OSHA Update and Safety and Health Management Systems

2009 DOL Forum

Jim Shelton, Houston North

Topic Areas

• OSHA Update and Emphasis Areas

• Business Case• Elements of an

Effective Safety Program

• OSHA Compliance Assistance Overview

• Finding Safety Resources

OSHA Update

• New Deputy Assistant Secretary and Acting Assistant Secretary Donald Shalhoub

• Updated Field Operations Manual (CPL 02-00-148 replaces the Field Inspection Reference Manual (FIRM)

• Advanced Notice of Proposed Rulemaking related to combustible dust

OSHA Update

• Stimulus Work – Looking for outreach possibilities for companies involved in stimulus work, green or renewable energy ect.

• Industrial Hygiene – Look for increased OSHA outreach and enforcement related to industrial hygiene including increased air monitoring and sampling for potential over exposures

Emphasis Industries

• FY 09 Operational Plan Industries:– Highway, Street, and Bridge Construction– Landscaping/Horticultural Services– Oil and Gas Field Services– Residential Building Construction– Blast Furnaces and Basic Steel Products– Concrete and Concrete Products– Fruits and Vegetables

Emphasis Hazards

• FY 09 Operational Plan Hazards:– Combustible Dust– Electrical– Falls from Elevation– Noise (Non-Construction)– Silica– Struck-By– Trenching

National Emphasis Programs

• PSM Refineries (NEP)• Silica (NEP)• Amputations (NEP)• Combustible Dust (NEP)• Trenching (NEP)• Falls (NEP)• Portland Cement

Regional Emphasis Programs

• Construction (REP)• Demolition (REP)• Powerlines (REP)• Work Zone (REP)• Cranes in Construction (REP)• Falls in General Industry (REP)• Highway & Bridge Construction

and Maintenance (REP)• High Noise Industries (REP)

H1N1 Influenza

• OSHA has a number of publications and resources addressing pandemic flu

• Preparations and planning are important in the event this or another virus emerges

Typist During 1918 Influenza

H1N1 Influenza

• The CDC recommends:– Employees should be alert for the symptoms

of influenza. If you exhibit such symptoms as fever, cough, sore throat, body aches, headache, and chills, you should request leave from your supervisor, stay home, and limit contact with other people to prevent the spread of infection. Seek appropriate medical attention, and follow any instructions from your primary care provider

H1N1 Influenza

– Practice good hygiene. Wash your hands often with soap and water, especially after your cough or sneeze, after using the restroom, and before touching your eyes, mouth, or nose. Alcohol-based hand cleaners are also effective if soap and water are not readily available

– Practice good respiratory etiquette. Sneeze or cough into a tissue; then carefully dispose of the tissue in a waste receptacle

H1N1 Influenza

– Avoid sneezing or coughing in the direction of other employees, and avoid sneezing into your bare hands

– Employees who work in healthcare or laboratory settings may require additional precautions

– Additional information can be found at http://www.cdc/swineflu/guidance/

H1N1 Influenza

H1N1 Influenza

H1N1 Influenza

OSHA 3328-05 OSHA 3323-10N OSHA 3327-02N

Business Case for Safety

• According to Liberty Mutual Research Institute for Safety for every $1 invested in safety there is between $3 and $6 in savings

• Accidents with or without injury may also result in property damage, equipment replacement costs, downtime, and unhappy customers

• Workers compensation premiums and Experience Modification Rates (EMR) affect your bottom line. Lowering your EMR by buying down or paying smaller claims out of pocket still costs you money

Business Case for Safety

Mod Description Mod Premium

Average Mod 1.00 $200,000

Current Mod 0.71 $142,000

Minimum Mod 0.38 $ 76,000

Controllable Mod 0.33 $ 66,000

•If you’re at 0.71 and prevented all accidents you would save $66,000 in premiums• If your at 1.00 and your competitor is at 0.71 you are at a $58,000 per year disadvantage. If he’s at 0.38 you’re at a $124,000 disadvantage.

Information Courtesy of Liberty Mutual, Houston, TX

Direct Costs*Medical Costs*Indemnity Payments

Indirect Costs*Lost time by:

- Injured - Co-workers - Supervisor *Spoiled product*Loss of customers

*Cleanup time*Production delays*Training new workers*Overhead costs*Legal fees*Rise in insurance costs

Business Case for Safety

Business Case for Safety

Direct Cost of Injury Indirect Cost Multiplier

0 - $ 2,999 4.4

$ 3,000 – $ 4,999 1.6

$ 5,000 – $ 9,999 1.2

$10,000 + 1.1

Foreign body in the eye - Direct cost of $317* + indirect cost of $1394 = $1711 total cost. A 5% profit margin requires $34,236 in sales to cover

The 2003 average cost of a WC injury claim in Texas was $3,078**…$98,000 in sales to cover * Argonaut Insurance Average Claims 1992-1994** TDI WC Research Group Medical Cost Trends in TX - 2004

Business Case for Safety

• OSHA has found comprehensive safety and health programs reduce injury and illness rates an average of 20%

• Accident costs go directly to the bottom line– Many companies won’t hire you if have an EMR over

1.00 or an injury rate above the national average and many review your OSHA citation history

• Your safety performance affect the financial well being and competitiveness of your company and the lives of your work crews

Characteristics of Exemplary Pgms

• Uses organized and systematic methods to:– Assign responsibility to managers,

supervisors, and employees– Inspect regularly for and control hazards– Orient and train all employees to eliminate or

avoid hazards

General Guidelines

• An effective program– Includes provisions for systematic identification,

evaluation and prevention or control of hazards– Goes beyond specific requirements of the law

to address all hazards

• Written program– “In writing” less important than effectiveness– As size and complexity of worksite or process

increases, so does need for written guidance

Major Elements

• An effective occupational safety and health programs include:– Management commitment and employee

involvement– Worksite analysis– Hazard prevention and control– Safety and health training

Commitment and Involvement

– Management commitment and employee involvement are complementary

– Management commitment provides the motivating force and resources for organizing and controlling activities within an organization

– Employee involvement provides the means through which workers develop and express their own commitment to S&HG protection

Commitment and Involvement

• Recommended Actions:– State clearly a worksite safety and health

policy– Establish and communicate a clear goal and

objective for the safety and health program – Provide visible top management involvement

in implementing the program

Commitment and Involvement

• Recommended Actions:– Encourage employee involvement in the

program and in decisions that affect their safety and health (e.g., inspection or hazard analysis teams; developing or revising safe work rules; training new hires or co-workers; assisting in accident investigations)

– Assign and communicate responsibility for all aspects of the program

Commitment and Involvement

• Recommended Actions:– Provide adequate authority and resources

to responsible parties– Hold managers, supervisors, and

employees accountable for meeting their responsibilities

– Review program operations at least annually, to evaluate, identify deficiencies, and revise, as needed

Worksite Analysis

• Worksite analysis involves a variety of worksite examinations, to identify not only existing hazards, but also conditions and operations where changes might occur to create hazards

• Effective management actively analyzes the work and the worksite to anticipate and prevent harmful occurrences

Worksite Analysis

• Recommended Actions:– Conduct comprehensive baseline and

periodic surveys for safety and health – Analyze planned and new facilities,

processes, materials, and equipment– Perform routine job hazard analyses

Worksite Analysis

• Recommended Actions:– Provide for regular site safety and health

inspections– Provide a reliable system for employees,

without fear of reprisal, to notify management about apparent hazardous conditions and to receive timely and appropriate responses

Worksite Analysis

• Recommended Actions:– Provide for investigation of accidents and

“near miss” incidents, so that their causes and means for prevention are identified

– Analyze injury and illness trends over time, so that patterns with common causes can be identified and prevented

Hazard Prevention and Control

– Triggered by a determination that a hazard or potential hazard exists

– Where feasible, prevent hazards by effective design of job or job site

– Where elimination is not feasible, control hazards to prevent unsafe and unhealthful exposure

– Elimination or control must be accomplished in a timely manner

Hazard Prevention and Control

• Recommended Actions:– Establish procedures for timely correction or

control of hazards, including– Engineering techniques, where feasible and

appropriate– Procedures for safe work which are

understood and followed as a result of training, positive reinforcement, correction of unsafe performance, and enforcement

– Provision of personal protective equipment– Administrative controls

Hazard Prevention and Control

• Recommended Actions:– Provide for facility and equipment

maintenance– Plan and prepare for emergencies

• Training and drills, as needed

– Establish a medical program• First aid on site• Physician and emergency care nearby

Safety and Health Training

• Addresses the safety and health responsibilities of all personnel, whether salaried or hourly

• Most effective when incorporated into other training about performance requirements and job practices

• Complexity depends on size and complexity of worksite and nature of hazards

Safety and Health Training

• Recommended Actions:– Ensure that all employees understand the

hazards to which they may be exposed and how to prevent harm to themselves and others from exposure to these hazards

Safety and Health Training

• Recommended Actions:– Ensure that supervisors carry out their safety

and health responsibilities, including– Analyzing the work under their supervision to

identify unrecognized potential hazards

– Maintaining physical protections in work areas

– Reinforcing employee training through continual performance feedback and, if needed, enforcement of safe work practices

Safety and Health Training

• Recommended Actions:• Ensure that managers understand their

safety and health responsibilities, as described under the Management Commitment and Employee Involvement element of the guidelines

Education and Outreach

• Compliance Assistance Specialists (CAS)– Each OSHA Office

nation-wide– Non-Enforcement

• VPP Coordinators– Each OSHA Office in

Region VI– Enforcement position

Alliances

• Builds trusting and cooperative relationships

• Training, outreach, education, promoting safety dialogue

• Last up to two years

Partnerships

• Partnerships are written and identify goals, strategies, performance measures, etc.

• Must have a measurable impact

• Like alliances, you can withdrawal at any time

• Last up to five years

OSHA Cooperative Programs

Voluntary Protection Program:

• 1367+ Federal sites• 265+ Region VI• 130+ Houston offices

• VPP Mobile Workforce for construction is here

OSHA Cooperative Programs

• Voluntary Protection Program Elements:

– Management Leadership and Employee Involvement

– Worksite Analysis– Hazard Prevention and Control– Safety and Health Training

• Few companies ever voluntarily leave VPP

OSHA Challenge Program

• Run by Challenge Administrators• Three stage process of implementing a

comprehensive safety program based on VPP principles. No set time for completion

• OSHA is not involved except for recognition at the completion of a stage

• Goal is that once completed the company is ready to apply for VPP

www.oshachallenge.net

OSHCON

• The OSHA Consultation Service (OSHCON) is under the Texas Department of Insurance (TDI)

• Located in every State• Funded primarily by Federal OSHA• Provides free safety consultation services to

small employers – 250 in one location no more than 500 corporate wide

http://www.tdi.state.tx.us/wc/safety/oshcon.html

OSHA Website

• OSHA Website

www.osha.gov

• OSHA QuickTakes – a bi-weekly update by email on what’s new with OSHA

OSHA Website

• eTools• Electronic tools

covering various industries and hazards such as construction, lockout/tagout, scaffolds, etc.

OSHA Website

• Safety and Health Topics Pages

• Covers variety of topics. Overview of information with links to resources

• Many developed with industry through the OSHA Alliance program

RESOURCES -

OSHA Consultation Training Resources

CDC/NIOSH

Oil and Gas E & P

Harwood GrantMaterials

Safety Management

FAQs

State-PlannedState Resources

Disasters

Region VI OSHA Training Institutes

Other Resources

OSHA Cooperative Programs

OSHA 1 of 4

• OSHA Home Page• OSHA QuickTakes

– Sign up for a bi-weekly update on OSHA activities

• OSHA Compliance Assistance Page– Tools and information for assisting companies in their

safety programs– Introduction and review of OSHA

standards that may apply to your workplace– eTools, Expert Advisors, and eMatrix interactive tools

walk you through various hazards and industries

OSHA 2 of 4

• OSHA Small Business Page– Tools and resources of interest to small business

• OSHA Site Index- Quick way to search for topics listed alphabetically

• OSHA Safety and Health Topics– Topic pages on different hazards, industry’s, ect. Use

the search function or drop down menus

• OSHA Publications– Search for booklets, flyers, QuickCards, Fact Sheets,

and other information produced by OSHA

OSHA 3 of 4

• OSHA Recordkeeping Page• OSHA Standards Page

– The OSHA standards, searchable, with hyper links to interpretations from applicable paragraphs

• OSHA Interpretations Page– Search for OSHA standards interpretations

• OSHA Data and Statistics Page– Search for a company’s OSHA inspection history,

frequent citations for your industry, 5(a)(1) violations and other data

OSHA 4 of 4

• Find your industries incident and lost time rates– See how your injury and illness rates compare to

industry averages as compiled by the Bureau of Labor Statistics (BLS). Prior to 2003 the Standard Industrial Code (SIC) was used. Since then the North American Industrial Code System (NAICS) has been in used. You can find your NAICS number and search for your industry average on the BLS homepage

– OSHA Webpage with links to BLS statistics

Oil and Gas E & P 1 of 2

• OSHA Oil and Gas Homepage• OSHA eTools Homepage

– Oil and Gas Well Drilling and Servicing eTool

• WY OSHA (State Planned State)– Servicing Rig Worksheet

• American Petroleum Institute (API)– API Safety Recommended Practices

Oil and Gas E & P 2 of 2

• Association of Energy Servicing Companies– Safety Resources

• International Association of Drilling Contractors• Texas Oil and Gas Association

– Safety Resources

• SafeLandUSA– ‘‘Toolbox’

• South Texas Exploration and Production Safety (STEPS) Network

Disasters 1 of 3

• OSHA Hurricane eMatrix• OSHA Hurricane Recovery• OSHA Emergency Preparedness/Response• OSHA Avian Influenza

• ReadyGov– A Dept of Homeland Security website for disaster

preparedness information

Disasters 2 of 3

• Federal Emergency Management Agency (FEMA)

• CDC/NIOSH– Information and fact sheets for all types of disasters– Storm and Floods– Avian Influenza

• Florida OSHCON (Associated Site)– HurriPlanner, an interactive program to develop a

hurricane preparedness plan

Disasters 3 of 3

• Florida Business Disaster Survival Kit Website– Planning information and templates

• Nat. Institute of Environmental Health Sciences– Hurricane and floods clean-up training materials– Avian Influenza training materials

• Institute for Business and Home Safety– Open for Business® disaster planning materials

developed by the insurance industry

• OSHA Safety and Health Management Systems– Safety and Health Management eTool– Safety Topics Page

• OSHA 1989 Safety and Health Program Management Guidelines

• OSHA Program Evaluation Profile Program

Safety Management 1 of 2

Safety Management 2 of 2

• Business Case for Safety– OSHA Business Case for Safety– OSHA Safety Pays– Business Case Presentation

• Worksafe BC Accident Cost Calculation

OSHA Consultation 1 of 3

• Alabama OSHCONSample Safety Programs

• Arkansas OSHCONSample Safety Programs

• Colorado OSHCONSample Safety Programs

• Florida OSHCON (Safety Writer) • Idaho OSHCON

Sample Safety Programs

OSHA Consultation 2 of 3

• Georgia OSHCONTraining Materials

Sample Safety Programs

• Illinois OSHCONSample Programs, Checklists, Publications

• Missouri OSHCONSample Safety Programs

• Montana OSHCONSample Programs, Brochures, Checklists

OSHA Consultation 3 of 3

• Nebraska OSHCON• Ohio OSHCON

One Hour Safety Presentations

Training Programs and Manuals

Safety Publications

• South Dakota OSHCONSample Safety Programs

• Texas OSHCON

Sample Safety Programs

Publications and Training Resources

State Plan State Resources

• Keep in mind State Plan State’s run their own OSHA programs. Although they must be at least as stringent as Federal OSHA they may be different. Visit the OSHA State Plan State Webpage for additional information

Three State Plan States with a lot of resources

Oregon OSHA Resources

Washington OSHA Resources

Wyoming OSHA Resources

Other Resources

• Consultation Connection– Site for OSHA and OSHA Consultation personnel.

Several resource links available to the public including on-line management tools such as Safety Writer, Accident Tracker, and Record Keeper

• Gulf Coast Safety Training Institute – Training Resources

• US Chemical Safety Board– View or order a DVD on accidents investigated by the

CSB. Found under ‘Video Room’ on left side of website

CDC/NIOSH

• CDC/NIOSH– Homepage– Site Index

• NIOSH Downloadable Videos/Online Training– Working with Stress– Violence in the Workplace– Arc Flash Awareness– Trenching and Excavations or– Testing your Ear Plugs (Audio File) – How to Wear Soft Foam Earplugs

Harwood Grant Materials 1 of 7

• OSHA Harwood Grant Page• Associated General Contractors (AGC)

Fall Protection and Focused Four Hazards

• NorthWest Public Power Association

Wide Variety of Materials

• Texas Engineering and Extension (TEEX)

Oil and Gas Drilling and Servicing Safety

Harwood Grant Materials 2 of 7

• Construction Advancement Foundation

Hexavalent Chromium Materials and Safety and Health Management Systems

• Roadway Safety Awareness

Roadway Construction Safety Tips

Roadway Safety Awareness

• The Construction Institute

Excavation Safety

• Rochester Institute of TechnologySafety and Health Management Systems

Harwood Grant Materials 3 of 7

• Rochester Institute of Technology– Hazards in Food Processing and Preservation

Industry and Related Public Warehousing and Storage Industry

• Non Ferrous Founders’ Society– Arc Flash and Workplace Emergency Planning On-

Line Seminar

• Kirkwood College– Public Warehousing and Storage

Harwood Grant Materials 4 of 7

• Georgia Tech Research Institute– S&H Hazards of Renovation and Remodeling

• Purdue University North Central– Arc Flash and Electrical Safety Awareness

• Kansas State University– Landscaping and Horticulture and Fruit and

Vegetable Manufacturing

• University of Findlay– Warehouse Emergency Planning

Harwood Grant Materials 5 of 7

• UT San Antonio All Safe Mart™– Emergency Preparedness, Retail Grocery &

Convenience Shops, and Landscaping and Horticulture Services online training

• Wayne State University– Highway Construction Work Zones and Traffic Control

hazards

• Work Place Safety Awareness Council– Electrical Safety and Arc Flash On-Line Training

Harwood Grant Materials 6 of 7

• International Union of Operating Engineers– Disaster Response & Recovery, Avian Flu, Mold...– Demolition Safety Awareness On-Line Seminar

• Medical College of Wisconsin– Hazard We May Face When Helping Others

• Auburn University– Workplace Violence Awareness

• West Virginia University– Residential Fall Protection

Harwood Grant Materials 7 of 7

• Eastern Kentucky State– Residential Construction Safety

• AGC/University of New Mexico– Developing a safety Program

• North Carolina State University– Management Systems for Small Business On line

Training

• ABC Central Texas– Residential Construction Safety

R VI OSHA Training Institutes

The University of Texas at Arlington

SW Education Center-TX Engineering Extension Service

OSHA Cooperative Programs

• OSHA Cooperative Programs• OSHA Voluntary Protection Program (VPP)• OSHA Challenge Program

• Region 6 VPP Participants Association (VPPPA)

• Challenge Program Website in Houston

OSHA in Houston

Where is OSHA Located?

Houston North Area Office507 N. Sam Houston Pkwy E. Ste. 400Houston, TX 77060

281-591-2438Houston South Area Office

17625 El Camino Real #400Houston, TX 77058281-286-0583

Disclaimer

• This information has been developed by an OSHA Compliance Assistance Specialist and is intended to assist employers, workers, and others as they strive to improve workplace health and safety. While we attempt to thoroughly address specific topics [or hazards], it is not possible to include discussion of everything necessary to ensure a healthy and safe working environment in a presentation of this nature. Thus, this information must be understood as a tool for addressing workplace hazards, rather than an exhaustive statement of an employer’s legal obligations, which are defined by statute, regulations, and standards. Likewise, to the extent that this information references practices or procedures that may enhance health or safety, but which are not required by a statute, regulation, or standard, it cannot, and does not, create additional legal obligations. Finally, over time, OSHA may modify rules and interpretations in light of new technology, information, or circumstances; to keep apprised of such developments, or to review information on a wide range of occupational safety and health topics, you can visit OSHA’s website at www.osha.gov.