By: Michael E. Goldberg, CIH, CSP
As an Industrial Hygienist and Safety Professional, when evaluating workplace incidents and injuries I request written safety programs from the parties involved with the matter. When reviewing the documents, I look to see whether the documents were produced within the organization or are from an outside entity. The reason for this is to identify whether an organization’s safety manuals reflect the safety knowledge and capabilities of that organization.
Many organizations do not have an in-house Safety Department. An organization may assign the development of safe work practices to employees who do not have a background in safety and are not necessarily qualified to identify what safety programs are applicable or relevant to their organization. Therefore, the development of safe work practices may result in the adopting and/or “cutting and pasting” of safety manuals from other organizations without ensuring the application is pertinent to their workplace. For example, a pharmaceutical production company may have their manuals accessible from the web. However, that does not mean those programs are applicable for healthcare or food processing. There is nothing wrong with using an outside entity or using other programs as a template. However, the organization should review such documents to reasonably ensure that the safety programs appropriately reflect the intended workplace tasks.
When evaluating workplace incidents, a job hazard analysis (JHA) program provides safety professional with insight regarding the process where an injury occurred. The Occupational Health and Safety Administration (OSHA) defines a JHA as “a technique that focuses on job tasks as a way to identify hazards before they occur. It focuses on the relationship between the worker, the task, the tools, and the work environment. Ideally, after you identify uncontrolled hazards, you will take steps to eliminate or reduce them to an acceptable risk level.” However, a written JHA program does not necessarily mean that the hazard will be eliminated just because a written JHA program exists. It is also important that the JHA reflects a job specific procedure. Therefore, a safety inspector evaluating a specific process should ensure that the written program accurately reflects the physical actions of the user/operator. For example, if an inspector is assigned to evaluate a drill press operation and they assess the machine to be safe because it appears to be in good working condition without actually operating the drill press, it is an incomplete inspection. Whether or not interlocks or machine guards are in place and if those safety guards work are best evaluated during machine operation.
Similarly, lockout/tagout programs are often based upon the OSHA “Control of Hazardous Energy” standard which may result in an “umbrella” program. However, this likely does not address equipment specific procedures. A procedure for shutting down an HVAC fan system is very different than locking out a conveyor belt system. Therefore, a professional versed in safety and OSHA related standards/codes should evaluate the written program to determine its effectiveness for preventing workplace injuries. Having a written program and implementing the programs with properly performed JHA’s is important. It is also important to review this information as part of an evaluation of workplace injuries and incidents. The technical evaluation of safety programs is equally beneficial to plaintiff and defense matters.
At Consulting Engineers & Scientists, we can provide assistance in evaluating an organization’s safety programs to determine their efficacy, implementation, and whether they were a cause or factor in a workplace incident. Contact us for a safety program evaluation today.