Table of Contents TABLE OF CONTENTS... 2 THE IMPORTANCE OF A SAFETY PROGRAM... 3 WHO NEEDS A SAFETY PROGRAM?... 3 WHY IS AN ANNUAL SAFETY REVIEW IMPORTANT?... 3 WHAT IS INCLUDED IN A SAFETY PROGRAM?... 4 PENALTIES FOR NON- COMPLIANCE... 5 PERFORMING THE ANNUAL REVIEW... 6 REVIEW REQUIREMENTS... 6 4 QUESTIONS TO ASK YOURSELF... 6 THE 5 KEY AREAS OF REVIEW... 7 1. MANAGEMENT COMMITMENT... 7 2. EMPLOYEE INVOLVEMENT... 7 3. WORKSITE ANALYSIS... 7 4. HAZARD PREVENTION AND CONTROL... 7 5. TRAINING... 8 SAFETY TRAINING... 9 WHO NEEDS SAFETY TRAINING?... 9 OSHA S 7- STEP TRAINING MODEL... 11 COMMON SAFETY TRAINING CLASSES... 12 KEEPING RECORDS... 13 DOCUMENTATION BASICS... 13 WRITTEN PLANS... 13 RECORDS AND DOCUMENTATION... 13 HAZARD COMMUNICATION PROGRAM... 14 WHERE TO GET HELP... 16 IBT S SAFETY PROGRAM ASSESSMENT SERVICES... 16 CASE STUDY FAULTLESS STARCH/BON AMI... 16 IMPORTANT WORDS TO KNOW... 17 2
The Importance of a Safety Program Who Needs a Safety Program? Safety programs are required by OSHA for any business that has hazards on its worksite. Common hazard categories include: Chemical Electrical Respiratory Bloodborne pathogens Confined spaces Mechanical In today s world, nearly every business in operation has hazards even if it s simply cleaning chemicals or electrical equipment. If in doubt, IBT can help you determine whether your company needs a safety program. Why Is an Annual Safety Review Important? An estimated 4.1 million employees suffer work- related injuries and illness every year in the U.S. There are also 4,300 work- related fatalities every year. * That translates to a direct cost of $53.4 billion in workers compensation or $1 billion per week. In the 40 years since the Occupational Safety and Health Act (OSHA) was signed into law, workplace deaths and injuries have gone down by more than 60%. However, 12 workers still die on the job every day. * Statistics provided by the Occupational Safety & Health Administration, U.S. Department of Labor. See www.osha.gov.dsg/topics/safetyhealth/index.html. 3
Safety programs help to: Reduce the incidence of injury, illness, and death in the workplace Reduce worker s comp costs Improve employee morale and job satisfaction Lower the risk of lawsuits from an accident By performing an annual review, you can also: Avoid receiving a fine or citation from OSHA Cover the risk of new hazards that pop up Make sure that new employees are trained correctly OSHA requires you to perform an annual review of your safety program and training to make sure that they are current, up- to- date, and cover any new hazards that may have arisen during the previous year. What Is Included in a Safety Program? A safety plan should include a list of the environmental risks that occur in your business for employees, vendors, and visiting customers. For each risk, there should be a documented plan for how you are minimizing the risk of exposure to injury, illness, or death. This includes safety training and a prevention action plan for every risk. The following topics are recommended for a safety plan, depending on the nature of your business: Safety training Personal protective equipment (PPE) program Accident prevention program (APP) Hazardous chemical communication program Bloodborne pathogens exposure control plan Respiratory protection program Hearing loss prevention program Fall protection work plan (for construction industry) List provided by the Washington State Department of Labor & Industries, www.lni.wa.gov/safety/basics/programs/. 4
Penalties for Non- Compliance If a company fails to create, update, or annually review its safety plan, it can result in citations and/or fines from OSHA. If an accident results in an injury or death, it can also result in a lawsuit. 5
Performing the Annual Review Review Requirements OSHA requires all companies with existing hazards to review their safety programs annually. The beginning of the new year is an ideal time to review your safety and health program. Each year, when reviewing your program, make sure that it: Meets all OSHA requirements Covers any new hazards that have come up in the past year Is documented in written format Is familiar and easily accessible to employees and managers 4 Questions to Ask Yourself During your safety program review, you should ask yourself 4 key questions: 1. Is management committed to a safe and healthy work environment? If not, then what needs to be done? 2. Have any new hazards arisen at your worksite in the past year? 3. Do your employees follow OSHA s recommended hierarchy of: engineering controls, administrative controls, and personal protective equipment? 4. Does your training program follow OSHA s 7- step training model? 6
The 5 Key Areas of Review During your review, the goal is to make sure that your safety program is just as effective as it was last year. If this is a new safety program, then you ll want to make sure that it addresses each of the 5 key areas. The 5 main parts of an effective safety program review include: 1. Management Commitment Management should be committed to a safe and healthy work environment This commitment should be regularly communicated to employees If management is not committed and actively involved in creating a safe and healthy work environment, what can be done to make it happen? 2. Employee Involvement Involve employees in the creation of a robust safety and health program Get regular employee participation in the program If they are not currently involved, how can you include them in the decision- making and planning going forward? 3. Worksite Analysis Check your worksite for any new hazards that have popped up over the past year Have all new work processes been evaluated to determine if there are any additional hazards? Does your safety program cover all recognized hazards? Are these hazards documented in a list? 4. Hazard Prevention and Control Controls should be in place and properly utilized for each and every hazard identified during your review Make sure that employees recognize and follow OSHA s recommended: o Engineering controls o Administrative controls o Workplace controls 7
o Personal protective equipment (PPE) If your program does not have these controls in place, how can you implement them? 5. Training Review all training programs Make sure there is an active training program for every hazard identified in your worksite analysis Ensure that your training program follows OSHA s 7- step training model (see below) If your program does not meet these basic requirements, what can you do to fix it? 8
Safety Training Who Needs Safety Training? It can sometimes be difficult to decide who to train and which training they should receive. Consider the following: Incidental Training All employees should receive this type of training. The goal of incidental training is to: Raise awareness of worksite safety issues Educate participants on existing hazards Develop an appreciation for situations where other employees are exposed to hazards Example: 29 CFR 1910.1020 Access to Medical and Exposure Records. Employees must be informed of the existence and content of these records. Collateral Training Employees who are not directly exposed to hazards as part of their daily routine or job responsibilities need collateral training. The goal of collateral training is to: Equip employees to work safely Teach employees how to protect themselves in the event of an accident or unexpected exposure to a specific hazard Example: 29 CFR 1910.1200 Hazard Communication. Clerical staff who do not normally work with hazardous chemicals should know of their existence and potential danger represented by the chemicals. Primary Training Employees who are directly exposed to hazards as part of their daily routine or job responsibilities should receive this training. The goal of primary training is to: 9
Teach employees how to confront the hazard in a safe manner Present detailed safety information in the form of demos, hands- on exercises Assess each employee s knowledge to make sure they are adequately prepared to deal with the hazard Example: 29 CFR 1910.134 Respiratory Protection. Employees required to work in dangerous or contaminated atmospheres should be trained on the details of respiratory protection so that they might protect themselves and others with whom they work. 10
OSHA s 7- Step Training Model 11
Common Safety Training Classes Training can be as short as ½ hour, or as complex as a 6- month long, 24- hour program. It depends on the hazard, the worksite, and the number of employees to be trained. OSHA does allow video training to be used in some instances. However, an expert must be available to answer questions. Popular Training Topics Your safety training may include some or all of the following popular training topics, commonly offered by IBT: Permit- Required Confined Spaces Training Respiratory Protection Training Hazard Communications Training Bloodborne Pathogens Training Arc Flash Hazard Training Lockout/Tagout Training Electricity/Hazardous Energy Training 12
Keeping Records Documentation Basics OSHA requires you to document: Your safety program All training activities (including participants who attend) All written plans, required records, and support documents should be reviewed annually. Written Plans All written plans should be formally reviewed. All corrections should be initialed and dated to identify the reviewer and the date of the review. Your written safety plan should address the following questions: Do your written plans comply with the formal requirements of each standard? Do they accurately reflect the situation at the worksite? Have conditions/circumstances changed since the last review? Records and Documentation Review all of the following carefully: Medical records Exposure records Training records Equipment maintenance Engineering maintenance Ask yourself the following questions about your documentation: Are records appropriately filed for easy access to provide info to employees or OSHA? Are any records at the end of their respective retention periods and ready to be discarded? Have arrangements been made to retain all records for the required length of time? 13
OSHA Forms 300, 300A, and 301 Any employer with more than 10 employees (that is not classified as partially exempt) is required to record work- related injuries and illnesses using OSHA Forms 300, 300A, and 301. Review the OSHA 300 Log to make sure that it is current to within 45 days. Prepare to post it by February 1. Hazard Communication Program In 2012, OSHA published a revised Hazard Communication Standard (HCS). ** This new revision, which was designed to bring the U.S. standards in line with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), has a few new requirements you should know: Safety Data Sheets Safety Data Sheets will now replace Material Safety Data Sheets (MSDS). These must now conform to a uniform, 16- section format. Labels Under the new standard, labels should now have each of the following elements: Pictogram one of 8 approved symbols that conveys specific hazards about a chemical Signal words a single word (i.e., Danger, Warning) that tells the severity of the hazard Hazard statement describes the nature of the hazard and, where appropriate, degree of hazard Precautionary Statement recommended measures to minimize adverse effects from exposure, improper storage, or handling of a hazardous chemical See www.osha.gov/recordkeeping/rkforms.html. Available at www.osha.gov/recordkeeping/. ** OSHA 29 CFR 1910.1200. For more information about the Globally Harmonized System and the revisions to the Hazard Communication Standard, visit www.osha.gov/dsg/hazcom/index.html. 14
Training Full compliance with SDS format and labels is not required until June 1, 2015. However, since workers are already beginning to see these changes, OSHA is requiring that employees be trained on the revised pictograms by December 1, 2013. 15
Where to Get Help IBT s Safety Program Assessment Services Need help starting or reviewing your safety program? IBT can help you to: Create a new safety and health program Evaluate your current safety and health program Perform an annual safety program review Provide current, updated training that is enjoyable for employees To learn more about IBT s safety program consultation and safety training services, please contact Tom Smith at (816) 699-3968 or tsmith@ibtinc.com. Case Study Faultless Starch/Bon Ami Since 2002, IBT has helped Faultless Starch/Bon Ami company to update and maintain their safety and health program. They have provided general safety audits, occupational exposure monitoring, annual respirator fit- testing, and employee training to Faultless Starch for several years. The quality that I get from IBT is great, said Maria Butkovich, Safety Health and Environmental Engineer for Faultless Starch/Bon Ami. Their team is very knowledgeable, and they give us great advice. We get a very prompt response whenever we have questions usually a same- day response. Faultless Starch/Bon Ami routinely hires IBT to provide the following safety training: Confined Spaces Training Lockout/Tagout Training Respiratory Protection Training Bloodborne Pathogens Training Butkovich feels that the investment in their safety program has reduced the number of injuries and incidents. Getting our safety training and safety program consultation from IBT has been a huge help for us, she said. It has really improved the safety performance and compliance in our plant in Kansas City, and has made everyone more knowledgeable. 16
Important Words to Know WORD DEFINITION APP Accident prevention program. A safety program designed to minimize accidents by employees. Arc flash Bloodborne pathogens An intense and dangerous heat blast caused by a short circuit to an industrial electrical system. This short circuit can be caused by an equipment failure or an employee error. The heat blast can get up to 35,000 F. Any microorganisms that are present in human blood and can cause disease when an employee is exposed to it. Chemical hazard Any chemicals in the workplace that can cause harm to employees including dusts, mixtures, and even common materials such as paints, fuels, and solvents. OSHA currently regulates exposure to 400 different substances. Flash hazard Any dangerous condition that is created by the release of energy from an electrical arc. Also called shock hazard. GHS Globally Harmonized System. Worldwide system of classifying and labeling chemicals. As of 2013, this is now aligned with the Hazard Communication Standard. Hazard HCS MSDS Any situation on a worksite that could create injury, illness, or death for employees, vendors, or customers. For example: chemical hazards, respiratory hazards, electrical hazards. Hazards are regulated by OSHA. Hazard Communication Standard. Document published by OSHA that classifies health and physical hazards. Material safety data sheet. Inventory of onsite hazards. OSHA Occupational Safety & Health Administration. Agency of the U.S. Department of Labor that regulates workplace safety and health. 17
WORD DEFINITION OSHA 300 Log Under the OSHA recordkeeping regulation (29 CFR 1904), covered employers are required to prepare and maintain records of serious occupational injuries and illnesses, using the OSHA 300 Log. All employers with more than 10 employees, and whose establishments are not classified as partially exempt, must use OSHA forms 300, 300A, and 301. PPE Personal protective equipment. Safety equipment worn while working in an any hazard area, such as an arc flash area. Respiratory hazards Safety program Gases, vapors, dusts, fumes, smoke, chemicals, or sprays that are in the environment and can make employees sick or even cause death if they are breathed in. Comprehensive program designed to ensure employee safety; regulated by OSHA. Required for any business operating in the U.S. that has hazards (such as chemical, electrical, or respiratory). Shock hazard Any dangerous condition that is created by the release of energy from an electrical arc. Also called flash hazard. 18