This material is for training purposes only to inform the reader of occupational safety and health best practices and general compliance requirements and is not a substitute for provisions of the OSH Act of 1970 or any governmental regulatory agency.
MODULE 1: BASIC CONCEPTS
The goal of the hazard identification and control program is to make the workplace and its operations as safe as possible and to keep employees from being harmed. It is an ongoing program that is actually never finished. If you are involved in developing a system to identify and control hazards, you'll start by carefully planning and designing interrelated processes and procedures. You'll then implement and carefully watch the system perform. Finally, you'll revise and improve preventive measures and controls as your worksite changes and as your store of hazard information grows.
||If you are going to be effective in protecting employees from workplace hazards, obviously you must first understand just what those hazards are.
Some or all of these potential safety hazards may exist in a workplace. The list could go on and on. It's vitally important that workers and supervisors are knowledgeable to ensure that workplace hazards identified and eliminated as soon as possible.
- Many workplaces contain hazardous materials including raw materials (wood, metal, plastic) to be manufactured into finished goods, and toxic chemicals (solvents, acids, bases, detergents) used at various stages of the process.
- Stationary machinery and equipment may not be properly guarded, or in poor working order because of poor preventive/corrective maintenance.
- Tools may not be properly maintained. Saws may not be sharpened or safety harnesses may be old and in need of replacement.
- The work environmental might include extreme noise, flammable or combustible atmospheres, or poor workstation design. Floors may be slippery and isles cluttered. Guardrails, ladders, or floor hole covers may be missing or damaged.
- Employees might be fatigued, distracted in some way, or otherwise lack the mental of physical capacity to accomplish work safely.
What is a hazard?
Before we study identifying, analyzing and controlling hazards in the workplace, it's important to know how OSHA defines the term. OSHA usually defines a hazard as, "a danger which threatens physical harm to employees." Expanding on that basic definition we can think of a hazard as an:
Hazard + Exposure a Accident
"unsafe workplace conditions or practices (dangers) that could cause injuries or illnesses (harm) to employees. "
A hazard may be an object (tools, equipment, machinery, materials) or a person (when distracted, mentally/physically incapable). It's important to know that a hazard is only one part in the "accident formula" above. It takes a hazard and exposure before an accident can occur.
Look around...what do you see?
I'll bet if you look around your workplace, you'll be able to locate a few hazardous conditions or work practices without too much trouble. Did you know that at any time an OSHA inspector could announce his or her presence at your corporate front door to begin a comprehensive inspection. What would they find? What do they look for? Now, if you used the same inspection strategy as an inspector, wouldn't that be smart? Let's take a look at some information contained in OSHA's Field Compliance Manual, Chapter 3, relating to hazards and exposure.
Employer's obligation to remove hazards
OSHA standards require an employer to render the workplace free of certain hazards by any feasible and effective means which the employer wishes to utilize. Hazards describe the surface causes (conditions) for accidents in the workplace. For example:
Recognized Hazards. Occasionally, students ask what is considered a "recognized" hazard in the workplace. As described in OSHA's Field Compliance Manual, recognition of a hazard is established on the basis of industry recognition, employer recognition, or "common sense" recognition criteria.
- Employees doing sanding operations may be exposed to the hazard of fire caused by sparking in the presence of magnesium dust. One of the methods to abate (eliminate or reduce) may be training and supervision. The "hazard" is the exposure to the potential of a fire; it is not the lack of training and supervision that represents the safety management system failures (root causes) contributing to the hazard.
- In a hazardous situation involving high pressure gas where the employer has failed to train employees properly, has not installed the proper high pressure equipment, and has improperly installed the equipment that is in place, there are three abatement measures which the employer failed to take; there is only one hazard: exposure to the hazard of explosion due to the presence of high pressure gas.
What's a "foreseeable" hazard?
Another important question to ask about the nature of a hazard relates to whether it was "foreseeable." The question of foreseeability should be addressed by safety managers during the root cause analysis phase of an accident investigation. A hazard for which OSHA issues a citation must be reasonably foreseeable. All the factors which could cause a hazard need not be present in the same place at the same time in order to prove foreseeability of the hazard; e.g., an explosion need not be imminent. For example:
- Industry Recognition. A hazard is recognized if the employer's industry recognizes it. Recognition by an industry, other than the industry to which the employer belongs, is generally insufficient to prove industry recognition. Although evidence of recognition by the employer's specific branch within an industry is preferred, evidence that the employer's industry recognizes the hazard may be sufficient.
- Employer Recognition. A recognized hazard can be established by evidence of actual employer knowledge. Evidence of such recognition may consist of written or oral statements made by the employer or other management or supervisory personnel during or before the OSHA inspection, or instances where employees have clearly called the hazard to the employer’s attention.
- Common Sense Recognition. If industry or employer recognition of the hazard cannot be established, recognition can still be established if it is concluded that any reasonable person would have recognized the hazard. This argument is used by OSHA only in flagrant cases. Note: Throughout our courses we argue that "common sense" is a dangerous concept in safety. Employers should not assume that accidents in the workplace are the result of a lack of common sense.
If combustible gas and oxygen are present in sufficient quantities in a confined area to cause an explosion if ignited but no ignition source is present or could be present, no OSHA violation would exist. If an ignition source is available at the workplace and the employer has not taken sufficient safety precautions to preclude its use in the confined area, then a foreseeable hazard may exist.
It is necessary to establish the reasonable foreseeability of the general workplace hazard, rather than the particular hazard which led to the accident. For example:
A titanium dust fire may have spread from one room to another only because an open can of gasoline was in the second room. An employee who usually worked in both rooms was burned in the second room from the gasoline. The presence of gasoline in the second room may be a rare occurrence. It is not necessary to prove that a fire in both rooms was reasonably foreseeable. It is necessary only to prove that the fire hazard, in this case due to the presence of titanium dust, was reasonably foreseeable.
What is "Exposure"?
Well, I'm sure you thought the information above on hazards interesting ;-) Now, lets' talk about the concept of "exposure": the second variable in the accident formula. Exposure is generally defined as "the condition of being exposed," or as "a position in relation to a hazard." In this course we will consider three forms of exposure that we'll discuss here: physical, environmental and potential exposure:
Physical exposure. We may think of this form of exposure as "arm's length" exposure. If any part of the body can be injured as a result of proximity to a danger zone, physical exposure exists. For instance, if an employee removes a guard and works around moving parts that could cause an injury, that employee is exposed.
Environmental exposure. An employee may suffer from environmental exposure no matter how far away from the source of the hazard he or she might be. For instance, if an employee uses a loud saw all day, everyone working around the saw may be exposed to hazardous levels of noise and suffer from environmental exposure.
Potential Exposure The possibility that an employee could be exposed to a hazardous condition exists when the employee can be shown to have access to the hazard. Potential employee exposure could include one or more of the following:
Are you sure you know all of the potential hazards generally associated with your type of business and your specific working conditions? A strategy to systematically identify and analyze all workplace hazards would be useful. In this course we'll be taking a look at one successful strategy that is summarized below:
- When a hazard has existed and could recur because of work patterns, circumstances, or anticipated work requirements and it is reasonably predictable that employee exposure could occur.
- When a hazard would pose a danger to employees simply by employee presence in the area and it is reasonably predictable that an employee could come into the area during the course of the work, to rest or to eat at the jobsite, or to enter or to exit from the assigned workplace.
- When a hazard is associated with the use of unsafe machinery or equipment or arises from the presence of hazardous materials and it is reasonably predictable that an employee could use the equipment or be exposed to the hazardous materials in the course of work.
The above process, when accomplished systematically, will help ensure your workers experience freedom from conditions in the workplace that can cause death, injury, illness, or equipment damage. That, after all, is "safety."
Well, that's a lot of important information. All these activities to identify hazards in the workplace are so important to the overall effectiveness of your safety management system. Be sure you integrate these activities into the line positions...employees, supervisors and managers...safety is a line responsibility!
1. Identifying workplace hazards. Identifying hazards is accomplished through the use of a variety of methods including observation and periodic surveys and inspections.
2. Analyzing the workplace. Beyond initial identification, analysis takes a much closer look to determine the nature and impact of specific hazardous conditions or unsafe work practices. Methods include: change analysis of the potential hazards in new facilities, equipment, materials, and processes; and routine hazard analysis, such as job hazard analysis, process hazard analysis, management system analysis, or phase hazard analysis.
3. Developing solutions. Once hazards are identified, analyzed and understood, effective problem solving techniques are used to determine the source of those hazards. A critical analysis of root cause(s) is conducted to determine the system weaknesses needing improvement and how to make those improvements.
4. Writing recommendations. Once solutions are found, it becomes important to offering effective recommendations that "sell" management on the solutions you have developed. There are some do's and don'ts to effective recommendations that we'll discuss later in the course.
5. Taking action. After recommendations have been approved, carefully plan and implement the necessary improvements.
6. Evaluating the results. To ensure changes are effective long term, continuous evaluation through monitoring and feedback are necessary to revise and improve the changes made.
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