Understanding the fall hazards in your workplace is fundamental in determining your fall protection requirements. A Hazard Assessment through worksite analysis is one of the crucial steps towards reducing job-related accidents and injuries.
Occupational Safety and Health Administration (OSHA) is proposing a requirement for employers to develop a basic Health & Safety Program to improve worker protection. Employers must ensure that their program contains four basic elements:
- Management Leadership and Employee Involvement
- Worksite Analysis
- Hazard Prevention and Control
The Worksite Analysis section from OSHA's sample program is outlined below. This sample program follows OSHA's "Safety and Health Program Management Guidelines", as published on January 26, 1989 in the Federal Register. These guidelines were drawn from many resources, the experience obtained enforcing the OSHA Act, the Voluntary Protection Programs (VPP), OSHA’s programs to recognize excellence in worksite safety and health, OSHA’s Consultation Program and public commentary. This sample program is especially written for the small, independent business owner, but the outline can be applied to any size business.
Under each element are numerous sub-elements. This program contains descriptions of how the program elements and sub-elements are designed and implemented. Specific documents resulting from program implementation will need to be kept in an organized fashion.
WORKSITE GOODFELLOW SAFETY AND HEALTH PROGRAM
Management hires outside consultants as necessary to conduct baseline surveys that identify all safety and health hazards at the site at the time of the survey. All hazards found during these surveys are eliminated whenever possible or controlled. All employees who may encounter the controlled hazards are trained in appropriate job procedures to follow to protect themselves from these hazards.
Management establishes change procedures to follow whenever the site experiences changes in equipment, material, or processes. To ensure employee protection, these change procedures include consideration of safety and health in the selection of the change, equipment and process shut down procedures, start up procedures, and phase hazard analysis. Appropriate employees are trained to follow these procedures.
Management and employees work together to analyze safety and health hazards inherent in each job site and to find means to eliminate those hazards whenever possible, and otherwise to protect persons against those hazards. These job hazard analyses (JHAs) are revised as appropriate, for example, following a change in the job, the reappearance of a hazard, or an accident at this job.
All employees at this site are trained to recognize hazards and to report any hazard they find to the appropriate person so that the hazard can be corrected as soon as possible. In addition to taking immediate action to report a hazard orally and to provide interim protection, if necessary, including stopping the work causing the hazard, employees may submit a safety work order to the maintenance department, or they may submit a safety suggestion form. Safety work orders take priority over any other work order. Safety suggestions will be considered each week during the site inspection by the site inspection team. All employee reports of hazards must be eventually written, with the correction date recorded. These reports are posted in the lunch room until the hazard is corrected and then are kept on file in the owner's office for three years. During that time they are available for employee review.
Site management, with input from an hourly employee chosen by lot, organizes the monthly site inspection team. Membership on these teams rotates each month with the goal that all site employees serve one month each year. Teams consist of four people, two managers or supervisors, and two hourly employees. Each week, at the beginning of work on Wednesday morning, the team inspects the entire worksite, in writing describing all hazards found, including their location. The team assigns appropriate persons responsible for seeing that the hazard is corrected and documenting the date of the correction. These inspection reports are posted in the lunch room, in the maintenance shop, and in the owner's office. A hazard remains on the monthly report until it is corrected.
Any near miss, first aid incident, or accident is investigated by the trained team selected each year by the owner and an hourly employee. The team consists of two managers or supervisors and two hourly employees, each of whom has received training in accident investigation. All investigations have as a goal the identification of the root cause of the accident, rather than assigning blame. All accident reports are posted in the lunch room and are open to comment by any employee. The accident investigation team assigns responsibility to appropriate employees for correcting any hazards found and for assigning a date by which the correction must be completed.
As part of the annual safety and health program evaluation, the site owner, a manager, and an hourly employee review all near misses, first aid incidents, and entries on the OSHA 200 Log, as well as employee reports of hazards, to determine if any pattern exists that can be addressed. The results of this analysis are considered in setting the goal, objectives, and action plans for the next year.
Suggested documents to implement this element:
- Results of baseline safety and health surveys, with notation of hazard correction
- Forms used for change analysis, including safety and health considerations in the purchase of new equipment, chemical, or materials
- Job Hazard Assessments (JHAs)
- Employee reports of hazards
- Site safety and health inspection results, with hazard corrections noted
- Accident investigation reports, with hazard corrections noted
- Trend analyses results