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Developing a Hazard Inventory
10 Developing a Hazard Inventory INTRODUCTION Do you know all of the potential hazards that are associated with your type of industry and your site-specific workplace? If you do, we would be surprised. Yet if you want to protect your employees from workplace hazards, you must understand what those hazards are and how to control them [2]. A means of identifying hazards should be systematic. The following activities form the basis for a good hazard recognition, prevention, and control program and outline the three major actions needed to control hazards [2]: 9 Comprehensive survey. Periodic, comprehensive safety and indus-
trial hygiene surveys * Change analysis. Potential hazards associated with new facilities,
new/relocated equipment installation, materials, and processes; refer to Chapter 15 9 Job hazard analysis. Routine hazard analysis, such as job hazard analysis, process hazard analysis, or task hazard analysis [2]; refer to Chapter 15 After hazards have been identified and controls are put in place, additional worksite analysis tools can help to make sure that the controls stay in place and that other hazards do not appear. Refer to Chapter 11 for detailed discussions of specific tools~for example, inspections, methods for employees to report hazards, incident investigations, and pattern analysis. First, you must understand the existing and potential hazards that may exist in your workplace. Table 10-1 lists some methods of preventing hazards. 175
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Developing an Effective Safety Culture: A Leadership Approach
Table 10-1 Preventing Hazards Continually review the work environment and work practices to control or prevent workplace hazards. Some ways to prevent and control hazards include: 9 Perform regular and thorough equipment maintenance 9 Make sure that hazard correction procedures are in place 9 Make sure that everyone knows how to use and maintain PPE 9 Make sure that everyone understands and follows safe work procedures 9 Make sure that, when needed, there is a medical surveillance program tailored to your facility to help prevent workplace hazards and exposures http://www.osha-slc.gov/SLTC/safetyhealth_ecat/comp3.htm#, public domain.
COMPREHENSIVE SURVEYS
One thing that you must remember is that a comprehensive survey is not the same as an inspection. Employees often do inspections on a routine basis as part of a safety committee, etc. Other individuals who can bring fresh ideas and a knowledge of safety, health, or industrial hygiene should perform comprehensive surveys. Because there are few professionals equipped to do comprehensive surveys in all three areas, the best approach is to use a multiple-discipline team consisting of several specialists: a safety professional, an industrial hygienist, and a medical provider. In other cases, it could be comprised of a safety professional or someone from operations (management and an employee from another part of the operation) [2]. Figure 10-1 is a flowchart of a risk toolkit. To conduct a comprehensive survey you may need some level of professional knowledge. The following is a summary of those professionals you should consider when conducting any type of comprehensive survey for your organization. The medical provider can be a physician or a registered nurse with specialized training and experience in occupational medicine. He/she can assist the safety or industrial hygiene professional or can do a separate health survey, depending on the makeup of your workplace. Refer to Chapter 13 for suggested criteria for the occupational health professionals and/or medical provider. Many workers" compensation carriers and insurance companies offer loss control professional services to help
Developing a Hazard Inventory
177
Analyzework
Defineparticular ! Subsystems~1
Identifyhazard~
Defineongoing i hazardous | situations ~1
[,
Appreciate potential hazardousevent~l~ ..I Analyzep~ harms(or ~1 c~
[
|-~
Y
Verify
[
!
Estimaterisk(plot I riskdimensionson | matrix) ~1~ /
Introduce corrective/ 41--No preventative measures .~
r' Nochange [ Yes-~1 necessarymonitor/ L systems ~
Figure 10-1 Flowchart of the risk toolkit. Cox, Sue, Tom Cox, Safety Systems and
People, p. 41, Figure 2.6. Butterworth-Heinemann, 1996. Modified with permission.
clients evaluate safety hazards. Larger businesses may find the needed expertise at the company or corporate level or in an independent consultant. If you use a professional from within your company, be wary o f " t u n n e l vision," which can lead to failure to identify specific issues [2]. As the old
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Developingan Effective Safety Culture: A Leadership Approach
saying goes: Sometimes you cannot see the forest for the trees. It's possible to stay in a position so long that you cannot see what is really going on around you. For the industrial hygiene survey you should, at a minimum, want to inventory all chemicals and hazardous materials at the site, review the hazard communication program, and conduct air sampling in various areas to analyze the air for hazardous contaminants. For specific applications, a noise level survey and a review of the respirator program could be required [2].
EVALUATING THE PROFESSIONAL RESOURCE
If you hire a professional and you want to make sure that your worksite will be evaluated properly, you may want to ask the consultant specific questions: 9 What type of training and experience have you had? How recent is it? What is its scope of the training? Is it limited to a specific industry? Does it consist of only practical experience, without formal training [2]? If he/she has a professional certification, is it valid, or has it lapsed for lack of maintenance points~for example, training, presentations, seminar attendance, activity participation in a local society [2]? Check references where surveys have been recently completed. Determine if any O S H A inspections occurred after the survey. Were any serious hazards found that the consultant missed? What tools did the consultant use for the survey? How much knowledge or transferable skills does the consultant have [2]? 9 What kind of information will he/she need in advance? A professional who is planning an in-depth survey should prepare by learning as much as possible about the workplace and processes that exist Both safety and industrial hygiene professionals will usually want to see a layout of the operations The industrial hygienists may ask for a list of chemicals used or the Material Safety Data Sheets (MSDS) you received from your suppliers and the types of processes where you use them [2]
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9 What type of test equipment will the consultant use? Each professional will usually bring several items to the survey. You should expect the safety professional to bring a tape measure; a ground loop circuit tester to test electrical circuits; a multimeter (for 220 and/or 440 volts only); a tic tracer (or similar equipment) to check wires or electrical equipment to see if they are energized; and a ground fault circuit interrupter tester [2]. 9 The industrial hygienist may bring noise monitoring equipment. Depending on the chemicals or other contaminants expected, sampling pumps or grab sampling devices may be used. 9 How long will the review take? It should take several times longer than a routine inspection of your workplace. It will also depend on the complexity of the workplace For example, if the industrial hygienist does air sampling, it should be time-weighted, 8-hour or full-shift sampling to measure the overall exposure to employees [2].
EVALUATING THE SURVEY
The following are some signs of a thorough survey: 9 The consultant (safety professionals, industrial hygienists, and/or medical provider) should start with your injury and illness logs and look for patterns. 9 The safety professional also may want to see program documentation. 9 The industrial hygienist and health professional may want to see your hazard communication program, if applicable, your hearing conservation and/or respirator program. 9 The medical provider may want to see your records of employee visits to clinics, first aid stations, and other workplaces where treatment is provided for work-related injuries. 9 He/she will want to examine records of employee training in first aid and CPR or blood-borne pathogens. In addition, they may want to see a baseline and follow-up testing records. 9 The safety professional should start at the beginning of your process, where raw materials are brought in, and carefully go through all processes, inspecting each operation and talking to employees, until the point where the product is finished and shipped to the customer. The following areas should be evaluated or inspected:
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Developing an Effective Safety Culture: A Leadership Approach
How materials are handled from the time they are received and how they are moved and stored, checking the stability of storage racks and the safe storage of flammables/explosives The openings that expose moving parts for pinch points, machine guarding, and other hazards Hand tools and equipment and wiring in the maintenance shop and other areas as appropriate Operations on every shift and any after-hours operations, such as cleanup or forklift battery recharging How you manage your hazard prevention and control program Outside of buildings, for example: chocks for trucks at the loading/unloading docks, fork lift ramps, outdoor storage of flammables/explosives, oil, and any fueling areas The professional should also do the following: Open every door and look in every corner of the facility Suggest target tasks for job hazard analysis, especially those tasks that might involve ergonomic-related hazards Assist in developing and/or improving your injury reduction program The industrial hygienist and medical provider should start at the beginning of your production operation, observe all processes, talk to employees, and follow the production flow to the point of shipping [2]. They may do the following: Review a list of all hazardous substances that can be found in the worksite (as required by 29 CFR 1910.1200(e), OSHA's Hazard Communication standard), or the accuracy of the existing inventory list Determine what metals are used in any welding operations Check any production areas where eating or smoking is allowed Check for the possible presence of asbestos, lead, mercury, silica, other carcinogens, etc. If respirators are used, determine whether employees are using each brand properly, how to fit test each employee, whether pulmonary function testing is done, and how the respirators are cleaned, maintained, and stored Perform full-shift sampling of contaminants thought to be present to understand employee exposures Watch the movements that employees make in performing their tasks to see if there are existing or potential cumulative trauma disorders (CTDs) or other ergonomic issues Suggest processes for routine process hazard analysis
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Help you set up or improve regular monitoring programs for any contaminants or other health hazards found to be present [1, 2]. The items listed do not constitute an exhaustive list of activities you should expect [2]. This hazard inventory should be expanded and improved by what you learn from periodic surveys, change analyses, and routine hazard analyses. The baseline survey should provide the basic inventory of hazards and potential hazards. However, the foundation of your inventory is the baseline comprehensive survey. It is important that this initial survey be done well [2].
FOLLOW-UP SURVEYS
You will need periodic follow-up surveys if you are to apply the rapidly growing scientific and engineering knowledge about hazards, their prevention, and control. These follow-up surveys help to identify hazards that may have developed after the processes and/or procedures have been in place. The frequency of follow-up surveys depends on the size and complexity of the organization.
INVOLVING EMPLOYEES IN ESTABLISHING THE INVENTORY
Always use the knowledge that your employees have gained from their close involvement with equipment, materials, and processes. You should encourage your employees to communicate openly with the professionals who do the comprehensive surveys [2]. Do not make the mistake of limiting your employees' participation to what they can tell the professionals. Make sure that employees participate in the various types of hazard analysis. It makes good sense to involve employees in change analysis of new equipment and/or processes because of their valuable insights into how things really work. As indicated in Chapter 15 on job hazard analysis, many companies regularly include employees in this activity. Employees can play a similar role in
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Developingan Effective Safety Culture: A Leadership Approach
process hazard analysis. Greater understanding of hazards, prevention, and control helps employees do a better job of protecting themselves and their co-workers.
CHANGE ANALYSIS
Before making changes in the worksite, analyze the changes to identify potential hazards. Anytime you change your worksite, whether you are adding a piece of equipment, different materials, or a new process, relocating equipment, or building, you may unintentionally introduce new hazards. If you are considering a change in your workplace, you should analyze it thoroughly before making these changes. You need a good baseline (starting point) and independent review. This change analysis is cost effective in terms of the human suffering and financial loss it helps to prevent. Stopping problems before they develop is less expensive than attempting to fix them after the fact [2]. An important step in preparing for a worksite change is to consider the potential effect on all employees. Individuals respond differently to changes, and even a clearly beneficial change can throw an employee temporarily off balance and increase the risk of an incident. You want to make sure that you communicate all changes to affected employees as soon as possible, provide training as needed, and pay attention to employee work activities until everyone has adapted to the new change [2]. Refer to Chapter 15 for a description of change analysis.
Building or Leasing a New Facility Something as basic as a new facility needs to be reviewed carefully to identify hidden hazards~for example, the fire system, security, and environmental issues. This is often overlooked. A design that seems to enhance production of your product and appears to be a marvel to the architect may be a harmful or even fatal management decision. Safety professionals should take a careful look at all design/building plans prior to final approval [2]. When you lease a facility that was built for a different purpose, the risk of acquiring safety problems is even greater. This a true unknown. You should make a thorough review of the facility, by reviewing the blueprints and/or plans for any renovations. One of the most obvious concerns in acquiring an existing facility is whether any environmental issues such as
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lead paint, asbestos insulation, mercury, or PCBs may be present. But you also may discover that something as easy to fix as a loose stair railing has gone unnoticed in the rush to renovate production areas. Save frustration, money, and lives: Make sure that you have a safety professional involved in the planning of any facility construction, purchase, or lease [2].
Installing New Equipment Equipment manufacturers do not know how their products will be used at your facility. Therefore, you cannot rely on the manufacturer to have analyzed and designed guarding, controls, or safe procedures for the equipment. Another issue to take into consideration is if the equipment is produced in a foreign country. It may not meet U.S. requirements and laws. Therefore, you should also involve a safety professional in the purchasing decision, as well as in installation plans and startup [2]. Many companies also provide a period to test newly installed equipment. The company assigns its most experienced employees to watch for hidden hazards in the operations before full production begins. As with new facilities, the sooner hazards are detected, the easier and cheaper the corrections will be [2]. One of the best methods is to conduct a JHA (Chapter 15).
Using New Materials Before introducing any new materials into your production processes, you must research the hazards that the materials may present. Also try to determine any hazards that may appear as a result of the processes you plan to use with the materials [2]. When you review new material, the place to start is the manufacturer's Material Safety Data Sheet (MSDS). An MSDS is required for all materials containing hazardous substances. It should arrive with each shipment. The MSDS should provide hazard information. You should have someone knowledgeable to analyze the hazard a chemical presents and to prevent or control any associated hazard [2].
Starting Up New Processes New processes require employees to perform differently. Consequently, new hazards may develop even when your employees are using
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Developingan Effective Safety Culture: A Leadership Approach
familiar materials, equipment, and facilities. Carefully develop safe work procedures for new processes. After the employees have become familiar with these procedures, perform routine job hazard analysis to identify any hidden hazards [2].
ANALYZING MULTIPLE CHANGES
Often a big change is composed of several smaller changes. When you begin producing a new product, chances are you will have new equipment, materials, and processes to monitor. Make sure that each new change is analyzed not only individually, but also in relation to the other changes [2]. Once you have analyzed the changes at your worksite, add this information to your inventory of hazards. This inventory is the foundation of the design of your hazard prevention and control program.
WHEN EMPLOYEES CHANGE
When an employee changes position there can be huge safety ramifications. In staffing changes, one employee now is performing a task previously done by another. The new employee may bring to the position a different level of skill. He/she will possess a different degree of experience performing the tasks, following the specific work rules and procedures, and interacting with other employees. Especially in high hazard situations, these differences should be examined and steps should be taken to minimize any increased risk, both to the new employee and to anyone affected by their presence. Refer to Chapter 14 for a variety of training and job orientation methods that will help you to make sure that there is a safe employee transition [2]. The change may be related to temporary or chronic medical issues, a partial disability, family responsibilities and/or crisis and other personal problems, alcohol or drug abuse, aging, or the employee's response to workplace changes. An analysis of this change, followed by physical and/or administrative accommodations to ensure safe continued performance, sometimes may be appropriate~for example, when an incident affects an employee's ability to function. At other times, a less formal response may be more suitable [2].
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Workplace hazards do not exist in a vacuum. The human element is always present, and the human condition is a source of change that you must understand. An effective manager is sensitive to these changes and their potential effect on the safety of the individual and the company as a whole [2].
ROUTINE HAZARD ANALYSIS
To combat this issue, a routine hazard analysis should be conducted. One of the most common reasons for injuries are tasks that are performed over and over many times daily, weekly, monthly, year after year, etc. These become a hazard because we get used to doing the same task over and over. It becomes a natural routine. We loose the ability to think of the consequences. For example, driving a car becomes second nature to us. How many times have you passed a landmark and do not r e m e m b e r passing it? This is the same as an employee doing a specific task over and over without thinking. 9 Managers and employees are made aware that hazards can develop within existing job processes and/or phases of activity. 9 You will be able to determine if one or more hazard analysis systems designed to address routine job, process, or phase hazards are in place at the facility. 9 All jobs, processes, or phases of activity are analyzed using the appropriate hazard analysis system. For example, different m a n a g e m e n t measures may be needed for hazards that do not stay corrected, compared to those that have never received attention/correction. For hazards that cannot be quickly corrected, a record is required so that final correction is not forgotten. Figure 10-2 presents a hazard identification flowchart [1]. The importance of interim protection cannot be overemphasized:There is no way to predict when a hazard will cause serious harm, and there is no justification for continuing to expose employees to risk unnecessarily. These are suggested guidelines for establishing a hazard reporting system: 9 Develop a policy for hazard reporting 9 Make sure that all employees know about the policy for reporting hazards and that they understand that policy.
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Developing an Effective Safety Culture: A Leadership Approach
~1~itartHazard~ entificationJ
Employee IdentifiedHazard ! No
! Yes No
Yes m
No
IdentifyResources
~r
, Yes
~Jl CorrectHazard
1
No Request Management Assistance
Employee Feedback
Y
Management Provides Resources
~
1
ard Resolve~"~
End J
Figure 10-2 Hazard identification flowchart. Oklahoma Department of Labor, Safety and Health Management: Safety Pays, 2000, http://www.state.ok.us/-okdol/, Chapter 7, p. 41, public domain.
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9 See that the policy is written, distributed to all employees, posted, and discussed during regular safety meetings 9 Demonstrate that the policy for reporting hazards is real: Involve employees in creating the policy, share and discuss the policy with all employees, and follow through with the policy 9 Protect employees who report hazards from harassment or reprisal 9 Use the information gained through the hazard reporting system to improve the overall safety and health program It is better to have some non-hazards reported than to risk even one real hazard that was not reported because it was believed that the organization would not respond. The system provides for data collection and display as a means to measure the success of the system in resolving identified hazards [1].
SUMMARY
The authors would like to offer one caution here. This survey does not constitute a safety culture. You cannot implement inspections into a culture. These inspections are only to identify issues/hazards that you must fix to enhance your culture. A practical hazard analysis of the work environment involves a variety of elements intended to identify existing hazards and conditions, and operations subject to change that might create new hazards. Effective management systems continually analyze the workplace to anticipate and develop policies and procedures to help minimize the introduction and reoccurrence of hazards. The following are recommended measures that can be used to help identify existing and potential hazards: * Conducting comprehensive baseline assessments, updating assessments periodically, and allowing employees participation in the review 9 Analyzing planned new facilities, processes, materials, relocated equipment, and any plant, machine, and process modifications * Performing standard job hazards analyses, to include assessing ergonomic risk and other related factors with regard to employees' tasks . Conducting regular site inspections so that new or previously missed hazards can be identified and corrected
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Developing an Effective Safety Culture: A Leadership Approach
9 Providing a reliable management system for employees to notify management about conditions that appear hazardous, to receive timely and appropriate responses, and to encourage employees to use the management system without fear of reprisal 9 Investigating incidents (near miss/hit and significant loss-producing events) so their causes and means of prevention can be identified 9 Analyzing trends to identify patterns with common causes so they can be reviewed and corrected [2] These measures provide a good method of defining specific hazard training. Hazards that employees are exposed to should be systematically identified and evaluated. Evaluating other requirements that may impose additional and specific requirements for hazard identification and assessment is also important. Hazard identification and assessment analysis should be conducted: 9 As often as necessary to make sure the facility is in compliance with specific requirements, best management practices (BMP) or above and beyond compliance (ABC) 9 When workplace conditions change that could create a new or increased risk of hazards Each work-related incident with the potential to cause physical harm to employees should also be investigated. Keep accurate and complete records of the assessments and hazards identified. Develop action plans to control identified hazards. Establishing a complete hazard inventory is not as complicated as it may sound. It begins with having a professional conduct a comprehensive survey to determine existing and/or potential hazards of your worksite. Periodic surveys, conducted at intervals that make sense for the size and complexity of your worksite, will help to identify any new engineering or scientific knowledge of hazards and their prevention. These subsequent surveys also can help find new hazards that have evolved as a result of changing work procedures. Change analysis prevents expensive problems before they occur. Individuals who are knowledgeable in employee safety can help to design and plan for changes at the worksite. Change analysis uses elements of routine hazard analysis appropriate to the type of change being contemplated. Routine hazard analysis also adds hazards to your inventory. It will help you to control hazards that develop in work procedures or in processes, or that occur because of changes in the phases of the operation.
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The tools and approaches used in the various types of hazard analysis tend to overlap. This overlap helps ensure total coverage and a more comprehensive inventory on which to base your prevention program. When assessing workplace hazards, do not overlook the human element. Whenever one employee replaces another employee, the difference in skill level and experience can increase risk both to new employees and to their co-workers. Changes in the individual employee's health, ability to function on the job, and personal life, no matter whether these changes are sudden or gradual, can affect workplace safety. A manager needs to be sensitive to these changes and willing to provide training and orientation, physical and administrative adjustments, and/or other accommodations. Refer to Chapter 11 for a detailed review of this program. You should minimize hazards by substituting less hazardous materials or equipment whenever possible and engineering controls that distance the worker from the hazard. For the remaining hazards, design safe work practices, train your employees adequately in these practices, and enforce the practice consistently. In some cases, you may also need to establish other administrative controls, such as employee rotation or more frequent work breaks where needed. You need to use the surveys and analyses that we have described to plan and accomplish a program of hazard prevention and control. Remember, the first step in protecting your employees is recognizing the hazards.
REFERENCES
1. Oklahoma Department of Labor, Safety and Health Management: Safety Pays, 2000, http://www.state.ok.us/-okdol/, public domain. 2. U.S. Department of Labor. Office of Cooperative Programs, Occupational Safety and Health Administration (OSHA), Managing Worker Safety and Health, November 1994, public domain.
trial hygiene surveys * Change analysis. Potential hazards associated with new facilities,
new/relocated equipment installation, materials, and processes; refer to Chapter 15 9 Job hazard analysis. Routine hazard analysis, such as job hazard analysis, process hazard analysis, or task hazard analysis [2]; refer to Chapter 15 After hazards have been identified and controls are put in place, additional worksite analysis tools can help to make sure that the controls stay in place and that other hazards do not appear. Refer to Chapter 11 for detailed discussions of specific tools~for example, inspections, methods for employees to report hazards, incident investigations, and pattern analysis. First, you must understand the existing and potential hazards that may exist in your workplace. Table 10-1 lists some methods of preventing hazards. 175
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Developing an Effective Safety Culture: A Leadership Approach
Table 10-1 Preventing Hazards Continually review the work environment and work practices to control or prevent workplace hazards. Some ways to prevent and control hazards include: 9 Perform regular and thorough equipment maintenance 9 Make sure that hazard correction procedures are in place 9 Make sure that everyone knows how to use and maintain PPE 9 Make sure that everyone understands and follows safe work procedures 9 Make sure that, when needed, there is a medical surveillance program tailored to your facility to help prevent workplace hazards and exposures http://www.osha-slc.gov/SLTC/safetyhealth_ecat/comp3.htm#, public domain.
COMPREHENSIVE SURVEYS
One thing that you must remember is that a comprehensive survey is not the same as an inspection. Employees often do inspections on a routine basis as part of a safety committee, etc. Other individuals who can bring fresh ideas and a knowledge of safety, health, or industrial hygiene should perform comprehensive surveys. Because there are few professionals equipped to do comprehensive surveys in all three areas, the best approach is to use a multiple-discipline team consisting of several specialists: a safety professional, an industrial hygienist, and a medical provider. In other cases, it could be comprised of a safety professional or someone from operations (management and an employee from another part of the operation) [2]. Figure 10-1 is a flowchart of a risk toolkit. To conduct a comprehensive survey you may need some level of professional knowledge. The following is a summary of those professionals you should consider when conducting any type of comprehensive survey for your organization. The medical provider can be a physician or a registered nurse with specialized training and experience in occupational medicine. He/she can assist the safety or industrial hygiene professional or can do a separate health survey, depending on the makeup of your workplace. Refer to Chapter 13 for suggested criteria for the occupational health professionals and/or medical provider. Many workers" compensation carriers and insurance companies offer loss control professional services to help
Developing a Hazard Inventory
177
Analyzework
Defineparticular ! Subsystems~1
Identifyhazard~
Defineongoing i hazardous | situations ~1
[,
Appreciate potential hazardousevent~l~ ..I Analyzep~ harms(or ~1 c~
[
|-~
Y
Verify
[
!
Estimaterisk(plot I riskdimensionson | matrix) ~1~ /
Introduce corrective/ 41--No preventative measures .~
r' Nochange [ Yes-~1 necessarymonitor/ L systems ~
Figure 10-1 Flowchart of the risk toolkit. Cox, Sue, Tom Cox, Safety Systems and
People, p. 41, Figure 2.6. Butterworth-Heinemann, 1996. Modified with permission.
clients evaluate safety hazards. Larger businesses may find the needed expertise at the company or corporate level or in an independent consultant. If you use a professional from within your company, be wary o f " t u n n e l vision," which can lead to failure to identify specific issues [2]. As the old
178
Developingan Effective Safety Culture: A Leadership Approach
saying goes: Sometimes you cannot see the forest for the trees. It's possible to stay in a position so long that you cannot see what is really going on around you. For the industrial hygiene survey you should, at a minimum, want to inventory all chemicals and hazardous materials at the site, review the hazard communication program, and conduct air sampling in various areas to analyze the air for hazardous contaminants. For specific applications, a noise level survey and a review of the respirator program could be required [2].
EVALUATING THE PROFESSIONAL RESOURCE
If you hire a professional and you want to make sure that your worksite will be evaluated properly, you may want to ask the consultant specific questions: 9 What type of training and experience have you had? How recent is it? What is its scope of the training? Is it limited to a specific industry? Does it consist of only practical experience, without formal training [2]? If he/she has a professional certification, is it valid, or has it lapsed for lack of maintenance points~for example, training, presentations, seminar attendance, activity participation in a local society [2]? Check references where surveys have been recently completed. Determine if any O S H A inspections occurred after the survey. Were any serious hazards found that the consultant missed? What tools did the consultant use for the survey? How much knowledge or transferable skills does the consultant have [2]? 9 What kind of information will he/she need in advance? A professional who is planning an in-depth survey should prepare by learning as much as possible about the workplace and processes that exist Both safety and industrial hygiene professionals will usually want to see a layout of the operations The industrial hygienists may ask for a list of chemicals used or the Material Safety Data Sheets (MSDS) you received from your suppliers and the types of processes where you use them [2]
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9 What type of test equipment will the consultant use? Each professional will usually bring several items to the survey. You should expect the safety professional to bring a tape measure; a ground loop circuit tester to test electrical circuits; a multimeter (for 220 and/or 440 volts only); a tic tracer (or similar equipment) to check wires or electrical equipment to see if they are energized; and a ground fault circuit interrupter tester [2]. 9 The industrial hygienist may bring noise monitoring equipment. Depending on the chemicals or other contaminants expected, sampling pumps or grab sampling devices may be used. 9 How long will the review take? It should take several times longer than a routine inspection of your workplace. It will also depend on the complexity of the workplace For example, if the industrial hygienist does air sampling, it should be time-weighted, 8-hour or full-shift sampling to measure the overall exposure to employees [2].
EVALUATING THE SURVEY
The following are some signs of a thorough survey: 9 The consultant (safety professionals, industrial hygienists, and/or medical provider) should start with your injury and illness logs and look for patterns. 9 The safety professional also may want to see program documentation. 9 The industrial hygienist and health professional may want to see your hazard communication program, if applicable, your hearing conservation and/or respirator program. 9 The medical provider may want to see your records of employee visits to clinics, first aid stations, and other workplaces where treatment is provided for work-related injuries. 9 He/she will want to examine records of employee training in first aid and CPR or blood-borne pathogens. In addition, they may want to see a baseline and follow-up testing records. 9 The safety professional should start at the beginning of your process, where raw materials are brought in, and carefully go through all processes, inspecting each operation and talking to employees, until the point where the product is finished and shipped to the customer. The following areas should be evaluated or inspected:
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Developing an Effective Safety Culture: A Leadership Approach
How materials are handled from the time they are received and how they are moved and stored, checking the stability of storage racks and the safe storage of flammables/explosives The openings that expose moving parts for pinch points, machine guarding, and other hazards Hand tools and equipment and wiring in the maintenance shop and other areas as appropriate Operations on every shift and any after-hours operations, such as cleanup or forklift battery recharging How you manage your hazard prevention and control program Outside of buildings, for example: chocks for trucks at the loading/unloading docks, fork lift ramps, outdoor storage of flammables/explosives, oil, and any fueling areas The professional should also do the following: Open every door and look in every corner of the facility Suggest target tasks for job hazard analysis, especially those tasks that might involve ergonomic-related hazards Assist in developing and/or improving your injury reduction program The industrial hygienist and medical provider should start at the beginning of your production operation, observe all processes, talk to employees, and follow the production flow to the point of shipping [2]. They may do the following: Review a list of all hazardous substances that can be found in the worksite (as required by 29 CFR 1910.1200(e), OSHA's Hazard Communication standard), or the accuracy of the existing inventory list Determine what metals are used in any welding operations Check any production areas where eating or smoking is allowed Check for the possible presence of asbestos, lead, mercury, silica, other carcinogens, etc. If respirators are used, determine whether employees are using each brand properly, how to fit test each employee, whether pulmonary function testing is done, and how the respirators are cleaned, maintained, and stored Perform full-shift sampling of contaminants thought to be present to understand employee exposures Watch the movements that employees make in performing their tasks to see if there are existing or potential cumulative trauma disorders (CTDs) or other ergonomic issues Suggest processes for routine process hazard analysis
Developing a Hazard Inventory
181
Help you set up or improve regular monitoring programs for any contaminants or other health hazards found to be present [1, 2]. The items listed do not constitute an exhaustive list of activities you should expect [2]. This hazard inventory should be expanded and improved by what you learn from periodic surveys, change analyses, and routine hazard analyses. The baseline survey should provide the basic inventory of hazards and potential hazards. However, the foundation of your inventory is the baseline comprehensive survey. It is important that this initial survey be done well [2].
FOLLOW-UP SURVEYS
You will need periodic follow-up surveys if you are to apply the rapidly growing scientific and engineering knowledge about hazards, their prevention, and control. These follow-up surveys help to identify hazards that may have developed after the processes and/or procedures have been in place. The frequency of follow-up surveys depends on the size and complexity of the organization.
INVOLVING EMPLOYEES IN ESTABLISHING THE INVENTORY
Always use the knowledge that your employees have gained from their close involvement with equipment, materials, and processes. You should encourage your employees to communicate openly with the professionals who do the comprehensive surveys [2]. Do not make the mistake of limiting your employees' participation to what they can tell the professionals. Make sure that employees participate in the various types of hazard analysis. It makes good sense to involve employees in change analysis of new equipment and/or processes because of their valuable insights into how things really work. As indicated in Chapter 15 on job hazard analysis, many companies regularly include employees in this activity. Employees can play a similar role in
182
Developingan Effective Safety Culture: A Leadership Approach
process hazard analysis. Greater understanding of hazards, prevention, and control helps employees do a better job of protecting themselves and their co-workers.
CHANGE ANALYSIS
Before making changes in the worksite, analyze the changes to identify potential hazards. Anytime you change your worksite, whether you are adding a piece of equipment, different materials, or a new process, relocating equipment, or building, you may unintentionally introduce new hazards. If you are considering a change in your workplace, you should analyze it thoroughly before making these changes. You need a good baseline (starting point) and independent review. This change analysis is cost effective in terms of the human suffering and financial loss it helps to prevent. Stopping problems before they develop is less expensive than attempting to fix them after the fact [2]. An important step in preparing for a worksite change is to consider the potential effect on all employees. Individuals respond differently to changes, and even a clearly beneficial change can throw an employee temporarily off balance and increase the risk of an incident. You want to make sure that you communicate all changes to affected employees as soon as possible, provide training as needed, and pay attention to employee work activities until everyone has adapted to the new change [2]. Refer to Chapter 15 for a description of change analysis.
Building or Leasing a New Facility Something as basic as a new facility needs to be reviewed carefully to identify hidden hazards~for example, the fire system, security, and environmental issues. This is often overlooked. A design that seems to enhance production of your product and appears to be a marvel to the architect may be a harmful or even fatal management decision. Safety professionals should take a careful look at all design/building plans prior to final approval [2]. When you lease a facility that was built for a different purpose, the risk of acquiring safety problems is even greater. This a true unknown. You should make a thorough review of the facility, by reviewing the blueprints and/or plans for any renovations. One of the most obvious concerns in acquiring an existing facility is whether any environmental issues such as
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lead paint, asbestos insulation, mercury, or PCBs may be present. But you also may discover that something as easy to fix as a loose stair railing has gone unnoticed in the rush to renovate production areas. Save frustration, money, and lives: Make sure that you have a safety professional involved in the planning of any facility construction, purchase, or lease [2].
Installing New Equipment Equipment manufacturers do not know how their products will be used at your facility. Therefore, you cannot rely on the manufacturer to have analyzed and designed guarding, controls, or safe procedures for the equipment. Another issue to take into consideration is if the equipment is produced in a foreign country. It may not meet U.S. requirements and laws. Therefore, you should also involve a safety professional in the purchasing decision, as well as in installation plans and startup [2]. Many companies also provide a period to test newly installed equipment. The company assigns its most experienced employees to watch for hidden hazards in the operations before full production begins. As with new facilities, the sooner hazards are detected, the easier and cheaper the corrections will be [2]. One of the best methods is to conduct a JHA (Chapter 15).
Using New Materials Before introducing any new materials into your production processes, you must research the hazards that the materials may present. Also try to determine any hazards that may appear as a result of the processes you plan to use with the materials [2]. When you review new material, the place to start is the manufacturer's Material Safety Data Sheet (MSDS). An MSDS is required for all materials containing hazardous substances. It should arrive with each shipment. The MSDS should provide hazard information. You should have someone knowledgeable to analyze the hazard a chemical presents and to prevent or control any associated hazard [2].
Starting Up New Processes New processes require employees to perform differently. Consequently, new hazards may develop even when your employees are using
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Developingan Effective Safety Culture: A Leadership Approach
familiar materials, equipment, and facilities. Carefully develop safe work procedures for new processes. After the employees have become familiar with these procedures, perform routine job hazard analysis to identify any hidden hazards [2].
ANALYZING MULTIPLE CHANGES
Often a big change is composed of several smaller changes. When you begin producing a new product, chances are you will have new equipment, materials, and processes to monitor. Make sure that each new change is analyzed not only individually, but also in relation to the other changes [2]. Once you have analyzed the changes at your worksite, add this information to your inventory of hazards. This inventory is the foundation of the design of your hazard prevention and control program.
WHEN EMPLOYEES CHANGE
When an employee changes position there can be huge safety ramifications. In staffing changes, one employee now is performing a task previously done by another. The new employee may bring to the position a different level of skill. He/she will possess a different degree of experience performing the tasks, following the specific work rules and procedures, and interacting with other employees. Especially in high hazard situations, these differences should be examined and steps should be taken to minimize any increased risk, both to the new employee and to anyone affected by their presence. Refer to Chapter 14 for a variety of training and job orientation methods that will help you to make sure that there is a safe employee transition [2]. The change may be related to temporary or chronic medical issues, a partial disability, family responsibilities and/or crisis and other personal problems, alcohol or drug abuse, aging, or the employee's response to workplace changes. An analysis of this change, followed by physical and/or administrative accommodations to ensure safe continued performance, sometimes may be appropriate~for example, when an incident affects an employee's ability to function. At other times, a less formal response may be more suitable [2].
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Workplace hazards do not exist in a vacuum. The human element is always present, and the human condition is a source of change that you must understand. An effective manager is sensitive to these changes and their potential effect on the safety of the individual and the company as a whole [2].
ROUTINE HAZARD ANALYSIS
To combat this issue, a routine hazard analysis should be conducted. One of the most common reasons for injuries are tasks that are performed over and over many times daily, weekly, monthly, year after year, etc. These become a hazard because we get used to doing the same task over and over. It becomes a natural routine. We loose the ability to think of the consequences. For example, driving a car becomes second nature to us. How many times have you passed a landmark and do not r e m e m b e r passing it? This is the same as an employee doing a specific task over and over without thinking. 9 Managers and employees are made aware that hazards can develop within existing job processes and/or phases of activity. 9 You will be able to determine if one or more hazard analysis systems designed to address routine job, process, or phase hazards are in place at the facility. 9 All jobs, processes, or phases of activity are analyzed using the appropriate hazard analysis system. For example, different m a n a g e m e n t measures may be needed for hazards that do not stay corrected, compared to those that have never received attention/correction. For hazards that cannot be quickly corrected, a record is required so that final correction is not forgotten. Figure 10-2 presents a hazard identification flowchart [1]. The importance of interim protection cannot be overemphasized:There is no way to predict when a hazard will cause serious harm, and there is no justification for continuing to expose employees to risk unnecessarily. These are suggested guidelines for establishing a hazard reporting system: 9 Develop a policy for hazard reporting 9 Make sure that all employees know about the policy for reporting hazards and that they understand that policy.
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Developing an Effective Safety Culture: A Leadership Approach
~1~itartHazard~ entificationJ
Employee IdentifiedHazard ! No
! Yes No
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, Yes
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ard Resolve~"~
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Figure 10-2 Hazard identification flowchart. Oklahoma Department of Labor, Safety and Health Management: Safety Pays, 2000, http://www.state.ok.us/-okdol/, Chapter 7, p. 41, public domain.
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9 See that the policy is written, distributed to all employees, posted, and discussed during regular safety meetings 9 Demonstrate that the policy for reporting hazards is real: Involve employees in creating the policy, share and discuss the policy with all employees, and follow through with the policy 9 Protect employees who report hazards from harassment or reprisal 9 Use the information gained through the hazard reporting system to improve the overall safety and health program It is better to have some non-hazards reported than to risk even one real hazard that was not reported because it was believed that the organization would not respond. The system provides for data collection and display as a means to measure the success of the system in resolving identified hazards [1].
SUMMARY
The authors would like to offer one caution here. This survey does not constitute a safety culture. You cannot implement inspections into a culture. These inspections are only to identify issues/hazards that you must fix to enhance your culture. A practical hazard analysis of the work environment involves a variety of elements intended to identify existing hazards and conditions, and operations subject to change that might create new hazards. Effective management systems continually analyze the workplace to anticipate and develop policies and procedures to help minimize the introduction and reoccurrence of hazards. The following are recommended measures that can be used to help identify existing and potential hazards: * Conducting comprehensive baseline assessments, updating assessments periodically, and allowing employees participation in the review 9 Analyzing planned new facilities, processes, materials, relocated equipment, and any plant, machine, and process modifications * Performing standard job hazards analyses, to include assessing ergonomic risk and other related factors with regard to employees' tasks . Conducting regular site inspections so that new or previously missed hazards can be identified and corrected
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Developing an Effective Safety Culture: A Leadership Approach
9 Providing a reliable management system for employees to notify management about conditions that appear hazardous, to receive timely and appropriate responses, and to encourage employees to use the management system without fear of reprisal 9 Investigating incidents (near miss/hit and significant loss-producing events) so their causes and means of prevention can be identified 9 Analyzing trends to identify patterns with common causes so they can be reviewed and corrected [2] These measures provide a good method of defining specific hazard training. Hazards that employees are exposed to should be systematically identified and evaluated. Evaluating other requirements that may impose additional and specific requirements for hazard identification and assessment is also important. Hazard identification and assessment analysis should be conducted: 9 As often as necessary to make sure the facility is in compliance with specific requirements, best management practices (BMP) or above and beyond compliance (ABC) 9 When workplace conditions change that could create a new or increased risk of hazards Each work-related incident with the potential to cause physical harm to employees should also be investigated. Keep accurate and complete records of the assessments and hazards identified. Develop action plans to control identified hazards. Establishing a complete hazard inventory is not as complicated as it may sound. It begins with having a professional conduct a comprehensive survey to determine existing and/or potential hazards of your worksite. Periodic surveys, conducted at intervals that make sense for the size and complexity of your worksite, will help to identify any new engineering or scientific knowledge of hazards and their prevention. These subsequent surveys also can help find new hazards that have evolved as a result of changing work procedures. Change analysis prevents expensive problems before they occur. Individuals who are knowledgeable in employee safety can help to design and plan for changes at the worksite. Change analysis uses elements of routine hazard analysis appropriate to the type of change being contemplated. Routine hazard analysis also adds hazards to your inventory. It will help you to control hazards that develop in work procedures or in processes, or that occur because of changes in the phases of the operation.
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The tools and approaches used in the various types of hazard analysis tend to overlap. This overlap helps ensure total coverage and a more comprehensive inventory on which to base your prevention program. When assessing workplace hazards, do not overlook the human element. Whenever one employee replaces another employee, the difference in skill level and experience can increase risk both to new employees and to their co-workers. Changes in the individual employee's health, ability to function on the job, and personal life, no matter whether these changes are sudden or gradual, can affect workplace safety. A manager needs to be sensitive to these changes and willing to provide training and orientation, physical and administrative adjustments, and/or other accommodations. Refer to Chapter 11 for a detailed review of this program. You should minimize hazards by substituting less hazardous materials or equipment whenever possible and engineering controls that distance the worker from the hazard. For the remaining hazards, design safe work practices, train your employees adequately in these practices, and enforce the practice consistently. In some cases, you may also need to establish other administrative controls, such as employee rotation or more frequent work breaks where needed. You need to use the surveys and analyses that we have described to plan and accomplish a program of hazard prevention and control. Remember, the first step in protecting your employees is recognizing the hazards.
REFERENCES
1. Oklahoma Department of Labor, Safety and Health Management: Safety Pays, 2000, http://www.state.ok.us/-okdol/, public domain. 2. U.S. Department of Labor. Office of Cooperative Programs, Occupational Safety and Health Administration (OSHA), Managing Worker Safety and Health, November 1994, public domain.