Annette Olesen CIH, CET Cynthia Mellen CSP Occupational Safety and - - PowerPoint PPT Presentation

OSHA Consultation Program Annette Olesen CIH, CET Cynthia Mellen CSP

• Occupational Safety and Health Act of 1970

 Enforcement  Consultation

• Each State and US Territory must provide safety and health

consultation services

• Funded by
• Federal OSHA at 90%
• IUP and PA DOL at 10%
• 1 of 8 university based programs
• Pennsylvania is the 2nd largest in U.S.

• To assist PA employers with:

complying with OSHA standards saving workers lives and their livelihoods preventing needless occupational injuries, illnesses and disabilities minimizing property damage and costs avoiding OSHA penalties, fines and criminal prosecutions reducing workers compensation costs attaining and sustaining economic viability

 Program Director: Sam Gualardo  Safety and Health Consultants (10)

 All are Board Certified Professionals  CSPs or CIHs  Strategically located throughout PA

 Administrative Staff (2)

• Small-and medium-sized businesses

250 employees at a single site or 500 corporate wide

• Priority assistance given to:

employers in high-hazard industries involved in hazardous operations

• Large business requests honored as well…but

limited scope

• Onsite at YOUR company:

Physical hazard evaluations Industrial hygiene exposure monitoring Regulatory required program assessment and development assistance Regulatory required training assessment and delivery Post OSHA inspection compliance assistance Safety and health management program development assistance…

 leading to OSHA inspection deferral (Pre-SHARP)  SHARP

• Offsite

Daily telephone E-mail assistance Interventions Presentations and seminars

• Requests received and assigned to consultants
• Onsite visit

 Opening conference

• Review of regulatory program
• Training
• Recordkeeping requirements

 Walkthrough of facility

• Physical hazards evaluation

 Closing conference

• Report generated with

 Specific hazards  Correction recommendations  Completion timelines

• Different than OSHA enforcement

No Citations issued No Penalties imposed

• The “catch”

 Employer must agree to correct t any

 “serious” hazards identified (within agreed upon time period)  “imminent danger” identified (immediately)

 Must refer to OSHA Enforcement if employer fails to provide documentation of hazard correction…very rare !

• Must maintain total employer confidentiality
• Cannot divulge any information to:
• OSHA Enforcement
• Lawyers pursuing liability cases
• Protected from subpoena's

A request fo for Consulta ltati tion

• n Services

s wi will not trigger r an OSHA inspection… It may prevent one and will defi finitely y reduce the impact t if o f one occurs! s!

• Must have:
• An exemplary safety and health management system.
• OSHA rates better than their industry average
• Exempt from OSHA programmed inspections…

for up to 3 years

 Be a single, fixed worksite  Have at least a one (1) year of operating history  Exhibit a reasonable promise of achieving agreed-

upon milestones and time frames for SHARP participation

 Priority for Pre-SHARP/SHARP participation will be

given to employers with 250 or less employees

• nsite.

 CANNOT

NOT have an incentive program that would:

• Discourage Reporting Injury and illness:

 Forms of recognition to a unit that has the greatest reduction in incidence rates  awarding paid time off or other benefits  Rewarding workers with a pizza party for achieving an injury/ rate reduction goal or maintaining an injury and illness free worksite for a period of time

• Discourage Workplace involvement

 Acceptable Incentives are those that

PROMOTE and ENCOURAGE:

• safety awareness
• Injury and illness reporting
• Worker involvement
• Positive incentive program encourages or rewards workers for
• Reporting injuries, illnesses, near-misses or hazards
• Involvement in Injury and Illness prevention programs



Receive a full service safety and health consultation visit, and a comprehensive review of their safety and health management system.



Receive a score of at least “two” on all fifty basic attributes of the Safety and Health Program Assessment Worksheet (OSHA Form 33).



Correct all hazards identified by the consultants:



imminent danger



serious



• ther-than-serious



regulatory

 Agree to notify the program director and request a

subsequent on-site consultation visit when

• changes in working conditions or
• work processes occur that may introduce new hazards into the

workplace.

 Submit a request for Pre-SHARP or SHARP participation and

an Action Plan or Achievement Plan to the program director.

 Currently 54

54 Pennsylvania companies in SHARP

• Are not able to meet all the SHARP eligibility criteria
• Are committed to working toward full SHARP approval
• Can meet all SHARP requirements during the deferral

period

• May be recommended for an inspection deferral… up

to 18 months

• Currently 4

4 Pennsylvania Companies in Pre-SHARP

Safety and Health Assessment Worksheet

Operational Cultural Managerial

Seven Categories:

• 1. Hazard Anticipation & Detection
• 2. Hazard Prevention & Control
• 3. Planning and Evaluation
• 4. Administration and Supervision
• 5. Safety and Health Training
• 6. Management Leadership
• 7. Employee Participation

 0=No  1=No Needs major improvement;  2=Yes Needs minor improvement;  3=Yes  NA= Not Applicable;  NE= Not Evaluated;  *=Stretch items Attribute of Excellence

Focus on workplace hazards

 Concerns workplace hazards

• Hazard Anticipation & Detection

 Attributes 1-10

• Hazard Prevention & Control

 Attributes 11-19

Legend: 0 = No; 1 = No, Needs major improvement; 2 = Yes, Needs minor improvement; 3 = Yes; NA = Not Applicable; NE = Not Evaluated * = Stretch Items Attribute of Excellence Detection

HAZARD ANTICIPATION AND DETECTION

1 2 3 NA NE

• 1. A comprehensive, baseline hazard survey has been conducted within the past five (5) years.
• 2. Effective safety and health self-inspections are performed regularly.
• 3. Effective surveillance of established hazard controls is conducted.
• 4. An effective hazard reporting system exists.
• 5. Change analysis is performed whenever a change in facilities, equipment, materials, or processes occurs.
• 6. Accidents are investigated for root causes.
• 7. Material Safety Data Sheets are used to reveal potential hazards associated with chemical products in the workplace.
• 8. Effective job hazard analysis is performed.
• 9. Expert hazard analysis is performed.
• 10. *Incidents are investigated for root causes.

 A comprehensive baseline hazard

survey has been conducted in the past five years

 Effective safety and health inspections

are performed regularly

 Effective surveillance of established

hazard controls is conducted

 An effective hazard reporting

system exists

 Change analysis is performed

when a change in:

• facilities equipment,
• materials, or
• processes occurs

 Accidents are investigated for

root causes

 SDSs are used to reveal potential

hazards

 Effective Job Hazard Analysis is

performed

 Expert Hazard Analysis Performed  *Incidents are investigated for

root causes

Legend: 0 = No; 1 = No, Needs major improvement; 2 = Yes, Needs minor improvement; 3 = Yes; NA = Not Applicable; NE = Not Evaluated * = Stretch Items Attribute of Excellence Detection

HAZARD PREVENTION AND CONTROL

1 2 3 NA NE

• 11. Feasible engineering controls are in place.
• 12. Effective safety and health rules and work practices are in place.
• 13. Applicable OSHA-mandated programs are effectively in place.
• 14. Personal protective equipment is effectively used.
• 15. Housekeeping is properly maintained.
• 16. The organization is properly prepared for emergency situations.
• 17. The organization has an effective plan for providing competent emergency medical care to employees and others

present at the site.

• 18. *Effective preventive maintenance is performed.
• 19. An effective procedure for tracking hazard correction is in place.

 Feasible engineering controls  Effective S&H rules and work practices  Applicable OSHA mandated programs  PPE effective  Housekeeping  Prepared for emergencies  Competent medical care  *Effective PM performed  Effective tracking of hazard corrections

Focus on effect of traditional managerial functions

• Planning & Evaluation

 Attributes 20-25

• Administration & Supervision

 Attributes 26-33

• Safety & Health Training

 Attributes 34-39

Legend: 0 = No; 1 = No, Needs major improvement; 2 = Yes, Needs minor improvement; 3 = Yes; NA = Not Applicable; NE = Not Evaluated * = Stretch Items Attribute of Excellence Detection

PLANNING AND EVALUATION

1 2 3 NA NE

• 20. Workplace injury/illness data are effectively analyzed.
• 21. Hazard incidence data are effectively analyzed.
• 22. A safety and health goal and supporting objectives exist.
• 23. An action plan designed to accomplish the organizations safety and health objectives is in place.
• 24. A review of in-place OSHA-mandated programs is conducted at least annually.
• 25. *A review of the overall safety and health management system is conducted at least annually.

 Injury/ Illness data are effectively

analyzed

 Hazard incidence data are effectively

analyzed

 S& H Goal and supporting objectives

exist

 Action plan for objectives is in place

 Annual review of in place OSHA

mandated programs

 *Annual review of overall S&H

management system

Legend: 0 = No; 1 = No, Needs major improvement; 2 = Yes, Needs minor improvement; 3 = Yes; NA = Not Applicable; NE = Not Evaluated * = Stretch Items Attribute of Excellence Detection

ADMINISTRATION AND SUPERVISION

1 2 3 NA NE

• 26. Safety and health program tasks are each specifically assigned to a person or position for performance or

coordination.

• 27. Each assignment of safety and health responsibility is clearly communicated.
• 28. *An accountability mechanism is included with each assignment of safety and health responsibility.
• 29. Individuals with assigned safety and health responsibilities have the necessary knowledge, skills, and timely

information to perform their duties.

• 30. Individuals with assigned safety and health responsibilities have the authority to perform their duties.
• 31. Individuals with assigned safety and health responsibilities have the resources to perform their duties.
• 32. Organizational policies promote the performance of safety and health responsibilities.
• 33. Organizational policies result in correction of non-performance of safety and health responsibilities.

 S&H tasks specifically assigned  Assignment is clearly communicated  *Accountability included with assignment  Individuals assigned have the necessary:

• knowledge, skills to perform duties
• authority to perform duties
• resources to perform duties

 Individuals rewarded or disciplined for meeting S&H

responsibilities

Legend: 0 = No; 1 = No, Needs major improvement; 2 = Yes, Needs minor improvement; 3 = Yes; NA = Not Applicable; NE = Not Evaluated * = Stretch Items Attribute of Excellence Detection

SAFETY AND HEALTH TRAINING

1 2 3 NA NE

• 34. Employees receive appropriate safety and health training.
• 35. New employee orientation includes applicable safety and health information.
• 36. Supervisors receive appropriate safety and health training.
• 37. *Supervisors receive training that covers the supervisory aspects of their safety and health responsibilities.
• 38. Safety and health training is provided to managers.
• 39. *Relevant safety and health aspects are integrated into management training.

 Employees

• Co-Workers
• New employee orientation

 Supervisors

• Knowledge of S&H
• *Supervisory aspects of S&H responsibilities

 Managers

• *S&H aspects are integrated in their training

Focus on the values and principles mutually held by members of an organization

• Management Leadership

 Attributes 40-49

• Employee Participation
• Attributes 50-58

Legend: 0 = No; 1 = No, Needs major improvement; 2 = Yes, Needs minor improvement; 3 = Yes; NA = Not Applicable; NE = Not Evaluated * = Stretch Items Attribute of Excellence Detection

MANAGEMENT LEADERSHIP

1 2 3 NA NE

• 40. Top management policy establishes clear priority for safety and health.
• 41. Top management considers safety and health to be a line rather than a staff function.
• 42. *Top management provides competent safety and health staff support to line managers and supervisors.
• 43. Managers personally follow safety and health rules.
• 44. Managers delegate the authority necessary for personnel to carry out their assigned safety and health

responsibilities effectively.

• 45. Managers allocate the resources needed to properly support the organizations safety and health system.
• 46. Managers assure that appropriate safety and health training is provided.
• 47. Managers support fair and effective policies that promote safety and health performance.
• 48. Top management is involved in the planning and evaluation of safety and health performance.
• 49. Top management values employee involvement and participation in safety and health issues.

 Top Management:

• Establishes clear priority for S&H
• Considers S&H a “line” function
• *Provides competent staff assistance
• Involved in planning and evaluation of S&H performance
• Values employee involvement and participation

 Managers:

• Personally follow S&H rules
• Delegate authority
• Allocate the resources needed
• Ensure S&H training provided
• Support fair and effective reward/ disciplinary policies

Legend: 0 = No; 1 = No, Needs major improvement; 2 = Yes, Needs minor improvement; 3 = Yes; NA = Not Applicable; NE = Not Evaluated * = Stretch Items Attribute of Excellence Detection

EMPLOYEE PARTICIPATION

1 2 3 NA NE

• 50. There is an effective process to involve employees in safety and health issues.
• 51. Employees are involved in organizational decision making in regard to safety and health policy.
• 52. Employees are involved in organizational decision making in regard to the allocation of safety and health

resources.

• 53. Employees are involved in organizational decision making in regard to safety and health training.
• 54. Employees participate in hazard detection activities.
• 55. Employees participate in hazard prevention and control activities.
• 56. *Employees participate in the safety and health training of co-workers.
• 57. Employees participate in safety and health planning activities.
• 58. Employees participate in the evaluation of safety and health performance.

 There is an effective process to involve employees in S&H issues  Employees involved in organizational decision making in regard to:

• S&H policy
• Allocation of S&H resources
• S&H training

 Employees participate in:

• Hazard detection activities
• Hazard prevention and control activities
• *Safety and health training of co-workers
• Safety and health planning activities
• Evaluation of safety and health performance.

Companies that have been through the process…

 2002: First SAFETY hazard Visit

• 9 Serious Hazards
• Including implementing a PSM program
• Several required engineering changes

 2003: Second SAFETY hazard Visit

• 5 Serious Hazards
• Material Handling
• Ergonomic Issues-again engineering abatements

 2004: Began in SHARP process through

deferral (Pre-SHARP).

NAICS CS (avg.

• g. 2004-2006

006 Company ny 2004 04 Company ny 2005 05 Company ny 2006 06 TRC 9.3 6.52 5.44 5.26 DART 5.1 2.4 1.5 1.4

 2006: Became SHARP  2006 to Present:

• Continue to improve even when it seems like there

is no more room for improvement.

• Through their Achievement Plans they reaffirm their

commitment to safety.

 3/2011: First SAFETY hazard Visit

• 6 Serious Hazards: OSHA required program additions
• DART rate slightly above industry

 Continue with “possible SHARP” until could see how 2011

incident rates were.

 6/2011: Conducted Phase 2 visit

• Corrected hazards from March visit
• 9 Program issues “Non-Mandatory” recommendations

TRC TRC DART

NAICS rate 4.1 2.1 Company 2010 3.9 2.9 2.9

 2/2012:Follow up Visit (from 2011)

• Implemented 3 program issues
• DART rate had increased

 Still had 6 program issues to work on  Decided to apply for Pre-SHARP for 2012  Pre-SHARP period from 3/2012 to 3/2013 TRC TRC DART

NAICS rate 5.5 2.8 Company 2011 3.5 3.5 3.5

 2/2013:Follow up Visit (from 2012-Pre-SHARP)

• Completed program issues
• DART rate still above industry
• Failed to qualify for SHARP

 9/2013 Initial Safety Visit TRC TRC DART

NAICS rate 4.2 2.2 Company 2012 4.1 2.8 2.8

 4/2014:Comprehensive Safety & Health Visit

• Completed program issues
• DART rate below industry
• TRC rate below industry
• Applied for SHARP

 6/

6/20 2014 14 Qualifi fied ed for & Entere ered d SH

SHARP!!!!

TRC TRC DART

NAICS rate 4.6 2.5 Company 2013 3.6 3.6 2.1 2.1

 Larger Company

• 70 employees on site
• 400 Nationwide

 2014 Safety and Health Initial Visits

• Very few hazards identified

 2015 Comprehensive Program Visit

• Very few program issues
• Strong Achievement Plan

 2015 Entered SHARP

 Small Warehousing Company

• 13 employees on site
• 330 Nationwide
• No other sites of this company in SHARP
• Each site helps each other out with safety guidance

 In SHARP for 8 years

 A wood cabinet and millwork manufacturer  Located in Lancaster, Pennsylvania  55 employees  Contacted IUP in 1999  12 years in SHA

HARP

 Dave Landis,

• Keystone Safety Compliance Director

 Be one of 54 Companies in Pennsylvania with this status  Lower incident rates  Lower Worker’s Compensation Costs  Safe Working Environment "Since we started the implementation of the SHARP program our incident rate decreased

• ver 82 percent. Saving money from worker's comp dollars is important, but there are

many other savings more important to the plant in reference to production. Just the amount of work involved in a work-related incident can be a good afternoon's worth, until all reports are filled out and proper investigation to the root cause of the incident to the implementation of the safety mechanism so we are able to prevent a re-occurrence." Jim Rieker, Safety Director, Rynone Mfg.

• OSHA Consultation is a great service for PA

employers

• We often hear “this is OSHA’s best kept

secret”

• Repeat business… tells the story

• Phone 800-382-1241
• Website ww

www. w.iup.edu/pa p.edu/pa-oshaconsult

• shaconsultation

ation

• Priority of requests determined by:

 the nature of the worksite problem,  the worksite size and industry category, and  the type of consultation service desired