Improving safety on a construction worksite is one of the most important contractor activities. To do this, we need to analyze the ways to identify the hazards on site. Next, we need to compare those hazards with the control methods we know work best. Once we have this information, we can then make improvements.
In this module, we'll study the general steps in the worksite analysis, evaluation and improvement process. Failing to conduct a comprehensive worksite analysis on each worksite is a costly decision on the part of the employer.
Let's take a look at OSHA's Top 10 Most Frequently Cited Violations for Fiscal Year 2020 to get a better idea where to focus our efforts:
Ergonomics is not covered by OSHA. Ergonomic hazards cause back injuries, strains, sprains, and other musculoskeletal disorders. Although there is no OSHA specific rule on ergonomics, it is the cause of most injuries on the worksite: One cause for this is a lack of reporting by injured workers. OSHA may resort to the use of the "General Duty Clause" to cite employers for ergonomics-related violations or issue an ergonomic hazard alert letter.
Worksite analysis is a combination of systematic actions to provide you with the information you need to recognize and understand the hazards and potential hazards of your workplace. We will discuss five important processes in the worksite analysis plan. The first of these important processes should be the baseline survey that helps the employer determine the current status of the CSMS. When planning for a construction worksite analysis, be sure to include at a minimum all the following processes:
A comprehensive hazard survey is the most basic of all the tools used to establish the inventory of hazards and potential hazards at the worksite. After a baseline has been established, periodic comprehensive surveys need to be done to take advantage of new information about hazards or the introduction of new hazards into the workplace. Each time there is a change of facilities, equipment, processes or materials in your workplace, they should be analyzed for hazards before they are introduced. Ideally, auditing segments of the survey should be assessed for continuous improvement.
The baseline survey should include a review of the following:
As part of the worksite analysis process, the employer/general contractor should also require subcontractors to perform a baseline analysis as necessary in accordance with OSHA and company requirements. The subcontractors should share pertinent information with the general contractor, and/or other subcontractors.
A very important part of the hazard identification process is to look for the hazardous conditions, themselves, and the circumstances which may result in exposure to hazardous conditions. To have an event that results in an injury or illness, a hazard and exposure to the hazard must exist. So, let's briefly look at the two concepts:
When analyzing the construction worksite, it's important we don't just look for hazardous conditions. We also need to identify potential opportunities for exposure to the hazard's conditions.
The following is a list of topics relevant to worksite analysis by identifying worksite hazards:
When conducting the worksite analysis, it's important to look for hazards that are generally recognized within the construction industry. Recognized hazards are generally foreseeable on the worksite OSHA will require that these hazards are properly eliminated or controlled.
As described in OSHA's Field Operations Manual, recognition of a hazard is established based on industry recognition, employer recognition, or "common sense" recognition criteria.
To help identify workplace hazards 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 last category, the system, contributes to both the hazardous conditions and unsafe behaviors. If you consider both the surface and root causes for accidents, failures in the CSMS are ultimately responsible for most accidents in the workplace.
Note: To remember the five categories, just use the acronym "MEEPS" (Materials, Equipment, Environment, People, System).
A Job Hazard Analysis (JHA) is a technique that focuses on job tasks to identify hazards before they occur. It focuses on the relationship among the worker, the task, the tools, and the work environment. Ideally, after you identify uncontrolled hazards, you will take steps to eliminate or reduce them to an acceptable risk level.
A JHA should be conducted for all hazardous jobs/procedures to determine potential hazards and identify methods to reduce exposure to those hazards at construction worksites. Here are the steps in a basic JHA:
Click here to see a sample JHA.
The JHA also serves as an excellent training tool that trainers can use to train hazardous procedures. The step-by-step format is great for on-the-job practice. You can learn more about conducting a JHA in course 706 Job Hazard Analysis.
As you know, change is continuous on a construction worksite. Change analysis is simply the management of that change, conducted by competent persons, to make sure it does not introduce new hazards or unsafe procedures in the work environment.
A designated person should analyze how changes on the worksite can affect equipment, processes, and materials for hazards and potential hazards. Findings should be documented and plans developed to minimize or design out the new hazards.
Changes in the following categories need to be reviewed:
To more specifically analyze how changes worksite layout, materials, processes and equipment, affect the work being conducted, include the following in your analysis:
Employees play a key role in identifying, controlling, and reporting hazards that may occur or already exist in your workplace. Safety inspection reports of potential hazards can be an effective tool to trigger a closer look at a piece of equipment, operation, or how work is being performed. The only caveat related to safety inspections is that, although, they may be good at uncovering hazardous conditions, they are not so good at uncovering unsafe behaviors. Reports of potential hazards can also provide suggestions to eliminate a hazard.
There are many positive reasons for conducting safety inspections, including:
Information obtained from the various hazard analysis processes is most useful when hazard control strategies are developed and incorporated into the worksite. It's important to recognize that not all hazard control strategies are equal. Some are more effective than others at reducing the risk in the job.
Remember, a very basic hazard control principle is that we must either (1) eliminate the hazard or (2) control exposure to the hazard. The second principle is that it's more effective to eliminate the hazard, if you can, than to control exposure to the hazard. After all, if you can get rid of the hazard, you don't have to manage the exposure. These two important principles help guide safety and health professionals in constructing a "hierarchy" of hazard control strategies.
Traditionally, a hierarchy of controls has been used to determine how to implement feasible and effective controls. ANSI Z10, Occupational Health and Safety Management Systems, encourages employer employ the following hierarchy of hazard control strategies:
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.
Safety committees function best when they understand their purpose is to play the role of an internal consultant to the employer. The safety committee can assist by helping the employer analyze and evaluate CSHM programs and making written recommendations to improve the program where applicable.
To conduct an evaluation, we need to take the information gathered from the baseline survey and rate it against an established benchmark. A benchmark is a standard by which the system can be measured or judged, for instance, we might say XYZ's CSMS is the "benchmark of quality" in our industry.
OSHA has two excellent partnership programs to help companies achieve their benchmarks:
OSHAcademy and the American Society of Safety Engineers have excellent publications. We recommend purchasing:
Dr. W. Edwards Deming is considered by most to be the father of Total Quality Management and Continuous Improvement. His PDSA Cycle uses a systematic series of steps to gain data for the continual improvement of a product or process. The process is called a "cycle" because the steps are continually repeated. As the image to the right shows, the PDSA Cycle contains four primary steps. These four steps may be used when improving the worksite through the use of hazard controls as follows:
Each of the four steps in the PDSA Cycle are important and must not be skipped.
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