Step 1: Develop a plan of action that includes both
management and employee involvement.
It is important to develop a program that will meet the
needs of both management and employees. An elegant safety and health program
manual that describes protective measures that are seldom put into practice
serves no useful function. This is why MOSH encourages management to
involve employee representatives in the development of the safety and health
program and to encourage their continued participation in company safety and health efforts.
Step 2: Designate a person to be responsible for safety and health.
In an effective safety and health program, the person
responsible for the safety and health program will have both the
authority to do the job and the respect of management and
employees. The choice of the safety and health director must be
based on his or her knowledge of the facility and of safety and
health requirements. The person or persons designated to do
training must be credible, respected, and knowledgeable about the
operations and must be given the time, authority and resources to develop an effective program.
Step 3: Determine the safety and health requirements for the
specific workplace and operations.
It is important to become familiar with the safety and health
requirements associated with the company’s physical location,
operations, and equipment. This information will be used to:
- Develop a hazard assessment strategy
- Pinpoint areas and procedures that historically have caused
significant injury or illness, and identify potential causes
- Provide a background for correction and control strategy planning
Resources that will aid in the determination of your workplace safety and health requirements include:
MOSH laws, regulations, and standards. Determine which
requirements apply to the specific workplace. It is not necessary
to become familiar with every law, regulation, and standard that
MOSH enforces, because not all standards apply to every industry.
Equipment manuals. Make a list of all the equipment used
in workplace operations and obtain the manufacturer's operating
manuals for each piece of equipment. Examine the manuals for:
- Recommended safety controls, such as guarding
- Potential hazards, such as noise or vibration
- Recommended maintenance schedules
Other sources of information about equipment hazards include
the National Electrical Code (NEC), the American National
Standards Institute (ANSI) codes for various industries and
equipment, and publications by the American Conference of Governmental Industrial Hygienists (ACGIH).
Chemical Inventory. Develop an inventory of chemicals used in the workplace. include:
- Chemical substances used
- Processes employed
- Quantities involved
- Potential hazards
- Safety controls
Knowledge of the chemicals used or stored in a company facility
is necessary for hazard assessment and program planning. It should
be initiated as part of assessment activities. Much of this
information also is required by the Maryland Access to
Information about Hazardous and Toxic Substances Act, also
known as the "Right to Know Law".
Employee capabilities: Make a list of all employees.
Include each employee's date of hire, job title, experience and
training, special skills (first aid trained, CPR trained, training
abilities, etc.) and special needs (people who have physical
disabilities, people who have visual impairments, etc.). This list
can be used to involve employees in the program, to use their
capabilities and talents most effectively, and to provide
appropriate protection where special needs require it.
Accident and injury/illness history: MOSH law requires
most employers to maintain records of occupational accidents,
injuries, illness, and lost workdays on a OSHA/MOSH log (OSHA
Form No. 300). Review these records to determine if there is a
concentration of injuries or illnesses related to a particular
department, operation, piece of equipment, process, or area. Also
determine if there is a consistency or pattern in the type of
injury, illness, or personnel involved. This information may point
to specific safety and health issues that should be addressed.
Existing safety and health materials: Review any
existing company safety and health materials and determine their usefulness.
Step 4: Conduct a hazard assessment of the workplace.
An effective safety and health program will systematically
identify and prevent hazards. An ineffective or non-existent program will not
identify hazards or potential hazards, and preventive controls will not be
implemented, leaving the possibility of injury or illness.
Develop an initial plan for assessing the workplace that addresses:
- The completion of a comprehensive safety and health survey of the workplace
- Approaches to problem areas noted during Step 3.
Conduct a safety and health self-inspection/survey of the workplace according to the plan developed
A comprehensive baseline survey of the work and working
conditions at a site permits a systematic record of the hazards and
potential hazards that can be recognized without intensive analysis. During
the initial comprehensive survey:
Identify any situations that present hazards or are in violation of law, regulations or standards.
Pay particular attention to areas which prior research indicated were potential problems, and determine
if a problem exists.
Assess the effectiveness of the survey plan, and revise, if necessary.
Although the person assigned responsibility for the
safety and health program may have extensive knowledge of the facility's
operations, additional knowledge is required to perform an effective safety
and health survey. The initial research performed as part of Step 3 will
assist in developing this expertise. The employer also may wish to solicit
assistance for the initial survey from MOSH, an insurance carrier, or a private consultant.
There are many approaches to workplace assessments. Factors influencing the most effective approach include:
- Whether the operation is consistent throughout the day or cyclical, or whether no obvious work pattern
- Whether the operation is a fixed site, mobile operation or combination. If it is a mobile worksite,
refer to the Construction section of this document.
- The complexity of operations
- The size of the worksite
Effective strategies for an initial workplace survey include:
Floor Plans: Prepare a floor plan of each department or work area. Mark on the plan all pertinent
machinery, processes, and facilities. Also note the standards or
requirements applicable to the machinery or process which must be
assessed; for example, guarding of machinery, noise level checks,
housekeeping, and chemical exposure levels. As you proceed through the
initial assessment, make additional notes on hazards observed, training needed, and monitoring required.
Checklists: Many employers use checklists that summarize the items to be included as part of a
facility survey. The checklists should be site specific and should
include each item to be checked in every area of the workplace.
Generic checklists available from various trade associations can be
used as a basis for the company checklist. It also may be necessary to
revise the checklist as the initial hazard assessment is conducted.
Process Flow: The simplest method
of proceeding with the hazard assessment may be to follow each process
from receiving area to shipping. This approach is effective when the
company's processes are fairly consistent and simple. It can be
coupled with the floor plan system or the checklist system.
Job Hazard Analysis: This method examines each job classification, rather than areas or processes, for
associated hazards. As a job classification is examined, associated
machinery, equipment, and chemical and other processes are reviewed.
Committee Survey: Frequently in large establishments, a safety committee will conduct hazard
assessment surveys. This approach permits several people with diverse
interests, perspectives and expertise to provide input. The committee
may consist of employee representatives, management representatives,
and persons knowledgeable in production, processes or machinery.
As the hazard survey proceeds, note areas where
additional investigation and expert consultation may be necessary. For
example, monitoring levels of airborne chemical substances or noise,
or additional research on equipment or chemical substances, may be
required. Also note conditions that might be alleviated through
employee training and education. Remember to pay particular attention
to those areas identified in Step 3 as having significant incident
occurrences. Also note areas where required personal protective equipment (PPE) is lacking.
This initial survey may take several sessions, and
repeated visits to certain areas may be required. Take the time to be
thorough. Following the survey, review your results. Start planning for future action.
- Provide for regular safety and health inspections.
During periodic inspections, identify new or previously
missed hazards and failures in hazard control. Question whether the
changes made to eliminate the original hazard may have created new
hazards. When initially identified hazards are under control, attention
can be given to the intensive analysis required to recognize less obvious
hazards. Subsequent comprehensive surveys provide an opportunity to step
back from the routine check on control of previously recognized hazards and look for new hazards.
Step 5: Correct identified hazards.
Hazards, once recognized, should be promptly abated or controlled.
Hazard abatement is an essential activity. Management
action at this point will determine the credibility of the company’s safety
and health policy, as well as the usefulness and effectiveness of the entire
workplace safety and health program.
All available resources should be devoted to this
objective. Keep in mind that recognized hazards might constitute violations of
MOSH laws, regulations, and standards. Should an enforcement inspection occur,
the company could be cited and monetary penalties issued. More importantly,
these conditions present hazards to employees that could result in injury,
illness, property or production loss, or even loss of life.
- Develop a plan of action and a method of tracking the correction of all hazards.
- Correct all identified hazards.
- Implement interim protective measures while taking corrective action.
- Provide all required personal protective equipment.
- Comply with all requirements specified in equipment manuals.
Financial resources may be required to correct some
hazards. This is a part of doing business in a safe and healthful manner.
Court decisions have emphasized that economic feasibility is not a valid
excuse for violating an adopted standard.
Every reasonable effort must be made to provide adequate
funding to protect the workplace safety and health of employees. It may be
necessary to prepare documentation to justify expenses associated with hazard
abatement. In addition, long term planning and expert advice may be required.
Costs can be minimized with proper planning and research. Remember that
financial commitment to safety and health is a strong indicator of
management's overall commitment.
Employee involvement can help. When there are
alternative ways to address a hazard, effective managers have found that
involving employees in discussions of methods can identify useful prevention
and control measures, serve as a means for communicating the rationale for
decisions made, and encourage employee acceptance of the decisions.
Correction of some hazards may take a long time. To
eliminate hazards, workstations, work methods and tools may have to be
designed or modified. Research into substitute materials may be necessary. New
equipment may have to be purchased or existing equipment may have to be repaired or redesigned.
Interim measures may be necessary. For those items that
cannot be corrected immediately, an effective program provides interim
measures for the protection of the employees. These can vary greatly, but
should include advising employees of the existing hazards and how to minimize
the danger while corrective measures are being taken.
Interim measures may include requiring the use of personal
protective equipment, installing temporary guarding, posting signs to remind
employees of particular hazards, and taking certain pieces of equipment out of
service. Remember, if personal protective equipment is issued, training must
be provided to assure effective usage. The employer must also take steps to
maintain the equipment in sanitary and operational condition.
Address other program elements while completing hazard
abatement. Other safety and health program elements are integral to
correction of hazards. As hazard correction progresses, an effectively managed
program will continue to work on:
Safety work rules
Training programs for employees
Medical surveillance programs
For example, an employer may initiate the training that is
part of the five essential elements of a safety and health program. This
training also may be a required step for correction of a violation of MOSH
requirements, such as the training required under the Maryland Access
to Information About Hazardous and Toxic Substances law.
Step 6: Keep the workplace hazard-free.
Once recognized hazards are corrected, take steps to ensure that the workplace remains hazard-free.
- Develop work practices, administrative controls, work rules and emergency procedures.
- Provide for facility and equipment maintenance to prevent hazardous breakdowns.
Work rules and emergency procedures. Work rules, practices, and
emergency procedures must be specific to each workplace. For some locations it
may be appropriate to have generalized rules and procedures. For other
locations, very detailed procedures may be necessary. The formality and
complexity of work rules and emergency procedures are influenced by a number of factors including:
- The size and stability of the workforce
- The types of processes involved and the level of hazard the processes pose
Whether the workplace is fixed, mobile, dispersed or a combination
Rules and procedures should be clearly stated and
understandable. Although it is not always required that work rules and
emergency procedures be in writing, it is recommended. The written material
provides an historical record that can be reviewed and revised periodically,
and also can serve as documentation of site specific requirements.
Additionally, a number of MOSH standards require work
rules, work practices, and emergency procedures. For example, almost all
workplaces must have provisions for emergencies, basic first aid, and a plan to address fire hazards.
If administrative controls are used to reduce employee
exposures, it is important to formalize the system and document the
procedures. For example, administrative controls may involve rotating
employees or altering work hours to reduce exposure to acceptable levels.
This is also an appropriate time to review operations that
occur infrequently. It is particularly important to develop written procedures
for these operations since the procedures are not often used and may be forgotten.
Enforcement. Once the procedures are established, it is important to
develop a means for enforcing them. Enforcement is particularly important
initially, when management will experience the most resistance to the changes
the rules and procedures will require. Rules without enforcement frequently are violated.
Workplace discipline reinforces a safety and health program
in two ways. It removes the employee and his or her coworkers from the danger
of the unsafe work practice, and it reinforces the message to all employees
that management is committed to safety and health.
It is important to work with employee representatives to
develop enforcement procedures. It may be worthwhile to involve employees in
the development of both the rules and enforcement measures through safety committees.
Equipment maintenance and status checks. Equipment maintenance and
status check programs should be considered at this time. Maintenance of
equipment and facilities is an especially important means of anticipating
potential hazards and preventing their development. Planning, scheduling, and
tracking preventive maintenance activities provides a systematic way of
ensuring that equipment and facilities are not neglected. It may also prolong
the usefulness of expensive equipment.
Step 7: Train Employees in Safety and Health.
Most employers must provide some training for employees. For example, MOSH standards
require that most employers provide training concerning:
- Employee emergency plans and fire protection plans
- Personal protective equipment
- Maryland’s "Right to Know" Law
An employer also must inform and train employees about the company safety and health
program, how it is intended to benefit employees, and what is
expected of employees in order to make the program work.
OSHA publication. Training Requirements in OSHA Standards and Training Guidelines
(OSHA publication 2254) lists OSHA standards that require employee training. MOSH
also has adopted several State-specific standards that may require
training for employees. Additionally, new standards adopted by
OSHA and MOSH may affect your workplace and require additional training.
Requirements are results-oriented. Although
many standards require that particular topics be covered during
training, the approach to providing the training is left to the
employer. Generally, MOSH expects training to result in the employee
being able to explain how to perform his or her assignments safely,
and to be able to identify the hazards associated with the job.
An employer should 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. A thorough understanding of the
hazards and their prevention will affect employee acceptance and
use of established safety and health protections. Training for
this purpose is reinforced by encouraging attempts to work safely
and by positive recognition of safe behavior.
Ensure that training is conducted by someone knowledgeable about the subject and familiar
with the workplace.
Consider employees’ ability to read, speak, and understand English.
Schedule short training sessions. It is better to divide training into several sessions
rather than to conduct one long session.
Use audio-visual presentations, actual experiences, and workplace conditions to illustrate points.
Incorporate drills, demonstrations and hands-on practice to ensure that training is
understood. Drills should include emergency action drills.
Provide a period for questions.
Verify the effectiveness of training through paper and pencil tests, oral questioning,
employee skill demonstrations, and observation of employee work habits after training.
Retraining required. Employee training
is a long-term commitment and must be repeated periodically. Re-training
should be scheduled on an annual basis. Additional training should
be provided when employee actions indicate a need for earlier
or more frequent retraining.
New employees. New employees need training prior to starting work that would expose them to hazards.
Transfer employees will also require training whenever they are
exposed to new hazards. This need is reflected by the disproportionately
high injury rates among workers newly assigned to work tasks.
Although some of these injuries may be attributable to other causes,
a substantial number are directly related to inadequate knowledge
of job hazards and safe work practices.
Step 8: Keep the program up-to-date and effective.
At this point, much of what an employer must do to implement an effective program
has been accomplished. The employer can now attend to program
maintenance: coordination of the program, documentation of program
details, addition of new work practices and hazard controls, and
continuation of enforcement. Each of these components may vary
in detail and formality, depending on the size and complexity
of the workplace. Many of these items may have been completed
during development of other steps of the program.
Documentation: An important part of any safety and health program, documentation provides:
An historical reference that can be reviewed to determine program effectiveness
An accessible document to which management and employees can refer when unsure of proper
Evidence of the employer's efforts to provide a safe and healthful work environment
All employers must maintain:
- The MOSH poster (posted)
- The OSHA 300 Log and Summary of Occupational Injuries and
Illnesses (except employers who have ten or less employees in
the course of a year, and employers in exempt SIC codes)
- OSHA 101 Supplementary Record of Occupational Injuries and Illnesses or workers’ compensation
- A written hazard communication program
- Emergency procedures
- Administrative control programs where used in place of engineering controls
Many MOSH standards require some form of documentation for sampling results, medical surveillance,
equipment inspection, personal protective equipment programs, and other activities.
Employers also must maintain documentation if required by applicable standards for
the following procedures:
- environmental monitoring, including noise and chemical sampling
- exposure control programs required under many of the air contaminant standards
- employee medical records as part of any medical surveillance program
- records of employee testing for personal protective equipment programs when respirators
or hearing protection is required
- certifications for inspection programs for cranes and forklifts
It is strongly recommended that the employer provide some level of documentation for the following:
- all employee training
- safety rules and procedures for employees
- workplace self-inspections
- accident investigations
- accident investigations
Refer to the applicable standard to determine what the documentation must include, who
must have access to the documentation, and how long the records must be maintained.
MOSH can help. Development of an occupational safety and health program may not be an easy task,
but the benefits far outweigh the effort. Identifying potential
hazards may be one of the most difficult tasks in the process.
MOSH can serve as a resource in obtaining information and acquiring
answers to compliance questions. MOSH has a free consultation
program to assist small businesses with on-site problems. All
of the MOSH professional staff stands ready to assist you with your questions.
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