Self Assessment Guide for an Effective Safety and Health Program

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Self Assessment Guide for an Effective Safety and Health Program The revised Rural Electric Safety Achievement Program provides the frame work for cooperatives to develop safety and health programs that is driven by a continuous improvement process. Effective safety and health performances are based on a common set of key elements. These elements represent applied safety and health management practices that have proven to be effective in achieving planned objectives. The purpose of this document is to provide electric cooperatives with an effective tool for evaluating the continuous improvement of their safety and health performance as it relates to these key elements. These key elements include: Enhanced Leadership and Culture: Management leadership Worker participation Contractor Safety Program Implementation Assessment and Analysis Process: Survey and Hazard Analysis Site Inspections Data Analysis Hazard identification Hazard Reporting Accident Investigation Safety Knowledge and Awareness Education and training Leading Practices: Hazard Control Maintenance Emergency Response Program evaluation and improvement. These elements are consistent with the revised RESAP program, OSHA s proposed Injury and Illness Prevention Program (I2P2), Safety and Health Program Management Guidelines published by OSHA and the ANSI Z 10 Occupational Health and Safety Management Systems program. Evaluating these key elements as they relate to a co ops program is based on many variables within each category. Co ops should evaluate the elements based on their assessment that what best fits your specific organization. The evaluation will allow the co op to focus on the items that show the greatest opportunity for improvement or the highest return on investment in their safety improvement plans. Self Assessment Guide for an Effective Safety & Health Program (updated 06.08.12) 1

ENHANCED LEADERSHIP AND CULTURE Visible top leadership involvement provides the motivating force for an effective safety and health program Evaluation # Management Leadership Attributes 1 Top leaders set and communicate safety and health policies and goals 2 Top leaders follow all safety and health rules 3 Top leaders give visible support to the safety and health efforts of others 4 Top leaders participate in the co ops safety and health program including: site inspections incident reviews program reviews 5 Top leaders create an environment that encourages reporting of accidents, near miss incidence, injuries, or hazards 6 Site safety and health issues are regularly included on agendas of management operations meetings. 7 Top leaders actively demonstrate by involvement, support, and example the primary importance of safety and health for everyone 8 Top leaders consistently monitor, safety processes, plans and safety performance measures to ensure progress Self Assessment Guide for an Effective Safety & Health Program (updated 06.08.12) 2

ENHANCED LEADERSHIP AND CULTURE Employee participation is how employees identify hazards, recommend and monitor abatement, and otherwise participate in their own protection Evaluation # Employee Participation Attributes 1 Employees can participate freely in safety and health activities without fear of reprisal 2 Employees understand they can pause or stop work at any time when they believe work is unsafe and management works to instill this behavior at all levels of the organization 3 Employees help develop and deliver the safety and health program 4 Employees are involved in inspection of work area 5 Employees have the training necessary to participate in inspections 6 Employees ' understand their right of access to information 7 Employees have access to pertinent health and safety information 8 A documented procedure is in place for raising complaints of hazards or discrimination and receiving timely responses 9 Employees participate in workplace analysis inspections and investigations, and development of control strategies 10 Employees have the necessary training and education to participate in analysis and inspections Self Assessment Guide for an Effective Safety & Health Program (updated 06.08.12) 3

ENHANCED LEADERSHIP AND CULTURE Implementation is achieved with tools provided management, such as budgets; information; personnel; assigned responsibility and activities; adequate expertise and authority; and program review procedures. Evaluation # Program Implementation Attributes 1 Responsibility for implementing the safety and health program is clearly assigned to identified person(s) 2 Lines of authority to address and correct hazards is clearly established 3 Tools to implement a safety and health program are available and appropriate 4 Top leadership representative(s) has expertise in hazard recognition and applicable OSHA requirements 5 Applicable OSHA standards are assessable and top leaders seek appropriate guidance for interpretation of standards 6 The authority to order/purchase safety and health equipment is appropriately delegated 7 Written safety procedures, policies, and interpretations are updated based on reviews of the safety and health program 8 Safety and health expenditures, including training costs and personnel, are identified and budgeted for 9 Hazard abatement is an element in management performance evaluation 10 The co op has the safety and health expertise appropriate for its size and needs 11 The co op has access to professional advice for safety and health issues when needed 12 Safety and health budgets and funding procedures are reviewed periodically for adequacy Self Assessment Guide for an Effective Safety & Health Program (updated 06.08.12) 4

ENHANCED LEADERSHIP AND CULTURE Contractor safety: An effective safety and health program protects all personnel on the worksite, including the employees of contractors and subcontractors. Evaluation # Contractor Safety Attributes 1 Co op policy and contracts require contractors to conform to OSHA regulations and other applicable legal requirements 2 A co op representative monitors contractor safety and health practices, and has the authority to stop or pause work that expose contractor employees to hazards 3 Contractors receive a safety orientation prior to starting work 4 Contractor safety and health records are considered as part of the bid criteria in awarding the bid 5 The co ops safety and health program includes everyone working for the co op, i.e. regular full time employees, contractors, temporary and part time employees Self Assessment Guide for an Effective Safety & Health Program (updated 06.08.12) 5

PROGRAM ASSESSMENT AND ANALYSIS PROCESS Survey and hazard analysis: An effective, proactive safety and health program will seek to identify and analyze all hazards. Evaluation # Survey and Hazard Analysis Attributes 1 Applicable OSHA standards for the co op have been indentified 2 Analyses are communicated to and understood by affected employees 3 Environmental surveys are conducted by knowledgeable person(s) and updated as needed or as required by applicable standards 4 Current hazard analyses are written (where appropriate) for high hazard jobs 5 Current hazard analyses are documented for all work areas and are communicated to the employees 6 Knowledgeable persons review all planned changes to facilities, processes, materials, or equipment 7 Regular surveys including documented comprehensive workplace hazard evaluations are conducted by qualified safety and health professional 8 Corrective action is documented and hazard inventories are updated 9 Hazard analysis is integrated into the design, development, implementation, and changing of all processes and work practices Self Assessment Guide for an Effective Safety & Health Program (updated 06.08.12) 6

PROGRAM ASSESSMENT AND ANALYSIS PROCESS Inspection: Identifies new or previously missed hazards and failures in hazard controls. An effective safety and health program will include regular site inspections Evaluation # Site Inspection Attributes 1 Supervisors dedicate time to observing work practices and other safety and health conditions in work areas where they have responsibility 2 Competent personnel conduct inspections with appropriate involvement of employees 3 Items in need of correction are documented 4 Inspections include compliance with relevant OSHA standards 5 Time periods for correction are established 6 Inspections are conducted by specifically trained employees 7 All items are corrected / addressed promptly and appropriately 8 Workplace inspections are planned, with key observations or check points defined 9 Results are available to employees 10 Random observations are conducted and analyzed to evaluate progress Self Assessment Guide for an Effective Safety & Health Program (updated 06.08.12) 7

PROGRAM ASSESSMENT AND ANALYSIS PROCESS A reliable hazard reporting system enables employees, without fear of reprisal, to notify management of conditions that appear hazardous and to receive timely and appropriate feedback Evaluation # Attributes of a Reliable Hazard Reporting System 1 Employees are encouraged to report hazards 2 Supervisors are expected to encourage and respond to employee reports 3 Employees use the system with no risk of reprisals 4 A formal system for hazard reporting exists 5 Employee reports of hazards are documented, corrective action is scheduled, and documented when complete 6 Employees are periodically instructed in hazard identification and reporting procedures 7 Top leadership regularly reviews the reporting process to ensure the system is working. 8 Management responds to reports of hazards in writing within specified time frames 9 The employees readily identify and self correct hazards 10 Employees are supported by top leadership when they self correct hazards Self Assessment Guide for an Effective Safety & Health Program (updated 06.08.12) 8

PROGRAM ASSESSMENT AND ANALYSIS PROCESS Accident investigation: An effective program will provide for investigation of accidents and "near miss" incidents, so their root causes, and the means for their prevention, are identified Evaluation # Attributes of an Accident Investigation Program 1 Incidents investigations identify a root cause and the corrective action to be taken to prevent reoccurrence 2 Supervisors prepare injury reports for injury cases according to clearly defined co op procedures 3 Workers Compensation Report or the OSHA 301 is completed for all recordable incidents 4 OSHA recordable incidents are always investigated 5 Reports and recommendations are available to employees 6 Quality and completeness of investigations are systematically reviewed by trained safety personnel and a responsible executive leader 7 All loss producing accidents and "near misses" are investigated for root causes by teams or individuals that include trained personnel Self Assessment Guide for an Effective Safety & Health Program (updated 06.08.12) 9

PROGRAM ASSESSMENT AND ANALYSIS PROCESS Data analysis: An effective program will analyze injury and illness records for indications of sources and locations of hazards, and specific jobs or tasks that experience a higher numbers of injuries. By analyzing injury and illness trends over time, patterns with common causes can be identified and addressed to prevent reoccurrence Evaluation # Attributes of Data Analysis 1 Data is collected and analyzed, and used for prevention 2 OSHA 301 or Workers Compensation First Report of Injury form is completed for all recordable cases 3 Exposure records and analyses are organized and available to safety personnel 4 Injury/illness logs and exposure records are regularly updated, accurate and complete 5 Analysis identifies the frequent and most severe problem areas, high risk areas, job classifications, etc. 6 Data is effectively communicated to employees 7 Illness/injury data are audited and certified by a responsible person 8 All levels of management and the workforce are aware of results of data analyses and resulting preventive activity 9 External audits of accuracy of injury and illness data, including periodic review of all available data sources are conducted Self Assessment Guide for an Effective Safety & Health Program (updated 06.08.12) 10

SAFETY KNOWLEDGE AND AWARENESS Safety and health training should cover the safety and health responsibilities of all personnel. It is most effective when incorporated into other training concerning performance requirements and job practices. It should include all areas necessary to address existing hazards of the work Evaluation # Attributes of Safety Training and Awareness 1 Safety orientation and/or training is given to new hires 2 Safety training materials (e.g., pictures, diagrams, posters, videotapes) are used at safety meetings and documented 3 Assessment of worker knowledge is regularly conducted and documented 4 Training includes OSHA rights and access to information 5 Training required by applicable standards is provided to applicable employees 6 Supervisors and managers attend training in subjects provided to employees under their direction 7 Employees can demonstrate the skills/knowledge necessary to perform their jobs safely 8 Records of training are kept and training is evaluated to ensure that it is effective 9 Employees are trained to recognize hazards, violations of OSHA standards, and safe work practices 10 Employees are trained to report unsafe conditions and hazards 11 There are easily retrievable scheduling and record keeping systems 12 Knowledgeable persons conduct safety and health training 13 Training covers all necessary topics and situations, and includes all applicable personnel (including; hourly employees, supervisors, managers, part time and temporary employees) 14 Employees participate in creating co op specific training methods and materials 15 Retraining is provided based on standard requirements, accident investigations and work observations that identify a lack of knowledge or awareness Self Assessment Guide for an Effective Safety & Health Program (updated 06.08.12) 11

BEST PRACTICES HAZARD CONTROL AND PREVENTION Hazard Control: Exposure to current and potential hazards should be prevented or controlled by using engineering controls wherever feasible and appropriate, work practices and administrative controls, and personal protective equipment (PPE) Evaluation # Attributes of Hazard Control 1 Hazards that have caused past injuries in the facility have been evaluated and corrected 2 Documented reviews of needs for machine guarding, energy lockout, ergonomics, materials handling, blood borne pathogens, confined space, hazard communication, and other generally applicable standards have been conducted 3 Hazard controls are in place, and are known and supported by employees 4 All deviations are identified and causes determined 5 Hazard controls are fully in place and continually improved upon based upon regular hazard assessments 6 All PPE is inspected each day before use. Defective PPE is replaced 7 All rubber goods are inspected each day before use, including line hose and blankets Self Assessment Guide for an Effective Safety & Health Program (updated 06.08.12) 12

BEST PRACTICES HAZARD CONTROL AND PREVENTION Maintenance: An effective safety and health program will provide for facility and equipment maintenance, so that hazardous breakdowns are prevented Evaluation # Attributes of an Effective Maintenance Program 1 Manufacturers' and industry recommendations for maintenance frequency are complied with (Such as vehicle overhauls and routine maintenance) 2 Breakdown repairs for safety related items are expedited and the equipment is taken out of service until repaired 3 An effective preventive maintenance schedule has been implemented that applies to all equipment. 4 Equipment repair and field performance experience is used to improve safetyrelated preventative maintenance scheduling 5 A comprehensive safety and preventive maintenance program is in place that maximizes equipment reliability. 6 Vehicle Pre Trip and Post Trip inspections are performed each day a record is made of the post trip inspection 7 Lower controls are tested on aerial lift vehicles each day before use Self Assessment Guide for an Effective Safety & Health Program (updated 06.08.12) 13

BEST PRACTICES HAZARD CONTROL AND PREVENTION Emergency preparedness: There should be appropriate planning, training/drills, and equipment for response to emergencies. Note: In some facilities the plan is to evacuate and call the fire department. In such cases, only applicable items listed below should be considered Evaluation # Attributes of Emergency Preparedness 1 Emergency response plans for fire, chemical, and weather emergencies as required by 29 CFR 1910.38, 1910.120, or 1926.35 are present 2 Training is conducted as required by the applicable standard 3 Emergency response plans have been prepared by persons with specific training 4 Appropriate alarm systems are present 5 Employees are trained in emergency procedures 6 Adequate supply of spill control and PPE appropriate to hazards on site is available 7 Evacuation drills are conducted no less than annually 8 The plan is reviewed by a qualified safety and health professional 9 All potential emergencies have been identified 10 Plan and performance are reevaluated at least annually and after each significant incident 11 Procedures for terminating an emergency response condition are clearly defined Self Assessment Guide for an Effective Safety & Health Program (updated 06.08.12) 14

BEST PRACTICES HAZARD CONTROL AND PREVENTION First aid/emergency care should be readily available to minimize harm if an injury or illness occurs Evaluation # Attributes of First Aid and Emergency Care 1 On site or nearby community aid is available for every facility or job site 2 Personnel with certified first aid skills are always available on site; their level of training is appropriate to the hazards of the work being done 3 Adequacy of first aid is formally reviewed after significant incidents 4 Personnel trained in advanced first aid and/or emergency medical care are available on site as required by OSHA standards (e.g., 1910.151, 1910.269(b), 1926.23) Working with Rural Electric Safety Achievement Program ( RESAP ) participants, the National Rural Electric Cooperative Association ( NRECA ) prepared these materials as a resource for RESAP participants. To help promote and enhance safety, these materials may provide guidelines or suggestions exceeding legal requirements and standards of care. To the extent a guideline or suggestion exceeds a legal requirement or standard of care, the guideline or suggestion is not intended to increase or extend the legal requirement or standard of care. When developing and implementing safety procedures and practices, RESAP participants should: (1) consult other resources, in addition to these materials; (2) consult local legal counsel and local safety professionals; (3) consider local, state, and national legal requirements and standards of care; and (4) consider local, state, and national safety and practices. NRECA does not represent that these materials are complete or exhaustive, and disclaims any liability or responsibility associated with a RESAP participant complying, or not complying, with legal requirements and standards of care. Self Assessment Guide for an Effective Safety & Health Program (updated 06.08.12) 15