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Course 833 - Developing a Construction Safety Management System

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Plans and Programs

Develop the CSMS Components

Develop, Deploy, Design Image

Now that you have the basic design of the CSMS completed, it’s time to get down to the nitty-gritty by completing the “6-P’s”. Yes, another acronym! Using the 6-P development model, we can systematically complete the following components:

Plans, Programs, Policies, Processes, Procedures and Practices.

In most instances, a safety professional will be responsible to assist others, but it’s important to understand that development of the CSMS should not be a “one person show” – others, from top management, to employees should be involved in the development phase.

The outcome of the development phase is a formal comprehensive written CSMS Plan containing all components of the CSMS. This will serve as the primary document that everyone at all levels in the company will use to help them fulfill their own safety responsibilities.

The CSMS Written Plan

One of the most important end-results of the design and development phases when creating a CSMS is the written plan. This is the formal document that contains all of the important information needed to deploy the CSMS.

It’s important to note that you will not only write a plan for the overall CSMS, but you’ll need to write a plan for each of the various programs within the CSMS as well. OK, this might be a little confusing, and even the language can get you tied up, so let’s define a couple of terms:

The CSMS will also contain many “programs” and each program will require a more narrowly-focused “plan.
The CSMS will also contain many “programs” and each program will require a more narrowly-focused “plan”.

Plan vs. Program

One of the most important end-results of the design and development phases when creating a CSMS is the written plan. This is the formal document that contains all of the important information needed to deploy the CSMS.

Plans Within Plans

The CSMS will also contain many “programs” and each program will require a more narrowly-focused “plan”. When all of the program plans are combined, you have your CSMS “plan”. I hope that clears it up. I know I was confused about this for a couple of years. Both the CSMS and each program within the CSMS should contain at least the following sections:

  • vision and mission statements,
  • goals and objectives,
  • roles and responsibilities (R&R), and
  • programs, policies, processes, procedures, and practices

Last, but not least, a “formal” CSMS plan should be written, approved, and signed by top management. We’ll discuss each of these components of the written plan below.

CSMS Program

A safety “program” may be thought of as a plan of action to accomplish a safety objective. The safety program will give specific details on:

  • The task or work to be done. For example, a task described within the Fall Protection Program might be to conduct a routine inspection of fall protection equipment.
  • The person or group responsible. Usually this would be the person or group performing the hazardous procedure or work practice.
  • When the hazardous procedure or practice is to be done. For instance, a safety inspection program might specify that an inspection must be completed before and after each use of the fall protection equipment.
  • The means or resources used to accomplish the task or work. A worker might use a magnifying glass to look for tiny cracks in the fall protection metal parts or tears in the fabric.

An effective safety program is designed around the processes, procedures, and practices normally assigned to employees and integrates safety-related decisions and precautions into them.

Sample Program Responsibilities

Now let’s look at a few examples of OSHA-required responsibilities you will most likely need to include in your CSMS.

Hazard Identification Program

  • Evaluate operations, procedures, facilities, and equipment to identify hazards [29 CFR 1926.20(a), 29 CFR 1926.21(b)].
  • Monitor exposure levels [29 CFR 1926.55, 29 CFR 1926.62, 29 CFR 1926 Subpart Z, 29 CFR 1926.1101].
  • Ensure regular safety and health inspections [29 CFR 1926.20(b)(2), 29 CFR 1926.703(b), 29 CFR 1926.1081].
  • Conduct accident investigations [29 CFR 1904.4].
  • Determine if engineering or administrative controls or personnel protective equipment are to be used [29 CFR 1926.103, 29 CFR 1926.951].

Hazard Control Program

  • Ensure machines and tools are in safe working order and in compliance with relevant standards [29 CFR 1926.20(b)(3), 29 CFR 1926.550(a), 29 CFR 1926.951].
  • Institute engineering and work practice controls to eliminate health hazards [29 CFR 1926.55, 29 CFR 1926.103, 29 CFR 1926 Subpart Z].
  • Perform housekeeping to remove hazards posed by scrap and debris in work areas [29 CFR 1926.25, 29 CFR 1926.852, 29 CFR 1926.152(c)(5), 29 CFR 1926.900(k)(5)].
  • Provide appropriate personal protective equipment when other controls are infeasible [29 CFR 1926.28(a), 29 CFR 1926 Subpart E].
  • Guarantee safe means of egress [29 CFR 1926.34].

Sample Program Responsibilities (continued...)

Emergency Response Program

  • Develop emergency response plans [29 CFR 1926.35, 29 CFR 1926.65(q)].
  • Develop fire prevention and protection programs [29 CFR 1926.24, 29 CFR 1926.352, 29 CFR 1926 Subpart F].

First Aid and Medical Program

  • Provide medical services, first aid treatment, and supplies [29 CFR 1926.50(a), 29 CFR 1926.103, 29 CFR 1926.50(c), 29 CFR 1926.50(d), 29 CFR 1926 Subpart Z].
  • Ensure availability of emergency rescue for injured employees [29 CFR 1926.50(e), 29 CFR 1926.106(a), 29 CFR 1926.21(b)(6), 29 CFR 1926.802(b)].
  • Post emergency numbers for physicians, hospitals, or ambulances [29 CFR 1926.50(f)].

Training Program

  • Train employees to recognize hazards [29 CFR 1926.21(b)(2), 29 CFR 1926.65, 29 CFR 1926.302(e), 29 CFR 1926.1060].
  • Train workers to recognize and avoid unsafe conditions [29 CFR 1926.21(b)(2), 29 CFR 1926.65, 29 CFR 1926.454, 29 CFR 1926.901(c)].
  • Provide training on safe work practices and applicable standards [29 CFR 1926.21(b)].
  • Provide training on safe operation of equipment and machinery [29 CFR 1926.20(b)(4), 29 CFR 1926.302(e)].
  • Provide training on hazards of access ladders and stairways [29 CFR 1926.1060(a), 29 CFR 1926.454, 29 CFR 1926.800(b) and (c)].
  • Provide training on confined and enclosed space entry hazards and precautions [29 CFR 1926.21(b)(6), 29 CFR 1926.353(b), 29 CFR 1926.801].

Recordkeeping and Abatement Verification Program

  • Record injuries and fatalities [29 CFR 1904.5, 29 CFR 1904.8].
  • Maintain medical records [29 CFR 1926.33].
  • Maintain exposure records [29 CFR 1926.33].
  • Maintain appropriate documents and tags for abatement verification [29 CFR 1903.19].
OSHAchallenge

OSHA Challenge: Industrial Hygiene (IH) Program*

Stage 4: No action required for IH Program. (Establishment of a written program for some OSHA standards is required.)

Stage 5: Establish, document, & implement future sampling schedule, strategy, and rationale, e.g., develop a formal written IH program. Follow-up on results of baseline IH study. Conduct more in-depth analysis if warranted to determine actual employee exposures. Require subcontractors to participate in the company IH program where necessary. Follow-up on results of subcontractor baseline IH study, if applicable, and conduct more in-depth analysis, if warranted.

Stage 6: Continue implementing the written IH programs taking proactive steps to improve control of health hazards to prevent occupational disease.

* Note: The actions within the three stages will apply to any safety and health program you develop.

VIDEO

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!

1. What is one of the most important end-results of the development phases when creating a CSMS?

2. Which of the following may be thought of as a plan of action to accomplish a safety objective?

3. An effective safety program will give specific details on which of the following?

4. According to the text, a well-written corporate CSMS plan contains all of the important information needed to _____ the CSMS.

5. The "formal" CSMS plan should be written, approved, and signed by _____.


Have a safe day!

Important! You will receive an "error" message unless all questions are answered.