EVALUATING
YOUR SAFETY AND HEALTH PROGRAM
INTRODUCTION
The
scenario: Your safety and health program
is in place. You have set your goal for
the year and clearly stated the objectives,
procedures, and activities necessary to
meet that goal. Responsibilities have been
defined and clearly assigned. Adequate authority
and resources have been allocated. People
have been trained in their safety and health
program roles, and they understand the consequences
of failing to perform their assignments.
Your
responsibility for employee safety and health
does not stop here. The next step -- a critical
one -- is to evaluate how well your safety
and health program is working.
This
process is more than an inspection or an
audit. Inspections are necessary to look
at the facility, the process and the individual
jobs in order to identify and then to eliminate
or control any hazards that may exist. Audits
focus on program activities and seek to
determine whether specific objectives have
been met. For example, if you are assessing
employee participation by looking at the
activities of the safety committee you will
want to know if that committee met at the
intervals specified, and if most of the
members attended each meeting. These are
audit questions.
But
beyond this simple accounting are larger
questions. For example, has employee participation
at safety committee meetings helped improve
the worksite's safety and health program?
How is the work of the safety committee
helping you meet your goal? These are the
kinds of issues addressed by an evaluation.
A
safety and health evaluation looks at the
systems you have created to carry out your
safety and health program. It asks if these
systems are working effectively and efficiently.
All systems that contribute to your safety
and health program should be reviewed. These
should include management leadership and
the evaluation of that leadership, the analysis
of the worksite to identify hazards, hazard
prevention and control, accident and near
miss investigations, employee involvement,
safety and health training, use of personal
protective equipment (PPE), the health program,
and the emergency response program. The
site may have additional programs or systems
that contribute to the safety and health
program. You will need to evaluate these
also.
Who
should conduct the evaluation? Although
evaluations can be performed by worksite
employees, they are best done by people
who are knowledgeable about the site's processes
and managing safety and health programs.
The evaluator should not work at the site
being evaluated. The fresh look an outsider
brings produces a more accurate and helpful
evaluation. This outsider may come from
corporate headquarters, another worksite
within the company, an insurance company
or a consulting firm.
Evaluation
often causes anxiety for workers. You may
be able to reduce that anxiety by letting
your employees know that the evaluator will
be focusing on systems and not on people.
Three
useful tools for this evaluation are document
review, employee interviews and review of
site conditions. These tools will provide
the basis for an evaluation report. This
report should contain a list of the programs
or systems reviewed and a narrative account
of the examination of each system or program.
It also should contain a schedule of needed
changes with target completion dates, responsible
parties, and space to indicate the date
when changes are actually completed. Some
reports include pictures of excellent situations
and those needing improvement. Some provide
a grading system, so that each year's results
can be compared quickly to previous years.
This report should be available to any employee
who wants to read it. This chapter will
explain in detail how you can accomplish
this evaluation.
WHAT
SHOULD BE EVALUATED?
Ideally,
everything that you know to be contributing
directly to your safety and health program
should be evaluated. OSHA's Safety and Health
Program Management Guidelines can help you
determine which areas of your program need
evaluation. These are the four major areas
of the Guidelines, that are called Major
Elements:
1.The
demonstration of management leadership and
employee involvement through:
-
Setting and communicating the safety and
health policy;
-
Setting and communicating a clear goal
and objectives;
-
Being visibly involved in employee safety
and health;
-
Assuring employee involvement in safety
and health problem identification and
resolution;
-
Assigning clear responsibility for safety
and health;
-
Giving adequate authority and assuring
efficient use of resources;
-
Holding all personnel accountable; and
-
Assuring quality.
2.Worksite
analysis to identify existing and potential
hazards through:
-
Comprehensive safety and health hazard
surveys;
-
Analysis of planned changes to identify
hazards that might be introduced;
-
Routine hazard analyses, such as:
-
Job hazard analysis (also known
as job safety analysis),
- Process hazard analysis (used in industries
with complex and hazardous processes),
and
- Phase hazard analysis (used mainly
in construction);
Periodic worksite inspections, including:-
Self-inspections conducted by supervisors
in their work areas, and
-
General inspections of the entire site
conducted by safety and health staff;
-
Employee reports of hazards;
-
Work practice control; and
-
Analysis of injury/illness trends.
3.
Hazard prevention and control through:
-
Engineering controls;
-
Work practice control;
-
Personal protective equipment;
-
Administrative controls;
-
Disciplinary systems to enforce controls;
-
Preventive maintenance;
-
Emergency preparedness; and
-
Medical program.
4.
Safety and health training to ensure that
all employees know how to protect themselves
and others from existing and potential hazards
of the worksite.
WHO
SHOULD EVALUATE
Evaluators
can be drawn from the workplace safety and
health department or the safety committee,
but the best evaluators will be people possessing
fresh vision. They will not be involved
in the day-to-day operations of the site.
Look in the corporate safety department,
another worksite of the company, insurance
companies and outside consulting firms.
Or have two activity managers switch places
and evaluate each other's results.
Many
workers' compensation insurance carriers
offer their clients the services of a certified
safety professional and a certified industrial
hygienist. These experts are qualified to
review your program activities.
Evaluators
should be knowledgeable in the technical
aspects of occupational safety and health,
the management of safety and health, and
the evaluation of programs. Of these three
areas, management of safety and health is
the most important.
TOOLS
FOR COLLECTING INFORMATION USED IN EVALUATION
There
are three indispensable evaluation tools
for judging the effectiveness of occupational
safety and health program management. These
are:
-
Document review,
-
Interviews with employees at different
levels, and
-
Review of site conditions.
See
Appendix 12-2 for a detailed description of
how to use these tools.
Documentation.
Every worksite will have, at an absolute
minimum, written accident reports and the
OSHA log of injuries and illnesses as required
by law. Major companies should have written
procedures and records of all their safety
and health programs. The evaluator should
compare the written program to the written
records of what occurred.
Interviews.
In addition to the documentation, interviews
can be very helpful in establishing what
has occurred. We use two kinds of interviews,
formal and informal. The formal interviews
are conducted privately with randomly selected
employees who are asked preselected questions.
Informal interviews occur at employee work
stations and generally follow a list of
topics.
To
assess how well the worksite safety and
health policy is communicated and understood
and how well the disciplinary system is
working, ask the employees to explain them.
To
gauge the effectiveness of safety and health
training, interview hourly employees and
first-line supervisors. Ask employees to
describe what hazards they are exposed to
and how they are protected. Ask them to
explain what they are supposed to do in
several different types of emergencies.
Ask supervisors how they teach, how they
reinforce the teaching, how they enforce
safety and health rules and safe work practices
and what their responsibilities are during
emergency situations.
Interviews
with management should focus on its involvement
in and commitment to the safety and health
program. Ask how the policy statement was
created and how that statement is communicated
to all employees. Ask what information management
receives about the safety and health activities
and what action management takes as a result
of that information. Ask how management's
commitment to safety and health is demonstrated
to the workforce.
Review
of Site Conditions. The conditions
at the worksite reveal much about the safety
and health program's effectiveness. Worksite
conditions can be observed indirectly by
examining documents such as inspection reports
of hazards, employee reports of hazards
and accident/incident investigations.
Site
tours also may reveal hazards. Be careful,
however, that the site tour does not become
a routine inspection with emphasis only
on hazard correction. When a hazard is found,
certainly take steps to ensure its correction.
But in addition, ask what management system(s)
should have prevented or controlled the
hazard. Determine why system(s) failed and
either change them or take other appropriate
corrective measures. Chapter 8 has more
information on this technique. See especially
the hazard analysis flow charts, Appendix
9-4.
DO
PROGRAM ACTIVITIES GET RESULTS?
THE
TARGET OF EVALUATION
Time
and resources can be wasted when safety
and health program activities do not achieve
the desired results. Each year activities
should be planned with the intention of
achieving specific objectives. These objectives,
in turn, are geared toward reaching the
year's safety and health program goal.
As
an example, a company's goal is:
Develop
a comprehensive safety and health program
that effectively protects employees by
preventing or controlling existing and
potential workplace hazards.
To
reach this goal, one objective this
year is:
Develop
a comprehensive preventive maintenance
program.
The
company expects that achieving this objective
will require more than one year. For the
current year the company plans to undertake
two activities, each with governing
procedures:
Activity
1: Create preventive maintenance checklists
for all classes of company vehicles.
Procedure:
By February 1, Transportation Department
Chief will hold joint meeting of all drivers
and vehicle maintenance mechanics to determine
maintenance needs and create checklist
of preventive maintenance tasks. Checklist
will assign responsibilities to appropriate
staff, indicate required time frames and
provide for sign-off.
Activity
2: Conduct a survey of non-vehicle
machinery throughout the worksite to determine
preventive maintenance needs.
Procedure:
By February 1, each Department will submit
to Maintenance Department a list of all
machinery located within the Department,
together with notations regarding operating
problems, hazards and maintenance needs.
By March 1, Maintenance Department Chief
and staff will visit each department to
examine machinery and to discuss needs
with operators. By April 1, a comprehensive
report will be submitted to Vice-President
for Operations, inventorying machinery
and indicating maintenance needs and suggested
maintenance schedule.
The
end-of-year safety and health program evaluation
will determine whether these activities
were conducted and whether they had the
desired effect, i.e., successfully began
the process of developing a comprehensive
preventive maintenance program.
The
evaluation then will examine the value of
this objective: did the achievement of this
phase of a preventive maintenance program
move the company closer to its targeted
safety and health goal? If this analysis
finds program efforts that are ineffective
and do not contribute to the goal, the evaluation
should include recommendations for program
changes for the next year. For more information
about setting a goal and objectives, see
Chapter 2.
ACTIVITIES
AND PROCEDURES
Do
the actual safety and health program activities
and the procedures for implementing them
bring the expected results?
Larger
worksites. Large companies will
have written procedures for the major activities
of their safety and health program. They
also will have written records of those
activities as they were performed. Evaluating
whether the written procedures were followed
in the period evaluated, or how well they
were followed, is an audit function of quality
assurance or program evaluation.
Smaller
worksites. Even if yours is a smaller
business with more limited recordkeeping
you still should put some effort into thinking
about how safety and health activities were
carried out for the period evaluated and
whether the results achieved were those
expected at the outset.
Sample
questions. The precise questions
you should ask will depend upon the activity
being audited and the way the activity was
to be accomplished. For example, if plans
call for a certain person to carry out the
inspection program, did that person actually
conduct the inspections? In many workplaces
inspections are conducted by the person
with the most expertise along with members
of the site safety and health committee.
Was the expert present during every inspection?
Did the employee members always participate?
Other
questions about inspections might include
the following:
-
Is there evidence that the inspectors
went to every part of the worksite that
was specified in the inspection plans?
-
Did their reports indicate that the inspectors
were finding the kinds of hazards they
were trained to recognize?
-
Was hazard correction appropriately assigned?
-
Were the hazards corrected in an appropriate
and timely manner?
-
Was the correction tracked to completion?
Similar
questions should be asked about each activity
under the safety and health program. When
a discrepancy is found between the original
plan and actual execution of the activity,
assess which way best meets the safety and
health objectives and goal. Then make sure
that everyone follows that procedure.
OBJECTIVES
The
objectives connect the goal for the safety
and health program to the program procedures
and activities.
Objectives
that can be audited. Sometimes a
program objective will be to complete a
new or improved activity. For example, suppose
the objective states, "Complete one job
safety analysis each month, with follow-up
revision of safe work procedures and employee
training in the following month." In this
case the objective describes the frequency
of activities rather than the desired result.
An evaluation of this objective involves
no more than determining whether the activities
occurred. Therefore, an audit will be appropriate.
Look for evidence that job safety analyses
were done each month. Is there evidence
that revisions of procedures and training
also were made each month as a result of
the previous month's job safety analysis?
If the answer is yes and other program evaluation
reveals no need to do anything differently,
the frequency of these activities will become
an ongoing subject of audit.
Objectives
that must be evaluated. Ordinarily,
objectives should focus on the results desired
from the program activities. For example,
an objective might state, "Identify and
assign all areas of safety and health responsibility
that are not presently clearly assigned,
so that all safety and health responsibilities
can be successfully carried out." A set
of activities will be needed to accomplish
this objective. The activities might include
assigning a committee to list all the safety
and health responsibilities; reviewing assignment
of those responsibilities; identifying missing,
duplicate and unclear assignments; and recommending
clearer assignments.
In
this case the evaluation will focus on whether
the objective was accomplished. That is,
were all areas of safety and health responsibilities
that were not clearly defined actually identified
and clarified? Perhaps these areas were
identified but the corrections not made
because the Personnel Department needed
to first rewrite seven major job descriptions
to get the responsibilities correctly assigned.
This, then, leads to a new objective to
get the seven job descriptions rewritten
with clearer assignment of safety and health
responsibilities. If all safety and health
areas have been identified and clarified
this objective will not lead to another
objective.
As
another example, say the objective is to
increase employee safety and health awareness
by involving the employees' families in
a safety and health awareness program. The
evaluation will seek to measure the difference
between employee awareness before the family
program and after it. One way to measure
that difference is to ask them if they thought
their awareness was increased. Still another
is to ask supervisors if they perceived
a difference in employee awareness after
the family program began. If, after using
some type of meaningful measurement tool,
the findings indicate that the program has
increased awareness it will make sense to
designate the family program an ongoing
activity subject to audit. If the findings
show no measurable increase in awareness
the family program can be changed or another
activity substituted. The altered objective
then will be to increase employee awareness
by this new means.
GOAL
The
goal is the ultimate intention of the safety
and health program, its basic aim.
Objectives
should be evaluated to make sure they are
leading to the program goal. For example,
suppose the goal is the reduction of employee
exposure to hazards and one of the objectives
to achieve that goal is to hold monthly
safety meetings for all employees. Since
this is an activity objective it can be
audited to determine whether safety meetings
are actually being held. But the next question
is, "Did achieving this objective help fulfill
the goal of the safety and health program?"
In other words, did the safety meetings
help employees understand the hazards to
which they are exposed and result in plans
to reduce exposure?
There
are various ways to collect such information.
A sign-off sheet can indicate who attended
the training. The same sheet can ask employees
to describe hazards and potential hazards
that exist in their work area and ways to
better control them. If there is no sign-off
sheet interviews with some randomly selected
employees can reveal their opinion of whether
the meetings improved their understanding
of hazards and resulted in plans to control
them. Interviews with supervisors can reveal
whether employees exhibited better understanding
after training.
If
the results indicate that not much was learned
at these sessions, ask further questions
to see what went wrong. In this way, all
the objectives can and should be checked
to see if they are helping achieve the goal.
Program
evaluation can identify activities that
are not really helping to improve worksite
safety and health. In so doing, evaluation
can save you time, effort and money.
EVALUATION
JUDGMENTS
The
important work of gathering information
about safety and health program activities
is the most time-consuming part of program
evaluation. It is, however, the easiest
to understand and accomplish. The hardest
part is making judgments about program effectiveness.
To
assist smaller businesses in making these
judgments, a sample checklist is provided
in Appendix 12-1. It can be used in deciding
what information should be gathered and
what judgments need to be made. Suggested
evaluation questions in the previously cited
examples and a sample section of evaluation
instructions in Appendix 12-2 can provide
additional guidance.
Employers
should draw up appropriate, site-specific
procedures for gathering information and
making judgments. You may also want to add
environmental, product safety or security
considerations to the evaluation process.
The questions you ask should be based on
individual site program activities and site
objectives. The sample question in Appendix
12-3 may be helpful.
Insist
that the evaluator determine the program's
bottom line profitability, its real benefit.
In other words, which activities contribute
to the safety and health goal and which
do not? Judgments and decisions made by
evaluators should be driven by this quest
for profitability, by which we mean improvement
in safety and health program. Insist that
the hard questions about program effectiveness
be addressed.
HOW
TO USE THE EVALUATION
The
evaluation will prove valuable only if it
leads to improved performance in meeting
the safety and health goal. Some of the
recommendations that result from the evaluation
will be for one-time corrections. Many,
however, will involve changing emphasis
or trying new activities. These recommendations
should be incorporated into the objectives
for the next year. Consider establishing,
as a permanent objective, an audit of the
procedures that your program sets for safety
and health program activities. See Chapter
2 for more information about establishing
objectives.
Larger
Worksites. The evaluation should
result in a written report with written
recommendations and documented follow-up
to those recommendations. It may be useful
to refer to past years' evaluations when
preparing new ones or when planning new
objectives. If you find that the same recommendations
are being made year after year the process
of implementing and tracking recommendations
to completion needs improvement.
Smaller
Worksites. At smaller sites a written
evaluation report may not be practical.
However, it is important to set aside time
to think about desired changes. The evaluation
process already has involved considering
what was done during the course of the year,
talking to people, looking at the site's
working conditions and reviewing available
documents. Next, decide what you want to
do differently and make sure that everyone
understands what is expected.
SUMMARY
This
chapter has defined a safety and health
program evaluation. It has described what
should be evaluated, who should do the evaluation
and with what tools, how the evaluation
should be conducted and how to use the results.
The
following appendices offer additional examples,
guidelines and instructions:
Appendix
12-1 provides an example of a self-evaluation
checklist for small businesses. This can
be used to perform a comprehensive evaluation
of the safety and health program.
Appendix
12-2 is a step-by-step guide to using the
three evaluation tools: documentation review,
employee interviews and hazardous conditions
review and analysis. These tools are used
to assess each element and subsidiary component
of a safety and health program.
Appendix
12-3 provides a sample evaluation instruction
sheet that can be used to evaluate routine
inspections when such inspections are part
of your safety and health program.
By
using this information to perform annual
evaluations you will be able to compute
your company's safety and health bottom
line, just as you now can calculate your
organization's financial bottom line. You
will have the information needed to make
knowledgeable and effective decisions promoting
workplace safety and health.
APPENDIX
12-1
EXAMPLE
OF A SELF-EVALUATION CHECKLIST FOR SMALL
BUSINESSES
Instructions:
Fill out the last five columns after judging
the effectiveness of each part of your safety
and health program. If the part of your
program indicated in the first column is
fully effective enter "YES" in the second
column. If not fully effective enter "NO".
-
Explain the deficiencies in the "Comments/Improvements"
column and list any specific, planned
improvements.
-
Indicate the persons responsible for these
improvements in the next column.
-
Enter the target date for these improvements.
-
Finally, when the improvements are actually
completed enter the completion date in
the last column.
ELEMENT
I. MANAGEMENT LEADERSHIP AND EMPLOYEE INVOLVEMENT
ELEMENT
II. WORKSITE ANALYSIS
ELEMENT
II. WORKSITE ANALYSIS (CON'T)
ELEMENT
III. HAZARD PREVENTION AND CONTROL
ELEMENT
III. HAZARD PREVENTION AND CONTROL (CON'T)
ELEMENT
IV. SAFETY AND HEALTH TRAINING
SPECIAL
OBJECTIVES (LIST AND EVALUATE INDIVIDUALLY)
|
INDICATORS
|
YES/NO
|
COMMENTS
IMPROVEMENTS
|
RESPONSIBLE
PARTY
|
TARGET
DATE
|
DATE
COMPLETED
|
| |
|
|
|
|
|
APPENDIX
12-2
FURTHER
DESCRIPTION OF
A SAFETY
AND HEALTH PROGRAM ASSESSMENT
INTRODUCTION
There
are three basic methods for assessing safety
and health program effectiveness. This description
will explain each of them. It also will
provide more detailed information on how
to use these tools to evaluate each element
and subsidiary component of a safety and
health program. The outlined information
that begins on page 12-22 corresponds in
format to pages 12-2 to 12-4.
The
three basic methods for assessing safety
and health program effectiveness are:
1.
Checking documentation of activity;
2.
Interviewing employees at all levels for
knowledge, awareness and perceptions;
and
3.
Reviewing site conditions and, where hazards
are found, finding the weaknesses in management
systems that allowed the hazards to occur
or to be "uncontrolled."
Some
elements of the safety and health program
are best assessed by using one of these
methods. Others lend themselves to assessment
by two or all three methods.
Documentation.
Checking documentation is a standard
audit technique. It is particularly useful
for understanding whether the tracking
of hazards to correct is effective. It
can also be used to determine the quality
of certain activities, such as self-inspections
or routine hazard analysis.
Inspection
records can tell the evaluator whether
serious hazards are being found or whether
the same hazards are being found repeatedly.
If serious hazards are not being found
and accidents keep occurring there may
be a need to train inspectors to look
for different hazards. If the same hazards
are being found repeatedly the problem
may be more complicated. Perhaps the hazards
are not being corrected. If so, this would
suggest a tracking problem or a problem
in accountability for hazard correction.
If
certain hazards recur repeatedly after
being corrected, someone is not taking
responsibility for keeping those hazards
under control. Either the responsibility
is not clear or those who are responsible
are not being held accountable.
Employee
Interviews. Talking to randomly
selected employees at all levels will
provide a good indication of the quality
of employee training and of employee perceptions
of the program. If safety and health training
is effective employees will be able to
tell you about the hazards they work with
and how they protect themselves and others
by keeping those hazards controlled. Every
employee should also be able to say precisely
what he or she is expected to do as part
of the program. And all employees should
know where to go in an emergency.
Employee
perceptions can provide other useful information.
An employee's opinion of how easy it is
to report a hazard and get a response
will tell you a lot about how well your
hazard reporting system is working. If
employees indicate that your system for
enforcing safety and health rules and
safe work practices is inconsistent or
confusing you will know that the system
needs improvement.
Interviews
should not be limited to hourly employees.
Much can be learned from talking with
first-line supervisors. It is also helpful
to query line managers about their understanding
of their safety and health responsibilities.
Site
Conditions and Root Causes of Hazards.
Examining the conditions of the workplace
can reveal existing hazards. But is can
also provide information about the breakdown
of those management systems meant to prevent
or control these hazards.
Looking
at conditions and practices is a well
established technique for assessing the
effectiveness of safety and health programs.
For example, let's say that in areas where
PPE is required you see large and understandable
signs communicating this requirement and
all employees -- with no exceptions --
wearing equipment properly. You have obtained
valuable visual evidence that the PPE
program is working.
Another
way to obtain information about safety
and health program management is through
root analysis of observed hazards. This
approach to hazards is much like the most
sophisticated accident investigation techniques
in which many contributing factors are
located and corrected or controlled.
For
example, let's say that during a review
of conditions, you find a machine being
operated without a guard on a pinch point.
You should not limit your response to
ensuring that a guard is installed. Asking
a few questions can reveal a lot about
the safety program's management systems.
Why was the guard missing? If the operator
says he did not know a guard was supposed
to be on the machine, follow up with questions
about the existence of safe work procedures
and/or training.
If
he says that the guard slows him down
and that the supervisor knows he takes
it off, ask questions about the enforcement
of rules, accountability and the clarity
of the worksite objective of putting safety
and health first.
Let's
say, however, that your insurance inspector
or an OSHA inspector is the first person
to notice the need for the guard. Or you
first notice it when someone is hurt.
A different lead-off question is appropriate.
Has a comprehensive survey of the worksite
been done by someone with enough expertise
to recognize all potential and existing
hazards?
Analyzing
the root causes of hazards, while very
helpful during a formal assessment, is
a technique that also lends itself to
everyday use. Attempt to analyze causes
whenever hazards are spotted.
When
evaluating each part of your worksite's
safety and health program, use one or
more of the above methods, as appropriate.
The
remainder of this appendix will identify
the components found in each element of
a quality safety and health program and
will describe useful ways to asses these
components.
1.
Assessing the Key Components of Management
Leadership and Employee Involvement.
-
Worksite
Policy on Safe and Healthful Working
Conditions
-Documentation.
If there is a written policy, does
it clearly declare the priority of
worker safety and health over other
organizational values, such as production.
-Interviews.
When asked, can employees at all levels
express the worksite policy on worker
safety and health?
If
the policy is written, can hourly
employees tell you where they have
seen it? Can
employees at all levels explain the
priority of worker safety and health
over other organizational values,
as the policy intends?
-Site
Conditions and Root Causes of Hazards.
Have injuries occurred because employees
at any level did not understand the
importance of safety precautions in
relation to other organizational values,
such as production?
-
Goal and Objective for Worker Safety
and Health
-Documentation. If there is
a written goal for your safety and
health program, is it updated annually?
If there are written objectives, such
as an annual plan to reach that goal,
are they clearly stated?
If managers and supervisors have written
objectives, do these documents include
objectives for the safety and health
program?
-Interviews. Do managers and
supervisors have a clear idea of their
objectives for worker safety and health?
Do hourly employees understand the
current objectives of the safety and
health program?
-Site Conditions and Root Causes
of Hazards. (Only helpful in a
general sense.)
-
Visible
Top Management Leadership
-Documentation. Are there
one or more written programs which involve
top-level management in safety and health
activities? For example, top management
can receive and sign off on inspection
reports either after each inspection
or in a quarterly summary. These reports
can then be posted for employees to
see. Top management can provide "open
door" times each week or each month
for employees to come in to discuss
safety and health concerns. Top management
can reward the best safety suggestions
each month or at other specified intervals.
-Interviews.
Can hourly employees describe how management
officials are involved in safety and health
activities?
Do
hourly employees perceive that managers
and supervisors follow safety and health
rules and work practices, such as wearing
appropriate personal protective equipment?
-Site
Conditions and Root Causes of Hazards.
When employees are found not wearing
required personal protective equipment
or not following safe work practices,
have any of them said that managers
or supervisors also did not follow these
rules.
-
Employee
Involvement
-Documentation.
Are there one or more written programs
that provide for employee involvement
in decisions affecting their safety
and health?
Is
there documentation of these activities;
for example, employee inspection reports,
minutes of joint employee-management
or employee committee meetings?
Is
there written documentation of any management
response to employee safety and health
program activities?
Does
the documentation indicate a genuine
substance to employee activities?
-Interviews.
Are employees aware of ways they can
be involved in decisions affecting their
safety and health.
Do
employees appear to take pride in the
achievements of the worksite safety
and health program?
Are
employees comfortable answering questions
about safety and health programs and
conditions at the site?
Do
employees feel they have the support
of management for their safety and health
activities?
-Site
Conditions and Root Causes of Hazards.
(Not applicable.)
-
Assignment
of Responsibility
-Documentation.
Are responsibilities written out so that
they can be clearly understood?
-Interviews.
Do employees understand their own responsibilities
and those of others?
-Site
Conditions and Root Causes of Hazards.
Was the hazard caused in part because
no one was assigned the responsibility
to control or prevent it?
Was the hazard allowed to exist in part
because someone in management did not
have the clear responsibility to hold
a lower-level manager or supervisor accountable
for carrying out assigned responsibilities?
-
Adequate Authority and Resources
-Documentation. (Only generally
applicable.)
-Interviews. Do safety staff
members or any other personnel with
responsibilities for ensuring safe operation
of production equipment have the authority
to shut down that equipment or to order
maintenance or parts?
Do employees talk about not being able
to get safety and health improvements
because of cost?
Do employees mention the need for more
safety or health personnel or expert
consultants?
Do hazards go unrecognized because greater
expertise is needed to diagnose them?
-Site
Conditions and Root Causes of Hazards
Do
recognized hazards go uncorrected because
of lack of authority or resources?
Do hazards go unrecognized because greater
expertise is needed to diagnose them?
-
Accountability
of Managers, Supervisors and Hourly
Employees
-Documentation.
Do performance evaluations for all line
managers and supervisors include specific
criteria relating to safety and health
protection?
Is
there documented evidence of employees
at all levels being held accountable
for safety and health responsibilities,
including safe work practices? Is accountability
accomplished through either performance
evaluations affecting pay and/or promotions
or disciplinary actions?
-Interviews.
When you ask employees what happens to
people who violate safety and health rules
or safe work practices, do they indicate
that rule breakers are clearly and consistently
held accountable?
Do
hourly employees indicate that supervisors
and managers genuinely care about meeting
safety and health responsibilities?
When
asked what happens when rules are broken,
do hourly employees complain that supervisors
and managers do not follow rules and never
are disciplined for infractions?
-Site
Conditions and Root Causes of Hazards.
Are hazards occurring because employees,
supervisors and/or managers are not being
held accountable for their safety and
health responsibilities?
Are
identified hazards not being corrected
because those persons assigned the responsibility
are not being held accountable?
-
Evaluation
of Program Operations
Documentation.
Is there a written evaluation of each
major part of the program, as identified
in the OSHA Safety and Health Program
Management Guidelines (54 CFR 3908,
January 26, 1989)? Does this written
evaluation list what is being done,
assess the effectiveness of each program
element against the goal and objectives
and recommend changes as needed to make
the program more effective or to try
alternatives?
Interviews.
Can employees, supervisors and/or managers
tell you how the program is evaluated
and revised each year?
Site
Conditions and Root Causes of Hazards.
(Only generally applicable).
2.
Assessing the Key Components of Worksite
Analysis
-
Comprehensive Surveys, Change Analysis,
Routine Hazard Analysis
-Documentation.
Are there documents that provide comprehensive
analysis of all potential safety and health
hazards of the worksite?
Are
there documents that provide both the
analysis of potential safety and health
hazards for each new facility, equipment,
material or process and the means for
such hazards' elimination or control?
Does
documentation exist of the step-by-step
analysis of the hazards in each part of
each job, so that you can clearly discern
the evolution of decisions on safe work
procedures?
If
complicated processes exist, with a potential
for catastrophic impact from an accident
but low probability of such accident (as
in nuclear power or chemical production),
are there documents analyzing the potential
hazards in each part of the processes
and the means to prevent or control them?
If
there are processes with a potential for
catastrophic impact from an accident but
low probability of an accident, have analyses
such as "fault tree" or "what if" been
documented to ensure enough back-up systems
for worker protection in the event of
multiple control failure?
Interviews.
Do employees complain that new facilities,
equipment, materials or processes are
hazardous?
Do
any employees say they have been involved
in job safety analysis or process review
and are satisfied with the results?
Does
the safety and health staff indicate ignorance
of existing or potential hazards at the
worksite?
Does
the occupational nurse/doctor or other
health care provider understand the potential
occupational diseases and health effects
in this worksite?
Site
Conditions and Root Causes of Hazards.
Have hazards appeared where no one in
management realized there was potential
for their development?
Where
workers have faithfully followed job procedures,
have accidents or near misses occurred
because of hidden hazards?
Have
hazards been discovered in the design
of new facilities, equipment, materials
and processes after use has begun?
Have
accidents or near misses occurred when
two or more failures in the hazard control
system occurred at the same time, surprising
everyone?
-
Regular Site Safety and Health Inspections
-Documentation.
If inspection reports are written, do
they show that inspections are done on
a regular basis?
Do
the hazards found indicate good ability
to recognize those hazards typical of
this industry?
Are
hazards found during inspections tracked
to complete correction?
What
is the relationship between hazards uncovered
during inspections and those implicated
in injuries or illness?
-Interviews.
Do employees indicate that they see inspections
being conducted and that these inspections
appear thorough?
-Site
Conditions and Root Causes of Hazards.
Are the hazards discovered during accident
investigations ones that should have been
recognized and corrected by the regular
inspection process?
-
Employee Reports of Hazards
-Documentation.
Is the system for written reports being
used frequently? Are valid hazards that
have been reported by employees tracked
to complete correction?
Are
the responses timely and adequate?
-
Interviews.
Do employees know whom to contact and
what to do if they see something they
believe to be hazards to themselves or
co-workers?
Do
employees think that responses to their
reports of hazards are timely and adequate?
Do
employees say that sometimes when they
report a hazard they hear nothing further
about it?
Do
any employees say that they or other workers
are being harassed, officially or otherwise,
for reporting hazards?
-Site
Conditions and Root Causes of Hazards.
When hazards are found, do employees ever
say they have complained repeatedly but
to no avail?
Are
hazards ever found where employees could
reasonable be expected to have previously
recognized and reported them?
-
Accident and Near Miss Investigations
-Documentation.
Do accident investigation reports show
a thorough analysis of causes, rather
than a tendency automatically to blame
the injured employees?
Are
near misses, (property damage or close
calls) investigated using the same techniques
as accident investigations?
Are
hazards that are identified as contributing
to accidents or near misses tracked to
correction?
-Interviews.
Do employees understand and accept the
results of accident and near misses investigations?
Do
employees mention a tendency on management's
part to blame the injured employee?
Do
employees believe that all hazards contributing
to accidents are corrected or controlled?
-Site
Conditions and Root Causes of Hazards.
Are accidents sometimes caused at least
partly by factors that might also have
contributed to previous near misses that
were not investigated or accidents that
were too superficially investigated?
-
Injury and Illness Pattern Analysis
-Documentation.
In addition to the required OSHA log,
are careful records kept of first aid
injuries and/or illnesses that might not
immediately appear to be work-related?
Is
there any periodic, written analysis of
the patterns of near misses, injuries
and/or illnesses over time, seeking previously
unrecognized connections between them
that indicate unrecognized hazards needing
correction or control?
Looking
at the OSHA 200 log, and where applicable,
first aid logs, are there patterns of
illness or injury that should have been
analyzed for previously undetected hazards?
If
there is an occupational nurse/doctor
on the worksite, or if employees suffering
from ordinary illness are encouraged to
see a nearby health care provider, are
the lists of those visits analyzed for
clusters of illness that might be work-related?
-Interviews. Do employees mention
illnesses or injuries that seem work-related
to them but that have not been analyzed
for previously undetected hazards?
-Site
Conditions and Root Causes of Hazards.
(Not generally applicable.)
3.
Assessing the Key Components of Hazard
Prevention and Control.
-
Appropriate Use of Engineering Controls,
Work Practices, Personal Protective
Equipment and Administrative Controls
- Documentation.
If there are documented comprehensive
surveys are they accompanied by a plan
for systematic prevention or control
of hazards found?
If
there is a written plan does it show
that the best method of hazard protection
was chosen?
Are
there written safe work procedures?
If
respirators are used, is there a written
respirator program?
-Interviews.
Do employees say they have been trained
in and have ready access to reliable,
safe work procedures?
Do
employees say they have difficulty accomplishing
their work because of unwieldy controls
meant to protect them?
Do
employees ever mention personal protective
equipment, work procedures or engineering
controls as interfering with their ability
to work safely?
Do
employees who use PPE understand why
they use it and how to maintain it?
Do
employees who use PPE indicate that
the rules for PPE use are consistently
and fairly enforced?
Do
employees indicate that safe work procedures
are fairly and consistently enforced?
-Site
Conditions and Root Causes of Hazards.
Do you ever find that controls meant
to protect workers are actually putting
them at risk or not providing enough
protection?
Are
employees engaging in unsafe practices
or creating unsafe conditions because
rules and work practices are not fairly
and consistently enforced?
Are
employees in areas designated for PPE
wearing it properly, with no exceptions?
Are
hazards that could feasibly be controlled
through improved design being inadequately
controlled by other means?
-
Facility
and Equipment Preventive Maintenance
-Documentation.
Is there a preventive maintenance schedule
that provides for timely maintenance
of the facilities and equipment?
Is there a written or computerized record
of performed maintenance that shows
the schedule has been followed?
Do maintenance request records
show a pattern of certain facilities
or equipment needing repair or breaking
down before a maintenance was scheduled
or actually performed?
Do any accident/incident investigations
list facility or equipment breakdown
as a major cause?
-Interviews.
Do employees mention difficulty with
improperly functioning equipment or
facilities in poor repair?
Do
maintenance employees believe that the
preventive maintenance system is working
well?
Do employees believe that hazard
controls needing maintenance are properly
cared for?
-
-Site Conditions and Root Causes
of Hazards. Is poor maintenance
a frequent source of hazards?
Are
hazard controls in good working order?
Does
equipment appear to be in good working
order?
-
Emergency
Planning and Preparation
-Documentation.
Are there clearly written procedures
for every likely emergency, with clear
evacuation routes? Can employees tell
you exactly what they are supposed to
do?
-Interviews.
When asked about any kind of likely
emergency, can employees tell you exactly
what they are supposed to do?
-Site Conditions and Root Causes
of Hazards. Have hazards occurred
during actual or simulated emergencies
due to confusion about what to do?
In
larger worksites, are emergency evacuation
routes clearly marked?
Are emergency telephone numbers
and fire alarms easy to find?
-
Establishing
a Medical Program
-Documentation.
Are good clear records kept of medical
testing and assistance?
-
Interviews. Do employees say that
test results were explained to them?
Do employees feel that more first
aid or CPR-trained personnel should be
available?
Are
employees satisfied with the medical
arrangements provided at the site or
elsewhere?
Does
the occupational health care provider
understand the potential hazards of
the worksite, so that occupational illness
symptoms can be recognized?
-Site
Conditions and Root Causes of Hazards.
Have further injuries or worsening of
injuries occurred because proper medical
assistance (including trained first
aid and CPR providers) was not readily
available?
Have
occupational illnesses possibly gone
undetected because no one with occupational
health specialty training reviewed employee
symptoms as part of the medical program?
4.
Assessing the Key Components of Safety
and Health Training.
-
Ensuring
that all Employees Understand Hazards
-Documentation.
Does the written training program include
complete training for every employee
in emergency procedures and in all potential
hazards to which employees may be exposed?
Do
training records show that every employee
received the planned training?
Do
the written evaluations of training
indicate that the training was successful
and that the employees learned what
was intended?
-Interviews. Can employees tell
you what hazards they are exposed to,
why those hazards are a threat and how
they can help protect themselves and
others?
If
PPE is used, can employees explain why
they use it and how to use and maintain
it properly?
Can
employees tell you precisely what they
are supposed to do and where they are
supposed to go in every kind of emergency
likely to occur at your worksite?
Do
employees feel that health and safety
training is adequate?
-Site Conditions and Root Causes
of Hazards. Have employees been
hurt or made ill by hazards of which
they were completely unaware, or whose
dangers they did not understand or from
which they did not know how to protect
themselves?
Have employees or rescue workers
ever been endangered by employees not
knowing what to do or where to go in
a given emergency situation?
Are there hazards in the workplace that
exist, at least in part, because one
or more employees have not received
adequate hazard control training?
Are
there any instances of employees not
wearing required PPE properly because
they have not received proper training?
-
Ensuring
that Supervisors Understand Their Responsibilities
-Documentation.
Do training records indicate that all
supervisors have been trained in their
responsibilities to analyze work under
their supervision for unrecognized hazards;
to maintain physical protections; to
reinforce employee training through
performance feedback; and, where necessary,
to enforce safe work procedures and
safety and health rules?
-Interviews. Are supervisors
aware of their responsibilities?
Do
employees say that supervisors are carrying
out these duties?
-Site Conditions and Root Causes.
Has a supervisor's lack of understand
of safety and health responsibilities
played a part in creating hazardous
activities or conditions?
-
Ensuring
that Managers Understand Their Safety
and Health Responsibilities
-Documentation.
Do training plans for managers include
training in safety and health responsibilities?
Do records indicate that all line managers
have received this training?
-Interviews. Do employees
indicate that managers know and carry
out their safety and health responsibilities?
-Site Conditions and Root Causes of
Hazards. Has an incomplete or inaccurate
understanding by management of its safety
and health responsibilities played a part
in the creation of hazardous activities
or conditions?
APPENDIX
12-3
SAMPLE
FROM AN EVALUATION INSTRUCTION
The
questions asked in this sample instruction
relate to the section of the evaluation
dealing with routine inspections. They
are similar, however, to those that should
be asked for every element in your safety
and health program.
Write
an evaluation report by responding to
the following questions and instructions.
Use complete sentences. Where appropriate,
one sentence can cover more than one question.
Your answers should reflect completed
judgments. Avoid using terms that suggest
incomplete judgments, such as "appears,"
"apparently" and "seems."
Section
2. Routine Inspections
1.List
any established objectives that involve
routine inspections.
2.If
any specific objectives were set for inspections
were they effectively met? Describe.
3.Are
inspections following set procedures?
If not, describe how they differ and how
frequently this difference occurs.
4.If
procedures are not being followed, discuss
the reasons and whether the alternative
activity meets the objective seen for
inspections.
5.Has
inspection activity contributed to identification
and control of hazards and potential hazards?
Describe.
6.If
not otherwise covered above, please answer
the following and provide examples.
a.Are
inspections revealing hazards escaping
their controls? Examples: guards removed
from machines, housekeeping problems,
employees failing to follow established
safety procedures. If so, be sure to deal
with this topic in the evaluation of hazard
prevention and control.
b.Are
inspections revealing new hazards that
either did not exist or were not identified
previously? If so, be sure to deal with
this topic under the evaluation comprehensive
surveys, change analysis or routine hazard
analysis.
c.Are
inspections revealing repeated instances
of the same problem? If so, is the problem
going uncorrected or is it recurring after
being corrected? If the former, be sure
to deal with the problem under the evaluation
of tracking of hazard correction, accountability
or both. If the latter, be sure to address
the problem under hazard prevention and
control.
7.List
any recommendations for changes in routine
inspection activity needed for next year.
Make sure that the recommended logically
reflect the conclusions made above.