It is important to develop a program that will meet the needs of both management and employees. An elegant safety and health program manual that describes protective measures that are seldom put into practice serves no useful function. This is why MOSH encourages management to involve employee representatives in the development of the safety and health program and to encourage their continued participation in company safety and health efforts.
In an effective safety and health program, the person responsible for the safety and health program will have both the authority to do the job and the respect of management and employees. The choice of the safety and health director must be based on his or her knowledge of the facility and of safety and health requirements. The person or persons designated to do training must be credible, respected, and knowledgeable about the operations and must be given the time, authority and resources to develop an effective program.
It is important to become familiar with the safety and health requirements associated with the company’s physical location, operations, and equipment. This information will be used to:
Resources that will aid in the determination of your workplace safety and health requirements include:
MOSH laws, regulations, and standards. Determine which requirements apply to the specific workplace. It is not necessary to become familiar with every law, regulation, and standard that MOSH enforces, because not all standards apply to every industry.
Equipment manuals. Make a list of all the equipment used in workplace operations and obtain the manufacturer's operating manuals for each piece of equipment. Examine the manuals for:
Other sources of information about equipment hazards include the National Electrical Code (NEC), the American National Standards Institute (ANSI) codes for various industries and equipment, and publications by the American Conference of Governmental Industrial Hygienists (ACGIH).
Chemical Inventory. Develop an inventory of chemicals used in the workplace. include:
Knowledge of the chemicals used or stored in a company facility is necessary for hazard assessment and program planning. It should be initiated as part of assessment activities. Much of this information also is required by the Maryland Access to Information about Hazardous and Toxic Substances Act, also known as the "Right to Know Law".
Employee capabilities: Make a list of all employees. Include each employee's date of hire, job title, experience and training, special skills (first aid trained, CPR trained, training abilities, etc.) and special needs (people who have physical disabilities, people who have visual impairments, etc.). This list can be used to involve employees in the program, to use their capabilities and talents most effectively, and to provide appropriate protection where special needs require it.
Accident and injury/illness history: MOSH law requires most employers to maintain records of occupational accidents, injuries, illness, and lost workdays on a OSHA/MOSH log (OSHA Form No. 200). Review these records to determine if there is a concentration of injuries or illnesses related to a particular department, operation, piece of equipment, process, or area. Also determine if there is a consistency or pattern in the type of injury, illness, or personnel involved. This information may point to specific safety and health issues that should be addressed.
Existing safety and health materials: Review any existing company safety and health materials and determine their usefulness.
An effective safety and health program will systematically identify and prevent hazards. An ineffective or non-existent program will not identify hazards or potential hazards, and preventive controls will not be implemented, leaving the possibility of injury or illness.
Develop an initial plan for assessing the workplace that addresses:
Conduct a safety and health self-inspection/survey of the workplace according to the plan developed above.
A comprehensive baseline survey of the work and working conditions at a site permits a systematic record of the hazards and potential hazards that can be recognized without intensive analysis. During the initial comprehensive survey:
Identify any situations that present hazards or are in violation of law, regulations or standards.
Pay particular attention to areas which prior research indicated were potential problems, and determine if a problem exists.
Assess the effectiveness of the survey plan, and revise, if necessary.
Although the person assigned responsibility for the safety and health program may have extensive knowledge of the facility's operations, additional knowledge is required to perform an effective safety and health survey. The initial research performed as part of Step 3 will assist in developing this expertise. The employer also may wish to solicit assistance for the initial survey from MOSH, an insurance carrier, or a private consultant.
There are many approaches to workplace assessments. Factors influencing the most effective approach include:
Effective strategies for an initial workplace survey include:
Floor Plans: Prepare a floor plan of each department or work area. Mark on the plan all pertinent machinery, processes, and facilities. Also note the standards or requirements applicable to the machinery or process which must be assessed; for example, guarding of machinery, noise level checks, housekeeping, and chemical exposure levels. As you proceed through the initial assessment, make additional notes on hazards observed, training needed, and monitoring required.
Checklists: Many employers use checklists that summarize the items to be included as part of a facility survey. The checklists should be site specific and should include each item to be checked in every area of the workplace. Generic checklists available from various trade associations can be used as a basis for the company checklist. It also may be necessary to revise the checklist as the initial hazard assessment is conducted.
Process Flow: The simplest method of proceeding with the hazard assessment may be to follow each process from receiving area to shipping. This approach is effective when the company's processes are fairly consistent and simple. It can be coupled with the floor plan system or the checklist system.
Job Hazard Analysis: This method examines each job classification, rather than areas or processes, for associated hazards. As a job classification is examined, associated machinery, equipment, and chemical and other processes are reviewed.
Committee Survey: Frequently in large establishments, a safety committee will conduct hazard assessment surveys. This approach permits several people with diverse interests, perspectives and expertise to provide input. The committee may consist of employee representatives, management representatives, and persons knowledgeable in production, processes or machinery.
As the hazard survey proceeds, note areas where additional investigation and expert consultation may be necessary. For example, monitoring levels of airborne chemical substances or noise, or additional research on equipment or chemical substances, may be required. Also note conditions that might be alleviated through employee training and education. Remember to pay particular attention to those areas identified in Step 3 as having significant incident occurrences. Also note areas where required personal protective equipment (PPE) is lacking.
This initial survey may take several sessions, and repeated visits to certain areas may be required. Take the time to be thorough. Following the survey, review your results. Start planning for future action.
During periodic inspections, identify new or previously missed hazards and failures in hazard control. Question whether the changes made to eliminate the original hazard may have created new hazards. When initially identified hazards are under control, attention can be given to the intensive analysis required to recognize less obvious hazards. Subsequent comprehensive surveys provide an opportunity to step back from the routine check on control of previously recognized hazards and look for new hazards.
Hazards, once recognized, should be promptly abated or controlled.
Hazard abatement is an essential activity. Management action at this point will determine the credibility of the company’s safety and health policy, as well as the usefulness and effectiveness of the entire workplace safety and health program.
All available resources should be devoted to this objective. Keep in mind that recognized hazards might constitute violations of MOSH laws, regulations, and standards. Should an enforcement inspection occur, the company could be cited and monetary penalties issued. More importantly, these conditions present hazards to employees that could result in injury, illness, property or production loss, or even loss of life.
Financial resources may be required to correct some hazards. This is a part of doing business in a safe and healthful manner. Court decisions have emphasized that economic feasibility is not a valid excuse for violating an adopted standard.
Every reasonable effort must be made to provide adequate funding to protect the workplace safety and health of employees. It may be necessary to prepare documentation to justify expenses associated with hazard abatement. In addition, long term planning and expert advice may be required. Costs can be minimized with proper planning and research. Remember that financial commitment to safety and health is a strong indicator of management's overall commitment.
Employee involvement can help. When there are alternative ways to address a hazard, effective managers have found that involving employees in discussions of methods can identify useful prevention and control measures, serve as a means for communicating the rationale for decisions made, and encourage employee acceptance of the decisions.
Correction of some hazards may take a long time. To eliminate hazards, workstations, work methods and tools may have to be designed or modified. Research into substitute materials may be necessary. New equipment may have to be purchased or existing equipment may have to be repaired or redesigned.
Interim measures may be necessary. For those items that cannot be corrected immediately, an effective program provides interim measures for the protection of the employees. These can vary greatly, but should include advising employees of the existing hazards and how to minimize the danger while corrective measures are being taken.
Interim measures may include requiring the use of personal protective equipment, installing temporary guarding, posting signs to remind employees of particular hazards, and taking certain pieces of equipment out of service. Remember, if personal protective equipment is issued, training must be provided to assure effective usage. The employer must also take steps to maintain the equipment in sanitary and operational condition.
Address other program elements while completing hazard abatement. Other safety and health program elements are integral to correction of hazards. As hazard correction progresses, an effectively managed program will continue to work on:
Safety work rules
Training programs for employees
Medical surveillance programs
For example, an employer may initiate the training that is part of the five essential elements of a safety and health program. This training also may be a required step for correction of a violation of MOSH requirements, such as the training required under the Maryland Access to Information About Hazardous and Toxic Substances law.
Once recognized hazards are corrected, take steps to ensure that the workplace remains hazard-free.
Work rules and emergency procedures. Work rules, practices, and emergency procedures must be specific to each workplace. For some locations it may be appropriate to have generalized rules and procedures. For other locations, very detailed procedures may be necessary. The formality and complexity of work rules and emergency procedures are influenced by a number of factors including:
Whether the workplace is fixed, mobile, dispersed or a combination
Rules and procedures should be clearly stated and understandable. Although it is not always required that work rules and emergency procedures be in writing, it is recommended. The written material provides an historical record that can be reviewed and revised periodically, and also can serve as documentation of site specific requirements.
Additionally, a number of MOSH standards require work rules, work practices, and emergency procedures. For example, almost all workplaces must have provisions for emergencies, basic first aid, and a plan to address fire hazards.
If administrative controls are used to reduce employee exposures, it is important to formalize the system and document the procedures. For example, administrative controls may involve rotating employees or altering work hours to reduce exposure to acceptable levels.
This is also an appropriate time to review operations that occur infrequently. It is particularly important to develop written procedures for these operations since the procedures are not often used and may be forgotten.
Enforcement. Once the procedures are established, it is important to develop a means for enforcing them. Enforcement is particularly important initially, when management will experience the most resistance to the changes the rules and procedures will require. Rules without enforcement frequently are violated.
Workplace discipline reinforces a safety and health program in two ways. It removes the employee and his or her coworkers from the danger of the unsafe work practice, and it reinforces the message to all employees that management is committed to safety and health.
It is important to work with employee representatives to develop enforcement procedures. It may be worthwhile to involve employees in the development of both the rules and enforcement measures through safety committees.
Equipment maintenance and status checks. Equipment maintenance and status check programs should be considered at this time. Maintenance of equipment and facilities is an especially important means of anticipating potential hazards and preventing their development. Planning, scheduling, and tracking preventive maintenance activities provides a systematic way of ensuring that equipment and facilities are not neglected. It may also prolong the usefulness of expensive equipment.
Most employers must provide some training for employees. For example, MOSH standards require that most employers provide training concerning:
An employer also must inform and train employees about the company safety and health program, how it is intended to benefit employees, and what is expected of employees in order to make the program work.
OSHA publication. Training Requirements in OSHA Standards and Training Guidelines (OSHA publication 2254) lists OSHA standards that require employee training. MOSH also has adopted several State-specific standards that may require training for employees. Additionally, new standards adopted by OSHA and MOSH may affect your workplace and require additional training.
Requirements are results-oriented. Although many standards require that particular topics be covered during training, the approach to providing the training is left to the employer. Generally, MOSH expects training to result in the employee being able to explain how to perform his or her assignments safely, and to be able to identify the hazards associated with the job.
An employer should ensure that all employees understand the hazards to which they may be exposed and how to prevent harm to themselves and others from exposure to these hazards. A thorough understanding of the hazards and their prevention will affect employee acceptance and use of established safety and health protections. Training for this purpose is reinforced by encouraging attempts to work safely and by positive recognition of safe behavior.
Ensure that training is conducted by someone knowledgeable about the subject and familiar with the workplace.
Consider employees’ ability to read, speak, and understand English.
Schedule short training sessions. It is better to divide training into several sessions rather than to conduct one long session.
Use audio-visual presentations, actual experiences, and workplace conditions to illustrate points.
Incorporate drills, demonstrations and hands-on practice to ensure that training is understood. Drills should include emergency action drills.
Provide a period for questions.
Verify the effectiveness of training through paper and pencil tests, oral questioning, employee skill demonstrations, and observation of employee work habits after training.
Retraining required. Employee training is a long-term commitment and must be repeated periodically. Re-training should be scheduled on an annual basis. Additional training should be provided when employee actions indicate a need for earlier or more frequent retraining.
New employees. New employees need training prior to starting work that would expose them to hazards. Transfer employees will also require training whenever they are exposed to new hazards. This need is reflected by the disproportionately high injury rates among workers newly assigned to work tasks. Although some of these injuries may be attributable to other causes, a substantial number are directly related to inadequate knowledge of job hazards and safe work practices.
At this point, much of what an employer must do to implement an effective program has been accomplished. The employer can now attend to program maintenance: coordination of the program, documentation of program details, addition of new work practices and hazard controls, and continuation of enforcement. Each of these components may vary in detail and formality, depending on the size and complexity of the workplace. Many of these items may have been completed during development of other steps of the program.
Documentation: An important part of any safety and health program, documentation provides:
An historical reference that can be reviewed to determine program effectiveness
An accessible document to which management and employees can refer when unsure of proper procedures
Evidence of the employer's efforts to provide a safe and healthful work environment
All employers must maintain:
Many MOSH standards require some form of documentation for sampling results, medical surveillance, equipment inspection, personal protective equipment programs, and other activities.
Employers also must maintain documentation if required by applicable standards for the following procedures:
It is strongly recommended that the employer provide some level of documentation for the following:
Refer to the applicable standard to determine what the documentation must include, who must have access to the documentation, and how long the records must be maintained.
MOSH can help. Development of an occupational safety and health program may not be an easy task, but the benefits far outweigh the effort. Identifying potential hazards may be one of the most difficult tasks in the process. MOSH can serve as a resource in obtaining information and acquiring answers to compliance questions. MOSH has a free consultation program to assist small businesses with on-site problems. All of the MOSH professional staff stands ready to assist you with your questions.
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