On August 1, 2017, the Occupational Safety and Health Administration (OSHA) launched its Injury Tracking Application (ITA), which allows employers to begin observing compliance with this year’s new electronic reporting requirements. Through the ITA, employers can submit necessary injury and illness records from their 2016 OSHA Form 300A.
WHY IS THIS CHANGE IMPORTANT?
Ultimately, maintaining injury and illness records allows employers and OSHA to identify trends in workplace hazards and target them more accurately when developing safety programs and regulatory provisions. The transition to electronic reporting will eventually lead to free public access to an employer’s injury and illness history. It is OSHA’s belief that this type of disclosure will effectively “nudge” employers to take greater responsibility for workplace safety as they will soon be held publically accountable.
This will certainly lead to improvements in an employer’s bottom line (as there is no downside to improving and prioritizing safety), but will also be valuable information for employers, workers, OSHA, and researchers, in addition to potential clients and job applicants who would like to ensure a safe working environment before making the next move.
Employers: Information compiled in OSHA-required injury records allow employers to identify trends and patterns of occupational injury in the workplace, contributing greatly to their ability to correct hazards and prevent similar injuries from occurring in the future. This is essential for employers to be able to maximize the effectiveness of their safety and health programs.
Workers: Thanks to their Right to Know, workers are able to access injury and illness records during the required five-year record retention period. Using this knowledge, they can have a better understanding of the hazards common in their workplace, leading to increased awareness and personal responsibility. Seeing in writing how certain hazards can lead to devastating injuries, an informed worker is more likely to observe safe work practices and report known hazards.
OSHA: For OSHA, transforming the information provided by injury records into visual representations allows them to investigate trends and direct their standard and regulatory efforts where they’re needed the most. For example, seeing a pattern emerge in a particular industry where machine-related injuries are unusually common tells OSHA that they need to more closely examine how they approach machine guarding regulation.
Bureau of Labor Statistics (BLS): The BLS takes the data provided by employer injury records and translates them into national statistics. OSHA, Congress, and safety and health policymakers are then able to use these published statistics to make informed decisions in safety and health legislation. Additionally, both employers and employees can use the statistics as a way to compare their workplace to others within the industry.
Included in the final rule which led to these new reporting requirements are improved anti-retaliation measures. Although it has always been against the law for an employer to retaliate against an employee for exercising their right to report injuries and hazards, before this year OSHA could only take action if a worker filed a complaint within 30 days of the retaliation. Now, OSHA can cite employers for retaliation with or without a worker complaint, or if the employer has some sort of workplace program which discourages reporting. The purpose of these revisions is to protect workers who, after experiencing employer retaliation, cannot speak up out of fear of further retaliation.
Employers can comply with the new anti-retaliation protections by informing workers of their right to report workplace injuries and illnesses without retaliation, and ensuring established reporting procedures in no way deter workers from using that right. The former can easily be accomplished by properly displaying OSHA’s “Job Safety and Health: It’s the Law” poster, which is already a requirement.
WHO NEEDS TO SUBMIT INJURY AND ILLNESS RECORDS, AND WHEN?
The new electronic reporting requirements do not change who is required to maintain injury and illness records, or what injury and illnesses are recordable. The only change is in how those records are submitted.
Employers with 20-249 employees are only required to submit necessary injury and illness records if their establishment falls within an industry which has a historically high rate of incidents. If you must submit records:
This year, OSHA Form 300A is due by 12/1/2017
In 2018, OSHA Form 300A is due by 7/1/2018
Beginning in 2019 and every year thereafter, OSHA Form 300A is due by March 2.
Employers with 250 or more employees:
This year, OSHA Form 300A is due by 12/1/2017
In 2018, OSHA Forms 300A, 300, and 301 are due by 7/1/2018
Beginning in 2019 and every year thereafter, OSHA Forms 300A, 300, and 301 are due by March 2
WHAT DO I NEED TO RECORD?
Again, despite updates to how injury and illness records are submitted, what is considered recordable (and therefor mandatory) remains the same:
Any work-related fatality
Any work-related injury or illness that results in loss of consciousness, days away from work, restricted work, or transfer to another job
Any work-related injury or illness requiring medical treatment beyond first aid
Any work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums
Needlesticks and sharps injuries where the object was contaminated with another person’s blood or other potentially infectious material
Circumstances under which an employee is medically removed under the medical surveillance requirements of an OSHA standard
If an employee’s hearing test shows the employee has experienced a work-related Standard Threshold Shift (STS) in hearing in one or both ears, and the employee’s total hearing level is 25 decibels or more above audiometric zero in the same ear(s) as the STS
Any employee who has been exposed in the workplace to someone with a known case of active tuberculosis, and later tests positive for a tuberculosis infection
OSHA defines the following as first aid:
Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes);
Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment); Cleaning, flushing or soaking wounds on the surface of the skin
Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.; or using butterfly bandages or Steri-Strips™ (other wound closing devices such as sutures, staples, etc., are considered medical treatment)
Using hot or cold therapy
Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes)
Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.). Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister
Using eye patches
Removing foreign bodies from the eye using only irrigation or a cotton swab
Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means
Using finger guards
Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes)
Drinking fluids for relief of heat stress
HOW DO I GO ABOUT SUBMITTING RECORD FORMS?
OSHA’s secure website provides three record data submission options:
Via web form
Via uploaded CSV files for processing single or multiple establishments simultaneously
Via electronic data transmission using an application programming interface (API)
The electronic submission process, regardless of which avenue your establishment takes to achieve this, involves four steps:
Create your establishment (much like creating a user account for other web-based processes)
Inputting summary data from your injury and illness record forms
Officially submitting the data to OSHA
Reviewing the details in your confirmation e-mail to ensure accuracy
You can access OSHA’s Injury Tracking Application to begin the process here. Just remember to prepare ahead and allow yourself enough time to meet the aforementioned deadline.
If you need additional assistance meeting injury and illness recordkeeping requirements, contact one of our safety specialists here.
Near miss reporting is a fundamental piece of a strong safety culture. While OSHA doesn’t require near miss reporting, companies capturing that information can gain insight into potential problem areas. Understanding the difference between incidents, near misses, and accidents is important when developing a comprehensive safety meeting topics.
An Incident is an unplanned, undesired event that hinders completion of a task and usually causes injury, illness, or property damage. The terms “unplanned and undesired” don’t mean unpreventable, nor do they mean that you can’t prepare for them. Analysis and planning are how we prepare for serious incidents that may occur, and how we take action to eliminate them.
A near miss is defined as an incident that could have resulted in injury, illness, or property damage, but didn’t. Near misses, also known as ‘close calls’, should really be near hits.
The definition of accident is similar to that of incident, but implies that the occurrence was unpreventable. An accident, using this definition, contradicts the basic concepts of a safety program, which is to find and fix hazards, and prevent incidents. If we accept that accidents have no cause, that means they are unpreventable, and they will happen again.
Training employees on the importance of reporting near misses not only will raise their awareness of potential hazards; it moves your safety program from a purely reactive mode toward a more proactive effort. Near misses are often a precursor to more serious incidents, and may be a warning that procedures and practices need to be examined.
The reporting and investigation of near misses can be instrumental in preventing injuries. Near misses are really a zero-cost learning opportunity, because it signals a potential problem without resulting in injury or loss.
If your current safety program doesn’t include the mandatory reporting of near misses, perhaps it should. Consider implementing near miss reporting the next time you review your safety program, which you should do annually. This commitment to continuous improvement will demonstrate the importance of safety to your company to all employees.
Life doesn’t always give us warning signs, but when it does, we should heed them. Having an internal near miss reporting and investigation procedure as part of your safety program is heeding one of those signs. Being able to anticipate and avoid incidents is far less costly than reacting to one. An ounce of prevention could be worth someone’s life.
Do you consider workplace checklists an important part of ensuring all necessary safe work procedures are consistently followed? Or do you consider a checklist a slow, tedious, and largely unnecessary procedure for work you already know how to do?
Here are two interesting accounts where checklists have been used to great effect. One is a matter of history that changed an industry, and the other occurred much more recently, demonstrating that there can be human resistance to following demonstrably better procedures.
Boeing B-17 and the First Checklist
On a B-17 test flight, in 1935, the aircraft stalled on takeoff because the elevator lock was accidentally left on, and pitch control didn’t work. Three men were injured, and two later died.
Because this new airplane was much more complicated to fly, it was determined that even experienced pilots would need a checklist. Instead of relying on memory every time, a checklist would ensure that all necessary steps were completed to keep the airplane safely in the air. Because of this simple, new process, Boeing was able to get the government to mass produce the B-17, and it went on to be a very successful asset for the United States in World War II.
Believe it or not, Boeing’s checklist is considered the first. Certainly, checklists are a very common practice in aviation today, where a focus on safety requires numerous variables to be checked before every flight. There are more than 25,000 daily commercial flights in the U.S. each day.
Hospital Checklist Slashes Infection Rates
In 2003, Dr. Peter J. Pronovost established a simple, five-step checklist to be followed every time a common catheter (central venous catheter) was inserted at 108 intensive-care units in Michigan. Over 18 months, catheter-related infection rates dropped from 4% to 0, saving 1,500 lives and nearly $200 million.
As you can see, the checklist is as simple as it gets:
Wash hands with soap.
Clean patient’s skin with chlorhexidine antiseptic.
Put sterile drapes over the entire patient.
Wear a sterile mask, hat, gown and gloves.
Put a sterile dressing over the catheter site.
According to Dr. Pronovost, he wanted to change behavior, which he says is the biggest opportunity to improve health care. Still hospitals lag in implementing similar checklists. However in the news, the CDC procedures where health care workers who may come into contact with Ebola patients will have another person guide them through the step by step process of putting on and removing PPE amounts to a checklist.
Some reasons people resist using checklists include:
Experts such as doctors don’t want to be monitored by others
Experts want to have the freedom to act as they see fit
Standardized tasks are associated with bureaucracy, and more paperwork
There is a focus on new medical procedures rather than ensuring current ones are enforced
Checklists in the Workplace
So, looking at these two examples, can you see where workplace safety can benefit from following a checklist? Anywhere a series of steps has to be followed correctly every time, a checklist can be implemented to make sure everything has been covered and nothing is missed.
Here are a few places where creating a checklist may be helpful:
Making sure a first-aid kit is fully stocked with necessary materials
Daily and monthly inspections of vehicles such as: forklifts, cranes, and ladders
Annual workplace inspections
PPE maintenance and repair schedules
Required monthly and quarterly fire-extinguisher inspections
Equipment inspection and repair schedules
Start-up and shutdown procedures
Established lockout/tagout procedures
Other Safety School articles that examine the more academic concepts of occupational safety:
Too often companies are told that they need to have a custom safety manual to protect them from OSHA violations, and while that’s true, understanding how that works is just as informative to a safely run company as having all the right words and regulations in a policy.
During an inspection, the inspector will ask for the written safety policy and all documentation of training, inspections and discipline. This documentation becomes important after the inspection, when a company can challenge or attempt to mitigate any possible penalties.
In legal terms you have “negating defenses” and “affirmative defenses” to argue any possible citations. The negating defense is simply arguing that that an allegation wasn’t a violation or it didn’t happen. More interestingly there is an affirmative defense, which admits the violation occurred but provides a justification. In a criminal case, “self-defense” is an affirmative defense.
So if an employee is spotted performing an unsafe action and a violation has been assessed, the inspector can look at the safety manual and training documents and ask:
Is there is a system in place?
Are employees trained in it?
Do you inspect the worksite and enforce the policy?
As an example, if the inspector cites an employer for a worker not wearing a hard hat, the company can challenge it with a policy stating that all employees must wear hard hats, evidence that employees are trained to know it’s a requirement, and evidence of inspections to enforce the policy with discipline when an employee doesn’t follow it.
Just having the policy isn’t enough; it needs to be backed up with ongoing application and training.
Safety Key Performance Indicators (KPI)
To go a step further, another way to demonstrate a commitment to safety in your policy is to track it.
Every company has its Key Performance Indicators (KPI). An easy way to know if a company prioritizes safety is to see if they track any safety KPIs such as:
Days since last incident
Number of regulatory violations
Annual change in percentage of training compliance
Annual change in the Total Case Incidence Rate (TCIR)
A company’s safety performance is the same as any other metric. Have you heard the saying,” what gets tracked is what gets done”?
When you track these safety KPIs, this information can be used in annual safety policy reviews of your manual. Use this information to see if there are incidents or close calls being repeated, or if the current manual and policies cause different hazards not planned for, or if there is something that changed in the last year that needs its own safe work practices.
Other Safety School articles that examine the more academic concepts of occupational safety:
Contractor Earl Has Several Ongoing Jobs, What Should He Do?
The OSHA Recordkeeping regulation requires employers keep a record of serious injuries and illnesses using the OSHA 300 Log. And although it sounds simple enough, the particulars of which employees are covered, how many separate logs need to be used, and what types of injuries are serious enough to be reported can get complicated enough that OSHA updates their Frequently Asked Questions (FAQ) and Letters of Interpretation (LOI) websites. Contractor Earl has several ongoing jobs, what should he do?
In February 2014, OSHA answered several questions from a business asking for more details about the requirement to keep a separate OSHA 300 Log for multiple business establishments, 1904.30.
1904.30 Multiple Business Establishments
The basic requirements start with the idea that each establishment expected to be working for at least one year must have its own separate OSHA 300 Log. One OSHA 300 Log can be kept for all shorter-term establishments. The records can be kept at headquarters if information of an injury can be logged within seven days, and the records can be quickly sent to the establishment.
Every employee must be linked to an establishment. Also, if an employee is injured while at a different establishment, the record must be logged where the injury occurred. If an employee is injured away from a company establishment, the case must be logged where the employee normally works.
Question: For a company that has employees working at many locations controlled and operated by clients, does that company need to have a separate OSHA 300 log for each client site?
OSHA Response: If the company has a continuous presence at a client’s site, like an office at the job site for at least one year they need to maintain an OSHA 300 log.
Question: When the company has to keep OSHA 300 logs, can they keep them at headquarters?
OSHA Response: Yes, Section 1904.30(b)(2) allows that if the company can produce copies of injury and illness forms when permitted access is requested.
Question: Where should the company record employee injuries at a remote location not associated with a company building or a client’s site?
OSHA Response: To make sure all employees are included in a company’s records, injuries at remote locations must be recorded at the home establishment that employee is linked to. If an employee works at several locations, making one establishment impractical, they should be linked to a general OSHA 300 log for short-term establishments.
Question: Does posting the OSHA 300-A Summary Form electronically for all employers to review satisfy OSHA’s posting requirements?
OSHA Response: A hard copy of that form must be posted conspicuously at each establishment where notices are normally posted.
Question: Where does the company with several locations post the annual summary?
OSHA Response: Post the annual summary at the employee’s home establishment.
In addition to creating new and updating current regulations, OSHA publishes interpretations and answers to questions about existing rules.
Imagine the following situation and ask yourself if you know exactly why or why not the employer should log the injury as work related.
An employee, while walking up 80 feet of steps at work, had their left knee suddenly “pop” and couldn’t place weight on it, requiring first aid. After being taken to a hospital, the employee was diagnosed with a strained/sprained knee.
Then, four days later, a second physician says the knee condition is non-occupational — citing the exception in 1904.5(b)(2)(ii) that says employers don’t need to report an injury that happened solely from a non-work related event, even if the symptoms occurred while at work — because there were no obvious aggravating factors at the workplace that contributed to the knee injury.
OSHA first made it clear it is the employer’s responsibility to make the correct decision whether a specific injury or illness is work related, even though the employer may use the guidance of a health care professional.
Also, a work event doesn’t have to be the only, or even main, cause of a work injury. The injury doesn’t even have to be caused by a unique or “out-of-the-normal” event like a fall.
Question: Is walking up 80 feet of steps at work an identifiable event or exposure, even without a slip, trip, or fall?
OSHA Response: Yes, normal body movements like walking, bending down or sneezing can be an event that makes it related to work if these actions can be identified as the cause of an injury.
Question: If a physician determines the injury is a reoccurrence and not a new case, is the employer relieved from the requirement to determine the injury is recordable?
OSHA Response: 1904.6(b)(3) says employers must follow the health care professional’s determination of whether an injury is a new case or reoccurrence, but that’s when the employee has a recorded similar workplace injury. Without any previous OSHA recorded left knee injuries, the employee’s case is new and a health care professional’s evaluation isn’t necessary.
Question: If two health care professionals come to different conclusions about whether an employee’s injury is work related, do you use the first one or second one?
OSHA Response: OSHA’s recordkeeping regulation allows advice from multiple health care professionals to determine if an injury or illness is work-related. But it is the employer’s responsibility to make the correct decision.
When two or more health care professionals make conflicting determinations, the employer must base its decision on the most authoritative — best documented, best reasoned, or most persuasive — evidence or recommendation — 1904.6(b)(3).
In addition to creating new and updating current regulations, OSHA publishes interpretations and answers to questions about existing rules. Here is what has been released in 2014:
Most third-party prequalification websites (ISN®* (via their ISNetworld®* database), PICS®, PEC Premier®, BROWZ, ComplyWorks®, Veriforce, Textura or Others.) revise their standard questionnaires fairly regularly. These are known as “updates”. The frequency at which they happen are variable depending on the third-party auditor. ISNetworld® is the largest third-party auditor, and we will be taking a look at what a quarterly update is and how it can affect your score.
What is a quarterly update?
At the end of each quarter, ISN® takes initiative and takes a couple days to revise their Management System Questionnaire™ (MSQ™) to ensure that it is up to date with the most current legislative requirements and other important information as requested by Owner Clients. During this time, the MSQ™ will be inaccessible until the revisions have been made. The table below details how the quarters are split up during the year.
January, February, March
April, May, June
July, August, September
October, November, December
Multiple changes can happen during a quarterly update. New questions may be added, obsolete questions removed, and new requirements may be populated. With each quarterly update, every ISNetworld® account will have to answer statistical questions such as concerning the number of employees, hours worked, injuries, time away from work, and other important information for the past three months. This can be expected and prepared for in advance – this will always be added during a quarterly update.
Note: Keeping track and utilizing this feature can make it much easier to document your OSHA 300/A Logs or statistics at the end of the year! All of your statistical information will already be uploaded to your account – all you will have to do is add up the statistical information for each quarter and document them!
How can a “Quarterly Update” affect my grade?
After the quarterly update has been completed and the statistical information has been entered, there are a few different items that can affect your grade. These may affect your grade in a positive or negative manner.
After your quarterly statistics are added in, the most crucial aspect is ensuring that you have a safe workplace. New incidents and injuries will definitely hurt your Total Recordable Incident Rate (TRIR) for the previous 3 years. However, if you have had incidents and injuries in the past but have worked incident-free, your TRIR will naturally become lower. Most, if not all, Owner Clients will take a very serious look at a contractor’s safe hours worked when considering them for a project.
New questions added to the MSQ™, depending on the Owner Client, may appear in your GAP report. These should be addressed as soon as feasibly possible to ensure that your account does not fall into an unfavorable grading. Keep a close eye on any additional questions!
RAVS® revisions commonly happen during quarterly updates as well – meaning you may have to revise existing policies and procedures or write new programs. These have a major impact on most Owner Client’s grading scales. Some Owner Clients may keep you off of a project until the new policies are written. These should take a high priority on any contractor’s “to-do” list.
How can Safety Services Company help?
Safety Services Company can review every aspect of your company’s statistical information, safety program, EMR, TRIR, and information based on the answered questions of the MSQ™ and provide a Contractor Improvement Program tailored specifically to your organization. These improvement programs don’t focus on problems, but instead identify effective solutions and assign responsible parties to ensure that they are upheld.
Additionally, Safety Services Company’s Global Compliance Solutions department offers a multitude of cost-effective solutions when dealing with the requirements of any third-party prequalification outfit. Our staff can produce comprehensive and compliant safety programs, effective safety training material, and perform continual maintenance on your ISNetworld®, PEC®, PICS Auditing®, ComplyWorks®, CanQual®, and many other third-party prequalification accounts. Why worry about your account and give yourself undue stress when your time can be better spent managing your business?
*Safety Services Company is an independently owned company, specializing in compliance with Third-Party Prequalification Providers such as ISNetworld®, PEC Premier®, PICS®, Complyworks® and Canqual®. Safety Services Company is in no way sponsored or affiliated with ISNetworld®, PEC Premier®, or PICS Auditing®. ISN®, ISNetworld®, RAVS®, SSQ®, PQF® are registered trademarks of ISN Software Corporation®, PEC Premier®, and PICS Auditing®.
Every year, over 4 million workers are the victim of a serious injury or illness on the job. Daily, more than 12 of these injuries result in death. The majority of these injuries and deaths can be prevented if the hazards that caused them had been properly identified and controlled ahead of time. The importance of conducting a worksite hazard assessment is immense; if the tragedies caused to an employee and their family by serious injury or death isn’t reason enough, company losses as a result each year are in the billions of dollars.
A thorough hazard assessment will allow you to identify and then eliminate or control physical hazards and unsafe employee work practices before they occur. Review these five basic steps to get you started on your hazard assessment.
Before you can begin the actual assessment, you’ll need to create a system of job prioritization and a ranking system for the severity of each hazard. In general, it’s most effective to begin with jobs with the highest risks, such as:
Documented to have frequently resulted in injury or illness
Present severe and life-threatening hazards even if there is no documented instances of prior occurrences
Undergone significant changes in procedure or equipment or are altogether new to your company
Procedures of a nature complicated enough to require written instructions
Involve serious and life-threatening hazards that could be triggered by a single worker error
After you have determined a priority system, the next step in preparation is to develop a method of ranking hazards by their potential severity considering both probability and severity. To give you an example:
The highest ranking of probability would include employee contact with a hazardous material or atmosphere, because an injury is nearly guaranteed. The lowest ranking would be that it is virtually impossible for injury to occur.
In terms of severity, the highest ranking may be that the injury will almost certainly cause fatality to numerous workers, and the lowest that the worst-case scenario is a minor cut or bruise.
In this way, you will be able to see a written, visual representation of what jobs and hazards will require the most highly-focused attention.
2. Job Step
Next you create your job hazard analysis. For best organization and record keeping, you should create a separate document for each individual job on the worksite. Each document should consist of three columns: Job Step, Possible Hazards, and Preventative Measures.
In the Job Step column, describe each basic step of a task, from first to last. For example, if the task involves an employee receiving a shipment at the warehouse, the first step may be described:
Employee guides delivery truck to the loading dock.
Cover each individual step of the job process, including both the person involved (employee, manager, maintenance crew, etc.) as well as the action (guiding the truck, loading shipment onto pallets, etc.).
3. Possible Hazards
In the center column, describe any imaginable safety hazards associated with the job step indicated in the first column. Be thorough — where safety is concerned, leave no stone unturned.
Regarding the aforementioned example, the obvious safety hazard may be that the worker is out of view of the driver and the delivery truck is backed up over them. But there are other considerations.
Is the worker guiding the truck from an elevated loading dock (is there a falling hazard?)?
Is it possible for the worker to become crushed between the truck and a nearby stationary object?
Are there clearance issues?
When identifying and documenting hazards, be complete enough in your description to answer the following questions:
What could possibly go wrong?
What would the result be should a worker come into contact with the hazard?
How could the worker come into contact with the hazard?
What other factors may contribute to the hazard?
What is the likelihood of the hazard arising?
“If the employee is standing too close to an unprotected edge of the loading dock(1) or they are knocked over by the moving delivery truck(4), there is a high risk(5) that they may fall to the lower level(3) resulting in bodily impact injuries or death(2).”
4. Preventative Measures
In the final column, describe any possible preventative measures that could be implemented to either control or altogether eliminate the safety hazard. When considering prevention, take the three control methods into account:
Engineering controls involve physically altering equipment or environments to prevent employees from coming into contact with a hazard. In the example we’ve been using, one possibility may be to install guardrails along the leading edges of the dock where an employee would be stationed. Another idea would be to implement visual or audial indicators such as flashing lights or warning sounds to assist delivery truck drivers in backing up without the necessity of an employee being within close physical proximity.
Engineering controls are considered to be the most desirable and effective form of hazard prevention because they eliminate the hazard altogether. Engineering should always be the first step when possible.
If it is impossible to engineer a hazard out of existence or displace employees from a hazard’s exposure, the next best step would be administrative controls.
These controls involve monitoring, adjusting, or training safe work practices into employees’ job routines. An example may be that the employee uses pre-established hand signals for guiding a delivery truck driver while remaining in a designated and visible safe area.
Safety training is included as an administrative control.
Administrative controls are often thought of as only moderately effective since they rely on human behavior.
Personal Protective Equipment (PPE)
PPE should be required whenever possible, but never considered the primary defense against a safety hazard. This can include safety goggles, gloves, hard hats, back braces, face shields, chemical protection aprons, respirators, etc. For example, if the employee is exposed to exhaust fumes while guiding delivery trucks to the loading docks, requiring respirators or face masks may be desirable.
Job hazard assessments need to be thought of as a living document; they should undergo constant maintenance and upgrades as new hazards and hazard control methods are identified. Also update the assessment whenever there is a change to the work process.
Remember to be as thorough as possible — it’s much better to go overboard in describing the layout of a hazard than to overlook a crucial element.
To leave you with a final thought from a supervisory perspective:
Unfortunately, employees who have become comfortable and adept enough at performing their jobs may be inclined to implement their own ideas on safe practices. A job hazard assessment is only effective if it results in preventative actions taken, and actions taken are only guaranteed if employees are encouraged to do so with positive supervision and continuing training.
In response the September death of a California wine worker the state’s Division of Occupational Safety and Health (Cal/OSHA) has issued a warning about the dangers of anhydrous ammonia.
Anhydrous ammonia is used under pressure as a liquid refrigerant in many wineries across California.
The chemical is extremely hazardous to a person’s health, if released in the air. Potential health effects include skin, eye and lung corrosion ant lower levels and death at levels of 300 ppm.
Signs of exposure listed in the warning include throat pain and coughing.
The release states to prevent exposures and injuries employers must:
Develop and require refrigeration maintenance personnel to follow written standard procedures for maintaining the refrigeration system per manufacturer’s recommendations including such routine procedures as oil draining.
Ensure that the ammonia refrigeration system is operated and maintained only by trained and competent personnel.
All employees need to be trained on the hazards of ammonia, the signs, symptoms and detection of an ammonia release, and the proper procedures for escape during an emergency.
The document also describes General Responses to Ammonia Release. Those responses include if you:
Smell ammonia, immediately leave the area and notify your supervisor.
Inhale ammonia, immediately move to fresh air and get medical attention.
Have skin or eye contact, immediately flush affected area with water for fifteen minutes.
See an ammonia cloud (white fog), immediately exit the building or area and move upwind to a designated location.
The states that report the fewest nonfatal injuries for construction workers have some of the highest rates of fatal injuries according to a report released by the RAND corporation, a nonprofit research organization.
States with low injury reporting are often in the South, where workers get less pay, lower worker compensation benefits, and are less unionized. On the other hand, the report points to higher injury reporting and fewer fatalities in workplaces in the West where wages and benefits are higher, unions are stronger and there are more inspections.
“We were surprised by the relationship between fatal and nonfatal injuries,” said John Mendeloff, lead author of the study and a senior policy researcher with RAND. “One key factor influencing injury trends seems to be the scope of benefits offered by a state’s workers’ compensation program, but that explains only part of what we found.”
The research points to workers reporting more injuries in states with higher worker’s compensation benefits, suggesting the higher payouts create an incentive to report more injuries.
The study, published in the April issue of the American Journal of Industrial Medicine, seems to also suggest that a safety program where more injuries are reported is more effective. Mendeloff proposes the trend suggests two things, first, that reporting might be a sign of a more effective, more honest worker safety program. Second, the low non-fatal injury rates in states with high worker fatality rates may suggest underreporting of injuries and less effective worker safety programs.
The study found that the construction industry has the largest number of fatalities among all industrial sectors.
The On-site Implementation and Audit Team were a great help building a robust safety program, walking us through implementation and facilitating the audit.