New Safety and Health Guidelines published

OSHA Published new guidelines for Safety & Health Management

"New guidelines provided on best practices in safety and health management for construction and general industry."

Really not any significant changes if you were paying attention to detail.  The older version published in 1989 covered the new elements, but they were part of the Four Main Elements.  Now they are broken out into 7 Main Elements to emphasize the importance.  Evaluation your programs was always implied in the older version, but now it is spelled out for you.

Need help setting up a safety and health management program?

Author: Deborah Grow, Safety Specialist

Private Safety Consultant, assistant Damon Fall Protection and Coordinator EHS Network ~ Kansas.   Extensive safety experience in General Industry, Construction, D.O.T. Compliance, and OSHA consultation project.  Contact Deborah if you would like to schedule a consultation

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Fall Hazards Assessment

The new walking-working surfaces standard was published in November 2016. It had several new requirements. One of which includes conducting a fall hazard assessment and regular inspections of walking-working surfaces. Another of which included training. Are you compliant?

 

Site Survey:

•A Site Survey can focus on one (1) specific area of concern or an entire facility. The Site Survey should include: –A review of the company's current safety program –Walk-through of the facility –Digital photographs and the collection of site-specific information

 

Hazard Analysis:

•The Hazard Analysis should verify that the current safety program and work practices comply with all OSHA, ANSI and other applicable regulations.

 

The Hazard Analysis includes:

•Any safety deficiencies or hazards identified should be detailed

•The necessary control measures and any recommended inspection procedures should be outlined 

 

Who Falls?

•53% of the falls occurred a distance of 10 feet or less.

•Most victims were not using fall protection.•More accidents occur in the morning than any other time of day.

•Falls are the leading causes of fatalities and catastrophes investigated by OSHA

 

Fall Protection Training has been mandatory for years.  Are you compliant?

Employers must provide a training program for each employee who may be exposed to fall hazards.

This training program must include:

• Employee training on the recognition of fall hazards and the procedures necessary to minimize fall hazards.
• A written certification record to document training including employee name, training date(s), and signature of the trainer. 
• Retraining for employees who do not have the understanding or skill to recognize fall hazards.
• Training must include: Where, when, how to use, Proper Anchorage and Tie-off Locations, How to determine free fall distance, How to determine total fall distance, and Environmental and workplace factors Inspection and Storage

OSHA Regulation 1926.503(a)(1)

"Training Program."

The employer shall provide a training program for each employee who might be exposed to fall hazards. The program shall enable each employee to recognize the hazards of falling and shall train each employee in the procedures to be followed in order to minimize these hazards.

The employer shall assure that each employee has been trained, as necessary, by a competent person qualified in the following areas:

• The nature of fall hazards in the work area;
• The correct procedures for erecting, maintaining, disassembling, and inspecting the fall protection systems to be used;
• The use and operation of guardrail systems, personal fall arrest systems, safety net systems, warning line systems, safety monitoring systems, controlled access zones, and other protection to be used;
• The role of each employee in the safety monitoring system when this system is used;
• The limitations on the use of mechanical equipment during the performance of roofing work on low-sloped roofs;
• The correct procedures for the handling and storage of equipment and materials and the erection of overhead protection; and
• The role of employees in fall protection plans;
• The standards contained in this subpart.

"Certification of training."

The employer shall verify compliance with paragraph (a) of this section by preparing a written certification record. The written certification record shall contain the name or other identity of the employee trained, the date(s) of the training, and the signature of the person who conducted the training or the signature of the employer. If the employer relies on training conducted by another employer or completed prior to the effective date of this section, the certification record shall indicate the date the employer determined the prior training was adequate rather than the date of actual training.

• The latest training certification shall be maintained.
• "Retraining." When the employer has reason to believe that any affected employee who has already been trained does not have the understanding and skill required by paragraph (a) of this section, the employer shall retrain each such employee. Circumstances where retraining is required include, but are not limited to, situations where:
• Changes in the workplace render previous training obsolete; or
• Changes in the types of fall protection systems or equipment to be used render previous training obsolete; or
• Inadequacies in an affected employee's knowledge or use of fall protection systems or equipment indicate that the employee has not retained the requisite understanding or skill.

 

 

 

 

Need help setting up a fall protection program?

Author: Deborah Grow, Safety Consultant

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Hazard Hunts

Hazards – Blog

I am often asked about some of the hazards I generally found during inspections. These are by far the most frequent hazard I found while conducting inspections.  Most of them are actually very simple to fix.

Description: A bench grinder in the maintenance shop was not safeguarding to OSHA’s minimum requirements.  OSHA requires the following items with respect to bench grinders:

•  Tool rests (work rests) shall be kept adjusted closely to the wheel with a maximum opening of 1/8” to prevent the work from being jammed between the wheel and the rest.
• Tongue guards shall be kept adjusted to within 1/4” of the outside of the grinding wheel to deflect fragments away from the operator should the wheel shatter.
• As the bench grinder is designed for a fixed location, it must be securely anchored to prevent walking or moving during operation. (1910.212b)
• Immediately before mounting, all abrasive wheels are to be closely inspected and sounded (ring tested) by the user to make sure they have not been damaged in transit, storage, or otherwise.

Condition:  Work rests. On offhand grinding machines, work rests shall be used to support the work. They shall be of rigid construction and designed to be adjustable to compensate for wheel wear. Work rests shall be kept adjusted closely to the wheel with a maximum opening of one-eighth inch to prevent the work from being jammed between the wheel and the rest, which may cause wheel breakage. The work rest shall be securely clamped after each adjustment. The adjustment shall not be made with the wheel in motion.  Exposure adjustment. Safety guards of the types described in Subparagraphs (3) and (4) of this paragraph, where the operator stands in front of the opening, shall be constructed so that the peripheral protecting member can be adjusted to the constantly decreasing diameter of the wheel. The maximum angular exposure above the horizontal plane of the wheel spindle as specified in paragraphs (b)(3) and (4) of this section shall never be exceeded, and the distance between the wheel periphery and the adjustable tongue or the end of the peripheral member at the top shall never exceed one-fourth inch. (See Figures O-18, O-19, O-20, O-21, O-22, and O-23.)  Inspection. Immediately before mounting, all wheels shall be closely inspected and sounded by the user (ring test) to make sure they have not been damaged in transit, storage, or otherwise. The spindle speed of the machine shall be checked before mounting of the wheel to be certain that it does not exceed the maximum operating speed marked on the wheel. Wheels should be tapped gently with a light nonmetallic implement, such as the handle of a screwdriver for light wheels, or a wooden mallet for heavier wheels. If they sound cracked (dead), they shall not be used. This is known as the "Ring Test".

Standard: 1910.215(a)(4), 1910.215(b)(9), 1910.215(d)(1)

Potential Effects: Cuts to fingers and penetration injuries from contact with or disintegration of the grinding wheel.

Recommended Action: Ensure the grinder is bolted to the bench and adjust the tongue guard and tool rest to the specifications listed above.  As the wheel is ground down, readjust the guards.  This adjustment should be checked routinely before energizing the wheel, as a standard safe operating procedure.  Ring test stones.

Procedures for ring test stone: To conduct the ring test on smaller wheels, they should be tapped lightly with a light nonmetallic implement, such as the handle of a screwdriver for light wheels, or a wooden mallet for heavier wheels. Tap wheels about 45 degrees each side of the vertical centerline and about one or two inches from the periphery.  Then rotate the wheel 45 degrees and repeat the test.  A sound and undamaged wheel will give a clear metallic tone.  If cracked, there will be a dead sound and not a clear "ring." If they sound cracked (dead) they must not be used. Wheels must be dry and free from sawdust when applying the ring test, otherwise the sound will be deadened.  It should also be noted that organic bond wheels do not emit the same clear metallic ring as do vitrified and silicate wheels.

Larger wheels may be tested by vibration to detect damage.  To perform the vibration test, an abrasive wheel is set on a test fixture in a horizontal position and coated with a thin layer of fine dry sand.  The wheel is vibrated gently.  As the wheel vibrates, the sand granules respond to the vibration.  The granules will move away from any cracks that may be in the wheel.  Conversely, the granules will be uniformly distributed over the surface of a sound and undamaged wheel.

Note that the spindle speed of the machine must be checked before mounting the wheel to be certain that it does not exceed the maximum operating speed marked on the wheel. 

Author:  Deborah Grow, Safety Specialist

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Safety & Health Management System is like a puzzle

Safety & Health Management System is like a puzzle

All the pieces must be put together for it to work

SH Mgt. System Elements

• Management Leadership and Employee Involvement
• Worksite Analysis
• Hazard Prevention and Control
• Safety and Health Training

SH Elements Interrelated

• All elements of a safety and health system are interrelated.
• All pieces are related to all other pieces.
•  A flaw in one piece will probably impact all the other pieces, and therefore the system as a whole.

The Bigger Picture of the Safety & Health Management System

Now let's talk about the safety and health management system and its components:

• A system is an established arrangement of components that work together to attain a certain objective, in this case to prevent injuries and illnesses in the workplace. 
• Within a system, all parts are interconnected and affect each other.

 Overview of System Components

• Management must provide the resources and authority so all personnel can find the hazards in the worksite and, once found, to eliminate or to control those hazards.
• Training is the backbone of this system. For management to lead, for personnel to analyze the worksite for hazards, and for hazards to be eliminated or controlled, everyone involved must be trained.
• No parts of this system exist independently. An effective and functioning program is the sum of all the parts.

 Worksite Analysis is Just ONE piece of the puzzle!

Worksite Analysis

• Worksite analysis involves a variety of worksite examinations to identify not only existing hazards, but also conditions and operations in which changes might create hazards.
• Effective management actively analyzes the work and the worksite, to anticipate and prevent harmful occurrences.

Comprehensive surveys

• For small businesses, OSHA-funded, state-run consultation services can conduct a comprehensive survey at no cost. Many workers’ compensation carriers and other insurance companies offer expert services to help their clients evaluate safety and health hazards. Numerous private consultants provide a variety of safety and health expert services. Larger businesses may find the needed expertise at the company or corporate level.
• For the industrial hygiene survey, at a minimum, all chemicals and hazardous materials in the plant should be inventoried, the hazard communication program should be reviewed, and air samples analyzed. For many industries, a survey of noise levels, a review of the respirator program, and a review of ergonomic risk factors are needed.

Here’s a suggested plan to identify all worksite hazards:

• Conduct a comprehensive, baseline survey for safety and health and periodic, comprehensive update surveys.
• Conduct periodic and daily safety and health inspections of the workplace.
• Perform routine job safety hazard analyses. (JSA or JHA)
• Change analysis of planned and new facilities, processes, materials, and equipment.

Conduct Self Assessments/Bench Marking

• In order to get where you want to go, it is essential to know where you are starting from.
• You can use a variety of self-audit mechanisms to compare your site processes with other recognized models of excellence such as SHARP sites or Star VPP sites.
• Visiting other sites to gain first hand information is also invaluable.
• You can use perception surveys to measure the strengths and weaknesses of your site safety culture.
• These surveys can give you data from various viewpoints within the organization. For instance, you can measure differences in employees' and managers' perceptions on various issues.
• This is an excellent way to determine whether alignment issues exist and, if so, what they are. One example is the Safety and Health Program Check Up.
• At this stage, it is important to look at issues that surface as symptoms of larger system failures. For example, ask what major system failed to detect the unguarded machine, or why the system failed to notice that incident investigations are not being performed on time, or if workers are being blamed for the failures. Your greatest level of success will come when these larger system failures are recognized and addressed.

Develop an Inspection Program

• To identify hazardous conditions and employee behavior and determine what actions are required to reduce or eliminate accident potential. 
• Additionally, inspections can help determine the extent to which employees adhere to the company's safety program, operating procedures, rules and regulations.
• Developing a self-inspection program and associated checklists can help to protect company assets from fire, employee injury and injury to the public.  
• Their development will require the attention of someone who has a sound knowledge of the company's operations and as well as knowledge of relevant safety standards and local codes.
• The self-inspection program should be a process of fact finding with an emphasis on identifying potential hazards and developing the necessary corrective actions necessary to eliminate them.
• Routine site safety and health inspections are designed to catch hazards missed at other stages. This type of inspection should be done at regular intervals, generally on a weekly basis. In addition, procedures should be established that provide a daily inspection of the work area

You can use a checklist already developed or make your own, based on:
~ Past problems.
~ Standards that apply to your industry.
~ Input from everyone involved.
~ Your company's safety practices or rules.

Important things to remember about inspections are:
~ Inspections should cover every part of the worksite.
~ They should be done at regular intervals.
~ In-house inspectors should be trained to recognize and control hazards.
~ Identified hazards should be tracked to correction.
~ Information from inspections should be used to improve the hazard prevention and control program.

Perform routine job safety hazard analyses (JSA, JHA, or JSHA)

• Hazard analysis techniques can be quite complex. While this is necessary in some cases, frequently a basic, step-by-step review of the operation is sufficient. One of the most commonly used techniques is the Job Hazard Analysis (JHA). Jobs that were initially designed with safety in mind may now include hazards or improper operations. When done for every job, this analysis periodically puts processes back on the safety track.
• Other, more sophisticated techniques are called for when there are complex risks involved. These techniques include: WHAT-IF Checklist, Hazard, Failure Mode and Effect Analysis, and Fault Tree Analysis. 

 Change Analysis

• Anytime something new is brought into the workplace, whether it be a piece of equipment, different materials, a new process, or an entirely new building, new hazards may unintentionally be introduced. Before considering a change for a worksite, it should be analyzed thoroughly beforehand. Change analysis helps in heading off a problem before it develops.

You may find change analysis useful when:
~  Building or leasing a new facility.
~  Installing new equipment.
~  Using new materials.
~ Starting up new processes.
~  Staffing changes occur.

Author: Deborah Grow, Safety Specialist

Private Safety Consultant, assistant Damon Fall Protection and Coordinator EHS Network ~ Kansas.  Extensive safety experience in General Industry, Construction, D.O.T. Compliance, and OSHA consultation project.  Contact Deborah if you would like to schedule a consultation

Follow me on:  Google-plus     Facebook     Twitter      ChekSafety

 

Information in this post was taken from OSHA's Safety & Health Management e-tools

For more information visit OSHA's e-tools

https://www.osha.gov/SLTC/etools/safetyhealth/mod2_sample_sh_program.html

https://www.osha.gov/SLTC/etools/safetyhealth/comp2.html