OSHA Update and Safety and Health Management Systems

1. OSHA Update and Safety and Health Management Systems 2009 DOL Forum Jim Shelton, Houston North

2. Topic Areas • OSHA Update and Emphasis Areas • Business Case • Elements of an Effective Safety Program • OSHA Compliance Assistance Overview • Finding Safety Resources

3. OSHA Update • New Deputy Assistant Secretary and Acting Assistant Secretary Donald Shalhoub • Updated Field Operations Manual (CPL 02-00-148 replaces the Field Inspection Reference Manual (FIRM) • Advanced Notice of Proposed Rulemaking related to combustible dust

4. OSHA Update • Stimulus Work – Looking for outreach possibilities for companies involved in stimulus work, green or renewable energy ect. • Industrial Hygiene – Look for increased OSHA outreach and enforcement related to industrial hygiene including increased air monitoring and sampling for potential over exposures

5. Emphasis Industries • FY 09 Operational Plan Industries: • Highway, Street, and Bridge Construction • Landscaping/Horticultural Services • Oil and Gas Field Services • Residential Building Construction • Blast Furnaces and Basic Steel Products • Concrete and Concrete Products • Fruits and Vegetables

6. Emphasis Hazards • FY 09 Operational Plan Hazards: • Combustible Dust • Electrical • Falls from Elevation • Noise (Non-Construction) • Silica • Struck-By • Trenching

7. National Emphasis Programs • PSM Refineries (NEP) • Silica (NEP) • Amputations (NEP) • Combustible Dust (NEP) • Trenching (NEP) • Falls (NEP) • Portland Cement

8. Regional Emphasis Programs • Construction (REP) • Demolition (REP) • Powerlines (REP) • Work Zone (REP) • Cranes in Construction (REP) • Falls in General Industry (REP) • Highway & Bridge Construction and Maintenance (REP) • High Noise Industries (REP)

9. H1N1 Influenza • OSHA has a number of publications and resources addressing pandemic flu • Preparations and planning are important in the event this or another virus emerges Typist During 1918 Influenza

10. H1N1 Influenza • The CDC recommends: • Employees should be alert for the symptoms of influenza. If you exhibit such symptoms as fever, cough, sore throat, body aches, headache, and chills, you should request leave from your supervisor, stay home, and limit contact with other people to prevent the spread of infection. Seek appropriate medical attention, and follow any instructions from your primary care provider

11. H1N1 Influenza • Practice good hygiene. Wash your hands often with soap and water, especially after your cough or sneeze, after using the restroom, and before touching your eyes, mouth, or nose. Alcohol-based hand cleaners are also effective if soap and water are not readily available • Practice good respiratory etiquette. Sneeze or cough into a tissue; then carefully dispose of the tissue in a waste receptacle

12. H1N1 Influenza • Avoid sneezing or coughing in the direction of other employees, and avoid sneezing into your bare hands • Employees who work in healthcare or laboratory settings may require additional precautions • Additional information can be found at http://www.cdc/swineflu/guidance/

13. H1N1 Influenza

14. H1N1 Influenza

15. H1N1 Influenza OSHA 3328-05 OSHA 3323-10N OSHA 3327-02N

16. Business Case for Safety • According to Liberty Mutual Research Institute for Safety for every $1 invested in safety there is between $3 and $6 in savings • Accidents with or without injury may also result in property damage, equipment replacement costs, downtime, and unhappy customers • Workers compensation premiums and Experience Modification Rates (EMR) affect your bottom line. Lowering your EMR by buying down or paying smaller claims out of pocket still costs you money

17. Business Case for Safety • If you’re at 0.71 and prevented all accidents you would save $66,000 in premiums • If your at 1.00 and your competitor is at 0.71 you are at a $58,000 per year disadvantage. If he’s at 0.38 you’re at a $124,000 disadvantage. Information Courtesy of Liberty Mutual, Houston, TX

18. Business Case for Safety Direct Costs *Medical Costs *Indemnity Payments Indirect Costs *Lost time by: - Injured - Co-workers - Supervisor *Spoiled product *Loss of customers *Cleanup time *Production delays *Training new workers *Overhead costs *Legal fees *Rise in insurance costs

19. Business Case for Safety Foreign body in the eye - Direct cost of $317* + indirect cost of $1394 = $1711 total cost. A 5% profit margin requires $34,236 in sales to cover The 2003 average cost of a WC injury claim in Texas was $3,078**…$98,000 in sales to cover * Argonaut Insurance Average Claims 1992-1994 ** TDI WC Research Group Medical Cost Trends in TX - 2004

20. Business Case for Safety • OSHA has found comprehensive safety and health programs reduce injury and illness rates an average of 20% • Accident costs go directly to the bottom line • Many companies won’t hire you if have an EMR over 1.00 or an injury rate above the national average and many review your OSHA citation history • Your safety performance affect the financial well being and competitiveness of your company and the lives of your work crews

21. Characteristics of Exemplary Pgms • Uses organized and systematic methods to: • Assign responsibility to managers, supervisors, and employees • Inspect regularly for and control hazards • Orient and train all employees to eliminate or avoid hazards

22. General Guidelines • An effective program • Includes provisions for systematic identification, evaluation and prevention or control of hazards • Goes beyond specific requirements of the law to address all hazards • Written program • “In writing” less important than effectiveness • As size and complexity of worksite or process increases, so does need for written guidance

23. Major Elements • An effective occupational safety and health programs include: • Management commitment and employee involvement • Worksite analysis • Hazard prevention and control • Safety and health training

24. Commitment and Involvement • Management commitment and employee involvement are complementary • Management commitment provides the motivating force and resources for organizing and controlling activities within an organization • Employee involvement provides the means through which workers develop and express their own commitment to S&HG protection

25. Commitment and Involvement • Recommended Actions: • State clearly a worksite safety and health policy • Establish and communicate a clear goal and objective for the safety and health program • Provide visible top management involvement in implementing the program

26. Commitment and Involvement • Recommended Actions: • Encourage employee involvement in the program and in decisions that affect their safety and health (e.g., inspection or hazard analysis teams; developing or revising safe work rules; training new hires or co-workers; assisting in accident investigations) • Assign and communicate responsibility for all aspects of the program

27. Commitment and Involvement • Recommended Actions: • Provide adequate authority and resources to responsible parties • Hold managers, supervisors, and employees accountable for meeting their responsibilities • Review program operations at least annually, to evaluate, identify deficiencies, and revise, as needed

28. Worksite Analysis • Worksite analysis involves a variety of worksite examinations, to identify not only existing hazards, but also conditions and operations where changes might occur to create hazards • Effective management actively analyzes the work and the worksite to anticipate and prevent harmful occurrences

29. Worksite Analysis • Recommended Actions: • Conduct comprehensive baseline and periodic surveys for safety and health • Analyze planned and new facilities, processes, materials, and equipment • Perform routine job hazard analyses

30. Worksite Analysis • Recommended Actions: • Provide for regular site safety and health inspections • Provide a reliable system for employees, without fear of reprisal, to notify management about apparent hazardous conditions and to receive timely and appropriate responses

31. Worksite Analysis • Recommended Actions: • Provide for investigation of accidents and “near miss” incidents, so that their causes and means for prevention are identified • Analyze injury and illness trends over time, so that patterns with common causes can be identified and prevented

32. Hazard Prevention and Control • Triggered by a determination that a hazard or potential hazard exists • Where feasible, prevent hazards by effective design of job or job site • Where elimination is not feasible, control hazards to prevent unsafe and unhealthful exposure • Elimination or control must be accomplished in a timely manner

33. Hazard Prevention and Control • Recommended Actions: • Establish procedures for timely correction or control of hazards, including • Engineering techniques, where feasible and appropriate • Procedures for safe work which are understood and followed as a result of training, positive reinforcement, correction of unsafe performance, and enforcement • Provision of personal protective equipment • Administrative controls

34. Hazard Prevention and Control • Recommended Actions: • Provide for facility and equipment maintenance • Plan and prepare for emergencies • Training and drills, as needed • Establish a medical program • First aid on site • Physician and emergency care nearby

35. Safety and Health Training • Addresses the safety and health responsibilities of all personnel, whether salaried or hourly • Most effective when incorporated into other training about performance requirements and job practices • Complexity depends on size and complexity of worksite and nature of hazards

36. Safety and Health Training • Recommended Actions: • Ensure that all employees understand the hazards to which they may be exposed and how to prevent harm to themselves and others from exposure to these hazards

37. Safety and Health Training • Recommended Actions: • Ensure that supervisors carry out their safety and health responsibilities, including • Analyzing the work under their supervision to identify unrecognized potential hazards • Maintaining physical protections in work areas • Reinforcing employee training through continual performance feedback and, if needed, enforcement of safe work practices

38. Safety and Health Training • Recommended Actions: • Ensure that managers understand their safety and health responsibilities, as described under the Management Commitment and Employee Involvement element of the guidelines

39. Education and Outreach • Compliance Assistance Specialists (CAS) • Each OSHA Office nation-wide • Non-Enforcement • VPP Coordinators • Each OSHA Office in Region VI • Enforcement position

40. Alliances • Builds trusting and cooperative relationships • Training, outreach, education, promoting safety dialogue • Last up to two years

41. Partnerships • Partnerships are written and identify goals, strategies, performance measures, etc. • Must have a measurable impact • Like alliances, you can withdrawal at any time • Last up to five years

42. OSHA Cooperative Programs Voluntary Protection Program: • 1367+ Federal sites • 265+ Region VI • 130+ Houston offices • VPP Mobile Workforce for construction is here

43. OSHA Cooperative Programs • Voluntary Protection Program Elements: • Management Leadership and Employee Involvement • Worksite Analysis • Hazard Prevention and Control • Safety and Health Training • Few companies ever voluntarily leave VPP

44. OSHA Challenge Program • Run by Challenge Administrators • Three stage process of implementing a comprehensive safety program based on VPP principles. No set time for completion • OSHA is not involved except for recognition at the completion of a stage • Goal is that once completed the company is ready to apply for VPP www.oshachallenge.net

45. OSHCON • The OSHA Consultation Service (OSHCON) is under the Texas Department of Insurance (TDI) • Located in every State • Funded primarily by Federal OSHA • Provides free safety consultation services to small employers – 250 in one location no more than 500 corporate wide http://www.tdi.state.tx.us/wc/safety/oshcon.html

46. OSHA Website • OSHA Website www.osha.gov • OSHA QuickTakes – a bi-weekly update by email on what’s new with OSHA

47. OSHA Website • eTools • Electronic tools covering various industries and hazards such as construction, lockout/tagout, scaffolds, etc.

48. OSHA Website • Safety and Health Topics Pages • Covers variety of topics. Overview of information with links to resources • Many developed with industry through the OSHA Alliance program

49. RESOURCES - INDEX OSHA Consultation Training Resources State-Planned State Resources Region VI OSHA Training Institutes CDC/NIOSH Other Resources Disasters Harwood Grant Materials FAQs Oil and Gas E & P OSHA Cooperative Programs Safety Management

50. OSHA 1 of 4 • OSHA Home Page • OSHA QuickTakes • Sign up for a bi-weekly update on OSHA activities • OSHA Compliance Assistance Page • Tools and information for assisting companies in their safety programs • Introduction and review of OSHA standards that may apply to your workplace • eTools, Expert Advisors, and eMatrix interactive tools walk you through various hazards and industries