Health & Safety Management Jerry Henderson, CSHO University of Texas at Arlington
29 CFR 1900.1 Proposed Safety and Health Program Rule
Scope • All employers covered by the Act except construction and agriculture. • The rule applies to hazards covered by General Duty Clause and OSHA Standards. Everyone! Who’s Covered Everything! What’s Covered
Management’s Basic Obligation … “manage workplace safety and health to reduce injuries, illnesses and fatalities by systematically achieving compliance with OSHA standards and the General Duty Clause.”
Management’s Basic Obligation … “manage workplace safety and health to reduce injuries, illnesses and fatalities by systematically achieving compliance with OSHA standards and the General Duty Clause.” Big Rocks
Core Elements of Program • (i) Management leadership and employee participation; • (ii) Hazard identification and assessment; • (iii) Hazard prevention and control; • (iv) Information and training; and • (v) Evaluation of program effectiveness.
Grandfather Clause? • Yes! • Meets basic obligation for each core element; and • Employer can demonstrate effectiveness of any component that differs from core elements.
Management Leadership The employer must demonstrate management leadership of the safety and health program.
Management Leadership The employer must demonstrate management leadership of the safety and health program. by
DuPont Leadership Demonstration • program responsibilities of managers, supervisors, and employees… …and hold them accountable. • Provide managers, supervisors, and employees with the authority, access to relevant information, training, and resources they need to carry out their safety and health responsibilities
Leadership Demonstration • (C) Identify at least one manager, supervisor, or employee to receive and respond to reports about workplace safety and health conditions and, where appropriate, to initiate corrective action. Safety Manager
Employee Participation • The employer must provide employees with opportunities for participation in establishing, implementing, and evaluating the program.
Employee Participation • (A) Regularly communicate with employees about workplace safety and health matters; • (B) Provide employees with access to information relevant to the program; • (C) Provide ways for employees to become involved in hazard identification and assessment, prioritizing hazards, training, and program evaluation;
Employee Participation • (D) Establish a way for employees to report job-related fatalities, injuries, illnesses, incidents, and hazards promptly and to make recommendations about appropriate ways to control those hazards; and • (E) Provide prompt responses to such reports and recommendations.
Whistle-Blower? The employer must not discourage employees from making reports and recommendations about fatalities, injuries, illnesses, incidents, or hazards in the workplace, or from otherwise participating in the workplace safety and health program.
Hazard Identification and Assessment • Employer must systematically identify and assess hazards to which employees are exposed and assess compliance with the General Duty Clause and OSHA standards.
Hazard Identification and Assessment • (i) Conduct inspections of the workplace; • (ii) Review safety and health information; • (iii) Evaluate new equipment, materials, and processes for hazards before they are introduced into the workplace; and • (iv) Assess the severity of identified hazards and rank those that cannot be corrected immediately according to their severity. Big Rocks
Assessment - How Often??? • (i) Initially; • (ii) As often thereafter as necessary to ensure compliance with the General Duty Clause and OSHA standards and at least every two years; and
Assessment - How Often??? • (iii) When safety and health information or a change in workplace conditions indicates that a new or increased hazard may be present.
Employer Investigation? The employer must investigate each work-related death, serious injury or illness, or incident (near-miss) having the potential to cause death or serious physical harm.
Records Employer Must Keep? The employer must keep records of hazards identified and the actions taken or plans to take control of those hazards identified.
Are you melting the whole… Fatalities Equipment Damage Lost Time Injuries Environmental Accidents Customer Complaints INCIDENTS With potential to cause major accidents, production outages, or environmental damage. NEAR MISSES Or close calls with minor consequences. PROBLEMS Such as at-risk behaviors, unreliable equipment, unsafe conditions, quality issues, excessive human errors, environmental permit violations, bad designs…. ICEBERG?
Accident Relational Pyramid 1 Fatality Serious Injuries 10 Minor Injuries 30 Near-Misses 600
Accident Relational Pyramid 1 Fatality Serious Injuries 10 Minor Injuries 30 Near-Misses 600
Near Miss is 3 seconds on either side of a Fatality 3 2 2 1 1 Near Miss Minor Serious Fatality
Accident Relational Pyramid 1 Fatality Serious Injuries 10 Minor Injuries 30 Near-Misses 600
Accident Relational Pyramid 1 Fatality 10 Serious Injuries Minor Injuries 30 Near-Misses 600
Eliminate Accident Relational Pyramid 10 Serious Injuries Reduce Minor Injuries 30 Near-Misses 600
eTools
$afety Pays
Crushing
Crushing $9,195,565
Hazard Prevention and Control • The employer's basic obligation is to systematically comply with the hazard prevention and control requirements of the General Duty Clause and OSHA standards.
Hazard Prevention and Control • The employer's basic obligation is to systematically comply with the hazard prevention and control requirements of the General Duty Clause and OSHA standards. If not immediately
Hazard Prevention and Control • The employer's basic obligation is to systematically comply with the hazard prevention and control requirements of the General Duty Clause and OSHA standards. If not immediately • The employer must develop a plan for coming into compliance as promptly as possible, which includes setting priorities and deadlines and tracking progress in controlling hazards.
Information & Training Program Evaluation
Effective Dates
Effective Dates -10 +10 c. Management Leadership f. Information & Training 18 Mo. 9 Mo. h. Multi-employer Worksites d. Hazard Assessment e. Hazard Prevention & Control 36 Mo. 18 Mo. g. Evaluation
Questions??? Thank You
