Introduction

In Module Four we studied about communication and how it can be used to improve employee involvement in the company's injury and illness prevention program. In this module, we'll take a look at how employees can get involved in proactive hazard identification (eh-heh...that should be hazard investigation) to help eliminate hazards in the workplace. So, let's get hopping!

OK...so what's a hazard?

Before we study identifying, investigating and controlling hazards in the workplace, it's important to know how OSHA defines the term. A hazard is:

Any workplace condition or a person's "state of being" that could cause an injury or illness to an employee.

Look around...what do you see?

I'll bet if you look around your workplace, you'll be able to locate a few hazardous conditions or work practices without too much trouble. Did you know that at any time an OSHA inspector could announce their presence at your corporate front door to begin a comprehensive inspection? What would they find? What do they look for? Now, if you used the same inspection strategy as an inspector, wouldn't that be smart? Well, that's what I'm going to show you in this module!

Controlling Exposure - The Hierarchy of Controls

Controlling exposures to occupational hazards is the fundamental method of protecting workers. Traditionally, a hierarchy of controls has been used as a means of determining how to implement feasible and effective controls. One representation of this hierarchy can be summarized as follows:

1. Elimination
2. Substitution
3. Engineering controls
4. Administrative controls
5. Personal protective equipment

The idea behind this hierarchy is that the control methods at the top of the list are potentially more effective and protective than those at the bottom. Following the hierarchy normally leads to the implementation of inherently safer systems, ones where the risk of illness or injury has been substantially reduced.

Elimination and substitution, while most effective at reducing hazards, also tend to be the most difficult to implement in an existing process. If the process is still at the design or development stage, elimination and substitution of hazards may be inexpensive and simple to implement. For an existing process, major changes in equipment and procedures may be required to eliminate or substitute for a hazard.

Engineering controls are used to remove a hazard or place a barrier between the worker and the hazard. Well-designed engineering controls can be highly effective in protecting workers and will typically be independent of worker interactions to provide this high level of protection. The initial cost of engineering controls can be higher than the cost of administrative controls or personal protective equipment, but over the longer term, operating costs are frequently lower, and in some instances, can provide a cost savings in other areas of the process.

Administrative controls and personal protective equipment are frequently used with existing processes where hazards are not particularly well controlled. Administrative controls and personal protective equipment programs may be relatively inexpensive to establish but, over the long term, can be very costly to sustain. These methods for protecting workers have also proven to be less effective than other measures, requiring significant effort by the affected workers.

Note: ANSI/AIHA Z10-2005 also includes "Warnings" as one of the strategies in the Hierarchy of Controls. However, I would classify this strategy as an administrative control because warnings are only as effective as the awareness of and compliance with their message. Warnings do not eliminate or reduce hazards.

The Five Workplace Hazard Categories

To help identify workplace hazards it's useful to categorize them into easy-to-remember categories. The first three categories represent hazardous physical conditions that, according to SAIF Corporation, account for only 3% of all workplace accidents. The fourth category describes behaviors in the workplace which may contribute up to 95% of all workplace accidents. The final category may contribute to both the hazardous conditions and unsafe behaviors, and therefore, may be ultimately responsible for fully 98% of all accidents in the workplace.

1. Materials. Hazardous materials include hazardous:

• Liquid and solid chemicals such as acids, bases, solvents, explosives, etc. The hazard communication program is designed to communicate the hazards of chemicals to employees, and to make sure they use safe work practices when working with them.

• Solids like metal, wood, plastics. Raw materials used to manufacture products are usually bought in large quantities, and can cause injuries or fatalities in many ways.

• Gases like hydrogen sulfide, methane, etc. Gas may be extremely hazardous if leaked into the atmosphere. Employees should know the signs and symptoms related to hazardous gases in the workplace.

2. Equipment. This area includes machinery and tools used to produce or process goods. These examples all represent hazardous conditions in the workplace. Hazardous equipment includes machinery and tools.

• Hazardous equipment should be properly guarded so that it's virtually impossible for a worker to be placed in a danger zone around moving parts that could cause injury or death. A preventive maintenance program should be in place to make sure equipment operates properly. A corrective maintenance program is needed to make sure equipment that is broken, causing a safety hazard, is fixed immediately.

• Tools need to be in good working order, properly repaired, and used for their intended purpose only. Any maintenance person will tell you that an accident can easily occur if tools are not used correctly. Tools that are used while broken are also very dangerous.

3. Environment. This area includes facility design, hazardous atmospheres, temperature, noise, factors that cause stress, etc. Are there areas in your workplace that are too hot, cold, dusty, dirty, messy, wet, etc. Is it too noisy, or are dangerous gases, vapors, liquids, fumes, etc., present? Do you see short people working at workstations designed for tall people? Such factors all contribute to an unsafe environment.

4. People. This area includes unsafe employee behaviors at all levels in the organization such as taking short cuts, not using personal protective equipment, and otherwise ignoring safety rules.

5. System. Every company has, do some degree, a safety and health management system (SHMS). It's good to think of the "state" of the SHMS as a condition. For instance, management may develop and implement ineffective policies, procedures and safety rules. I consider a flawed SHMS as a systemic hazardous condition because it could increase the number accidents. If the condition of the SHMS is flawed, it may also result in manager and supervisor behaviors such as ignoring safe behaviors or by actually directing unsafe work practices that will contribute to accidents in the workplace.

To remember the five hazard areas, just remember the acronym...

MEEPS = Materials, Equipment, Environment, People, and System.

Two identification and control strategies

To identify and control hazards in the workplace, two basic strategies are used. First, and most common is the walk-around inspection. Now, you probably have participated in a safety inspection, or at least have watched others conduct one.

• Most companies conduct safety inspections in compliance with OSHA rule requirements. But, is that good enough? Safety inspections may be effective, but only if the people conducting the inspection are properly educated and trained in hazard identification and control concepts and principles specific to your company. In high hazard industries which see change on a daily basis, it takes more than an occasional inspection to keep the workplace safe from hazards.

• In world-class safety cultures supervisors, as well as all employees inspect their areas of responsibility as often as the hazards of the materials, equipment, tools, environment, and tasks demand. It's really a judgment call, but if safety is involved, it's better to inspect often.

• Employees should inspect the materials, equipment, and tools they use, and their immediate workstation for hazardous conditions at the start of each workday. They should inspect equipment such as forklifts, trucks, and other vehicles before using them at the start of each shift. Again, it's better to inspect closely and often.

Inspection checklists...write'm and use'm!

• Use the following steps if you are asked to write questions for a safety inspection.
• Determine the area to be inspected.
• Ask workers in the area what tasks/jobs they do.
• Call OSHA Technical Services (1-800-922-2689) and ask one of their representatives to help you determine which rules apply to your workplace.
• Ask them to send you a copy of applicable rules.
• When you receive the rules (don't panic) read through the applicable sections and mark those rules that you feel might result in serious injury if violated.
• Change each marked rule into a simple question. Questions will start with the words: Do, does, is, are.
• Construct your checklist using the questions you have developed.
• Show your boss. He or she will be surprised! (You will probably become a safety director!)

You may use this Self Inspection Checklist published by OSHA.

What's the major weakness of the safety inspection?

By its very nature, the walk-around inspection is ineffective in uncovering unsafe work practices because most inspectors look primarily at hazardous conditions and do not take enough time to effectively analyze individual task procedures. Sometimes the inspectors walk into an area, look up...look down...look all around...possibly ask a few questions, and move on to the next area (I call that the rolling-eyeball syndrome). In fact, the safety inspection may be effective in uncovering only about 3 percent of the causes for workplace accidents because the process only looks for conditions. Isn't it possible to inspect a workplace on a Monday, and then experience a fatality on Tuesday as a result of an unsafe work behavior that the inspection failed to uncover the day before? You bet it is.

What's the solution?

A walk-around inspection of this job site was completed just 30 minutes prior to this picture being taken. Did it catch this unsafe practice? This illustrates the major weakness of the inspection process. The Job Hazard Analysis (JHA) can be the answer to this weakness. It uncovers unsafe work practices as well as hazardous conditions because sufficient time is given to closely analysis of one unique task at a time. A typical JHA uses the following steps:

• While the employee accomplishes several cycles of the task, the supervisor or other person observes and takes notes about what's being done.

• Once the observation is completed, the analysts divide the task into a number of unique steps which are listed sequentially.

• Next, each step is analyzed to uncover hazardous materials, equipment, tools, and unsafe exposures are involved.

• Next, the hazards and exposures of each step are analyzed to determine the safety precautions required to eliminate or at least reduce any hazards or exposures present. This might include the use of personal protective equipment (PPE), using new or redesigned equipment, or changing the procedure itself.

• Lastly, a written safe work procedure (SJP) is developed for the entire task. The SJP is reviewed prior to accomplishing the task and it can also be used as a lesson plan to conduct training.

Check out OSHAcademy Course 706 for more information on the JHA and Course 703 on training.

Key Principle: Employees use their "own" procedures when not being directly supervised

Involvement is one of the key principles in making sure your safety management system (SMS) is effective (gets desired results). Management should involve employees/unions in all aspects of SMS development so that they will gain a sense of buy-in or ownership in the system.

Employee involvement in the JHA process helps ensure they will use the safe job procedure developed by the JHA when not being directly supervised. Employees want to work efficiently, and that means they're more likely to use procedures they believe will get the job done most efficiently. If they're not involved in developing safe job procedures, they're more likely to see their own (possibly less safe) procedures as more efficient. When employees are directly involved, supervisors can be a little more sure their employees are using safe job procedures.

Dig up the roots!

When investigating hazards discovered in a walk-around inspection or JHA, it's important that you uncover the root causes that have allowed those hazards to exist in the workplace. Taking this approach to hazard investigation is called root cause analysis.

Check out the well-known "accident weed" to the right.

The flower represents the injury. It's the result of the transfer of an excessive amount of energy from an outside source to the body. This is called the direct cause of the accident.

The leaves of the weed represent hazardous conditions and unsafe work practices in the workplace. Conditions and/or practices are typically called the surface or indirect causes of an accident.

The roots of the weed represent management's effort to maintain a safe and healthful workplace, safety policies, safety supervision, safety training, and enforcement of safety rules. Think of these as management controls which pre-exist every hazardous condition, unsafe work practice, and accident. Inadequate or missing system components represent the root causes for accidents in the workplace. System weaknesses may include programs, policies, plans, processes and procedures (remember the "5 P's") in any or all of the seven element areas of the safety management system. Root causes may feed and actually promote or nurture hazardous conditions and unsafe work practices.

Research findings indicate hazardous conditions, alone, represent only about 3% of the causes for accidents in the workplace, while unsafe behaviors make up about 95% of the causes for accidents. Consequently, about 98% of all workplace accidents are ultimately caused by a combination of inadequate safety management system components, under the control of management, that result in hazardous conditions and/or unsafe work practices.

If you have Adobe Acrobat Reader, take a look at a more complete accident weed with explanation.