Custom Building a Safety and Health Program, Step Three: Developing the Format
With your site safety audits completed, or at least started (see Roofing Contractor, October 2003), you should determine your preferred method of organizing a written corporate Safety and Health Program. This is rather an involved process requiring a moderate level of patience and perseverance. There are no two programs alike, although the basic goal is always the same: Achieve zero accidents.
There are three basic factors that control the design of all safety programs: Keep referring back to them and your will manage to keep the finished quality high.
1. Educate: Train your employees in the safe work practices stipulated by OSHA standards that will reduce and/or eliminate hazardous exposures on the job. Your program will form the syllabus for any safety training you will perform in the future.
2. Enact: Create precise daily safe work practices clearly explained in detail for every employee to understand. When on the job, everyone should understand what is expected of them by their employer without any imprecise instruction from the foreman. The easiest method of implementing safe work practices is by employing a checklist.
3. Enable: Only the employer can affect this factor. The three ingredients to achieving safety compliance are time, space and money. When in sufficient supply, they enable the employees to enact the safe work practices in which they've been thoroughly trained).
Analyzing the AuditsMy favorite method of getting started is to place the three volumes of the OSHA Standards (29 CFR, Part 1926 and Part 1910) to my right and the file containing my site-safety audits to my left. In front of me is a pad of yellow paper (or a laptop). I open up the audits and begin to read them. Regardless of the type of audit (narrative or checklist), I can easily identify the existing and potential hazards on one particular site on the day of the audit.
For instance, in one particular audit I noted a worker was refueling a forklift from 5-gallon fuel cans that he filled from a nearby storage fuel tank without using proper grounding. The fork truck was parked on an incline and the forks were left elevated 4 feet. During the refueling process, the worker carelessly spilled gasoline over the vehicle and himself and he did not have eye or hand protection. In order to reach the high fuel tank, he stood on several stacked 12-inch concrete blocks.
Nearby there was another co-worker cutting galvanized steel coping using a demolition saw with a damaged guard. He was not wearing respiratory, hearing, hand or adequate eye protection. He was standing on a pile of demolition waste, holding the material to be cut with his feet on top of 4-by-4 dunnage.
Before refueling was finished, the crane operator swung a pallet load of roofing slates over both workers en route to the two-story 12:12 pitch roof. The slate was not secured to the pallet, which had missing boards and was attached to the crane hook using two damaged, unequal nylon chokers. The crane's load line passed within 10 feet of a low-voltage line servicing the building. The roofer disconnected from his personal fall arrest lifeline and climbed down the roof deck, jumping 3 feet onto the scaffold below (no guardrail) to unload the slate whose weight exceeded the maximum rated load of the scaffold.
When I look closely at the standards' indexes I realize that there are quite a few sections in the regulations relative to these events and note them on my yellow pad. Just to name a few:
1910.178: Powered Industrial Trucks (N): Improper refueling methods; parked on grade without wheel chock and forks elevated.
1926.101 Hearing Protection (E): Adequate PPE for the decibel level of saw.
1926.102 Eye and Face Protection (E): Adequate PPE for fueling and saw cutting.
1926.151 Fire Prevention (F): Identification of ignition sources; safe work practices.
1926.152 Flammable & Combustible Liquids (F): Identify safe refueling stations; liquid transfer grounding; proper storage.
1926.251 Rigging for Material Handling (H): Inadequate training; no preshift inspection; unsecured loads; defective pallet.
1925.451 Scaffold, General Requirement (L): No guardrails; overloading; no competent person.
1926.502 Fall Protection Systems (M): No 100 percent PFAS over 6 feet; inadequate fall protection training.
1926.550 Cranes, Derricks, Hoists (N): Certified trained operator; workers prohibited underneath suspended loads; crane within 10 feet of conductor less than 50 kv.
I proceed through the analysis of all the site safety audits, compiling a list of hazardous acts and non-compliant conditions as I go. Audit analysis is often twice as time consuming as the entire physical site audit, portal-to-portal. However, it's an invaluable, eye-opening process for any owner of a construction firm.
Outlining the ContentsFrom just one simple inspection audit, you can identify any number of non-compliant site conditions and/or unsafe employee work practices. Consequently, the body of your corporate SHP may have in its table of contents at least the following sections:
Section 1: Equipment/Vehicle "Out-Of-Service" Policy
c) Equipment Repair
Section 2: Job Safety Analysis Part 1910
a) Standard Operating Procedures
b) Hazard Awareness Methods
c) Hazard Control Methods
Section 3: Hazard Communication Part 1910, Subpart Z
a) The written Hazard Communication Program
b) Right-To-Know Policy
c) Material Safety Data Sheets
Section 4: Personal Protective Equipment (PPE) Part 1926, Subpart E
a) Head Protection
b) Hand Protection
c) Foot Protection
d) Protective Clothing
Section 5: Fall Protection, Subpart M
a) The Duty to Have Fall Protection
b) Personal Fall Arrest Systems
c) Fall Restraint Systems
d) Safety Net Systems
e) Controlled Access Zones and Safety Monitors
f) Guardrail Systems
g) Control and Warning Lines
h) Falling Object Protection
Section 6: Rigging and Material Handling, Subpart H
a) General Housekeeping
b) Non-Hazardous Material Storage
c) Hazardous Material Storage
d) Rigging Safety
e) Pallet Safety
Section 7: Fire Protection and Prevention, Subpart F
a) Flammable Materials
b) Combustible Materials
c) Fire Extinguisher Safety
d) Sprinklers and Alarm Systems
Section 8: Cranes and Hoists, Subpart N
a) Preshift Inspections
b) Safe Operating Procedures
c) Authorized Signal Person
d) ANSI Universal Hand Signals
e) Radio Signal Procedures
Section 9: Hand and Power Tools, Subpart I
a) Power Cutting Tools
b) Power Abrasive Tools
c) Power Drills
d) Knives and Sharps
e) Pneumatic Tools
f) Mechanical Seamers
Section 10: Forklifts Part 1910, Subpart N
a) Types and Classifications
b) Operator Certification (AP)
c) Safe Operating Procedures
e) Refueling Procedures
Section 11: Ladders and Stairs Part 1926, Subpart X
a) 19 Inch Rule
b) Portable Step Ladders
c) Portable Extension Ladders
d) Fixed Ladders
e) Temporary Stairs
f) Fixed Stairs
While the site safety audit often indicates many of the hazards in the roofing work environment, there may be other sections that only become apparent when we investigate the OSHA standards further. According to your own site assessments, some of these additional general topics may possibly include:
Section 12: Respiratory Protection
Section 13: Hearing Protection
Section 14: Welding and Cutting
Section 15: Electrical and Lockout/Tagout
Section 16: Aerial and Scissor Lifts
Section 17: Conveyor Safety
Section 18: Powder Actuated Tools
Section 19: Hotwork and Kettle Safety
Section 20: Hazardous Weather
Section 21: Vehicle Safety
Section 22: First Aid, Bloodborne Pathogens and CPR
Section 23: Emergency Action Plan (EAP)
There are several other sections which may appear either in the body of the
SHP, its appendices or in the employee manual. These include:
Section 23: Workplace Violence Awareness
Section 24: Substance Abuse Program
Section 25: Sexual Harassment Policy
Section 26: Employer and Employee Rights and Obligations
Administrative SectionMost SHPs include a preliminary administrative section that is usually installed just after the CEO's mission statement. This section may contain several items that your firm may consider essential to implementing the safety and health practices contained in the body of the program. Some of these may include:
1. Corporate PoliciesAs with the entire body of the program, any corporate policy may be considered binding contracts between the employer and employee and should be thoroughly reviewed by your corporate legal advisor.
a) Inspection and Audit Policy: This section explains your policy and inspection procedures to your employees. Who is to inspect? How often? Are inspections random? How are reports analyzed and results reported to employees?
b) Hazardous Condition Reports: Anonymous employee form and procedures to report serious and non-serious hazards on the job.
c) Disciplinary Policy: Critical explanation of the uniform penalties and probationary periods every employee can expect for the first, second and third violation of policy relative to the severity of the offense.
d) Safety Incentives: Any proactive corporate incentive program or bonus plan intended to encourage safety without encouraging the under-reporting of injuries, illnesses or near-misses.
e) Accident Reporting Policy: Includes the accident reporting duties; identifies employer-designated accident investigator(s); and procedures for investigation.
f) Near-Miss Reporting Policy: Includes the near-miss reporting form; identifies employer-designated near-miss investigator(s); procedures for investigation.
h) Emergency Action Plan: Lists emergency telephone numbers, contacts and job-site procedures.
g) First Aid Injury/Illness Policy: Includes the First Aid Incident Report; explains the necessity to report all details involved in performance of first aid or CPR by certified, trained personnel on the job site during working hours; and also explains your state's position on the "Good Samaritan" laws.
h) Worker's Compensation Insurance: Includes a copy of the C-2 Report form; a brief overview of the C-2 Report Form; case hearing procedures and injury claim policies; employee/employer rights and obligations; procedures to be followed to evaluate the worker's recovery period; method of communication and contact during rehabilitation; privacy statement; an explanation of the relationship between your Experience Modification Rate, their compliance to the Safety Regulations and corporate profitability.
2. Employee DesignationsThese obligatory personnel assignments identify those employees by name whom the employer has selected, trained and authorized to perform particular functions or assigned regular duties such as preventive maintenance, equipment inspections, employee training. The exact period of their assignment and clearly defined responsibilities should be identified. Some of these designations may include:
a) Competent Person: An employee who is trained and experienced to identify existing and predictable hazards in the surroundings or working conditions that are unsanitary, hazardous or dangerous to employees. He is authorized by the employer to take prompt corrective measures to eliminate (or reduce) them using engineering, administrative and personal-protective-equipment control methods. There are 20 different areas of the standards where a CP is either mandated or recommended.
b) Qualified Person: An employee (or subcontractor, i.e., professional engineer, scaffold system designer) who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training and experience, has successfully demonstrated his ability to solve or resolve problems related to the work.
c) Approved Personnel: Closely monitored employees (such as new hires) who have adequate experience, supervision and basic training to perform only specified work duties.
d) Authorized Personnel: Employees above the "approved" status, who are certified by way of advanced training and experience to be field-evaluated by the CP to perform certain functions (confined space entrant-rescuer), operate specific equipment (crane or fork lift operators) or enter certain work areas.
e) Safety Director: A CP-employee who is responsible for the design, selection and maintenance of safety system equipment; the safety training and evaluation of all employees; and review and implementation of the written SHP. He performs accident and near-miss investigations and report analysis; coordinates employee medical and work-related injury and illness recordkeeping; performs regular JSA safety audits for compliance with the applicable regulatory agency; chairs the safety committee; manages safety incentive programs; and regularly reports on safety issues to the CEO.
f) Safety Committee: This rotating group of randomly-selected (or volunteer) employees is assigned some of the inspection and reporting duties typically required of the Safety Director.
3. Inspection PolicyIt is advantageous to notify your employees of your site inspection policy. It gives them the clear signal that their work-site and practices may be evaluated at any time. Be precise when discussing the effect inspections may have on any in-place employee safety incentive or bonus programs. Reference should also be made to the details contained in your Disciplinary Policy. Many employers attach a copy of the safety audit form to the appendix.
4. AppendicesThere are often documents, policies and record-keeping forms that are ancillary to the SHP that may be located in an appendix at the end of the program. Some of the items may include:
a) Employee Acknowledgement Form: This short form indicates (by date and signature) that each employee has read and understood the corporate SHP. Upon complete training in the SHP, each employee signs and dates this acknowledgement and returns it to his foreman to be kept in his personnel file.
b) Job Safety Analysis Form: A four-column form listing phases and steps of a standard operating procedure; existing or potential hazards associated with each step; hazard control methods to reduce or eliminate the hazard; and the material/labor cost of the abatement
c) Accident Report Form: This is an NCR three-copy report entailing all of the event details concerning an accident where there was bodily harm to an employee or a subcontractor including an injury, illness or fatality.
d) Near Miss Report Form: This is similar to the Accident Report Form, except that it refers to any event in which there was no injury, illness or death reported.
e) First Aid/Injury/Illness report form: Often accompanying an accident report, this details all of the onsite medical assessment and any first aid, CPR or blood-borne pathogen protection procedures and treatments that were performed on an individual(s) in an emergency medical situation
f) Emergency phone numbers and contacts.
Observe and ActYour goal in writing a Safety and Health Program is to enable every one of your employees, from office personnel to field worker, to quickly, accurately and easily identify potential hazards when they are still manageable, before they reach a critical hazard level. Once this is achieved, you must determine if your program stipulates the correct safety procedures for the employee to practice to avoid accidents.
How you actually format each section is almost a matter of personal taste. Over time I have arrived at a layout which is simple and direct for my needs. It is based on the old newspaper reporter's rule of "Who? What? Where? When? Why? How?" If I can answer every employee's potential questions on all of their work sites, then the program is practical and able to be implemented by your field foremen and project superintendents.
The best program is not the perfect program. The best advice I can give anyone compiling a Safety and Health Program is to take it by little bites.