C H A P T E R 8 HAZARD ANALYSIS 8.1. Safety Inspections All areas and operations of each workplace, including office areas, must be inspected at least once a year. More frequent inspections shall be conducted in workplaces where there is an increased risk of accident, injury, or illness due to the nature of the work performed (e.g., inspection facilities, laboratories, and aircraft support facilities). Inspections shall be conducted by staff assigned to the Safety and Occupational Health Branch (SOHB) or by personnel contracted through SOHB. However, in isolated or identified low-risk areas, the Collateral Duty Safety Officer may be assigned the responsibility to conduct the annual workplace evaluation. Collateral Duty Safety Officers (CDSOs) should conduct monthly safety surveys, and supervisors should conduct cursory walkthroughs of their areas each day. These surveys/walkthroughs are not intended to fulfill annual inspection requirements. Safety inspections conducted by the General Services Administration or others do not relieve CBP of the responsibility to perform safety inspections described in this part. Safety inspections must be performed in conformance with 29 CFR 1960, Subpart D. Following is a digest of the requirements of Subpart D. 8.1.1. Safety Inspectorʼs Qualifications and Equipment Safety inspections shall be conducted by individuals qualified to recognize and evaluate hazards of the area/operation inspected and to suggest general abatement procedures. Safety inspectors must be provided the appropriate equipment (i.e. light meter, sound level meter, electrical tester) necessary to conduct a thorough inspection of the workplace. 8.1.2. Conducting the Safety Inspection The safety inspector shall conduct an opening and close out conference with management and employee representatives. In the opening conference the safety inspector will describe the purpose of the inspection and the areas to be inspected. During the close out conference the safety inspector should report his/her findings, answer any questions, discuss methods to abate identified hazards, and discuss any recommendations to improve the local safety program. Participantsʼ attendance at opening and close out conferences should be documented on CF-506, Record of Safety & Health Inspection Conference. 31
The safety inspector shall be in charge of the inspection and is authorized to deny the right of accompaniment to any person that he/she believes might interfere with a fair and orderly inspection. The safety inspector shall consult with employees (to the extent deemed necessary for the conduct of an effective and thorough inspection) and may interview any employee in private if he/she feels that it is necessary. During the course of an inspection, any employee shall be granted an opportunity to bring hazards to the attention of the safety inspector. When an imminent danger, which could reasonably be expected to cause death or serious physical harm is discovered, the safety inspector shall inform the affected employees, employee representative (if not participating in the inspection) and the official in charge of the workplace immediately. The official in charge of the workplace, or a person empowered to act for that official, shall undertake immediate abatement action and the withdrawal of employees who are not necessary for abatement of the dangerous conditions. In the event the official in charge of the workplace needs assistance to undertake full abatement, that official shall promptly contact the Chief, Safety and Occupational Health Branch and other responsible CBP officials, who shall assist the abatement effort. Safety committees and the union shall be informed of all relevant actions. 8.1.3. Security Areas Offices which have areas containing information classified in the interest of national security shall provide access to safety inspectors who have obtained the appropriate security clearance. Only persons with proper authorization shall accompany an inspector into areas containing information classified in the interest of national security. 8.1.4. Participation by Management and the Union A representative of the official in charge of the workplace and a representative of the employees shall be given an opportunity to accompany safety inspectors. 8.1.5. Written Reports The safety inspector shall document his/her findings on the Safety and Health Inspection Report. Completed safety inspection reports shall be submitted to the Safety and Occupational Health Branch Headquarters in Indianapolis, Indiana for review. Completed reports will be forwarded to the management official in charge of the facility for corrective action. 8.1.6. Notices of Unsafe or Unhealthful Working Conditions. The safety inspector shall issue A Notice of Unsafe or Unhealthful Workplace Conditions, CF-510, for each hazardous condition identified during the course of the inspection. The purpose of the notice is to inform 32
employees about an unsafe or unhealthful condition, even if it has already been abated. The notice(s) shall be issued not later than 15 days after completion of the inspection for safety violations or not later than 30 days after completion of the inspection for health violations. If there are compelling reasons why the notice cannot be issued within these time frames, the employeesʼ representative and the official in charge of the establishment shall be informed of the reasons for the delay. Notices shall detail precisely the nature and degree of seriousness of the unsafe or unhealthful working condition, including a reference to the standard or other requirement involved. The notice shall fix a reasonable time, with respect to the seriousness of the hazard, for the abatement of the unsafe or unhealthful working conditions. A copy of the Notice of an Unsafe or Unhealthful Workplace Condition shall be sent to the official in charge of the workplace, the employee representative who participated in the closing conference and the local safety committee. Upon receipt of any Notice of an Unsafe or Unhealthful Workplace Condition, the official in charge of the workplace shall immediately post such notice, or copy thereof, unedited, except for reasons of national security, at or near each place an unsafe or unhealthful working condition referred to in the notice exists or existed. In addition, a notice shall be posted if any special procedures are in effect. Where, because of the nature of the workplace operations, it is not practicable to post the notice at or near the workplace, such notice shall be posted, unedited, except for reasons of national security, in a prominent place where it will be readily observable by all affected employees. For example, where workplace activities are physically dispersed, the notice may be posted at the location to which employees report each day. Where employees do not primarily work at or report to a single location, the notice may be posted at the location from which the employees operate to carry out their activities. Each Notice of an Unsafe or Unhealthful Workplace Condition, or a copy thereof, shall remain posted until the unsafe or unhealthful working condition has been abated or for 3 working days, whichever is later. 8.1.7. Maintenance of Records Inspection reports and Notices of Unsafe or Unhealthful Workplace Conditions shall be maintained on file at the facility for five years. 8.2 Risk Assessment Codes (RAC) A Risk Assessment Code (RAC) is a number assigned to a specific hazard or deficiency that measures the probability of a mishap occurring and the potential severity of the mishap if it occurs. The purpose of the RAC is to aid management in setting priorities when addressing identified safety related hazards. 33
8.2.1 General Each occupational hazard or deficiency must be evaluated and assigned a risk assessment code (RAC). Evaluation and assignment of RACʼs are to be made by safety and occupational health professionals. The RAC is determined by plotting the probability (A, B, C, D, or E) that a hazard or deficiency will result in a mishap and the potential severity (I, II, III, or IV) of the mishap if it occurs. The RAC is an Arabic numeral, one through five, determined from the matrix displayed in section 8.2.5. The implementation of interim control measures to reduce the level of risk associated with a particular hazard or deficiency will not affect the assigned RAC. 8.2.2 Hazard or Deficiency Severity This is an assessment of the expected consequence if a hazard or deficiency results in a mishap. It is defined by the degree of injury, occupational illness, or resource loss or damage that could occur. The severity categories are: I II Catastrophic: Hazard may cause death or total loss of a bodily system Critical: Hazard may cause severe bodily injury, severe occupational illness, or major damage to a bodily system III Marginal: Hazard may cause minor bodily injury, minor occupational illness, or minor damage to a bodily system IV Negligible: Hazard would cause less than minor bodily injury, minor occupational illness, or minor bodily system damage 8.2.3 Mishap Probability This is an assessment of the likelihood that a hazard or deficiency will result in a mishap. Mishap probabilities are categorized as follows: A B C D E Frequent likely to occur frequently Probable probably will occur in time Occasional likely to occur in time Remote unlikely but possible to occur Improbable so unlikely, it can be assumed occurrence may not be experienced 8.2.4. RAC Descriptions 1 Imminent Danger 2 Serious 3 Moderate 4 Minor 5 Negligible 34
8.2.5 Risk Assessment Code Matrix 8.3 Job Hazard Analysis 8.3.1 General Mishap Probability Severity A B C D E I 1 1 1 2 3 II 1 1 2 3 4 Risk Assessment III 2 3 3 4 5 Codes IV 3 5 5 5 5 Job Hazard Analysis (JHA) is a simple, but effective method of preventing accidents and illnesses. JHA is a procedure designed to review job methods, uncover hazards and recommend safe job procedures. JHAʼs shall be conducted on work tasks that: have a high frequency of accidents or near misses; have already produced fatalities, disabling injuries, or illnesses, regardless of the frequency; have the potential for causing serious injury or harm; have undergone a change in procedure, equipment, or materials and jobs whose operation may have been affected by a new standard; and are new to the operation. New work tasks should undergo a thorough JHA before employees are assigned to do it. Area Safety and Occupational Health Managers should confer with local CBP officials to identify specific jobs that meet the criteria shown above. A team comprising of the Area Safety and Occupational Health Manager, a supervisor over that job function, and at least one employee who performs that job task will then perform the JHA as outlined below. The three basic steps of a JHA are as follows: 1. Break the job down into successive steps or activities and observe how these actions are performed. 2. Identify the hazards and potential accidents (this is the critical step because only an identified problem can be eliminated). 3. Develop safe job procedures to eliminate the hazards and prevent the potential accidents. JHA can make work tasks as safe as humanly possible by finding hazards and eliminating or minimizing those hazards before the job is performed and before these hazards have a chance to become accidents. CF-505, Job Hazard Analysis should be used to document the job hazard analysis. 35
8.3.2 Benefits of JHA The principal benefits of JHA include: 8.3.3 Training Instructing new employees on the job Studying jobs for possible improvement in job methods Reviewing job procedures after accidents occur JHA training is included in the supervisor, safety officer, and safety committee training provided by the HRM, Safety and Occupational Health Branch. 8.4 Industrial Hygiene Evaluations Industrial hygienists analyze, identify, and measure workplace hazards or stresses that can cause sickness, impaired health, or significant discomfort in workers through chemical, physical, ergonomic, or biological exposures. Industrial hygiene evaluations will be conducted by HRM Safety and Occupational Health Branch staff in response to hazard reports or requests for assistance received from Field Managers or Area Safety and Occupational Health Managers. Industrial hygienists are trained to anticipate, recognize, evaluate, and recommend controls for environmental and physical hazards that can affect the health and wellbeing of workers. Industrial hygienists use environmental monitoring and analytical methods to detect the extent of worker exposure and employ engineering, work practice controls, and other methods to control potential health hazards. 8.4.1 Examples of industrial hygiene services provided by the HRM, Safety and Occupational Health Branch include, but are not limited to: Assessment of potential exposure to lead at indoor firing ranges; Assessment of potential exposure to motor vehicle exhaust fumes at border stations; Assessment of chemical hazards at laboratories, warehouses, aviation and marine support facilities; Indoor air quality evaluations; Asbestos surveys; Chemical hazard evaluations; Noise evaluations; Ergonomic assessments; Drinking water quality evaluations; Development of respiratory protection programs; 36
Selection of personal protective equipment and training; and Assessment of radiation hazards. Requests for industrial hygiene surveys should be forwarded to the HRM, Safety and Occupational Health Branch (317-290-3020 extension 1148). 8.5. Pre-Occupancy Inspections Area Safety and Occupational Health Managers shall conduct pre-occupancy inspections of all newly-acquired spaces or spaces that have undergone major construction/renovations. These surveys shall be completed prior to occupancy. 37
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