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Course 716 - Safety Management System Evaluation

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Introduction

Modules 6-12 will discuss the seven general categories within the Worksheet. Be sure you have downloaded and printed the attributes for each of the 58 elements so that you can refer to them throughout the rest of the course.

This first category analyzes and evaluates to determine the degree to which the SHMS is designed and able to anticipate potential hazards and detect actual hazards in the workplace. Performance in this area will generally not be considered effective unless hazardous conditions and unsafe behaviors are immediately corrected or appropriately scheduled for correction in your organization's action plan. Hazards identified in this category's elements may indicate deficiencies if the hazards could have been detected, and therefore corrected. With that in mind, let's get started.

_____1. A baseline hazard survey has been conducted within the last five years. (The survey should be documented in a written report as a requirement for a rating of "3" on this element.)

Discussion Points:

  • All major operations, especially high-risk operations, during all shifts should included in the baseline survey.
  • Be sure only qualified persons such as OSHA evaluators, private evaluators, insurance loss control specialists, or appropriately trained and experienced employees of your organization conduct the baseline hazard survey.
  • The 5-year time-frame, although a common planning horizon, is somewhat arbitrary. The OSHA evaluator may question the validity of your baseline hazard survey, even one conducted during the previous five years, if subsequent changes in your organization appear to nullify the survey's accuracy.

______2. Effective safety and health self-inspections are performed regularly.

Discussion Points:

  1. Formal inspections usually involve the use of checklists and include written reports. The written documents may be used to support a rating of "3" on this element if the they indicate inspections were thorough and conducted on a regular basis (daily, weekly, monthly, quarterly, etc.).
  2. The appropriate frequency of inspections depends on the nature of the factors covered by each inspection. The period of time between inspections may indicate the degree to which the employer tolerates safety and health system failures. A good general policy is to inspect your area of responsibility at the beginning and end of the shift. Bridge those inspections throughout the shift with observation.
  3. Self-inspections are ideally assigned to a number of employees. Workers should perform or participate in safety and health inspections of their own work areas or operations. Team efforts are highly desirable, especially for general inspections.

______3. Effective surveillance of established hazard controls is conducted.

Discussion Points:

  • Surveillance is constant or ongoing observation while inspections are intermittent. This means that surveillance normally provides a shorter time-tolerance for system failures than do inspections. On the other hand, inspections are usually more structured, systematic, and thorough than surveillance. Together these two complementary hazard detection techniques provide the best means to ensure early detection of existing hazards.
  • Whenever evaluators observe established controls (engineering controls, PPE, safety rules, safe work practices, etc.) are being violated, the desired effects are not occurring. Consequently, these violations indicates surveillance is missing or ineffective.
  • Employees, particularly supervisors, should be able to describe key safety and health controls associated with their work areas, operations, or job duties; how such controls are monitored; and what steps are taken when problems are detected. Make sure supervisors receive adequate training.

______4. An effective hazard reporting system exists.

Discussion Points:

  • The basic objective of a hazard reporting system is early detection and reporting of hazards effectively known to employees. A hazard is "effectively known" when the employee is both aware of the existence of the hazardous condition or activity and understands, at least generally, the possible harm it represents.
  • The design and performance of your organization's hazard reporting system is analyzed by interviewing managers, supervisors, workers.
  • The best hazard reporting systems have both centralized (formal) and decentralized (informal) features.
    • Centralized hazard reporting provides a common point for collection of hazard information. In addition to employee reports, the results of surveys, analyses, and formal inspections of the workplace are collected. In larger organizations, the safety director or safety committee usually collects such information. In very small organizations, the owner-manager or a designee is usually responsible.
    • Decentralized hazards reports are usually given directly to the supervisor for the affected work area, operation, or personnel. Workers should always have the option of reporting to your organizational level whenever they think correction of a directly reported hazard has been ineffective. Likewise, supervisors should always coordinate worker hazard reports when they are unable to take appropriate corrective action.
  • Be able to show that each individual who reports a hazard receives prompt feedback concerning when and how the hazard will be corrected.

______5. Change analysis is performed whenever a change in facilities, equipment, materials, or processes occurs.

Discussion

  • A safety change analysis program includes current and future planning activities involving the safety and health aspect of changes in facilities, equipment, materials, processes, or the environment.
  • The change analysis program should also include input line positions and from appropriate support staff (safety staff, the safety committee, etc.)
  • Change analysis is primarily a hazard anticipation function. An evaluator should also use Elements 11-19 to evaluate the degree to which your organization has successfully addressed correction of hazards or potential hazards it has identified by change analysis.

______6. Accidents are investigated for root causes.

Discussion

  • Be sure the accident investigation is conducted as a formal (written, structured) procedure, even if your organization is small. Establish policies to ensure that thorough and timely "root cause" accident investigations are designed, performed, and documented.
  • Your accident investigation plan should (1) require investigation of incidents as well as all injury accidents, (2) assign responsibilities for conducting investigations, preferably with line supervisors/managers, and (3) adopt a standard form for all accident investigations.
  • The objective of an accident investigation must not be to assign blame, but to identify root (SHMS)causes of the accident so that corrective actions and system improvements are completed. Considerable knowledge and skills is often required to uncover root causes of an accident. The root cause analysis phase of an accident investigation should be conducted by a qualified person such as the safety manager or safety committee.
  • Look at records and completed accident investigations to determine if root causes are being discovered and addressed by your organization. As a rule-of-thumb, any accident investigation that attributes a single cause for an accident has not adequately addressed root causes. Have root causes (system design and/or performance weaknesses) contributing to accidents been mitigated? If they have, root cause analysis is effective.

______7. Material Safety Data Sheets (MSDS) are used to reveal potential hazards associated with chemical products in the workplace.

Discussion Points:

  • The process of detecting workplace hazards associated with chemical products won't be effective until all MSDS's have been obtained and reviewed by your organization as required in the Hazcom standard.

______8. Effective job hazard analysis (JHA) is performed.

Discussion Points:

  • Informal examination of a job does not constitute job hazard analysis. Completed JHA worksheets must be available to document that your organization is performing JHA's. Review of the quality of safe job procedures developed with JHA's will reveal the effectiveness of the JHA process.
  • Make sure job hazard analysis is an ongoing effort in your organization. Jobs should be scheduled on a priority basis, with higher priority being assigned to jobs having the highest rates of accidents and disabling injuries, jobs where "close calls" have occurred, jobs where major changes have been made in processes and procedures, and jobs involving new workers.
  • Take OSHAcademy Course 706, Job Hazard Analysis for more information on this process.

______9. Expert hazard analysis is performed.

Discussion Points:

  • Expert hazard analysis include industrial hygiene (IH) testing, ergonomic evaluations, and other specialized safety and health services requested by employers. These services are provided by private consultants, insurers, and OSHA.
  • Evidence that an organization has engaged insurance loss control professionals, consulting engineers, private safety or health evaluators, medical personnel or other experts in specialized safety and health analyses of its workplace strongly supports this element. Caution: rejection of these services should be considered a negative indicator in evaluating this element.

______10. Incidents are investigated for root causes.

Discussion Points:

  • Be sure you maintain an accurate first aid log with root cause analysis performed for log entries. Incident logs, near miss logs, or other means of recording and analyzing incidents can also be effective.
  • To score "2" or "3" on this element, you must develop and require incident reporting procedures. This must be a no-fault reporting method integrated into the established hazard reporting system. The goal is a "fix-the-system" safety culture.
  • Evaluate the effectiveness of this element by reviewing records, root cause analysis reports, and employee interviews. Have root causes (system design and/or performance weaknesses) contributing to incidents been mitigated? If they have, root cause analysis is effective.