Element 5: Hazard Identification and Control

Introduction

Hazard Definition
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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 and analysis to help eliminate hazards in the workplace.

Hazard Definition

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.

Check out this short audio clip by Dan Clark of the theSafetyBrief.com that describes OSHA's Top Ten Hazards.

Look Around Your Workplace

What would an OSHA inspector find?

Use the Hierarchy of Controls.
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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!

The Hierarchy of Controls

Controlling hazards and exposure to occupational hazards is the fundamental method of protecting workers. Traditionally, a hierarchy of control strategies have been used as a means of determining how to implement feasible and effective controls. The hierarchy of controls includes the following five strategies:

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

It's easier to control the hazard than exposure.
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The Hierarchy of Controls (Continued)

Elimination and substitution, while most effective at reducing hazards, total elimination or replacement of materials, equipment and machinery may the most difficult and expensive to implement. If you can do it, the long term benefits are substantial.

Engineering controls are design or redesign of tools, equipment, machinery, materials and facilities 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/work practice controls include policies, procedures, training, safety rules, job rotation, signage, or temporary barriers to warn of a hazard or describe safe procedures. These methods for protecting workers have also proven to be less effective than other measures primarily because methods to control human behavior to reduce exposure are more difficult than higher-level controls that remove or reduce the hazard, itself.

Personal Protective Equipment (PPE) such as safety glasses, gloves, hearing protection, respirators, safety boots, and hardhats place a barrier between worker and the hazard, but they don't prevent the occurrence of the incident. PPE is considered the least effective method of controlling a hazard because it depends on proper selection and fit, employee compliance, and availability.

The first three strategies, elimination, substitution and engineering controls are the most important because they can eliminate or reduce hazards. The last two strategies eliminate or reduce exposure to hazards, but they don't do anything to the hazards themselves. That's why administrative controls and PPE are the less important strategies in the hierarchy. Basically, the ideas is that if you can eliminate the hazards, you don't have to worry about exposure to the hazards, nor the resulting accidents.

Blast from the Past - Here's a short audio clip by Steve Geigle during an OR-OSHA training session. The message: If you can get rid of the hazard, you don't have to manage exposure.

The Five Workplace Hazard Categories

Look for hazards in each of these five categories.
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Look for hazards in each of these five categories. To help identify workplace hazards it's useful to categorize them into an easy-to-remember acronym: "MEEPS".

• The first three categories, Materials, Equipment and Environment, represent hazardous physical conditions that, according to according to SAIF Corporation, account for about 3% of all workplace accidents.
• The fourth category, People, describes behaviors in the workplace which may contribute up to 95% of all workplace accidents.
• The fifth hazard category, Systems, includes all elements of the safety management system. System hazards may contribute to both the hazardous conditions and unsafe behaviors, and therefore, may be ultimately responsible for up to 98% of all accidents in the workplace.

Let's take a closer look at each of the five hazard categories:

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 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.

The Five Workplace Hazard Categories (Continued)

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, to 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 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.

Identification & Control Strategies

Conduct safety inspections to identify hazards.
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To identify and control hazards in the workplace, two basic strategies are used: the walk-around safety inspection and the job hazard analysis (JHA). The most common strategy is the walk-around inspection, and we'll cover that strategy first. Here are some important points to remember about safety inspections:

• 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

Always use checklists in your safety inspections.
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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.
• 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 as a reference. (Source: OSHA)

The Safety Inspection's Flaw

By its very nature, the walk-around inspection, as a process, suffers from a very serious flaw. It is ineffective in uncovering unsafe behaviors 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, and possibly ask a few questions, and move on to the next work area. In fact, the safety inspection may be effective in uncovering only a small percentage of the causes for workplace accidents because the process only looks for conditions. Think about it: 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.

The Job Hazard Analysis (JHA)

The Job Hazard Analysis (JHA) can answer weaknesses of the walk-around inspection process. It uncovers unsafe work practices as well as hazardous conditions because sufficient time is given to close analysis of one unique task at a time. A typical JHA uses the following steps:

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

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

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

4. 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.

5. Finally, 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

Involve employees in your safety inspections.
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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.

Always look for root causes for hazards and exposure.
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Dig Up The Roots!

When analyzing hazards discovered in a walk-around inspection or JHA, it's important to dig up the root causes that have allowed those hazards to exist in the workplace. Taking this approach is called root cause analysis. It's important to conduct root cause analysis to eliminate the ultimate causes for accidents in the workplace: system weaknesses.

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

Direct Cause of Injury. The flower represents the actual accident resulting in an injury. The injury is the result of the transfer of an excessive amount of harmful energy from an outside source to the body. This is called the direct cause of the injury. For example, the direct cause of a broken arm would be the excessive kinetic energy transferred when the arm strikes the floor.

Surface Causes. The leaves of the weed represent the surface causes for accidents. They are the unique hazardous conditions and individual unsafe or inappropriate behaviors. When an unsafe or inappropriate behavior exposes an employee to a hazardous condition, an accident may occur. We place surface causes into two categories: primary and secondary.

• Primary surface causes are the immediate unique conditions or individual behaviors that cause accidents.
• Secondary surface causes are the conditions and behaviors that indirectly contribute to the accident.

Root Causes. The roots of the weed represent the pre-existing root causes of accidents. Root causes may feed and nurture hazardous conditions and unsafe work practices. We place root causes into two categories: performance and design.

• Performance root causes are those behaviors and actions that managers and supervisors engage in that somehow contribute to accidents. Performance root causes are influenced by deeper root causes. For example, a performance root cause might be a situation in which the employer fails to conduct safety inspections.
• Design root causes are those SMS policies, programs, plans, processes, and procedures that are missing or inadequately designed.

Unique hazardous conditions represent only a small percentage of the causes for accidents in the workplace. On the other hand, individual unsafe behaviors cause many more accidents. Ultimately though, virtually all workplace accidents (except for "acts of God") are caused by system root causes, under the control of management, that result in unique hazardous conditions and/or unsafe work practices.

There's no fall protection here.

The Missing Guardrail

You are conducting a walk-around safety inspection when you notice the guardrail along an elevated platform area is missing. As you now understand, the missing guardrail represents a hazardous condition and would be considered a surface cause if an accident occurred. But it is actually a symptom of deeper root causes or system weaknesses.

To best make sure the guardrail gets replaced, and remains in place, you must always consider and correct the root causes/system weaknesses that allowed the hazardous condition in the first place. So, what were the system weaknesses in this example? Here are some questions you might ask to dig up the root causes for the missing guardrail:

• Are corrective and preventive maintenance programs in place?
• Are employees reporting hazards?
• Does safety training cover the guardrail requirements?
• Is an incentive program in place to motivate employees to report hazards?

Well, there it is: a few basic hazard identification, investigation and control concepts that will help you keep your workplace safe and healthful for all employees. If you develop effective inspection and JHA procedures, and always go after the root causes of the hazards you find in the workplace, you will be successful in proactive accident prevention. But don't rush off....it's time for a checkup!

Video

On February 7, 2008, fourteen workers were fatally burned in a series of sugar dust explosions at the Imperial Sugar plant near Savannah, Georgia. This CSB safety video explains how the accident occurred.

Instructions

Before beginning this quiz, we highly recommend you review the module material. This quiz is designed to allow you to self-check your comprehension of the module content, but only focuses on key concepts and ideas.

Read each question carefully. Select the best answer, even if more than one answer seems possible. When done, click on the "Get Quiz Answers" button. If you do not answer all the questions, you will receive an error message.

Good luck!