysis,
the analysis should be updated at least every
5 years to ensure that it is consistent with
the current process. This update is required
for businesses covered by the standard and the
analysis must be revalidated by a team meeting
the standard's requirements.
PHASE
HAZARD ANALYSIS
Phase
hazard analysis is a helpful tool in construction
and other industries that involve a rapidly
changing work environment, different contractors
and widely different operations. A phase is
defined as an operation involving a type of
work that presents hazards not experienced in
previous operations or an operation where a
new subcontractor or work crew is to perform
work. Before beginning each major phase of work
in this type of hazard analysis, the contractor
or site manager should assess the hazards in
the new phase. The assessment should not only
coordinate appropriate supplies and support
but also prepare for hazards that can be expected
and establish a plan to eliminate or control
them.
To
find these hazards and to eliminate or control
them, you will use many of the same techniques
that you use in routine hazard analysis, change
analysis, process analysis and job analysis.
One major additional task will be to find those
hazards that develop when combinations of activities
occur in close proximity. Workers for several
contractors with differing expertise may be
intermingled. They will need to learn how to
protect themselves from the hazards associated
with the work of nearby colleagues as well as
the hazards connected to their own work.
INVOLVING
WORKERS IN ESTABLISHING THE INVENTORY
Whenever
you can, use the special knowledge your workers
have gained from their close involvement with
equipment, materials and processes. You should
encourage your employees to communicate openly
with the professionals who do the comprehensive
surveys. Workers frequently participate in change
analysis of new equipment and/or processes because
of their valuable insights into how things really
will work. As mentioned above, many companies
regularly include hourly operators in job hazard
analysis. Employees can play a similar role
in process hazard analysis. In addition to the
benefit that you receive from their insights,
they also profit. Greater understanding of hazards,
prevention and control helps them do a better
job of protecting themselves and their co-workers.
USING
THE INVENTORY OF HAZARDS
You
will use the surveys and analyses we have described
to plan a program of hazard prevention and control.
Chapter 8 explains this program. Briefly, you
should prevent hazards by substituting less
hazardous materials or equipment whenever possible
Engineering controls that distance the worker
from the hazard are the next best option. For
the remaining hazards, design safe work practices,
train your workers adequately in these practices
and enforce them consistently. Use personal
protective equipment where needed. In some rare
instances, you may also need to establish administrative
controls, such as worker rotations or more frequent
work breaks.
SUMMARY
Establishing
a complete hazard inventory is not as complicated
as it may sound. It begins with having industrial
hygiene, safety and occupational health experts
conduct a comprehensive survey of your worksite
to determine the existing and potential hazards.
Periodic surveys, done at intervals that make
sense for the size and complexity of your worksite,
will bring into play any new engineering or
scientific knowledge of hazards and their prevention.
They also can help find new hazards that have
evolved along with changing work procedures
over time.
Change
analysis prevents expensive problems before
they occur. Individuals who are knowledgeable
in worker health and safety can help in designing
and plan for changes in your worksite. Change
analysis uses elements of routine hazard analysis
appropriate to the type of change being contemplated.
Routine
hazard analysis also adds to your inventory.
It enables you to control hazards that develop
in work procedures or within processes, or that
occur because of changes in the phases of the
operation.
The
tools and approaches used in the various types
of hazard analysis tend to overlap. This overlapping
helps ensure total coverage and a more comprehensive
inventory on which to base your prevention program.
Involving
your employees in the effort to inventory hazards
is sure to pay off. Hazard surveyors will benefit
from workers' practical knowledge. And employees
will be better able to protect themselves and
others as they become more knowledgeable about
workplace hazards, prevention and controls.
When
assessing workplace hazards do not overlook
the human element. Whenever one employee is
replaced by another the difference in skill
and experience can mean increased risk to both
the new worker and his/her co-workers. Many
factors can affect an employee's ability to
function; as an example, changes in an employee's
health or personal life may affect work performance,
and in turn, the level of workplace safety and
health. These changes can either be sudden or
gradual. A manager needs to be sensitive to
these changes and willing to provide training
and orientation, physical and administrative
adjustments, or other accommodations.
APPENDIX
7-1
PROCESS
OVERVIEW WORKSHEET
Begin
your process hazard analysis by writing down
answers to the following questions:
1.
What kind of process is it? Mechanical?
Chemical? Biological?
2.
What is the product?
3.
What is the rate of production?
4.
What raw materials will be used? How much?
5.
Will there be intermediate products? Their
quantities?
6.
Will there be waste materials that will
be a problem because of their toxicity
and/or their quantity?
7.
Does this process pose inherent hazards
that suggest that you should look for
a safer way to product the product?
8.
Have there been previous incidents involving
this process that had a potential for
catastrophic consequences in the workplace?
9.
Is the process sited where it could be
affected by a failure in nearby processes
or where its failure could affect other
processes?
10.
What kinds of equipment are used in the
process? Is other, safer equipment available?
11.
Is there sufficient and reliable monitoring
and control equipment? Is it fail-safe
in all instances.
12.
What are the various workers' roles?
13.
Where employees work directly with substances
and equipment, are their activities as
safe as possible?
14.
Are there points in the process where
workers' exposure to hazards could be
reduced?
15.
Could emergency situations develop? How
many unexpected events could happen at
the same time? What would result?
Combine
the above questions and answers and any added
information that you believe pertinent into
a detailed narrative report. This will be the
basis for your process flow chart.
APPENDIX
7-3
PROCESS
HAZARD ANALYSIS WORKSHEET
1.
Name the process.
2.
Give the date the operations began.
3.
Write a short description of the process.
4.
Conduct an overview, write a narrative and attach
it to this form.
(See Appendix 7-1). Date completed?
5.
Prepare process flow chart and attach. (See
sample, Appendix 7-2).
Date completed?
6.
For each step in the process as shown on your
flow chart, identify and
