May 16, 2011

Checklists for Work Areas




The Process

Self-Inspection

The most widely accepted way to identify hazards is to conduct safety and health inspections. The only way you can be certain of the actual situation is for you to look at it from time to time.

Make a Self-Inspection of Your Business

Begin a program of self-inspection in your own workplace. Self-inspection is a must if you are to know where probable hazards exist and whether they are under control.
Later in this Section, you will find checklists designed to assist you in this fact-finding. They will give you some indication of where you should begin action to make your business safer and more healthful for all of your employees.
These checklists are by no means all-inclusive. You may wish to add to them or delete portions that do not apply to your business. Consider carefully each item as you come to it and then make your decision.
Don't spend time with items that obviously have no application to your business. Make sure each item is seen by you or your designee, and leave nothing to memory or chance. Write down what you see, or don't see, and what you think you should do about it.
When you have completed the checklists, add this material to your injury information, your employee information, and your process and equipment information. You will now possess many facts that will help you determine what problems exist. Then, if you use the OSHA standards in your problem-solving process, it will be much easier for you to determine the action needed to solve these problems.
Once the hazards have been identified, you can institute the control procedures and establish your four-point safety and health program.
Technical assistance in self-inspection may be available to you as a small business owner or manager through your insurance carrier, the local safety council and many local, state, and federal agencies, including the state consultation programs and OSHA Area Offices. Additional checklists are available from the National Safety Council, trade associations, insurance companies, and other similar service organizations.

Self-Inspection Scope

Your self-inspections should cover safety and health issues in the following areas:
  • Processing, Receiving, Shipping and Storage — equipment, job planning, layout, heights, floor loads, projection of materials, material handling and storage methods, training for material handling equipment.
  • Building and Grounds Conditions — floors, walls, ceilings, exits, stairs, walkways, ramps, platforms, driveways, aisles.
  • Housekeeping Program — waste disposal, tools, objects, materials, leakage and spillage, cleaning methods, schedules, work areas, remote areas, storage areas.
  • Electricity — equipment, switches, breakers, fuses, switch-boxes, junctions, special fixtures, circuits, insulation, extensions, tools, motors, grounding, national electric code compliance.
  • Lighting — type, intensity, controls, conditions, diffusion, location, glare and shadow control.
  • Heating and Ventilation — type, effectiveness, temperature, humidity, controls, natural and artificial ventilation and exhausting.
  • Machinery — points of operation, flywheels, gears, shafts, pulleys, key ways, belts, couplings, sprockets, chains, frames, controls, lighting for tools and equipment, brakes, exhausting, feeding, oiling, adjusting, maintenance, lockout/tagout, grounding, work space, location, purchasing standards.
  • Personnel — training, including hazard identification training; experience; methods of checking machines before use; type of clothing; PPE; use of guards; tool storage; work practices; methods for cleaning, oiling, or adjusting machinery.
  • Hand and Power Tools — purchasing standards, inspection, storage, repair, types, maintenance, grounding, use and handling.
  • Chemicals — storage, handling, transportation, spills, disposals, amounts used, labeling, toxicity or other harmful effects, warning signs, supervision, training, protective clothing and equipment, hazard communication requirements.
  • Fire Prevention — extinguishers, alarms, sprinklers, smoking rules, exits, personnel assigned, separation of flammable materials and dangerous operations, explosion-proof fixtures in hazardous locations, waste disposal and training of personnel.
  • Maintenance — provide regular and preventive maintenance on all equipment used at the worksite, recording all work performed on the machinery and by training personnel on the proper care and servicing of the equipment.
  • PPE — type, size, maintenance, repair, age, storage, assignment of responsibility, purchasing methods, standards observed, training in care and use, rules of use, method of assignment.
  • Transportation — motor vehicle safety, seat belts, vehicle maintenance, safe driver programs.
  • First Aid Program/Supplies — medical care facilities locations, posted emergency phone numbers, accessible first aid kits.
  • Evacuation Plan — establish and practice procedures for an emergency evacuation, e.g., fire, chemical/biological incidents, bomb threat; include escape procedures and routes, critical plant operations, employee accounting following an evacuation, rescue and medical duties and ways to report emergencies.

The Audit Process

You will find a set of checklists in this section of the manual. You will use these checklist forms to conduct your workplace audit. Each form covers an individual work area, such as "Warehouse."

Step Two

When you are ready to do the audit, photocopy the appropriate forms. Proceed to the first work area.

Step Three

At the top of each form is a place for your designation of the location. For example, the form might be called "Chemical Storage Area," but in your facility this is Building D Annex. Fill in the location, the auditor's name and job title, and the date.

Step Four

Go through the work area, looking for the items listed. If the item or practice is not in compliance with the regulations, check the appropriate box. Keep an eye open for unlisted items also. Remember, neither OSHA nor EPA spells out everything. There are many general requirements that apply everywhere. There are blank lines at the bottom of most forms to enable you to write in any specific details to be corrected.
The regulatory citations appear after most listings on the forms. If you need more information, or are confused as to the context of an item, you can go to the regulations and look up the actual wording.

Step Five

After the audit is complete, the auditor makes necessary copies of the form. Transfer any necessary data to the summary sheet which is on the reverse side of the form. The original copy is filed, providing the necessary documentation for a variety of purposes, including corporate reviews, regulatory inspections, post-accident investigation reports, and insurance company requests.

Step Six

Next, you can finish filling out the summary sheet, listing the repairs to be made or corrections to be made in work practices. You will have room to provide details on necessary corrections and how they should be accomplished. You will provide a date by which repairs must be made. Make any necessary copies of the summary sheet at this point.

Step Seven

The auditor then forwards copies of the form and summary sheet to the appropriate personnel to make the changes.

Step Eight

When corrections or changes are made, this is indicated on the form, along with the initials of the person making the repairs, and the date. One copy is then returned to the auditor with one copy retained by the supervisor or person responsible for making the changes.

Create Your Own System

This Eight-Step Method should provide a little Novocain for a "painful" process. At least, it offers a beginning and a tracking system for your documentation.
If this system does not work in your operation, modify it any way you choose. There are many different ways to audit and document the process. The method of auditing is not mandatory. Just get started.

May 12, 2011

How Do I Audit My System?

Unlike inspecting a work area, conducting an audit requires that you use several methods to obtain the necessary data. These methods typically include:

  • Documentation review
  • Interviews
  • Site conditions assessment
Documentation
Every worksite will have, at an absolute minimum, written accident reports and the OSHA log of injuries and illnesses as required by law. Most companies should have written procedures and records of all their safety and health programs, as well as internal policies. The auditor should compare the written program to the written records of what occurred.
Interviews
In addition to the documentation, interviews can be very helpful in establishing what has occurred. There are two kinds of interviews, called formal and informal. The formal interviews are conducted privately with randomly selected employees who are asked preselected questions. Informal interviews occur at employee work stations and generally follow a list of topics.
To assess how well the worksite safety and health policy is communicated and understood, and how well the disciplinary system is working, ask the employees to explain them.
To gauge the effectiveness of safety and health training, interview hourly employees and first-line supervisors. Ask employees to describe what hazards they are exposed to, and how they are protected. Ask them to explain what they are supposed to do in several different types of emergencies. Ask supervisors how they teach, how they reinforce the teaching, how they enforce safety and health rules and safe work practices, and what their responsibilities are during emergency situations.
Interviews with management should focus on its involvement in and commitment to the safety and health program. Ask how the policy statement was created, and how that statement is communicated to all employees. Ask what information management receives about the safety and health activities, and what action management takes as a result of that information. Ask how management's commitment to safety and health is demonstrated to the workforce.
Site Conditions Review
The conditions at the worksite reveal much about the safety and health program's effectiveness. Worksite conditions can be observed indirectly by examining documents such as inspection reports, employee reports of hazards, and accident/incident investigations.
Site tours also may reveal hazards. Be careful, however, that the site tour does not become a routine inspection, with emphasis only on hazard correction. When a hazard is found, certainly take steps to ensure its correction. But in addition, ask what management system(s) should have prevented or controlled the hazard.

System Audits: Where to Turn

There is no concrete right or wrong way to audit your safety and health management system. OSHA doesn't require you to audit the system, or that you necessarily have a formal safety and health system — so how you audit is up to you.
But, there are some considerations. For starters, because there is no regulation, it can be difficult to figure out what to assess your system against. With inspections you have the regulations, for example, "Is the eyewash available when employees are exposed to corrosive?"
With a systems audit, you do not have that regulatory criteria. So, you have to develop your own audit protocol.
One place you might consider starting is the Safety and Health Program Assessment Worksheet (OSHA Form 33). This Form is used by OSHA's Consultation Services to review safety management programs. The form covers seven areas:
  1. Hazard anticipation and detection
  2. Hazard prevention and control
  3. Planning and evaluation
  4. Administration and supervision
  5. Safety and health training
  6. Management leadership
  7. Employee participation
A blank Form 33 is provided on the following pages. Though some of the fields are intended for OSHA's in-house use, the form may prove to be a good management tool to perform your own self-assessment.
Oregon SHARP/Consultation provides tips for using the Safety and Health Program Assessment Worksheet. They walk you through what to look for under each element. For example, for the element that says you should have a comprehensive, baseline hazard survey conducted within the past five years, the Oregon OSHA tip sheet advises you that in order to get a score of "3" for that element, the baseline must be written. It provides similar practical tips throughout. If you combine the worksheet and these tips, you should have the tools to do a fairly thorough assessment of your safety management system.

Systems Audits: Going Beyond Inspections


Most employers conduct inspections or what some call walkthroughs, and many employers conduct audits, as well. But, there are some employers that don't conduct audits — and there are some that think they conduct audits, but what they really conduct are inspections or walkthroughs.
Inspections and walkthroughs are extremely important and in many cases dictated by government regulations. So, their importance cannot be discounted.
But, going beyond the simple inspection or walkthrough process — and implementing an effective audit process is also important.

What is an Inspection?

Simply stated, an inspection is the process of closely looking at the workplace for hazardous conditions or compliance violations. There are a variety of inspections that employers conduct — some at the department level, some at the equipment level, and some company-wide.
Typically, an inspection is based on either OSHA standards, industry standards, manufacturer's requirements, or a combination. Inspections are heavily associated with checklists (as you can find in this manual) — where you walk around and compare what you see to what's on the checklist.

What is a Systems Audit?

A simple definition of a systems audit is: the process of verifying whether the safety system conforms to the audit criteria and that the system is effective.
The audit criteria can be OSHA standards, company policies and procedures, or ANSI or industry standards. So, when you think of a systems audit, remember, it's more than just a regulatory check; it involves looking at your safety management system to identify strengths and weaknesses.

Differences Between Inspections and Audits

Now that we've defined what an inspection and an audit are, we can start to see the differences between the two processes. The following table provides an overview of these differences.
Inspections vs. audits
Inspections
Audits
Focus on physical items or conditions
Focus on processes and systems
"Look and see" approach
Interview, review documentation, and "look and see"
"Yes/no" answers
Progressive scale — "Nothing in place" to "Fully in place and satisfactory"
Done by employees on the floor, supervisor, safety committee
Done by objective party (safety manager, outside consultant, insurance representative)
Not very time consuming — usually 15 minutes to an hour
Can take several hours or days
Frequent — Daily/weekly/monthly/quarterly
Infrequent — Annual, bi-annual
Primarily focuses on weaknesses
Focuses on weaknesses and strengths
Identifies a hazard, fixes THAT hazard
Deals with system-wide problems (root cause of an isolated hazard)
Corrective actions are straightforward
Corrective actions are often broad, performance-oriented
Document/follow-up
Document/follow-up — more detailed findings
Required by OSHA in many cases
Not required in most cases. BUT:
  • PPE hazard assessment
  • Lockout/Tagout periodic inspection
  • Confined spaces assessment
  • Process Safety Management of Highly Hazardous Chemicals, 1910.119
  • Construction Jobsites, 1926.20(b)(2)