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.
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.
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 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:
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.
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".
Let's take a closer look at each of the five hazard categories:
Hazardous materials include hazardous:
This area includes machinery and tools used to produce or process goods. These examples all represent hazardous conditions in the workplace.
To remember the five hazard areas, just remember the acronym:
MEEPS = Materials, Equipment, Environment, People, and System.
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.
Use the following steps if you are asked to write questions for a safety inspection.
You may use this Self-inspection Checklist as a reference. (Source: OSHA)
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) 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:
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.
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.
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.
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.
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.
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.
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:
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!
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.
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