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This material is for training purposes only to inform the reader of occupational safety and health best practices and general compliance requirements and is not a substitute for provisions of the OSH Act of 1970 or any governmental regulatory agency.
  MODULE 3: CORRECTING SAFETY HAZARDS

Introduction

In the last module, we examined the inspection and JHA processes to identify hazardous conditions and unsafe behaviors in the workplace. Once hazards have been identified, it's important that they be corrected in a timely manner. Even more importantly, the underlying safety management system weaknesses must be improved to make sure they do not produce the identified hazards in the future. In this module, we'll examine the hazard controls strategies used to correct identified hazards, and we'll discuss the safety management system improvement process.

Once hazardous conditions or unsafe work practices are identified, it's important that the supervisor makes sure they are eliminated or reduced as soon as possible. To do this, one or a combination of the following three hazard control strategies should be used.

The Hierarchy of Hazard Control Strategies

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. ANSI Z10-2005, Occupational Health and Safety Management Systems, encourages employer employ the following hierarchy of hazard control strategies:
  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. Let's take a closer look at the hierarchy of control strategies.

Elimination and Substitution

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.

These strategies are considered first because they have the potential of completely eliminate the hazard, thus greatly reducing the probability of an accident. Redesigning or replacing equipment or machinery may be expensive, but remember that, according to the National Safety Council, the average direct and indirect cost of a lost work time injury is $34,000 and $1,115,000 to close a fatality claim.

Engineering Controls.

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.

When considering engineering controls, you should think about the feasibility, costs, and ease of implementation of replacing or redesigning the equipment. OSHA will expect your employer to consider these first three control strategies before employing administrative controls or personal protective equipment (PPE).

Administrative Controls.

Administrative controls and personal protective equipment are frequently used together 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. The strategy differs in that exposure is limited by revising:

  • The frequency of exposure to the hazard.
  • The duration of the task that exposes the employee to the hazard.
  • The number of employees exposed to the hazard.

Personal Protective Equipment (PPE).

Sometimes it is impossible to eliminate a hazard through elimination, substitution, engineering controls or administrative controls. In these situations, personal protective equipment may be required to provide some degree of safety by placing a barrier between the employee and the hazard. For this reason, using personal protective equipment should be the strategy of last resort.

What's the solution?

Let's assume you are the supervisor of a warehouse. Your five employees must lift and carry 85 pound sacks of grain repeatedly to a pallet during their eight-hour work shift. How can you reduce or eliminate the possibility of an injury from carrying the heavy bags? Let's take a look at a few examples:

  • Elimination. Let's get rid of the heavy sacks of grain. Well, that's probably not feasible, so let's move on to the next strategy.
  • Substitution. Ah hah! I think we can work this. Let's substitute the heavy sacks with sacks that weigh less.
  • Engineering Controls. Maybe we could devise a conveyor belt system that eliminates the need to carry the bags.
  • Administrative Control. Let's change the work procedure so that two employees are required to carry a bag.
  • Personal Protective Equipment. Well, we can't use the body belt because it doesn't really protect anyone. I don't know what you could use. Do you?
In this situation, I think we can probably use a combination substitution, engineering controls, and administrative controls to reduce the exposure to lifting and carrying heavy sacks.

Improving safety management systems

Now let's switch gears a bit. Any organizational safety system may be less than "healthful" for any number of reasons. It is important to start an effective "safety management system wellness plan" to make sure the “prognosis” for all safety management systems within an organization remains positive. That is what the evaluation process is all about...wellness. Safety coordinators, safety committees, and other support staff can be very effective in evaluating programs to uncover those inadequate or missing safety management system components that are producing the hazardous conditions and unsafe behaviors you, as the supervisor, have identified.

Although you may not get directly involved in the safety management system evaluation program, you and your employees are critical in forwarding quality information so that the evaluation process is successful. To help you do this, think of the conditions and behaviors you identify as symptoms that point to underlying causes. You may identify symptoms that point to special or personal weaknesses, or you may uncover symptoms pointing directly to underlying system or program weaknesses.

Symptoms - Observable/Measurable indicators. What do we see?

Symptoms indicating personal weaknesses.
  • A unique hazardous condition or unsafe/inappropriate behavior performed by one person.
  • May occur at any level of the organization.
  • May indicate a “special” problem that requires a unique solution.
  • Attributing error to personal weakness should never be the initial assumption.

Symptoms indicating system weaknesses.

  • A number of similar conditions or behaviors common to a number of locations.
  • May occur at any level of the organization.
  • May contribute to, or produce a specific hazardous condition and unsafe behavior.
  • Indicates a “common” problem that requires a system solution.
  • The scope of the condition or behavior indicates the management level at which the cause exists.
  • Attributing error to system weaknesses should usually be the initial assumption.

Now that we have observable and measurable conditions and behaviors, you or safety professionals need to continue the evaluation process by assessing and analyzing their underlying systems causes.

Causes - What do the symptoms tell you?

Causes indicating weaknesses in organizational structure
  • Formulated by upper management.
  • Inadequate design of vision, mission, strategies, objectives
  • Inadequate design of policies, plans, processes, programs, procedures.
  • May exist in any program in any department
  • The natural result of a non-supportive leadership style.

Causes indicating weaknesses in leadership style

  • Non-supporting corporate vision.
  • Unreasonable expectations of the CEO or Owner.
  • External forces: stakeholders, materials, industry, community, society, government.
  • The natural result of inappropriate values creating a fear-based culture.

Last words...

Identifying hazardous conditions and unsafe behaviors is only a part of the equation in effective supervision. Controlling those hazards and making sure that the safety system weaknesses that produced them are improved, are critical activities. Sound management and leadership practices require a supervisor to pay close attention to the follow-through of top management as well as specific employee behaviors.

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