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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 FIVE: EVALUATING THE 58 ELEMENTS

Introduction

Well, it's time to get familiar with the various program elements of the SMS that are evaluated as part of the Safety and Health Achievement Recognition Program (SHARP). Believe me, if you complete and "pass" this evaluation, your SMS is probably designed and performing more effectively than most. The rest of this course will introduce you to 58 elements that are commonly evaluated in a SHARP Audit and offer important suggestions for each element . Relax though; you are not actually going to have to conduct an audit as part of this course.

The 58-Element Worksheet

As part of the SHARP audit, OSHA consultants use the Safety and Health Program Assessment (SHPA) Worksheet to assess the quality of an SMS. (Here here on, we'll refer to it as the "Worksheet.") It is a tool that helps the evaluator objectively evaluate 58 safety and health program elements. Each element is considered critical to the effectiveness of one or more programs in the SMS. To arrive at a conclusion about the quality of each element, the evaluator analyzes a number of characteristics or "attributes."

The Worksheet divides the elements into the following seven categories:

  1. Hazard Anticipation and Detection. This first category asks what proactive strategies the employer is using to anticipate and identify hazards in the workplace.
  2. Hazard Prevention and Control. This category evaluates the organization's ability to use engineering and management strategies to control hazards and exposure.
  3. Planning and Evaluation. This category examines the organization's SMS structure and its ability to evaluate that structure.
  4. Administration and Supervision. This category evaluates SMS performance in administering safety and health programs and supervising employees.
  5. Safety and Health Training. This category examines the SMS training program and the effectiveness of training.
  6. Management Leadership. This category uncovers how well management is demonstrating leadership through word and deed.
  7. Employee Participation. This final category evaluates the level of employee involvement in the SMS.

Elements and Attributes

Elements - Each of the 58 elements throughout the seven categories is presented as a positive statement about the quality of a specific program. Each statement is a "benchmark" typical of highly effective safety management systems.

Attributes - An attribute is a specific fact or perception used by the evaluator to rate an element. Each attribute describes an effect: an observable/measurable condition or behaviour which either confirms (supports) or negates (fails to support) the element's statement. Here are a couple of sample attributes associated with Element 1:

a. The surveys are conducted frequently enough to timely and effectively address hazards. (describes an observed activity)

d. The survey results in effective controls for hazards found. (describes a observed condition)

To get a list of the attributes within each of the 58 elements, download the Adobe Acrobat file, or open this web page.

Rating the Elements - Analyzing the Attributes

OSHA consultants use these attributes as part of their SHARP Audit. If a large number of confirming attributes are present, the cause is assumed to be the condition or activity described in the associated element. You may want to include other attributes as well those presented in this course. Use these attributes in addition to the "tips" listed under each element within the course.

Take a look at the table below. It shows the rating scale, a definition, and the criteria for the rating. Here's how it works. The evaluator's conclusion is entered as one four numeric ratings (0, 1, 2, or 3). Some evaluators may also use the "NE" or "NA" ratings. However, OSHA evaluator's use only the numeric ratings. To rate an element, the evaluator enters one of the ratings listed below next to the element's statement.

Rating Definition Criteria
0 No discernible or meaningful indication that the item is even partially in place. Complete absence of any CONFIRMING attributes. A single confirming attribute prohibits this rating.
1 Some portion or aspect is present, although major improvement is needed. A greater number of NEGATING attributes than CONFIRMING attributes
2 Item is largely in place, with only minor improvements needed. A greater number of CONFIRMING attributes than NEGATING attributes
3 Item is completely in place. Complete absence of any NEGATING attributes. A single negating attribute prohibits this rating.
NE Not Evaluated: Recognizes that comprehensive evaluations can be incremental Optional. Not used by OSHA Consultants
NA Not Applicable: Must have justification in the comments box why the item is not applicable Optional. Not used by OSHA Consultants

Notes:

  • In reality, there is a very small gap between the 0 (zero) rating and the 1 (one) rating and between the 2 (two) rating and the 3 (three) rating.
  • There is a large gap between the 1 (one) rating and the 2 (two) rating. That gap is the difference between mostly no and mostly yes.
  • Look for things that are done well and reinforce these things with personnel for their good efforts.
  • Encourage small incremental improvements to better manage the "unexpected."
  • In the SHARP certification process employers must participate in a complete audit. For a company to qualify for SHARP, it must achieve a rating of at least 2 (the item is largely in place, with only minor improvements needed) on all 58 elements.

  • All completed audits should have some justification and/or recommendations under the comment section for questions rated as 0 and 1. All completed assessments should be included and/or referenced in the report sent to the employer.

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