Needs Assessment and Prioritization of Safety and Health Issues

1. Needs Assessment and Prioritization of Safety and Health Issues Jason Schaufenbuel, MPH, CSP Regional Manager – Loss Control United Heartland

2. Agenda • Needs Assessment • Hazard Identification • Injuries • OSHA Compliance • JSAs • Audits • Employee Suggestions • Consultation • Prioritizing Your Actions • Hierarchy of Risk Control

3. Learning Objectives • After this session you should: • Explain the purpose of a needs assessment in regards to workplace safety. • Detail six methods to identify hazards in your workplace. • Summarize three methods to prioritize your efforts to improve workplace safety. • Describe the preferred risk control methods.

4. Needs Assessment • Purpose is to compare current practices to what is actually needed • Without this step you cannot focus you efforts to identify your biggest issues • Most critical but often most neglected step • While conducting the needs assessment keep track of the issue, it’s seriousness, how often employees are exposed and the number of employees exposed

5. Hazard Identification • Serves as the basis of the needs assessment – identifies what you need to address • Many methods to identify hazards • Use a combination of methods • Best methods are the one the organization can sustain

6. Hazard Identification – Accident Reports/Investigations • Use existing reports/investigations to identify trends • Ensure your reports require detail • Too many reports simply focus on the injury and not what happened – what happened is critical • Identify how it could have been prevented and what is going to take to prevent reoccurrence • Complete root cause analysis

7. Hazard Identification – Root Cause Analysis • Root Cause • The defining, underlying reason(s) for the problem • If this cause is eliminated and/or controlled then the problem does not occur again • Every incident has at least two causes

8. Hazard Identification - OSHA Injury/Illness Rates • Check to see how your rates compare to others in your industry – provides information on the scope of the problem – but not the problem itself • OSHA now publishes business specific information

9. Hazard Identification - Workers Compensation • Use your workers compensation loss runs to identify trends in severity and frequency • You carrier or TPA should be able to provide you the data in Excel or other usable fashion

10. Hazard Identification - Workers Compensation

11. Hazard Identification - Workers Compensation

12. Hazard Identification – OSHA Compliance • Can be the most complicated aspect to assess • Three primary elements: • Written programs • Required training • Physical requirements

13. OSHA Compliance – Written Programs (General Industry) • Employee emergency plans – 1910.38 • Fire prevention plan – 1910.39 • Occupational noise exposure – 1910.95 • Process safety management – 1910.119 • Hazardous waste operations and emergency response – 1910.120 • Personal protective equipment – 1910.132 • Respiratory protection – 1910.134

14. OSHA Compliance – Written Programs (General Industry) • Permit required confined space entry – 1910.146 • The control of hazardous energy – 1910.147 • Asbestos – 1910.1001 • Lead – 1910.1025 • Bloodborne pathogens – 1910.1030 • Hazard communication – 1910.1200 • Occupational exposure to hazardous chemicals in laboratories – 1910.1450

15. OSHA Compliance – Employee Training • 1910.38 Employee Emergency Plans • 1910.39 Fire Prevention Plans • 1910.67 Vehicle Mounted Elevating and Rotating Work Platforms • 1910.95 Occupational Noise Exposure • 1910.110 Storage and Handling of LPG • 1910.119 Process Safety Management • 1910.120 Hazardous Waste Operations and Emergency Response

16. OSHA Compliance – Employee Training • 1910.132 Personal Protective Equipment • 1910.134 Respiratory Protection • 1910.145 Accident Prevention Signs and Tags • 1910.146 Permit Required Confined Space Entry • 1910.147 The Control of Hazardous Energy • 1910.151 Medical Services and First Aid • 1910 Subpart L (.155 - .165) Fire Protection (including fire extinguishers)

17. OSHA Compliance – Employee Training • 1910.177 Servicing Multi-Piece and Single Piece Rim Wheels • 1910.178 Powered Industrial Vehicles • 1910.179 Overhead and Gantry Cranes • 1910.217/1910.218 Mechanical Power Presses and Forging Machines • 1910.252 – 255 Welding, Cutting, Brazing • 1910.331-.335 Electrical – Safety-Related Work Practices

18. OSHA Compliance – Employee Training • 1910.1001 Asbestos • 1910.1003 - 1052 Carcinogens and specific chemicals • 1910.1020 Employee Exposure and Medical Records • 1910.1025 Lead • 1910.1030 Bloodborne Pathogens • 1910.1200 Hazard Communication • 1910.1450 Occupational Exposure to Hazardous Chemicals in Laboratories

19. OSHA Compliance – Physical Requirements Based upon top OSHA citations • Electrical wiring • Machine guarding • Floor and wall opening and holes • Exit routes • Personal protective equipment • Grinders

20. OSHA Compliance – Physical Requirements • Fire extinguishers • Flammable material storage – including compressed gases • Hand and portable tool condition • Stairs/handrails • Housekeeping

21. Recent Examples

22. Hazard Identification – OSHA Compliance • Validate • It’s not enough to have written and employee training programs in place • Ensure the programs are doing what they were intended to • Lockout/Tagout • Confined Space • PPE

23. Lockout Periodic Inspection • Show examples of validation • Forms, checklists, etc

24. Validate • Confined Space • Permits must be retrained for one year • Review to ensure they are properly completed, no unexpected hazards occurred, properly closed • PPE • Hazard assessments completed; employees wearing PPE? • Hazard Communication • MSDS, container labeling

25. Hazard Identification - JSAs • Identify job(s) to be analyzed • List each step of the job (it takes balance) • For each step, identify: • What can go wrong • What are the consequences • How can it happen • What are the contributing factors • How likely is it to occur • Look at worker, task and tools • See OSHA “Job Hazard Analysis” - Publication 3071

26. Hazard Identification - JSAs

27. Hazard Identification - Audits • Conduct an audit of your facility • Don’t limit to physical conditions • Consider work practices • Use checklists specific to your industry or a general checklist • Ergonomics assessments • See OSHA “Small Business Handbook” – Publication 2209

28. Hazard Identification - Ergonomics • Simple ergonomics assessment form • Quick Exposure Check (UK) – • David, Geoffrey, et al (2008) The development of the Quick Exposure Check (QEC) for assessing exposure to risk factors for work-related musculoskeletal disorders. Applied Ergonomics. 39; 57-69

32. Hazard Identification – Employee Suggestions • Seek employee input • Ask what job tasks cause injuries, discomfort or are extremely challenging • Have the employees provide suggestions on how to correct the situations – they usually have some of the best solutions

33. Hazard Assessments - Consultation • Ask for assistance • Workers Compensation Carrier • Loss Control Representative • OSHA Consultation

34. Prioritizing Your Actions • After you know what should be done – how do you determine how you want to prioritize the needs you identified? • Three basic principles • Focus on compliance • Focus on injuries • Focus on exposure

35. Prioritizing Your Actions - OSHA • Focus on the issues most likely to result in an OSHA citation • Serious issues first – those most likely to lead to significant injury

36. Prioritizing Your Actions - Injuries • Focus on the issues causing the most injuries/illness • Focus on the issues causing the greatest amount of lost/restricted workdays • Focus on the issues causing the greatest workers compensation losses

37. Prioritizing Your Actions - Exposure • Use the data you collected during the needs/hazard assessment • Determine relative impact of the need • Severity * Frequency * % employees exposed • Highest scoring items should be addressed first

38. Severity 5 Catastrophic 4 Serious 3 Moderate 2 Minor 1 Insignificant Frequency 5 Multiple times per day 4 Once per day 3 Once per week 2 Once per month 1 Less than once per month Severity and Frequency

39. % Employees Exposed 5 80 – 100% 4 60 – 79% 3 40 – 59% 2 20 – 39% 1 0 – 19% Example Maintenance employees are not using lockout/tagout when repairing large power presses. Maintenance makes up 30% of employees. 5 * 5 * 2 = 50 % Employees Exposed and Example

40. Prioritizing Your Actions • Best method is generally a combination of the approaches • Ultimately dependent upon organizational philosophy

41. Hierarchy of Risk Control • Engineering controls • Administrative controls • Personal protective equipment • Better controls rely less upon human follow through • It may take a combination of controls to address a specific hazard

42. Hierarchy of Risk Control – Engineering Controls • Elimination/minimization of the hazard - Designing the facility, equipment, or process to remove the hazard, or substituting processes, equipment, materials, or other factors to lessen the hazard • Enclosure of the hazard using enclosed cabs, enclosures for noisy equipment, or other means • Isolation of the hazard with interlocks, machine guards, blast shields, welding curtains, or other means • Removal or redirection of the hazard such as with local and exhaust ventilation

43. Hierarchy of Risk Control – Administrative Controls • Written operating procedures, work permits, and safe work practices • Exposure time limitations (used most commonly to control temperature extremes and ergonomic hazards) • Monitoring the use of highly hazardous materials • Alarms, signs, and warnings • Buddy system • Training

44. Hierarchy of Risk Control – Personal Protective Equipment • May include hearing protection, protective clothing, safety glasses, and hardhats • Should only be used: • When engineering controls are not feasible or do not totally eliminate the hazard • While engineering controls are being developed • When safe work practices do not provide sufficient additional protection • During emergencies when engineering controls may not be feasible

45. Summary/Learning Objectives • After this session you should: • Explain the purpose of a needs assessment in regards to workplace safety. • Detail six methods to identify hazards in your workplace. • Summarize three methods to prioritize your efforts to improve workplace safety. • Describe the preferred risk control method.

46. Questions

47. Small Group Activity • Have teams write sample JSAs • Cutting a bagel • Shaving (with razor) • Making pizza • etc