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TOPICS
  • OSHA
  • Hazard Identification
  • Implementation
  • Compliance
  • Required Certifications

oSHA

OSHA is committed to strong, fair, and effective enforcement of safety and health requirements in the workplace. OSHA inspectors, called compliance safety and health officers, are experienced, well-trained industrial hygienists and safety professionals whose goal is to assure compliance with OSHA requirements and help employers and workers reduce on-the-job hazards and prevent injuries, illnesses, and deaths in the workplace. Normally, OSHA conducts inspections without advance notice. Employers have the right to require compliance officers to obtain an inspection warrant before entering the worksite. “OSHA” Stands for the Occupational Safety and Health Administration of the United. States Department of Labor, formed by the Occupational Safety and Health Act of 1970. “CSHO” is an abbreviation for an OSHA Compliance Safety and Health Officer or. Compliance Officer.

Hazard Identification

Hazard Identification and Assessment

One of the “root causes” of workplace injuries, illnesses, and incidents is the failure to identify or recognize hazards that are present, or that could have been anticipated. A critical element of any effective safety and health program is a proactive, ongoing process to identify and assess such hazards.

To identify and assess hazards, employers and workers:

  • Collect and review information about the hazards present or likely to be present in the workplace.
  • Conduct initial and periodic workplace inspections of the workplace to identify new or recurring hazards.
  • Investigate injuries, illnesses, incidents, and close calls/near misses to determine the underlying hazards, their causes, and safety and health program shortcomings.
  • Group similar incidents and identify trends in injuries, illnesses, and hazards reported.
  • Consider hazards associated with emergency or nonroutine situations.
  • Determine the severity and likelihood of incidents that could result for each hazard identified, and use this information to prioritize corrective actions.

Some hazards, such as housekeeping and tripping hazards, can and should be fixed as they are found. Fixing hazards on the spot emphasizes the importance of safety and health and takes advantage of a safety leadership opportunity. To learn more about fixing other hazards identified using the processes described here, see “Hazard Prevention and Control.”

Action item 1: Collect existing information about workplace hazards

Action item 2: Inspect the workplace for safety hazards

Action item 3: Identify health hazards

Action item 4: Conduct incident investigations

Action item 5: Identify hazards associated with emergency and nonroutine situations

Action item 6: Characterize the nature of identified hazards, identify interim control measures, and prioritize the hazards for control

Implementation

Once a safety and health program is established, it should be evaluated initially to verify that it is being implemented as intended. After that, employers should periodically, and at least annually, step back and assess what is working and what is not, and whether the program is on track to achieve its goals. Whenever these assessments identify opportunities to improve the program, employers, managers, and supervisors—in coordination with workers—should make adjustments and monitor how well the program performs as a result. Sharing the results of monitoring and evaluation within the workplace, and celebrating successes, will help drive further improvement.

Program evaluation and improvement includes:

  • Establishing, reporting, and tracking goals and targets that indicate whether the program is making progress.
  • Evaluating the program initially and periodically thereafter to identify shortcomings and opportunities for improvement.
  • Providing ways for workers to participate in program evaluation and improvement.

Action item 1: Monitor performance and progress

Action item 2: Verify the program is implemented and is operating

Action item 3: Correct program shortcomings and identify opportunities to improve

Action item 1: Monitor performance and progress

The first step in monitoring is to define indicators that will help track performance and progress. Next, employers, managers, supervisors, and workers need to establish and follow procedures to collect, analyze, and review performance data.

Both lagging and leading indicators should be used. Lagging indicators generally track worker exposures and injuries that have already occurred. Leading indicators track how well various aspects of the program have been implemented and reflect steps taken to prevent injuries or illnesses before they occur.

How to accomplish it
  • Develop and track lagging indicators of progress toward established safety and health goals, such as:
    • Number and severity of injuries and illnesses
    • Results of worker exposure monitoring that show that exposures are hazardous
    • Workers’ compensation data, including claim counts, rates, and cost
  • Develop and track leading indicators, such as:
    • Level of worker participation in program activities
    • Number of employee safety suggestions
    • Number of hazards, near misses and first aid cases reported
    • Amount of time taken to respond to reports
    • Number and frequency of management walkthroughs
    • Number and severity of hazards identified during inspections
    • Number of workers who have completed required safety and health training
    • Timely completion of corrective actions after a workplace hazard is identified or an incident occurs
    • Timely completion of planned preventive maintenance activities
    • Worker opinions about program effectiveness obtained from a safety climate or safety opinion survey
  • Analyze performance indicators and evaluate progress over time.
  • Share results with workers and invite their input on how to further improve performance.
  • When opportunities arise, share your experience and compare your results to similar facilities within your organization, with other employers you know, or through business or trade associations.

Note: Indicators can be either quantitative or qualitative. Whenever possible, select indicators that are measurable (quantitative) and that will help you determine whether you have achieved your program goals. The number of reported hazards and near misses would be a quantitative indicator. A single worker expressing a favorable opinion about program participation would be a qualitative indicator.

Action item 2: Verify that the program is implemented and is operating

Initially and at least annually, employers need to evaluate the program to ensure that it is operating as intended, is effective in controlling identified hazards, and is making progress toward established safety and health goals and objectives. The scope and frequency of program evaluations will vary depending on changes in OSHA standards; the scope, complexity, and maturity of the program; and the types of hazards it must control.

How to accomplish it
  • Verify that the core elements of the program have been fully implemented.
  • Involve workers in all aspects of program evaluation, including: reviewing information (such as incident reports and exposure monitoring results); establishing and tracking performance indicators; and identifying opportunities to improve the program.
  • Verify that the following key processes are in place and operating as intended:
    • Reporting injuries, illnesses, incidents, hazards, and concerns
    • Conducting workplace inspections and incident investigations
    • Tracking progress in controlling identified hazards and ensuring that hazard control measures remain effective
    • Collecting and reporting any data needed to monitor progress and performance
  • Review the results of any compliance audits to confirm that any program shortcomings are being identified. Verify that actions are being taken that will prevent recurrence.
Action item 3: Correct program shortcomings and identify opportunities to improve

Whenever a problem is identified in any part of the safety and health program, employers—in coordination with supervisors, managers, and workers—should take prompt action to correct the problem and prevent its recurrence.

How to accomplish it

If you discover program shortcomings, take actions needed to correct them.

  • Proactively seek input from managers, workers, supervisors, and other stakeholders on how you can improve the program.
  • Determine whether changes in equipment, facilities, materials, key personnel, or work practices trigger any need for changes in the program.
  • Determine whether your performance indicators and goals are still relevant and, if not, how you could change them to more effectively drive improvements in workplace safety and health.

Note: The scope and frequency of program evaluations will depend on the scope, complexity, and maturity of the program and on the types of hazards it must control. Program evaluations should be conducted periodically (and at least annually) but might also be triggered by a change in process or equipment, or an incident such as a serious injury, significant property damage, or an increase in safety-related complaints.

Compliance

            1. General Material. This includes all general correspondence and other material relating to inspection activities in federally inspected States or within the Federal Government. These materials should be filed under the appropriate subject listed in Appendix D of ADM 12-0.4A. The material will generally be filed in the subject files under CPL 2 or FAP 1.


            1. Policy Material. This includes records and other materials reflecting policy, precedent, and the like relating to planning developing and directing the Federal Inspection Program. These materials will generally be filed under CPL 2 or FAP 1. However, published instructions, directives, manuals, and the like are filed in binders or as electronic records, according to the established agency custom. Note that annual program plans themselves are filed in PAE 1.


            1. Reports. This includes reports dealing with compliance-related subjects including activity reports. These materials should be filed in CPL or FAP. Those reports which are made a part of inspection case files or should be placed in another of the categories in this appendix should be filed with the records within that category. This does not include IMIS copies of compliance forms.


            1. Meetings/Committees. This category consists of meetings and committees relating to safety and health inspection activities and functions. this category includes policy and mission statements, acceptances and regrets, membership lists, agendas, meeting arrangements, invitations, accommodations, authority to attend, and the like. File this material under CPL 2 or FAP. This does not include committee activities properly filed under ADV Inspection Case Files. The following three categories consist of safety and health inspection case files in federally inspected states and in Federal agencies and such related case files as nonformal complaints, referrals, refused inspections and attempted inspections.


            1. Active/Open Cases. This category consists of all inspection case files upon which an action remains to be completed. Arrange these files alphabetically by firm or establishment. Copies of case files in contest or those undergoing collection activities may be filed separately.


            1. Contested Cases. This category consists of duplicate copies of inspection case files which are appealed by the firm or establishment. File duplicate inspection case files in this category alphabetically by firm or establishment when the establishment or firm has appealed a citation or penalty. The original file is sent to the Solicitor and remains there until the appeal is decided. The original is sent to the Office of the Solicitor to satisfy the requirements of courts for the best available evidence. After the original file is returned, merge the duplicate file into the original file, destroying all duplicate documentation.


            1. Closed Cases. This category covers all closed inspection case files including all forms, photographs, correspondence, samples, test results, reports, video, audio, or electronic records and the like pertaining to a specific establishment. This includes inspection case files, referrals, formal and nonformal complaints, refused inspections, and attempted inspections. These materials should be interfiled and are not filed divided into safety or health. These records are filed alphabetically by firm or establishment. A case is closed when all actions have been completed including follow up inspections and abatement of hazards. (See Appendix D for disposition schedules.)

                1. Closed construction inspection case files may be filed separately.


                1. Simultaneous industrial hygiene and safety inspections are not combined inspections if they are conducted as and constitute complete, separate inspections.


                1. Formal complaints are filed in the appropriate inspection case file as part of that inspection.


                1. Compliance-related files such as nonformal complaints, referrals, refused inspections, and attempted inspections are maintained with the inspection case files because of their importance while preparing for and conducting inspections. They may be interfiled with the inspection case files. If desired, each type may be grouped together in a folder rather than each being filed in a separate folder. For example: all refused inspections may be filed together in one folder.


                1. Invalid complaints are filed with the inspection case files but are filed separately.


                1. Transfers. Inspection case files will be transferred to the FRC within three years after the case is closed. They may be sent to the FRC at any time before they reach the mandatory transfer age.


                1. Special Interest files. Inspection case files of special interest such as those involving companies or establishments in industries having no fixed worksite, those that could result in repeated violations, those with multiple work sites in different geographical areas or States, those that are unique or unusual precedent-setting court cases, or are otherwise of great value as reference sources may be maintained in the field office instead of being transferred to the FRC.


              1. GAO Site Audit Records. Original copies of GAO Site Audit records, such as collection registers, check forwarding receipts, and the like providing an audit trail for monies received by the agency cannot be filed in inspection case files. These records are filed in the agency file system under FIN (financial management). See OSHA Instruction ADM 12-0.1 Copies of these documents must be included in the inspection case files to provide documentation concerning payment of penalties and/or abatement of the hazard.

            1. Establishment Files. This material consists of case files of establishments, companies, or firms that do not relate to a specific inspection. Establishment case files should be started for each establishment that the Area Director determines contains unusual or special circumstances or situations; such as unusual processes, engineering controls, unusual toxic chemicals and other toxic products, and the like, which will probably result in a continuing need for information. Such a file may include health hazard evaluations, process descriptions, production data, product toxicity data, engineering controls, and other long-term safety and health data and related information of value in preparing for inspections. The area Director has full discretion in deciding which companies, establishments or firms will be documented in the establishment file. These materials should be filed alphabetically by name of establishment or firm. When a firm or establishment has a new name and/or a new owner, change the title of the folder and file the folder in the new location in this alphabetical file.


            1. Invalid Complaints. These are complaints that are not related to occupational safety and health or are not covered by OSHA. They include appeals where the office director determines the complaint is invalid for redress and the complainant appeals the decision. However, file successful appeals with the appropriate closed inspection case file. These materials should be filed as best suits the user’s needs.


          1. Discrimination. Records dealing with employer discrimination or retaliation (Section 11(c)) against employees who report violations of the Act or cooperate with OSHA inspections are included in these files. This file category consists of copies of materials sent to the regional office for investigation. This file does not include investigative files. These materials should be filed as best suits the user’s needs.

      1. Compliance File Folder Labeling.

        1. Inspection-Related Case Files.

            1. Inspection Case Files. Folder labeling for these files is accomplished as required.

Required Certification

  • BLOOD BORNE PATHOGHENS 
  • CPR 
  • FIRST AID 
  • INFECTION CONTROL
  • DISINFECTION & SANITATION  
  • ANATOMY 

 

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