ESTABLISHING HAZARD PREVENTION AND CONTROL PROGRAM
You have conducted a comprehensive survey of your workplace to uncover existing and potential hazards. Now what are you going to do about them? The Occupational Safety and Health Act of 1970 requires that each employer "...furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm..." (29 U.S.C. 651, Sec. 5(a)(1)).
In this chapter we will discuss the management systems used to prevent and control hazards. These include; control by engineering, safe work practices, administrative arrangements and personal protective equipment (PPE); systems to track hazard correction; preventive maintenance systems; emergency preparation; and medical programs.
Emergency preparation is the subject of OSHA Publication 3088 (Revised 1991), "How to Prepare for Workplace Emergencies." We cover medical programs later in Chapter 10. Therefore, these areas will be touched upon only briefly in this chapter.
The goal of the hazard prevention and control program is to make foolproof the workplace and its operations, to the extent feasible, to keep employees from being harmed. It is an ongoing program, never finished. You will design and implement and then revise and improve preventive measures and controls as your worksite changes and as your store of hazard information grows.
The most frequent sources for updating hazard information are routine general inspections, employee reports of hazards and accident/incident investigations. (See Chapter 9.) Other good sources for hazard information updates are the ongoing job hazard analyses (OSHA Publication 3071), process and phase hazard analyses, change analyses and periodic comprehensive hazard surveys. (See Chapter 7.)
Small business owners may wish to contact the nearest office of the OSHA-funded, State-run consultation service for advice and assistance in developing a hazard prevention and control system. Larger employers with specific difficulties can receive assistance over the telephone or by letter from the nearest State or Federal OSHA enforcement office.
THE TERMINOLOGY OF HAZARD CONTROL
Hazards take many forms: air contaminants, tasks involving repetitive motions, equipment with moving parts or openings that can catch body parts or clothing, microorganisms, extreme heat or cold, noise, toxic liquids, and more. The terms we use here to describe the principles of engineering control may sound strange when applied to some of these hazards. You may find that, in other discussions of hazard control, the terms are used somewhat differently. There should be agreement, however, about the concepts the terms describe.
These controls focus on the source of the hazard, unlike other types of controls that generally focus on the employee exposed to the hazard. The basic concept behind engineering controls is that, to the extent feasible, the work environment and the job itself should be designed to eliminate hazards or reduce exposure to hazards. While this approach is called engineering control, it does not necessarily mean that an engineer is required to design the control.
Engineering controls can be very simple in some cases. They are based on the following broad principles:
- If feasible, design the facility, equipment or process to remove the hazards and/or substitute something that is not hazardous or is less hazardous;
- If removal is not feasible, enclose the hazard to prevent exposure in normal operations; and
- Where complete enclosure is not feasible, establish barriers or local ventilation to reduce exposure to the hazard in normal operations.
Elimination of Hazards through Design
Designing facilities, equipment or processes so that the hazard is no longer even potentially present is obviously the best worker protection. Some examples of this are:
- Redesigning, changing or substituting equipment to remove the source of excessive temperatures, noise or pressure;
- Redesigning a process to use less toxic chemicals;
- Redesigning a work station to relieve physical stress and remove ergonomic hazards; or
- Designing general ventilation with sufficient fresh outdoor air to improve indoor air quality and generally to provide a safe, healthful atmosphere.
Enclosure of Hazards.
When you cannot remove a hazard and cannot replace it with a less hazardous alternative, the next best control is enclosure. Enclosing a hazard usually means that there is no hazard exposure to workers during normal operations. There still will be potential exposure to workers during maintenance operations or if the enclosure system breaks down. For those situations, additional controls such as safe work practices or personal protective equipment (PPE) may be necessary to control exposure.
Some examples of enclosure designs are:
- Complete enclosure of moving parts of machinery;
- Complete containment of toxic liquids or gasses from the beginning of the process using or producing them to detoxification, safe packing for shipment, or safe disposal of toxic waste products;
- Glove box operations to enclose work with dangerous microorganisms, radioisotopes or toxic substances; and
- Complete containment of noise, heat or pressure-producing processes with materials especially designed for those purposes.
Barriers or Local Ventilation.
When the potential hazard cannot be removed, replaced, or enclosed, the next best approach is a barrier to exposure or, in the case of air contaminants, local exhaust ventilation to remove the contaminant from the workplace. This engineered control involves potential exposure to the worker even in normal operations. Consequently, it should be used only in conjunction with other types of controls, such as safe work practices designed specifically for the site condition and/or PPE. Examples include:
- Ventilation hoods in laboratory work;
- Machine guarding, including electronic barriers;
- Isolation of a process in an area away from workers, except for maintenance work;
- Baffles used as noise-absorbing barriers; and
- Nuclear radiation or heat shields.
GENERAL WORKPLACE RULES AND SAFE WORK PRACTICES
Many of your organization’s general workplace rules have a bearing on safety and health. It is accurate to think of these rules as hazard controls.
In addition to the general workplace rules that apply to everyone, specific work practices may be needed to safeguard your employees in a variety of situations. For example, even when a hazard is enclosed, exposure can occur when maintenance is necessary, when the enclosure system suffers a partial or complete breakdown, or when enclosure does not fully control the hazard. By following established safe work practices for accomplishing a task safely (and using PPE in many cases), your employees can further reduce their exposure to hazard.
The safety and health rules that you develop and make part of your overall workplace rules are an important component of your hazard prevention and control program. These rules play a major part in identifying acceptable and unacceptable behavior. For example, you may have rules outlawing horseplay or violent behavior on company property, or requiring your employees to wear personal protective equipment.
Safety and health rules are most effective when they are written, posted, given to all affected employees, and discussed with them. Many employers emphasize the link between safety and health rules and the consequences of breaking them by reviewing the rules with their employees. They then ask the employees to sign a statement at the bottom of the list: "I have read the rules, I understand them, and I have received an explanation of the consequences of breaking them." Employer and employee both keep a copy of this signed statement.
Some employers ask their employees to help develop the workplace rules and then to help revise them as needed. When employees play a role in formulating the rules, they are more likely to understand and follow them.
For more examples of workplace safety and health rules, and guidance in developing them, see Appendix 8-3.
Some of these practices are very general in their applicability. They include housekeeping activities such as:
- Removal of tripping, blocking, and slipping hazards;
- Removal of accumulated toxic dust on surfaces; and
- Wetting down surfaces to keep toxic dust out of the air.
Other safe work practices apply to specific jobs in the workplace and involve specific procedures for accomplishing a job. To develop these procedures, you conduct a job hazard analysis. This process is clearly described with examples and illustrations in OSHA Publication 307l (Revised 1992), "Job Hazard Analysis," and summarized here in Chapter 7.
OSHA recommends that you keep the written analysis of a job separate from the written procedures your workers will follow to accomplish the job safely. A good job hazard analysis is more detailed than a good work instruction sheet. Each document suffers from being combined with the other.
You may decide that a training program is needed, using the job hazard analysis as the basis for training your workers in the new procedures. A training program may be essential if your employees are working with highly toxic substances or in dangerous situations.
While safe work practices are a necessity and can work very well, they are only as good as the management systems that support them. This is because they are susceptible to human error. The controls first must be designed from a base of solid hazard analysis. They then must be accompanied by good worker training, reinforcement, and consistent and reasonable enforcement. Safe work practices should be used in conjunction with, and not as a substitute for, more effective or reliable engineering controls.
Safe Work Practices Training
Anticipate resistance when teaching new job practices and procedures to workers. If your employees have done a job long enough without special precautions, they are likely to feel unconcerned about hazards. It is essential that they understand why special work practices are needed. Therefore, training begins with a discussion of hazards. Your workers must be assisted in understanding that, for an accident or injury to occur, two things must be present: a hazard and an employee. Remove the hazard and there will be no injury. Train the employee to follow proper work practices, and those safe work practices can significantly help the employee to avoid harm.
Just presenting training may not be sufficient. An employer has a responsibility to ensure that worker training has achieved its objective and that workers understand the hazards and know how to protect themselves. A supervisor easily can perform informal testing to check the results of training. This means stopping at an employee's work station and asking for an explanation of the hazards involved in the work and the employee's means of protection. If the training has been presented well and has been understood, each trained worker should be able to give a clear, comprehensive response.
Each supervisor should provide frequent reinforcement of work practices training. The informal testing described above serves not only to gauge training effectiveness, but also to reinforce the desired behavior. Some worksites also provide special recognition for the use of safe work practices. Some supervisors periodically hand out "Thank you for working safely" cards that can be redeemed for a free cup of coffee or soft drink. Other supervisors periodically observe individual workers at their tasks and give oral and/or written feedback on what was done safely.
OSHA recommends award systems that recognize positive activities rather than absence of injuries. Award programs with prizes for hours worked without injury can put heavy pressure on workers not to report injuries.
Workers must realize that safe work practices are a requirement of employment and that unsafe practices will not be tolerated. It is necessary, therefore, that the employer have a disciplinary system that is implemented fairly and consistently. If no such system exists in your workplace, you would be wise to have employees assist in designing one. We discuss disciplinary systems in greater detail below.
While workplace rules and safe work practices can legitimately be considered forms of administrative control, we use this term here to connote other measures aimed at reducing employee exposure to hazard, generally by manipulating the work schedule. Such measures include lengthened rest breaks, additional relief workers, exercise breaks to vary body motions, and rotation of workers through different jobs to reduce or "even out" exposure to hazards or to allow them to work part of the day without respirators or other burdensome PPE. Administrative controls normally are used in conjunction with other controls that more directly prevent or control exposure to hazard.
Administrative controls are often employed to reduce ergonomic hazards. For example, employees in a meatpacking plant might rotate among several tasks to reduce accumulated stress on particular muscles and tendons. Administrative controls have also been used in situations of extreme temperatures, and to counteract the dangers of some widely used chemicals. However, such controls are not appropriate in dealing with carcinogens or chronic chemical hazards such as lead.
PERSONAL PROTECTIVE EQUIPMENT (PPE)
When exposure to hazards cannot be engineered completely out of normal operations or maintenance work, and when safe work practices and other forms of administrative control cannot provide sufficient additional protection, a supplementary method of control is the use of protective clothing and/or equipment. These are collectively called personal protective equipment, or PPE. PPE may also be appropriate for controlling hazards while engineering and work practice controls are being installed.
The term PPE covers such items as face shields (whether worn by dentists or welders), steel-toed shoes and boots, safety glasses and goggles, hard hats, back supports, leather aprons, metal-mesh gloves, forearm guards, respirators, and "space suits."
One section of the OSHA standards (29 CFR 1910, Subpart I) specifically addresses PPE. Many other OSHA standards require certain types of PPE. If respirators are ever worn for any reason at your worksite, you must have a written respirator program, perform fit testing, train supervisors and workers in proper respirator use, and meet other requirements of the standard (29 CFR 1910.134). For further information about respirators, see OSHA Publication 3079 (Revised 1993), "Respiratory Protection." A useful general source of information is OSHA Publication 3077 (Revised 1994), "Personal Protective Equipment."
If you are not sure what is required or what types of PPE might be best for your employees, you can call or write the nearest State or Federal OSHA office for guidance. Small business employers may contact the OSHA-funded, State-run consultation service in their State.
The limitations and drawbacks of safe work practices also apply to PPE. Employees need training in why the PPE is necessary and how to use and maintain it. (See Chapter 11.) It also is important to understand that PPE are designed for specific functions and are not suitable in all situations. For example, no one type of glove or apron will protect against all solvents. To pick the appropriate glove or apron, you should refer to recommendations on the material safety data sheets of the chemicals you are using.
Your employees need positive reinforcement and fair, consistent enforcement of the rules governing PPE use. (See discussion below.) Some employees may resist wearing PPE according to the rules, because some PPE is uncomfortable and puts additional stress on employees, making it unpleasant or difficult for them to work safely. This is a significant drawback, particularly where heat stress is already a factor in the work environment. An ill-fitting or improperly selected respirator is particularly hazardous, since respirators are used only where other feasible controls have failed to eliminate a hazard.
Bearing the Cost.
OSHA standards require employers to provide respirators that fit individual employees. Most employers also provide other required PPE, with the exception of safety shoes and safety glasses. But even when employees must provide their own safety shoes, safety glasses, or other PPE, employers usually pay part of the cost.
When a hazard is recognized, the preferred correction or control cannot always be accomplished immediately. However, in virtually all situations, interim measures can be taken to eliminate or reduce worker risk. These can range from taping down wires that pose a tripping hazard to actually shutting down an operation temporarily. The importance of taking these interim protective actions cannot be overemphasized. There is no way to predict when a hazard will cause serious harm, and no justification to continue exposing workers unnecessarily to risk.
HAZARD CORRECTION TRACKING
An essential part of any day-to-day safety and health effort is the correction of hazards that occur in spite of your overall prevention and control program. Documenting these corrections is equally important, particularly for larger sites. Documentation is important because:
- It keeps management and the Safety Department or the person is charge of safety and health aware of the status of long-term correction items;
- It provides a record of what occurred, should the hazard reappear at a later date; and
- It provides timely and accurate information that can be supplied to an employee who reported the hazard.
Notations on the Report Form.
Many companies use the form that documents the original discovery of a hazard to track the correction of the hazard. Inspection reports include notations about hazard correction alongside the information about the hazard. Employee reports of hazards and reports of accident/incident investigations also should provide space for notations about hazard correction.(Chapter 9, Appendix 9-3 has three sample forms to use for employee reports of hazards, and each of them has a line for completed corrections.)
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 of 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 needing tracking will fail to be recorded.
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 your employees' 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. Adisciplinary 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 8-2will be useful for businesses planning to establish a disciplinary system for the first time.
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 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.
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 that 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 help informally in the enforcement of rules and practices. The intent here is not to turn employees into spies and informers, 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 coworker who needs reminding 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 fire someone for occasional tardiness. It is equally 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 his/her behavior.
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.
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 enabling you to 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, then 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.
You might 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. Periodic workplace monitoring, for example, to check for chemical exposures or noise exposures, will help assure that installed controls are still working as designed. 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 duct 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.
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 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. Whenever new equipment is placed in the worksite, the list should be revised accordingly.
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 is accessible. Easy availability of the 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.
Preventive maintenance can be a complicated matrix of timing and activity. 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 you to 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.
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 situations at your worksite. Start by listing 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 areas and consult experts on the chances of other types of natural disasters happening.
Human errors or deliberately caused disasters beyond the controls 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 chemical 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. What is your potential for explosion or release of toxic substances?
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 he/she is expected to do in each type of emergency.
For the most likely 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 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's Medical and First Aid standard, 29 CFR 1910.151 (b), for worksites that are not close to medical facilities. OSHA strongly advises that both first aid and CPR assistance be available on every shift at your worksite. OSHA's Bloodborne Pathogens standard, 29 CFR 1910.1030, also discussed in Chapter X, imposes various requirements to protect employees who provide first aid and CPR.
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 a local physician or 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. (See also Chapter X for a suggested method of determining health care 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.
You should approach each category of workplace hazard with the intention of totally preventing it, if feasible. If total prevention is not feasible, you should control the hazard as completely as is feasible 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 other administrative measures to control that exposure. Finally, you may need to use personal protective clothing and other equipment to further reduce levels of individual exposure.
To complement these hazard controls, you also must have good systems of preventive maintenance; hazard correction tracking; a fair and consistent enforcement of rules, work practices, and 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.