Books : Managing Worker Safety and Health : Establishing Hazard Prevention and Control Program

When recording information about hazard correction it is important to note all interim protective measures and to include the date of a completed action. Otherwise you run the risk of intended corrections never actually being completed. This may not pose a problem if the hazard can be corrected in a short period of time. Someone probably will remember to see that the final correction occurs. There is always a danger, however, that the expected correction will "slip through the cracks." This can happen when a part has to be ordered and time is needed for procurement or when interim, less than adequate measures become substitutes for preferred but possibly more costly or time-consuming actions.

Tracking by Committee. Some companies separate the tracking of hazard correction from the system that uncovered the hazard. Typically, either a central management safety committee or a joint employee-management committee will devote a part of each meeting to reviewing inspection reports, employee hazard reports and accident/incident reports. The committee will list in its minutes any remaining uncorrected hazards for continued tracking. The benefit of such a system is the high-level scrutiny applied to hazard correction tracking. The system can be cumbersome, however, especially when information must be transferred from the reports to the committee. There is the possibility of information being lost in transit or of incomplete and incorrect information being conveyed. This can be minimized by allowing the committee to review the original reports.

Tracking by Separate Form. Another way to track hazard correction is to transfer information from the original hazard report to a separate hazard tracking report. Ideally, this system receives information on all uncorrected hazards and not just information from one to the avenues for uncovering hazards. Tracking by separate form is most effective when computerized. (Appendix 8-1 contains a form that can be used for this system). For small businesses that do not use written inspection reports or written employee reports of hazards, this system provides important documentation that otherwise might not exist.

The weakness in this system is much the same as for tracking by committee. There is always a possibility that incorrect or incomplete information will be transferred or that a correction which needs tracking will fail to be recorded.

REWARD SYSTEM

Rewarding safe behavior is at least as important as correcting and punishing unsafe actions. Positive feedback can be a powerful motivator. It is especially important to recognize self-initiated acts of safety or health protection - those times when employees, of their own accord, act to protect themselves or others.

A reward system can be very simple and inexpensive: letters or certificates of appreciation, a few hours of paid leave, a special and convenient parking space for a month in the company parking lot, a small pin or tie tack. Evaluate your reward program periodically. If employees are showing signs of losing interest give your program a fresh charge with new ideas.

Rewarding an employee for good safety and health behavior not only recognizes the employee; it also provides incentive to other workers. Public recognition is likely to be more important than monetary value when distributing one-time awards. Of course, taking safety and health performance into account when promoting employees or issuing bonuses is probably the most meaningful reward.

One type of reward program can backfire and should be avoided. Rewards based on the least number of accidents can do more harm than good. They tend to create pressure on employees to avoid reporting injuries and illnesses. For best results, emphasize the positive; reward employees who demonstrate constructive safety and health efforts.

ROLE OF DISCIPLINARY SYSTEMS IN THE WORKPLACE

The disciplinary system does not exist primarily to punish employees. Its purpose should be to control the work environment so that workers are protected and accidents are prevented. A disciplinary system helps ensure workplace safety and health by letting your employees know what you expect of them. It provides workers with opportunities to correct their behavior before an accident happens.

A disciplinary system is one of the keys to successfully implementing your safety and health program. It ensures that your rules and safe working practices are taken seriously by employees and are actually followed. It lets employees know how you expect them to operate in relation to the goals of your safety and health program. And it lays out the actions you will take if individuals do not meet your expectations.

A disciplinary system cannot work in a vacuum. Before you can hold your employees accountable for their actions, you first need to establish your safety and health policy and disciplinary rules. Then you need to develop safe operating procedures, train your employees on these procedures and supervise their actions. The worksheet in Appendix 8-2 will be useful for businesses planning to establish a disciplinary system for the first time.

Policy Statement. Employees need to know where you stand on safety and health and what you expect of them. They need a clear understanding of the rules and the consequences of breaking those rules. This is true in all areas of work, but it is especially important for worker safety and health. As part of the policy statement, or in an employee manual or booklet, you should have a written statement setting forth your disciplinary policy.

Employee Information and Training. It is important that employees understand the system and have a reference to turn to if they have any questions. Therefore, in addition to issuing a written statement of your disciplinary policy, you should draw up a list of what you consider major violations of company policy and less serious violations. This list should specify the disciplinary actions that will be taken for first, second or repeated offenses.

Training can reduce the need for disciplinary action. Instruct your employees in the importance of workplace safety and health, the need to develop safety habits, your operation's safe work practices and the hazards they control, and the standards of behavior that you expect. Be sure your employees understand the disciplinary system and the consequences of any deliberate, unacceptable behavior.

Supervision. Supervision includes both training and corrective action. Ongoing monitoring of your employees work and safety habits gives you and/or your supervisors the opportunity to correct any problems before serious situations develop.

In most cases, effective supervision means correcting a problem before issuing any punishment. Where the relationship between employees and their supervisors is open and interactive problems are discussed and solutions are mutually agreed upon. This type of relationship fosters a work environment where the need for disciplinary action is reduced. When such action is needed, the parties are more likely to perceive it as corrective than punitive.

Employee Involvement. You may want to involve your employees in setting up or revising your disciplinary system. Employees who contribute their ideas to workplace rules and disciplinary actions are more likely to be knowledgeable about the system. They are more likely to understand the system is designed to protect them against the unsafe acts of others. Of course, at sites with collective bargaining agents you will need to involve employee representatives.

Employees should be encouraged to assist in the enforcement of rules and practices. The intent here is not to turn employees into spies and informants, but to encourage them to be their "brother's keeper" and to watch out for the safety and health of their colleagues. Many employers successfully have encouraged an atmosphere -- a company "culture" -- where employees readily speak up when they see an easily corrected problem; for example, a co-worker who needs reminded to put on safety goggles.

Your employees deserve the opportunity to correct their own behavior problems. An effective disciplinary system is a two-way process. Once a problem is spotted discuss it with the employee, who should be given at least one or two opportunities to change the behavior or correct the problem. Only after these discussions (and possibly some retraining) should disciplinary action be taken.

Appropriate Control Measures. Disciplinary actions need to be proportionate to the seriousness or hazardousness of the offense and the frequency of its occurrence. It is certainly inappropriate to issue only oral warnings to an employee who repeatedly removes a machine guard. Appendix 8-3 contains a list of suggested safety and health violations for inclusion in general workplace rules. Appendix 8-4 provides examples of disciplinary actions in three, four, and five-step disciplinary systems.

Disciplinary procedures should not be instituted without explanation. Be sure to provide feedback to the employee on what behavior is unacceptable, why the corrective action is necessary, and how the employee can prevent future violations and disciplinary action. In addition, take time to recognize an employee who improves or corrects the unacceptable behavior.

Consistent Enforcement. If your disciplinary system is to work well and be accepted by your workforce, you must assure your employees -- in word and deed -- that the system applies equally to everyone. This includes subjecting managers and supervisors to similar rules and similar or even more stringent disciplinary procedures.

Documentation. One key to ensuring fairness and consistency in a disciplinary system is keeping good records. It is in the best interest of both the employer and the employee to have written rules and disciplinary procedures. It is just as important to document instances of good or poor safety and health behavior, including discussions with the employee, and to place relevant information in the employee's personnel file.

Documentation serves a variety of purposes. It helps you to track the development of a problem, corrective actions and the impact of measures taken. It provides information which helps keep employees informed of problems that need correction. When you are evaluating the managerial and supervisory skills of your supervisors it provides a useful record of how they handled problems.

If warnings, retraining and other corrective actions fail to achieve the desired effect, and if you decide to discharge an employee, documentation becomes even more critical. Conversely, you may want to consider an annual clearing of the personnel files of employees whose good overall safety records are marred by minor warnings.
 

PREVENTIVE MAINTENANCE

You may not associate preventive maintenance with your safety and health program. Nonetheless, good preventive maintenance plays a major role in ensuring that hazard controls continue to function effectively. Preventive maintenance also keeps new hazards from arising due to equipment malfunction.

Whenever systems are enclosed the enclosure usually depends on the smooth functioning of pipes, valves, pressure releases, etc. Malfunctions of these parts of the enclosed system may result in hazards to workers. Ventilation systems that control hazards rely on the proper performance of duck work, fans, and filters. Many guards are electronic or electrically energized and require maintenance for continuing smooth operation. Equipment that is not hazardous under normal conditions may become so if it malfunctions. Clearly, preventive maintenance is a vital link in any safety and health program.

Scheduling. Preventive maintenance requires reliable scheduling of maintenance activity. The scheduling, in turn, depends on knowledge of what needs maintenance and how often. The whole point of preventive maintenance is to get the work done before repairs or replacement must be done.

Maintenance needs survey. A preventive maintenance program starts with a survey of maintenance needs at the worksite. Every piece of equipment or part of a system that needs maintenance, such as oiling, cleaning, testing, replacement of worn parts or checking, should be surveyed. You will need a complete list of all items to be maintained. If such a list does not exist at your worksite you should require your maintenance supervisor to develop one. The survey should be repeated periodically and the list of items updated. The list should be revised whenever new equipment is placed in the worksite.

Maintenance timetable. Once the complete list is developed a timetable must be established. For each item on your list, estimate the average length of time before the maintenance work becomes reactive rather than preventive. Plan to perform the maintenance before that average time. (Maintenance should be performed at least as often as recommended by the manufacturer). Review maintenance documents periodically to see how much reactive maintenance (repair or replacement of defective parts after failure) has been done. Then make new estimates of average time, and adjust your maintenance timetable accordingly.

Posted or computerized schedules. Make sure the preventive maintenance schedule will help your maintenance staff plan its work. A well communicated schedule also will help to ensure the maintenance department's accountability for performing the work on time. Select a method of communication that works well for your employees.

Maintenance Documentation. Preventive maintenance can be a complicated matrix of timing and actively. But keeping track of completed maintenance tasks can be as simple as adding a date and initials to the posted work schedule. Some employers use their computer system to keep track of completed maintenance activity.

Documentation can help identify and reward employees whose efforts have prevented costly repairs and accidents/incidents. It also can be instrumental in your effort to require accountability of employees responsible for maintenance.

EMERGENCY PREPARATION

This topic is more thoroughly covered by OSHA Publication 3088 (Revised 1991), "How to Prepare for Workplace Emergencies." Here we will consider only the most important general points.

The Nature of Emergencies. During emergencies hazards appear that normally are not found in the workplace. These hazards may be the result of natural causes such as earthquakes, tornadoes, hurricanes, floods or ice storms. Events caused by humans and beyond your control may create hazards, for example, train or plane accidents, terrorist activities, or occurrences at nearby worksites that affect your site. Finally, emergencies may occur within your own systems due to unforeseen combinations of events or the failure of one or more hazard control systems.

Emergencies, by their nature, are not part of the expected, everyday routine. They may never occur, but if they do their cost in terms of both dollar losses and human suffering can be enormous. Your job is to become aware of possible emergencies -- not merely probable events -- and to plan the best way to control or prevent the hazards they present.

Survey of Possible Emergencies. Just because a particular emergency has never occurred does not mean that it never will. Therefore, your emergency preparation should begin with a survey of all possible emergency occurrences by the general categories below, taking into consideration the unique characteristics of your worksite and its location.

Natural disaster. Review each type of natural disaster that has occurred in your geographical area and consult experts on the chances of other types of natural disasters happening.

Human errors or deliberately caused disasters beyond the control of your worksite. Consider the environment of your worksite. Are you near an airport or on an airport's landing/takeoff pattern? Is there a train track used to carry products other than those that you ship or receive? If so, is it near enough so that an accident involving release of toxic materials could impact your worksite? Are there chemicals or other dangerous sites in your neighborhood that could have internal emergencies that might affect your worksite? Have there been terrorist activities against other plants belonging to your company? Against plants involved in similar processes or products?

Hazard control failures at your worksite. Ask yourself, what are the worst things that could possibly happen as a result of conditions here? Every worksite has some potential for fire. Some have much greater potential than others.

Emergency Planning. After listing all possible emergencies you must plan actions to reduce their potential impact on your workers' safety and health. Some actions will be appropriate in all emergency situations. But the measures required by some types of emergencies may differ from or even contradict those needed in other emergency scenarios. Plan what first aid or medical response is needed and where that response will come from. If you are relying on outside medical or emergency response organizations establish communications with them and plan together for emergencies. If possible, have these outside resources participate in your drills.

Employee Information and Training. Your employees need to be informed of the emergency plans that require their participation. Each employee needs to know precisely what is expected in each type of emergency.

For most emergencies, employees should be drilled in the actions you expect them to take. You want their responses to become second nature, so that they will be able to protect themselves and others regardless of the stress of the moment. Fire and evacuation drills should be held annually. For other types of emergencies, such as tornadoes or earthquakes, drills should follow a predetermined schedule based on the frequency and/or probability of the event.

MEDICAL PROGRAMS

Medical programs provide occupational health care, both onsite and nearby. This care consists of approaches to both identifying health problems that may be work-related and responding to injuries and illnesses that occur. The size and complexity of a medical program will depend on the size of the worksite, its location in relation to health care provider organizations and the nature of the hazards at the worksite. Medical programs are covered in detail in Chapter 10, so only summary information is offered here.

You must always be prepared to offer first aid at your worksite. In fact, this is required by OSHA standard [29 CFR 1910.151(b)] for worksites that are not close to medical facilities. We strongly advise that both first aid and CPR assistance be available on every shift at your worksite regardless of distance to medical facilities.

Medical programs consist of everything from a basic first aid and CPR response to sophisticated approaches for the diagnosis and resolution of ergonomic problems. The nature and extent of your medical program will depend on a number of factors. Small business employers can contact the OSHA-funded, state-run consultation service for assistance in deciding what type of medical program meets their site's needs. If use of nearby medical facilities appears to be the best arrangement, be sure to meet with representatives of that facility to discuss your medical needs.

Whatever medical program you decide on, it is important to use medical specialists with occupational health/medical training. Not every nurse or doctor is trained to understand the relationships between the workplace, the work and certain medical symptoms.

SUMMARY

You should approach each category of workplace hazard with the intention of totally preventing it. If total prevention is not feasible you should control the hazard as completely as possible through work and equipment design. To the extent that potential exposure exists despite the designed controls then you should use safety and health rules, work practices and PPE to control that exposure. Finally, you may choose to employ administrative controls to further reduce levels of individual exposure.

To complement these hazard controls, the following components are also necessary: good systems of preventive maintenance, hazard correction tracking, fair and consistent enforcement of rules, work practices, PPE, a solid system for responding to unexpected emergencies, and a good medical program that helps identify hazards and minimize harm when injuries and work-related illnesses occur.

These are the basic components of a hazard prevention and control program. With these measures, you can provide your employees with comprehensive protection from occupational hazards.
 

APPENDIX 8-1