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Course 716 - Safety Management System Evaluation

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Introduction

_____11. Feasible engineering controls are in place.

Discussion

  • An engineering control is any change in facilities, equipment, tools, or process that eliminates or reduces a hazard. Such changes are usually physical changes involving some level of planning or design.
  • Under OSHA‘s current "Hierarchy of Controls" policy, a feasible engineering control must be implemented even if the method does not completely control the hazard. Interim measures are required until engineering controls are in place.
  • To achieve a rating of "3" on this element your must have no outstanding hazards requiring control by engineering methods.

_____12. Effective safety and health rules and work practices are in place.

Discussion

  • Workplace rules apply to general areas of conduct (e.g. "No horseplay" and "No smoking in this area.") Safe work practices apply to specific operations or tasks (e.g. "Hearing protection required while operating this equipment.")
  • To be effective, workplace rules and work practices (1) must exist, (2) must be correct and sufficient, (3) must be communicated, and (4) must be followed. evaluators may determine that improvement is needed for any or all of these requirements.
  • Formal communications should be written and include employee manuals, operating manuals, plans, posters, postings on bulletin boards, and work aids. Informal communications are usually verbal and include training, supervisory instructions, and peer influence. Communication is best when formal and informal methods are used in conjunction.

_____13. Applicable OSHA-mandated programs are effectively in place.

Discussion

  • A "mandated program" is required by rule, that are directed toward a specific safety and/or health objective. Examples of mandated programs are Hazard Communication, Hearing Conservation, Lock-Out/Tag-Out, and Confined Space Entry. Mandatory programs do not give employees options. They must comply.
  • Evaluation of this element is a 2-step procedure. First, determine the mandated programs that are applicable to your organization. Next, determine if the applicable programs have been fully and effectively implemented by your organization.

_____14. Personal protective equipment is effectively used.

Discussion

  • Personal protective equipment (PPE) may be used as an interim measure or as the last line of defense against a hazard. To be effective, however, PPE must be appropriate, available, carefully maintained, and properly used. There are management issues with each of these criteria that should be addressed in assessing this element.
  • Personal protective equipment assessment documentation and personal protective equipment training for affected employees are positive cues for this item.

_____15. Housekeeping is properly maintained.

Discussion

  • Overall housekeeping can be an indicator of effective safety and health systems because many of your organizational factors that determine good housekeeping are similar to the factors that result in safety and health performance.
  • Focus on evaluating those aspects of housekeeping that have direct bearing on safety and health. Examples include aisles marked and free of tripping hazards, clear emergency exits, flammables and combustibles stored away from sources of ignition, incompatible chemicals not stored together, prompt cleaning of spills, clean restrooms, and effective waste management.

_____16. The organization is properly prepared for emergency situations.

Discussion

  • Organizations should be prepared for any emergency situation that can be reasonably anticipated. Emergency situations include fire, natural disasters known to the area, catastrophic failures in the company or neighboring facilities, workplace violence, and perhaps, terrorist acts.
  • Assessment of this element is a 3-step procedure. First, determine the types of emergency situations for which preparation is indicated. At a minimum, each organization should be prepared for fires and relevant natural disasters. Second, determine if your organization has engaged in planning and developed adequate emergency procedures to address the areas of concern. These emergency procedures, which are normally written and posted, serve as the primary information source in the second step. Third, determine your organization‘s state of readiness to carry out the adopted procedures. Evidence of successful periodic drills is the best indicator of readiness.

_____17. The organization has an effective plan for providing competent emergency medical care to employees and others present at the site.

Discussion

  • Make sure you have procedures specifying when and how to summon ambulance or paramedic services. Procedures should be written, posted, and familiar to employees, especially supervisors.
  • When the response time for emergency medical services is not sufficient to meet the needs of an organization, onsite interim response capability is required. In the absence of a plant nurse, have interim first aid and CPR provided by onsite individuals holding current certifications. First aid kits and related equipment should be stocked to meet the particular anticipated needs of your organization.
  • If your organization has operations that pose serious danger to emergency medical responders, make sure they have been duly notified of the potential danger and the precautions needed to conduct a safe response.

_____18. Effective preventive maintenance is performed.

Discussion

  • Preventive maintenance refers to scheduled maintenance. The schedule is normally based on recommendations of the equipment manufacturer. There should be a log indicating if maintenance was performed according to schedule.
  • Predictive maintenance is based on periodic testing, such as vibration analysis. In this approach, maintenance actions are undertaken only when test results indicate a need. Records will normally be available to document that an organization has implemented a predictive maintenance approach. Another approach is the plant shutdown for overhaul of major equipment or processes. The practice of plant shutdown can be easily determined by interview.
  • Typically, organizations employ a variety of preventive and non-preventive maintenance methods as determined by technological and economic considerations. And preventive maintenance is not necessary for all equipment and facility components in order to have a safe and healthful workplace. Therefore, in assessing this element, the evaluator should focus on:
    • past accidents and incidents in which maintenance deficiencies were contributing factors,
    • identified hazards involving maintenance problems,
    • potential equipment failures with foreseeable safety and health consequences, and
    • high-risk emergency repair scenarios.
  • Particular attention should be devoted to the maintenance of engineered hazard controls and emergency equipment.

_____19. An effective procedure for tracking hazard corrections is in place.

Discussion

  • Make sure you have a written method to document the progress and status of hazard correction. The degree of sophistication in the tracking method will decrease with company size. You should have a system that requires line employees/supervisors to initiate hazard correction. The safety committee can track and record hazard correction with progress reported in the minutes. In small organizations, the owner/operator should track hazard corrections the same way other important business tasks are tracked.
  • If there has been a prior consultative visit to your organization and hazards were identified, the employer‘s adherence to established correction due dates suggests that an effective tracking system is in place.
  • Items identified multiple times in safety committee minutes, self inspection reports, employee hazard reports, etc. indicate potential problems with tracking systems.