Accident Prevention Program (APP)

An overview of what’s required and how to develop one

April, 2010

Accident Prevention Program (APP)

Purpose:

To assist you in developing and

implementing a written

Accident prevention program

that is tailored to the needs and

potential hazards associated

with your workplace.

What Will Be Covered

Why have an accident prevention program?

Rule requirements for accident prevention program

Elements of a written program

How to implement an effective program

Where to get help

Why have an Accident Prevention Program?

• It will help to prevent employee injuries on the job.

• It will help you find hazards

before they cause accidents.

• It will help you deal with accidents if they do occur.

By “accidents” we mean events where employees are killed, maimed, injured, or become ill from exposure to toxic chemicals or microorganisms

(TB, Hepatitis, HIV, Hantavirus etc).

It helps control Industrial Insurance costs

Your premium rate depends on number of claims filed. Your premium rate depends on number of claims filed. An accident prevention program can help you to control hazards that cause accidents and claims.

Average # of claims High # of ClaimsLow # of Claims

Why have an Accident Prevention Program?

A True Story

A Tire Store – 35 Employees

• Had a single high cost claim (shoulder injury)

• Premium rate increased from 71¢/hr to 86¢/hr

• Yearly premium increased $10,000

To make up for the premium increase @ 10% profit margin – you must get $100,000 additional business

These are actual facts and figures from a tire store in eastern Washington. The company had 13 minor claims in 2000-2002 with the single high-cost claim ($29,000) occurring in 2002. The employee was off work for several days and received time-loss payments from L & I. He also had expensive medical bills which were billed to L & I.

It’s required by L & I - DOSH Rules(Division of Occupational Safety & Health)

Safety & Health Core Rules – WAC 296-800-140

Safety Standards for Construction – WAC 296-155-110

Other standards – agriculture, logging, etc.

APP rules are nearly identical for all types of businesses. In most cases, if you are visited by a DOSH inspector, he or she will look for your APP. If the inspector finds serious hazards and no APP or major deficiencies in the APP, you could receive a citation with monetary penalty.

Why have an Accident Prevention Program?

A plan of action to:

– Involve workers and management in workplace safety and health,

– Identify and control safety hazards,

– Handle emergencies,

– Give new employees job safety orientation,

– Provide for personal protective equipment as needed.

A plan for safety must be more than posting a sign that says “Be Careful. In an emergency call 911.” It will help you to identify hazards before they cause accidents and help you deal with accidents if and when they occur.

What is an Accident Prevention Program?

What is required for all employers?

• Must be outlined in writing.

• Must be tailored to the worksite.

•Must include employee safety orientation and training.

•Must include safety committee or safety meetings.

Link to Core Rule APP requirements

• You must develop, superviseand enforce a safety training program

• You must make sure your APP is effective in practice.

Supervise and enforce an effective program

Outlined in writing

Employee safety orientation

Weekly leader/crew safety meetings

Weekly walk-around safety

inspections

APP Requirements For Construction

Link to Construction APP requirements

APP Requirements for Agriculture

• Outlined in writing

• Tailored to the needs and hazards of your operation

• Employee safety orientation

• Monthly walk-around safety inspections with employee representative

• Monthly foreman-crew safety meetings

Link to Agriculture APP requirements

A written APP can be an outline• Simple and direct is O.K.

• Must cover all the regular and predictable hazards of the worksite

• Include employee input to identify

new hazards not in outline

• Some employers will need a more complex APP depending on hazards

• It can’t be just a paper programThe written program must cover all the typical, predictable and evident hazards of the worksite. However, a written APP that is too long or complicated tends not be read. As long as there is method to report new or unforeseen hazards, it is not necessary to go into great detail about every possible hazard one could

imagine.

APP should be a “living plan”

If it is not a “living plan” that is actually used, then it will just be:

• a document gathering dust on a shelf,

• something you did to please L&I,

• of no real value to your company.

If you’re going to spend time and energy developing this plan, it might as well be a tool that will add value to your company, will help you to provide a safe and productive workplace, and keep your industrial insurance premiums to a minimum.

APP Must be Tailored to the Worksite

• It can’t be a non-specific generic program

• It must address the actual worksite hazards and conditions

• It must include the work of all employees

By “generic” we mean one that does not address the actual worksite hazards and conditions.

Some trade associations produce generic programs that includes the most common hazards of a particular industry. These are usually acceptable, but you must also cover the unique hazards of your worksite.

Employee Safety Orientation

The orientation must cover:

• A description of total safety program

• On-the-job instructions on how to do job tasks safely

• How to report accidents

• Location of first aid facilities

Employee Safety Orientation(con’t.)

• How to report safety hazards

• Use and care of personal protective equipment

• What to do in emergencies

• How to identify hazardous chemicals and what to do if exposed to them.

Also include in orientation:

Link to sample chemical hazard communication program

Safety Committees

• At least as many elected employees as management-selected members

• Elected chairperson

• Committee determines meeting schedules

• Keep meeting minutes and attendance

• Cover specific topicsSafety Committees are required if you have 11 or more employees at the worksite. The number of employee-elected members of the safety committee must be equal to or more than the number of employer-selected members

Safety Meetings

• Allowed if 10 or less employees

• Meet monthly

• At least one management representative

• Document attendance

• Cover specific topics

Safety meetings are an allowable substitute for a safety committee if you have 10 or less employees. They are also allowed if you have 10 or less employees on different shifts or there are 10 or less employees at widely separate work locations. You would need to have safety meetings at each shift or each work location.

Construction Crew/Leader Safety Meeting requirements

Hold worksite meetings:– At start of job– Every week– As needed when change in conditions or hazards

Document topics and attendance

Agriculture Safety Meetings

• Not required for short-term operations like harvesting

• Monthly meetings tailored to current activities

• Outline what discussed and who attended in meeting minutes

• Copies of minutes kept at location

where most employees report

• Retain minutes for one yearEven though safety meetings are not required for agriculture operations that last less than a month, a safety orientation is still required at the beginning of the operation. For example, in cherry harvesting, pickers should still have a safety orientation on how to safely use a ladder.

When is an APP “Effective in Practice”?

When It Works!!

• It is more than just words, platitudes or slogans.

• All regular and predictable hazards are addressed.

• Serious or frequent injuries are not occurring.

The goal of an APP is to prevent injuries. Frequent injuries would be a sign that not all hazards are addressed or your safety rules are not being enforced. Minor or infrequent non-serious injuries do not mean your APP is ineffective. An occasional missed hazard (one saw guard out of several saws is missing in a cabinet shop for example) also does not necessarily mean your APP is ineffective.

Some ways to make an APP “Effective in Practice”

• Determine what injuries and near-misses have occurred and why

• Do a hazard evaluation or survey of the workplace

• Establish safety goals – management commitment

• Train employees on job hazards (required)

• Effectively and consistently enforce safety rules

• Provide needed protective equipment and make sure it is used (required)

Injury Determination

Review claims and injury records

Interview employees for unreported injuries

Review your OSHA 300 Log if you have kept one. See if there are several people having the same type of accident (indicates that a process or procedures may need changing) or if one person is having several accidents doing different jobs (indicates that this person probably needs retraining).

Talk to employees: - Do they think they have a safe place to work.- Do they have ideas about how to improve safety.- Do they know how, when and to whom to report an accident.- Do they know of any accident that have NOT been reported.

Near Misses

Investigate near-misses since they are potential accidents

Accidents or injuries are the “tip of the iceberg” of hazards

Accidents

Hazards

Don’t just investigate accidents. Near misses should be reported and investigated. They were in a sense, “aborted accidents”.Criteria for investigating an incident or near miss: What is reasonably the worst injury the worker would have suffered had an actual accident happened?If it would have resulted in a serious injury, then the incident or near miss should be investigated with the same thoroughness as an actual accident investigation.

Job Steps Hazard Protection

Pick up stock Sharp edges & splinters

Gloves

Cut stock with power saw

Blade edgesAnd

flying chips

Blade guardand safety glasses

Safety Hazard EvaluationJob Hazard Analysis (JHA)

Link to JHA information

A JHA is not required, but is one method of determining hazards at the worksite. This is an example of a job safety analysis of a carpenter shop. Each task is listed with it’s particular hazard and protection for that hazard. This method can be used to determine your company’s need for personal protective equipment. Also called a job safety analysis (JSA)

Tailored to your workplaceUsed by foreman or safety supervisor

YESYES NONO ITEMITEM

Employees wearing safety glasses?

Saw guards in place?

Work area free of tripping hazards?

Workplace Safety Evaluation

Worksite Safety Checklist

A periodic safety evaluation is recommended, especially if conditions change frequently, such as in construction. Often representatives of the safety committee will do this. This checklist should be developed to check for the hazards that are likely to be found on your site. It can be used for periodic walkaround safety surveys to make sure all safety measures are in place.

Hazard Identification

Do with a team: supervisors, employees, outside experts Examine:

– Persons– Equipment– Environment

Look for fact, not fault Prepare a written report Do follow-up

Conduct Accident Investigations

Investigate as soon as possible. Take pictures, draw diagrams and interview all who witnessed the accident. Try to find what can be changes to prevent the accident from happening again. Write a formal report (can be covered at the next safety meeting).Make sure that suggested changes are made.

Link to more information on how to do an accident investigation

A successful APP needs Management Commitment

Sample statements:

– “We care about your safety…”

– “We will provide a safe work place…”

– “Nothing is important enough to do unsafely.”

– “Supervisors and employees are expected to work safely and bring up safety issues…”

A message from the owner ...

JJohn Smith

Management safety statements are not required, but are recommended. Management support is vital for success of program else neither supervisors nor employees will take it seriously. A specific written statement, is not required, however.

Resources needed to support an APP

Safety Equipment

Time Incentives

In addition to leading by example, management should give employees resources and incentives. Recognize that an effective program implies a commitment of:

- support of safety as a regular budget item,- time for inspections, training, safety committee, maintenance,- equipment such as guards, PPE, training materials, promotions,- safety recognition and incentive programs that reward safety efforts.

The Role of Line Manager/Foreman

Spell out their safety duties

Give them explicit safety authority

Hold them accountable for safety

For a successful APP you need line manager commitment.

To have a program that is “effective in practice”, management ( the owner, general manager, supervisor, foreman and crew boss) must practice safety as well as the employees. If management doesn’t wear PPE where the employee are required to, the employees are less likely to wear the required PPE when management is not present. Employees must be make to feel comfortable making safety corrections without getting “permission” from someone else.

Suggested ways to do that:

The Role of Line Managers/Foremen

They should:

Be personal examples

Identify hazards

Monitor workers

Participate directly in problem-solving

Employee Input

Employee hazard reports

– Get input from safety committee

– Consider using an employee report form

– Do a follow-up

Link to sample employee report form

You can use a report form, a suggestion box, or get input from safety committee or verbally during safety meetings. Make available and encourage the use of form for employees to report hazards they see. Management should have procedures to address issues identified and notify individuals or safety committee what actions were taken.

Training Programs

• Management also needs training to understand the hazards and safety requirements as much if not more than the line employees.

• Initial orientation is very important. New employees are quite vulnerable to accident unless you train them on:

- what to watch out for, and - what to do when something goes wrong.

• Employees may be expected to start the job with the skills necessary to do the job but it is the employer’s responsibility to insure that the employee knows the safety rules related to the job.

• Don’t rely on the previous employer having done the training or that the new employee says they have experience. You don’t know the quality of training they received or if any bad habits have developed.

Training Programs

– Who?• Management• Employees

– What?• Basic orientation• Specific machines, processes, skills

– When?• Before doing the work• When duties work change• When deficiencies are noted

– Documentation• Instructor’s outline• Attendance records

Need to cover the following:

Specific Training Programs

DOSH has specific training requirements for certain topics:

• Hazard communication

• Respirator use

• Other PPE use

• Forklifts

• Confined space work

• Fall protection in construction

• Pesticides in agriculture

• Others

Link to DOSH-required training Link to DOSH online training programs

Safety Rules are an Important Part of APP

General company safety rules such as:

– “Wear steel-toed shoes on the job”

– “No horseplay”

– “Do not operate machinery without guards in place.”

Specific job related safety rules such as:– Grinder safety rules– Roofing fall protection rules

There are two types:

Safety Disciplinary Policy

In writing

Employees are informed or trained on policy

Applies to everyone – including management

Fair and progressive enforcement “Where’s his fall protection?”

A disciplinary policy is not required, but highly recommended. The policy should be in writing and employees should be informed/trained before it can be used against them.Policy should be imposed on management as well as employees. Records of policy application should be kept for documentation that the policy is being enforced.

Personal Protective Equipment

• Determine need –who, when, what

• Ensure it provides adequate protection

• Train employees on use

• Provide, maintain and replace as needed.

What hazards exist that require use of PPE?

A PPE hazard assessment is required by DOSH Rules on PPE. You can determine what PPE is needed from doing a hazard assessment. Injury reports may also provide additional information – there may be a pattern of injuries that can be prevented with the use of appropriate PPE..

Link to sample PPE hazard assessment checklist

Additional InformationMore information on APP is available on the DOSH webpage at:http://www.lni.wa.gov/safety/basics/Programs/Accident/default.htm

For additional assistance, you can call one of our consultants.

Click below for local L & I office locations:http://www.lni.wa.gov/wisha/consultation/regional_consultants.htm