Accident Prevention Program (APP)

1. Accident Prevention Program (APP) An overview of what’s required and how to develop one April, 2010

2. Purpose: To assist you in developing and implementing a written Accident prevention program that is tailored to the needs and potential hazards associated with your workplace. Accident Prevention Program (APP)

3. What Will Be Covered • Why have an accident prevention program? • Rule requirements for accident prevention program • Elements of a written program • How to implement an effective program • Where to get help

4. It will help to prevent employee injuries on the job. • It will help you find hazards before they cause accidents. • It will help you deal with accidents if they do occur. Why have an Accident Prevention Program? By “accidents” we mean events where employees are killed, maimed, injured, or become ill from exposure to toxic chemicals or microorganisms (TB, Hepatitis, HIV, Hantavirus etc).

5. Why have an Accident Prevention Program? It helps control Industrial Insurance costs Low # of Claims Average # of claims High # of Claims Your premium rate depends on number of claims filed. An accident prevention program can help you to control hazards that cause accidents and claims.

6. A Tire Store – 35 Employees • Had a single high cost claim (shoulder injury) • Premium rate increased from 71¢/hr to 86¢/hr • Yearly premium increased $10,000 A True Story To make up for the premium increase @ 10% profit margin – you must get $100,000 additional business These are actual facts and figures from a tire store in eastern Washington. The company had 13 minor claims in 2000-2002 with the single high-cost claim ($29,000) occurring in 2002. The employee was off work for several days and received time-loss payments from L & I. He also had expensive medical bills which were billed to L & I.

7. Why have an Accident Prevention Program? It’s required by L & I - DOSH Rules (Division of Occupational Safety & Health) DOSH Safety & Health Core Rules – WAC 296-800-140 Safety Standards for Construction – WAC 296-155-110 Other standards – agriculture, logging, etc. APP rules are nearly identical for all types of businesses. In most cases, if you are visited by a DOSH inspector, he or she will look for your APP. If the inspector finds serious hazards and no APP or major deficiencies in the APP, you could receive a citation with monetary penalty.

8. What is an Accident Prevention Program? A plan of action to: • Involve workers and management in workplace safety and health, • Identify and control safety hazards, • Handle emergencies, • Give new employees job safety orientation, • Provide for personal protective equipment as needed. A plan for safety must be more than posting a sign that says “Be Careful. In an emergency call 911.” It will help you to identify hazards before they cause accidents and help you deal with accidents if and when they occur.

9. Must be outlined in writing. • Must be tailored to the worksite. • Must include employee safety orientation and training. • Must include safety committee or safety meetings. What is required for all employers? • You must develop, superviseand enforce a safety training program • You must make sure your APP is effective in practice. Link to Core Rule APP requirements

10. APP Requirements For Construction • Supervise and enforce an effective program • Outlined in writing • Employee safety orientation • Weekly leader/crew safety meetings • Weekly walk-around safety inspections Link to Construction APP requirements

11. Outlined in writing • Tailored to the needs and hazards of your operation • Employee safety orientation • Monthly walk-around safety inspections with employee representative • Monthly foreman-crew safety meetings APP Requirements for Agriculture Link to Agriculture APP requirements

12. Simple and direct is O.K. • Must cover all the regular and predictable hazards of the worksite • Include employee input to identify new hazards not in outline • Some employers will need a more complex APP depending on hazards • It can’t be just a paper program A written APP can be an outline The written program must cover all the typical, predictable and evident hazards of the worksite. However, a written APP that is too long or complicated tends not be read. As long as there is method to report new or unforeseen hazards, it is not necessary to go into great detail about every possible hazard one could imagine.

13. APP should be a “living plan” • If it is not a “living plan” that is actually used, then it will just be: • a document gathering dust on a shelf, • something you did to please L&I, • of no real value to your company. If you’re going to spend time and energy developing this plan, it might as well be a tool that will add value to your company, will help you to provide a safe and productive workplace, and keep your industrial insurance premiums to a minimum.

14. It can’t be a non-specific generic program • It must address the actual worksite hazards and conditions • It must include the work of all employees APP Must be Tailored to the Worksite By “generic” we mean one that does not address the actual worksite hazards and conditions. Some trade associations produce generic programs that includes the most common hazards of a particular industry. These are usually acceptable, but you must also cover the unique hazards of your worksite.

15. The orientation must cover: • A description of total safety program • On-the-job instructions on how to do job tasks safely • How to report accidents • Location of first aid facilities Employee Safety Orientation

16. Also include in orientation: Employee Safety Orientation(con’t.) • How to report safety hazards • Use and care of personal protective equipment • What to do in emergencies • How to identify hazardous chemicals and what to do if exposed to them. Link to sample chemical hazard communication program

17. Safety Committees • At least as many elected employees as management-selected members • Elected chairperson • Committee determines meeting schedules • Keep meeting minutes and attendance • Cover specific topics Safety Committees are required if you have 11 or more employees at the worksite. The number of employee-elected members of the safety committee must be equal to or more than the number of employer-selected members

18. Safety Meetings • Allowed if 10 or less employees • Meet monthly • At least one management representative • Document attendance • Cover specific topics Safety meetings are an allowable substitute for a safety committee if you have 10 or less employees. They are also allowed if you have 10 or less employees on different shifts or there are 10 or less employees at widely separate work locations. You would need to have safety meetings at each shift or each work location.

19. Construction Crew/Leader Safety Meeting requirements Hold worksite meetings: • At start of job • Every week • As needed when change in conditions or hazards Document topics and attendance

20. Not required for short-term operations like harvesting • Monthly meetings tailored to current activities • Outline what discussed and who attended in meeting minutes • Copies of minutes kept at location where most employees report • Retain minutes for one year Agriculture Safety Meetings Even though safety meetings are not required for agriculture operations that last less than a month, a safety orientation is still required at the beginning of the operation. For example, in cherry harvesting, pickers should still have a safety orientation on how to safely use a ladder.

21. When It Works!! • It is more than just words, platitudes or slogans. • All regular and predictable hazards are addressed. • Serious or frequent injuries are not occurring. When is an APP “Effective in Practice”? The goal of an APP is to prevent injuries. Frequent injuries would be a sign that not all hazards are addressed or your safety rules are not being enforced. Minor or infrequent non-serious injuries do not mean your APP is ineffective. An occasional missed hazard (one saw guard out of several saws is missing in a cabinet shop for example) also does not necessarily mean your APP is ineffective.

22. Determine what injuries and near-misses have occurred and why • Do a hazard evaluation or survey of the workplace • Establish safety goals – management commitment • Train employees on job hazards (required) • Effectively and consistently enforce safety rules • Provide needed protective equipment and make sure it is used (required) Some ways to make an APP “Effective in Practice”

23. Injury Determination Review your OSHA 300 Log if you have kept one. See if there are several people having the same type of accident (indicates that a process or procedures may need changing) or if one person is having several accidents doing different jobs (indicates that this person probably needs retraining). • Review claims and injury records • Interview employees for unreported injuries Talk to employees: - Do they think they have a safe place to work. - Do they have ideas about how to improve safety. - Do they know how, when and to whom to report an accident. - Do they know of any accident that have NOT been reported.

24. Investigate near-misses since they are potential accidents Near Misses Accidents or injuries are the “tip of the iceberg” of hazards Accidents Hazards Don’t just investigate accidents. Near misses should be reported and investigated. They were in a sense, “aborted accidents”. Criteria for investigating an incident or near miss: What is reasonably the worst injury the worker would have suffered had an actual accident happened? If it would have resulted in a serious injury, then the incident or near miss should be investigated with the same thoroughness as an actual accident investigation.

25. Job Steps Hazard Protection Job Hazard Analysis (JHA) Safety Hazard Evaluation Sharp edges & splinters Pick up stock Gloves Blade guard and safety glasses Blade edges And flying chips Cut stock with power saw A JHA is not required, but is one method of determining hazards at the worksite. This is an example of a job safety analysis of a carpenter shop. Each task is listed with it’s particular hazard and protection for that hazard. This method can be used to determine your company’s need for personal protective equipment. Also called a job safety analysis (JSA) Link to JHA information

26. Workplace Safety Evaluation Worksite Safety Checklist Tailored to your workplace Used by foreman or safety supervisor YES NO ITEM Employees wearing safety glasses? Saw guards in place? Work area free of tripping hazards? A periodic safety evaluation is recommended, especially if conditions change frequently, such as in construction. Often representatives of the safety committee will do this. This checklist should be developed to check for the hazards that are likely to be found on your site. It can be used for periodic walkaround safety surveys to make sure all safety measures are in place.

27. Conduct Accident Investigations Hazard Identification Do with a team: supervisors, employees, outside experts • Examine: • Persons • Equipment • Environment • Look for fact, not fault • Prepare a written report • Do follow-up Investigate as soon as possible. Take pictures, draw diagrams and interview all who witnessed the accident. Try to find what can be changes to prevent the accident from happening again. Write a formal report (can be covered at the next safety meeting). Make sure that suggested changes are made. Link to more information on how to do an accident investigation

28. A successful APPneedsManagement Commitment A message from the owner ... Sample statements: • “We care about your safety…” • “We will provide a safe work place…” • “Nothing is important enough to do unsafely.” • “Supervisors and employees are expected to work safely and bring up safety issues…” John Smith J Management safety statements are not required, but are recommended. Management support is vital for success of program else neither supervisors nor employees will take it seriously. A specific written statement, is not required, however.

29. Resources needed to support an APP Time Incentives Safety Equipment • In addition to leading by example, management should give employees resources and incentives. Recognize that an effective program implies a commitment of: • - support of safety as a regular budget item, • - time for inspections, training, safety committee, maintenance, • - equipment such as guards, PPE, training materials, promotions, • - safety recognition and incentive programs that reward safety efforts.

30. For a successful APP you need line manager commitment. The Role of Line Manager/Foreman Suggested ways to do that: • Spell out their safety duties • Give them explicit safety authority • Hold them accountable for safety To have a program that is “effective in practice”, management ( the owner, general manager, supervisor, foreman and crew boss) must practice safety as well as the employees. If management doesn’t wear PPE where the employee are required to, the employees are less likely to wear the required PPE when management is not present. Employees must be make to feel comfortable making safety corrections without getting “permission” from someone else.

31. They should: • Be personal examples • Identify hazards • Monitor workers • Participate directly in problem-solving The Role of Line Managers/Foremen

32. Employee Input • Employee hazard reports • Get input from safety committee • Consider using an employee report form • Do a follow-up Link to sample employee report form You can use a report form, a suggestion box, or get input from safety committee or verbally during safety meetings. Make available and encourage the use of form for employees to report hazards they see. Management should have procedures to address issues identified and notify individuals or safety committee what actions were taken.

33. Management also needs training to understand the hazards and safety requirements as much if not more than the line employees. • Initial orientation is very important. New employees are quite vulnerable to accident unless you train them on: • - what to watch out for, and • - what to do when something goes wrong. • Employees may be expected to start the job with the skills necessary to do the job but it is the employer’s responsibility to insure that the employee knows the safety rules related to the job. • Don’t rely on the previous employer having done the training or that the new employee says they have experience. You don’t know the quality of training they received or if any bad habits have developed. Training Programs

34. Need to cover the following: Training Programs • Who? • Management • Employees • What? • Basic orientation • Specific machines, processes, skills • When? • Before doing the work • When duties work change • When deficiencies are noted • Documentation • Instructor’s outline • Attendance records

35. DOSH has specific training requirements for certain topics: • Hazard communication • Respirator use • Other PPE use • Forklifts • Confined space work • Fall protection in construction • Pesticides in agriculture • Others Specific Training Programs Link to DOSH-required training Link to DOSH online training programs

36. There are two types: Safety Rules are an Important Part of APP • General company safety rules such as: • “Wear steel-toed shoes on the job” • “No horseplay” • “Do not operate machinery without guards in place.” • Specific job related safety rules such as: • Grinder safety rules • Roofing fall protection rules

37. Safety Disciplinary Policy • In writing • Employees are informed or trained on policy • Applies to everyone – including management • Fair and progressive enforcement “Where’s his fall protection?” A disciplinary policy is not required, but highly recommended. The policy should be in writing and employees should be informed/trained before it can be used against them. Policy should be imposed on management as well as employees. Records of policy application should be kept for documentation that the policy is being enforced.

38. What hazards exist that require use of PPE? Personal Protective Equipment • Determine need –who, when, what • Ensure it provides adequate protection • Train employees on use • Provide, maintain and replace as needed. A PPE hazard assessment is required by DOSH Rules on PPE. You can determine what PPE is needed from doing a hazard assessment. Injury reports may also provide additional information – there may be a pattern of injuries that can be prevented with the use of appropriate PPE.. Link to sample PPE hazard assessment checklist

39. AdditionalInformation More information on APP is available on the DOSH webpage at: http://www.lni.wa.gov/safety/basics/Programs/Accident/default.htm For additional assistance, you can call one of our consultants. Click below for local L & I office locations: http://www.lni.wa.gov/wisha/consultation/regional_consultants.htm