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Workplace Accident and Injury Reduction Program
AWAIR
March 1, 2010
Prepared by: Laura Goodman
Director of Public Safety
2010
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Table of Contents I. ST. CATHERINE UNIVERSITY’S SAFETY POLICY STATEMENT .................................. 4
II. AWAIR POLICY ....................................................................................................................... 5
III. BACKGROUND ...................................................................................................................... 5 IV. SUMMARY .............................................................................................................................. 5 V. AWAIR PROGRAM GOALS .................................................................................................. 6 VI. PROGRAM OBJECTIVES ...................................................................................................... 6 VII. RESPONSIBILITIES .............................................................................................................. 7
A. University Leadership ...................................................................................................... 7 B. Supervisors ....................................................................................................................... 7 C. Public Safety Director ...................................................................................................... 8 D. Safety Committee Members ............................................................................................ 8 E. St. Catherine University Employees ................................................................................ 9
VIII. JOB HAZARD ANALYSIS .................................................................................................. 9
A. Policy ............................................................................................................................. 10 B. Procedures ...................................................................................................................... 10
IX. BUILDING (FACILITY) INSPECTIONS............................................................................. 11
A. Policy ............................................................................................................................. 11 B. Procedures ...................................................................................................................... 11
X. REPORT OF UNSAFE CONDITIONS ................................................................................. 12
XI. SAFETY RULES.................................................................................................................... 12 A. Policy ............................................................................................................................. 12
B. General Safety Rules...................................................................................................... 12 C. Slip, Trips and Fall Hazards (See Appendix H) ............................................................. 13 D. Cylinders ........................................................................................................................ 15
E. Electrical ........................................................................................................................ 15 F. Fire Safety ...................................................................................................................... 16
G. Flammables .................................................................................................................... 16 H. Ladders ........................................................................................................................... 17
I. Manual Material Handling ............................................................................................. 17 J. Machinery ...................................................................................................................... 18
K. Office ............................................................................................................................. 18
L. Personal Protective Equipment (Refer to PPE Program) ............................................... 19 M. Tools .............................................................................................................................. 20
N. Welding .......................................................................................................................... 21 XII. HAZARDOUS INCIDENT/ACCIDENT INVESTIGATIONS ........................................... 22
A. Policy ............................................................................................................................. 22
B. Procedures ...................................................................................................................... 22 XIII. AWAIR COMMUNICATION ............................................................................................ 23
A. Policy ............................................................................................................................. 23 XIV. SAFETY COMMITTEE...................................................................................................... 24
A. Policy ............................................................................................................................. 24 B. Objectives ...................................................................................................................... 24 C. Safety committee member’s responsibility .................................................................... 25
D. Safety committee member guidelines for notifying employees of safety hazards, unsafe
actions and safety rule violations. .................................................................................. 26 XV. EMPLOYEE TRAINING ..................................................................................................... 26
A. Policy ............................................................................................................................. 26
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B. Procedure ....................................................................................................................... 26 XVI. NEW EMPLOYEE ORIENTATION .................................................................................. 27
A. Policy ............................................................................................................................. 27 B. Procedure ....................................................................................................................... 27
XVII. ENFORCING SAFE WORK PRACTICES AND RULES ............................................... 27
XVIII. DEPARTMENT RESPONSIBILITIES ........................................................................... 28 XIX. MATERIAL SAFETY DATA SHEETS ........................................................................... 29 XX. DISCIPLINARY PROCEDURES ........................................................................................ 31 Appendix A ................................................................................................................................... 33
Hazard Assessment ................................................................................................................... 33
Appendix B ................................................................................................................................... 35 Hazardous Materials Inspection Report .................................................................................... 35
Appendix C ................................................................................................................................... 36 Report of Unsafe Condition ...................................................................................................... 36
Appendix D ................................................................................................................................... 37 Supervisor’s Accident Investigation Report ............................................................................. 37
Appendix E ................................................................................................................................... 38 Instructions for Completing Accident Report ........................................................................... 38
Appendix F.................................................................................................................................... 39
New Employee Safety Orientation Checklist ........................................................................... 39 Appendix G ................................................................................................................................... 40
SAFETY PROGRAM EVALUATION SUMMARY – (YEAR) ........................................ 40 Appendix H ................................................................................................................................... 43
Hazard Identification/Inspection ............................................................................................... 43
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I. ST. CATHERINE UNIVERSITY’S SAFETY POLICY STATEMENT
St. Catherine University believes that employees are the most important assets a company has and gives the highest priority to maintaining the safest working environment possible for our employees.
Safety is of vital importance for our patrons and our employees. Our goal is the elimination of accidents and injuries from our operations. A good safety record reflects the quality of our work force. It also
serves to promote business and thereby contributes to the continuing growth and success of the company.
Our workplace has been analyzed for safety hazards and continues to be monitored through effective employee communication, self-inspection, accident/incident investigation, employee training, and an established safety committee. With these and many other tools in place our company strives to reduce or even eliminate work place
hazards. A written safety program has been established and implemented for the protection of our employees. The success of our safety program
depends on the sincere, constant, and cooperative effort of all employees and their active participation and support. Safety must be
considered a vital part of every job in our company.
__________________________________________ _________________ Vice President of Finance & Administration Date
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II. AWAIR POLICY
It is the policy of St. Catherine University to provide a safe and healthy work environment for all employees. St. Catherine University will provide appropriate equipment, safeguards, personal protection, training and administrative support to protect employee safety and health. St. Catherine University employees will be trained to work
safely and will be required to comply with all safety rules and standards.
III. BACKGROUND
The purpose of ―A Workplace Accident and Injury Reduction‖ (AWAIR) program is to reduce employee injuries and illnesses by identifying, analyzing and controlling hazards. Under this program, all accidents and near misses will be investigated and measures will be taken to correct problems. St. Catherine University will develop and enforce mandatory safe work practices, while providing the equipment and
safeguards necessary for employees to work safely. The plan will be communicated to employees so they can participate and take an active role in health and safety. A joint management/ employee safety
committee will be formed to provide assistance in accident investigation, hazard analysis and hazard communication. The safety committee will meet on a regular basis.
IV. SUMMARY
The St. Catherine University has developed ―A Workplace Accident and Injury Reduction‖ (AWAIR) program to establish and implement a written program, promoting safe and healthy working conditions
based on clearly stated goals and objectives. This program includes
requirements covered under Minnesota Statutes 182.653, ―A Workplace Accident and Injury Reduction‖ Act.
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V. AWAIR PROGRAM GOALS
The St. Catherine University has established the following goals for the AWAIR program: A. Continuously reduce annual lost workday incident rate below level from
previous year.
B. Bring our facilities into compliance with applicable federal and state
occupational safety and health regulations identified in health and safety audits.
C. Implement continuing, effective health and safety programs to provide St. Catherine University employees with a safe and healthy workplace.
D. Actively encourage St. Catherine University employee involvement in health and safety programs.
VI. PROGRAM OBJECTIVES
The St. Catherine University has identified the following steps for
accomplishing these goals. (Copies of the St. Catherine University’s AWAIR program are available to employees upon request.)
A. Assign responsibilities
B. Establish systems for identifying, analyzing and controlling hazards
C. Communicate program effectively and encourage employee participation
D. Investigate all incidents
E. Enforce safe work practices and rules
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VII. RESPONSIBILITIES
Safety is the responsibility of every employee. This requires that all
levels work together to prevent accidents. The following duties have been established for each level to ensure compliance with all elements of the university’s safety program. The St. Catherine University’s AWAIR program is managed by the public safety director with oversight by the Safety Committee. Responsibilities
for implementation of the St. Catherine University’s safety programs are assigned as follows:
A. University Leadership
1. Establish company safety policies and procedures.
2. Actively promote and support safety policies and procedures.
3. Direct and support the public safety director in program execution.
4. Review the safety program to ensure effectiveness.
5. Allocate necessary funds, resources, and time to achieve program
goals.
6. Review progress in achieving safety program objectives.
7. Support supervisors in enforcing safety policies and procedures.
B. Supervisors
1. Execute and maintain each element of the safety program
including: training, safety inspections, accident investigations and completing the first report of injury.
2. Review progress in achieving program objectives with top
management. Consult with leadership to help establish company safety policies and procedures.
3. Inform leadership and employees of operational changes requiring
modification of company policies and procedures.
4. Enforce safety policies and procedures using the established disciplinary system.
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5. Direct implementation of each element of the safety program, which may include:
a. Comply with safety rules and regulations.
b. Ensure safety training of all company employees. c. Investigate all workplace accidents.
d. Complete regular building (facility) safety inspections. e. Maintain safety communication with all employees. f. Report all claims to the safety coordinator.
g. Evaluate program effectiveness. h. Identify and control workplace hazards through Job Hazard
Analyses (JHA).
C. Public Safety Director
1. Requests funding to maintain effective safety programs.
2. Oversees and coordinates implementation of AWAIR program. 3. Provides new employee orientation.
4. Monitors program effectiveness, revising program as necessary.
5. Evaluates and updates AWAIR program annually.
6. Conducts routine inspections. 7. Performs follow-up to verify problems are corrected promptly.
8. Oversees accident and incident investigations.
9. Oversees Job Hazard Analyses (JHA).
10. Oversees scheduling of safety meetings/training sessions.
11. Encourages and reinforces employee participation in safety matters.
D. Safety Committee Members
1. Attend committee meetings.
2. Complete assigned tasks determined by committee (inspections, job hazard assessments, accident investigations, etc.).
3. Post copies of minutes and solicit co-workers for suggestions and input.
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4. Communicate about safety issues and encourage safe behavior.
5. Recommend corrections and follow-up to be sure actions are
taken.
E. St. Catherine University Employees
1. Adhere to all company safety rules and policies.
2. Participate in company safety training classes as needed and/or
required by employer.
3. Cooperate with all accident investigations and building (facility)
safety inspections. 4. Maintain conduct in a reasonable and responsible manner to
prevent injury to themselves and others.
5. Assist in analysis of workplace hazards through Job Hazard Analyses.
6. Participate as a member of the safety committee when requested. 7. Work according to good safe practices as posted, instructed and
discussed.
8. Use all safety devices provided for their protection. For example, safety glasses and machine guarding.
9. Report any unsafe situation or act to their supervisor or a safety committee member immediately.
10. Report to the designated area for first-aid treatment in the event of
any injury. In all cases, the employee, supervisor shall report
and/or record all accidents. 11. Maintain a clean and safe work area.
VIII. JOB HAZARD ANALYSIS
The Public Safety Director oversees implementation and maintenance of safety management programs. The Public Safety Director will insure that a Job Hazard Assessment will be completed by supervisors for all
job functions throughout the university. Routine building (facility)
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audits and program reviews are conducted to verify compliance or identify hazardous conditions and work practices.
A. Policy
Leadership and supervisors will be responsible for completion of the Job Hazard Analysis (JHA) on all job functions. Leadership, supervisors and employees should actively assist in this process, due to their familiarity
with the job steps, hazards, and control measures needed. A JHA is an important accident prevention tool. It helps identify hazards and
eliminate or minimize them, making a job task safer to perform. Our JHA's can also be used to develop specific safety rules, special training programs, and provide orientation for new employees.
B. Procedures
When performing a JHA, the following elements should be considered:
1. A JHA should first be completed on all high hazard jobs.
2. Next, a JHA should be completed on jobs that have an actual or
potential high frequency or severity 3. After the jobs have been identified, look at the individual job
steps/tasks. Then concentrate on the high hazard/key steps/tasks.
4. Attain employee, team leader, and lead person input.
5. Note the safety controls in place and determine if they are adequate.
6. Add controls that are needed to reduce/eliminate hazards.
7. Develop job guidelines, controls, and safety measures. 8. Include these preventative measures in rules/regulations and
training programs.
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IX. BUILDING (FACILITY) INSPECTIONS (See Appendix B)
A. Policy
The primary purpose of the facility inspection is to detect potential
hazards so they can be corrected before an accident occurs. The facility will be inspected using continuous, ongoing inspections and interval inspections. This will help in achieving the goal of having each individual
vigilant and alert to any condition with accident potential and willing to initiate corrective action, as well as, establishing accountability for the role of management, supervisors and Individual employees in the Safety
Program.
B. Procedures
The frequency of the inspections will be determined by:
a. Loss severity of the problem
b. Potential for injury to employees c. Past history d. Monthly/Seasonal activity
Each location’s designated inspector will conduct inspections
monthly to seasonally.
Inspectors may use the designated checklist when conducting the inspection. (See Appendix B)
When deficiencies are noted on the inspection checklist, corrective
action must be taken. (See Appendix B)
The safety work order should be used if repair work is required on equipment or a work area.
Failure of anyone to obey safety rules should be reported to the
appropriate leader or supervisor.
The inspection reports will be reviewed by the Public Safety
Director/Safety committee to insure corrective action is taken and any required changes to procedure, programs, policies, and
etcetera are made and communicated.
Proper documentation is required. Work orders, repair bills, and invoices should be attached to the inspection forms as part of the
documentation process.
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X. REPORT OF UNSAFE CONDITIONS
Any person including employees, supervisors, vendors, and outside
contractors have the responsibility to report any suspected or actual unsafe condition, safety hazard, unsafe work practices, or unsafe/hazardous equipment immediately to leadership, supervisors or
the public safety director via verbal communication or by the use of the ―Unsafe Condition‖ form located in the public safety department.
All reported unsafe conditions, safety hazards, unsafe work practices, or unsafe equipment will be investigated immediately by the immediate
supervisor/leader. The public safety director will oversee the investigation and make sure corrective action is taken. Once corrective action has
taken place the employee who identified the unsafe condition will be notified of the action taken. All reports of unsafe conditions, safety hazards, unsafe work practices, and unsafe equipment will be reviewed by
the safety committee every meeting.
XI. SAFETY RULES
A. Policy
These guidelines and safety rules have been developed to ensure a safe working environment for all employees. General safety guidelines apply to
all personnel. Additional guidelines may be applicable for certain job functions. Knowledge of and adherence to these guidelines is the responsibility of each employee. All employees will be provided with a copy
of the applicable safety guidelines during orientation. At that time, the employees should sign the New-Employee Orientation Form, stating they understand and agree to comply with safety guidelines. Failure to adhere
to these rules and regulations may result in disciplinary action. University safety rules are categorized as follows:
B. General Safety Rules
Work areas should be kept neat, orderly, and free of obvious
physical hazards.
Workplace injuries or accidents must be reported to your supervisor immediately.
Unsafe acts or conditions should be reported to your supervisor at
once.
Horseplay is strictly prohibited.
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Loads that are too heavy or awkward require asking for assistance
or use of a mechanical lifting device.
Safety instructions and warning signs shall be observed.
Physical violence against another employee, visitor, equipment, building and oneself is strictly prohibited.
Proper personal protective equipment (PPE) must be worn in all
designated areas.
Smoking is prohibited on the Minneapolis campus and only
allowed in designated areas on the St. Paul campus.
Use or possession of controlled substances or alcohol on the job is prohibited.
Weapons are prohibited on campus.
C. Slip, Trips and Fall Hazards (See Appendix H)
General Safety
Avoid running or waling too fast, especially in higher risk areas.
Avoid carrying items that will obstruct one’s view of their walking pathway.
Avoid walking through potential slip, trip and fall hazards.
Use extra caution when traveling both outdoors and indoors
during/following wet weather.
General Housekeeping Procedures
Clean up spills immediately. For greasy liquids, use suitable
cleaning agent.
Do not leave floors wet after cleaning—clean them to a completely
dry finish is possible. If ―clean-to-dry‖ is not possible, then use barriers and ―wet floor‖ warning signs to keep people off the wet area.
Use cleaning methods that do not spread the problem. Small spills are often better dealt with using a paper towel instead of a
mop that wets a larger area of floor.
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Do not use cardboard to soak up spills.
Slip Hazards
Floors, platforms, and walkways shall be maintained in good repair and reasonably free of oil, grease, or water. Mats, grates, or
other methods that provide equivalent protection shall be used on areas where operation requires walking on slippery surfaces.
Slip-resistant floor coatings should be used in areas that are likely to get wet or subject to frequent spills.
Slip hazards must be identified and removed promptly.
Warning signs or other equally effective means (barricades) should be used as a warning system in areas where a slip hazard is
present.
Trip Hazards
Platforms and walkways shall be free of obstructions and dangerous projections (e.g. extension cords, power cables, hoses, carts, boxes, debris).
Position equipment to avoid cables crossing pedestrian routes; use cable covers securely fixed to surfaces or consider use of cordless tools.
Surfaces in poor repair (i.e. holes, surface upheaval, and broken tiles) shall be repaired or guarded by readily visible barricades,
rails or other equally effective means.
Floor mats and rugs must be securely fixed and not have curling edges.
Fall Hazards
Elevated Locations
Guardrails shall be provided on all open sides of unenclosed elevated locations. Examples of elevated locations include
balconies, runway ramps, or working surfaces that are more than 30 inches above the floor, ground, or other working areas of a building.
Roof guardrails shall be provided at locations where there is a routine need for an employee to approach within 6 feet of the edge of the roof. Where such roof access is needed no more than four
times a year, safety belts, lanyards, or an approved fall protection system may be used in lieu of guardrails.
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Stairways shall have handrails or stair rails on each side.
Elevating Work Platforms and Aerial Devices (e.g. vertical tower,
scissor lift, mast-climbing work platform):
Only employees who have been trained and approved by the supervisor shall operate elevating work platforms and aerial
devices. NOTE: Aerial device and elevating work platforms are vehicle-mounted or self-propelled devices designed to elevate a
platform/individual in a substantially vertical axis.
D. Cylinders
Gas cylinders shall have contents clearly identified.
Leaking or defective cylinders must be removed from the work area promptly and repaired as soon as possible. The cylinders should
be tagged and/or isolated for repair.
Cylinder valves must be protected with caps or guards when not in
use.
Cylinders must be secured in an upright position at all times and chained or braced securely.
Air nozzles must be used with an OSHA approved air pressure
restrictive device to limit pressure to thirty (30) psi.
Compressed air cleaning for any job must ensure other employees are not exposed to flying particles or dangerous vapors. Proper
personnel protective equipment (PPE) shall be worn.
Compressed air use to clean employees off is strictly prohibited.
E. Electrical
Electrical wires must be considered "live" until it is positively
known the wires are dead.
Extension cord use for permanent equipment is not allowed.
Portable electrical tools must be grounded with a three (3)-wire
circuit.
High voltage circuit contact should be avoided.
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Electrical cords should not be wrapped around any pipes.
Live wires should not be worked on with rubber gloves or insulated handles of tools that are not dependable.
Authorized employees only are permitted to do electrical
maintenance work.
F. Fire Safety
Do not use an open flame heat device in confined or enclosed
structures. Vent heaters to the atmosphere and make sure they are located an adequate distance from any combustible walls,
ceilings, and floors.
Have fire extinguishers available at all times when utilizing heat-
producing equipment such as welders, gas torches, or portable heaters.
Familiarize yourself with the exit routes from your workstation so
they can be used in an emergency.
Become familiar with the location of firefighting equipment in the work area and have knowledge of its use and application.
Never return a used fire extinguisher to its holder. Return the unit
to the public safety department for recharging.
Report all fire hazards to your supervisor as soon as possible.
Make sure that the area is clear of all combustible materials, when
utilizing heat-producing equipment.
Call 911 immediately in the event of a fire, followed by plan and evacuation procedures.
G. Flammables
Keep open flames or sources of ignition away from areas of use or
storage of flammable or combustible liquids.
Use proper ventilation where flammable or combustible liquids are
used or stored.
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Use U.L. listed safety cans, cabinets, or approved storage rooms for storage of flammable or combustible liquids depending on liquid
type and volume. (Refer to NFPA standards for specific information).
H. Ladders
Check to see that ladders are free from defects prior to use.
Report any problem to your supervisor at once.
Provide all catwalks with forty-two (42) inch handrails, mid-rails,
and six (6) inch toe boards.
Face the ladder when ascending or descending.
Slide down a ladder is strictly prohibited.
Work or standing on the top rung of the ladder in strictly prohibited.
Make sure a ladder is long enough for the job prior to the start of
the project.
Do not use metal ladders for electrical work.
Ensure that the base of an extension ladder is one-quarter (1/4) of its height out from the wall.
Do not over reach when on a ladder as the ladder may roll or slip
from under you.
I. Manual Material Handling
Always obtain help for heavy or awkward lifting projects.
Use mechanical assistance such as overhead hoists, pallet jacks,
forklifts, or two wheel carts whenever appropriate.
Warm up by stretching back and related muscles before any lifting activity, especially when first starting your shift or after an
extended time away from normal job duties.
Lift with your legs, NOT YOUR BACK, when lifting heavy objects
alone.
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Start by bending your knees, keep the load close, grasp firmly, and lift with your legs. Don't use jerky motions and avoid twisting your
back.
Do not overload two-wheel hand trucks.
Do not pile a load so high that it blocks your view when transporting it on a cart or dolly.
Always use a cart or truck specifically designed to handle drums
and barrels.
Push hand trucks. Hand trucks should not be pulled!
Make sure the load is stable by putting the weight on the axle, not on the handle.
Put the handle up and lower the forks when you leave an empty
hand truck so that it won't be a tripping hazard.
J. Machinery
Guard all belts, couplings, gears, and flywheels properly. Guards
should never be removed while the machine is in operation. When taken off for maintenance, they should be replaced immediately
after completion before taking off the lockout/tag out tags or locks.
Be sure proper warning signals have been given and acknowledged
before starting machinery
Lockout/tag out procedures must be followed when working on or repairing any machinery.
Beware of pinch points. Keep fingers and hands out of pinch
areas.
Do not operate any equipment unless all protective guards are in
place.
Do not start any machine unless you know how to stop it.
Operate machines only if authorized to do so.
K. Office
Never overload electrical sockets.
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Approach closed doors with caution and open slowly - someone may be on the other side.
Open and close file cabinet drawers one at a time using the drawer
handles only.
Clean up floor spillage promptly to prevent accidents.
Use the stairwells to exit the building in the event of an emergency evacuation—never use elevators.
Never lean back on a chair or to any position that would
compromise the stability of the chair.
Walk, never run or slide, when crossing floors.
Take one stair at a time at a walking pace when using stairs and
always use the handrail.
Confine computer cables and cords
Do not operate Xerox-type duplicators with the cover open, unless
absolutely necessary. If the cover is open, do not look directly at the light source.
L. Personal Protective Equipment (Refer to PPE Program)
A full face shield shall be worn with operations such as heavy
grinding, chiseling with an air tool or cold chisel, or cutting steel with an abrasive wheel cutoff saw.
Eye protection shall be kept clean and free of dirt and damage,
which could make visibility poor or lessen the strength of the protection.
Gloves shall be worn when exposed to bodily fluids, sharp materials and around chemicals, which could cause burns or
irritation.
Goggles or a full-face shield shall be worn when conducting
operations exposing you to chemicals, which could burn or irritate eyes or skin.
Hearing protection shall be worn when exposed to high levels of
noise for extended periods of time.
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Personal protective equipment (PPE) is required when working in
an area that exposes you to special hazards.
M. Tools
Be sure that a power tool is off and motion stopped before setting
tool down.
Disconnect tool from power source before changing drills, blades, bits, or attempting repair or adjustment.
Do not use tools until you have been properly instructed and
authorized to do so.
Inspect electrical extension cords and other wiring to be certain
they are properly insulated.
Do not use frayed or damaged cords.
Use the correct tool for the job and use it in a correct manner.
Keep tools in good working condition. Damaged, worn, or defective
tools can cause injuries and shall not be used.
Do not carry loose tools in pockets, but in tool pouches.
Do not remove machinery or equipment guards without
authorization.
Do not use an empty barrel for a worktable. The original contents of the barrel may be explosive.
Do not make repairs to tools or equipment unless authorized by
your supervisor.
Ground punch and chisel heads at a forty-five (45) chamfer to
prevent mushrooming.
Take special precautions when using power tools on catwalks.
Maintain a good footing, use both hands, keep cords clear of obstructions, and do not over reach.
Do not throw or drop tools and/or equipment when being transferred from one working level to another.
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Do not improvise or construct tools except on specific authorization from a supervisor.
N. Welding
Ensure that a ground return cable has a safe current carrying
capacity equal to, or exceeding, the specified maximum output capacity of the arc-welding unit that it services.
Clear area below cutting or welding operations so that you do not drop slag on combustibles, hoses, cables, or employees.
Ensure proper ventilation is provided whenever welding, cutting, or
heating, is performed in a confined space.
Keep a suitable fire extinguisher readily available when welding,
cutting, or heating on the job. Monitor the area for a minimum of 30 minutes after welding is complete.
Make sure that all parts subject to electrical current are fully
insulated against the maximum voltage encountered to ground.
Place cables, leads, and connections so that there is no fire or tripping hazards.
Shield all arc welding and cutting operations with non-combustible
or flame proof screens whenever possible. Use welding curtain when possible.
Use approved welding helmets and burning goggles for eye protection and to prevent flash burns. Always wear eye protection
to guard against slag while chipping, grinding, and dressing of welds.
Follow the "Hot Work‖ permit procedures whenever conditions
warrant.
Use proper personal protective equipment (PPE) such as leather
gloves, apron, goggles, helmet, cap, leggings, and sleeves.
Do not weld or cut near flammable liquids or gases that are within 20 feet.
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XII. HAZARDOUS INCIDENT/ACCIDENT INVESTIGATIONS
All hazardous incidents ("near misses") and accidents will be investigated and corrective actions taken. The public safety director oversees health
and safety investigations, including: Maintaining accident/incident form(s) to report, document and
analyze all incidents. Promptly reviews hazardous incidents ("near misses") and accident
investigations that have been completed by the supervisor. Overseeing the Implementation of corrective actions to prevent a
repeat incident.
A. Policy
In order to determine the accident cause(s), the injured employee and the supervisor will investigate the workplace injury and what actions are necessary to prevent recurrence. To accomplish this, the Accident
Investigation Form must be filled out in detail. The public safety director and the safety committee will review each accident/incident investigation to determine cause and make sure corrective action has been
implemented.
B. Procedures
1. Write down in detail, the events, conditions and circumstances
surrounding the accident. Include the part of the body affected and the type of accident (slip/fall, struck by, etc.) immediately after the accident or as soon as is medically possible. The employee or
supervisor should write this. 2. Fill in the injured employee's name, the date and time of the
accident and the department or plant area where the accident occurred. Indicate any witnesses and attach their statements.
3. Answer the questions in the analysis section and any pertinent
findings detailed in the explanation area.
4. Review the statements, analysis section, accident scene, and consider any facts brought out during interviews. State what the
underlying and direct causes of the accident are.
5. Indicate what corrective actions will be taken to prevent a recurrence of this type of accident based on the causes listed
above.
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6. Note if a work order was submitted (see Building (Facility) Inspection section) if faulty equipment or materials caused the accident. Indicate who is responsible for completing the work and
when the work is to be completed.
7. Complete disciplinary procedures as soon as possible if the accident was caused by a personnel deficiency. Any disciplinary
actions determined will be completed as soon as possible and verified by a follow-up procedure.
8. Sign the completed investigation form. The injured employee,
immediate supervisor if applicable, and the accident investigator should all sign the completed investigation form. This is done only
after the form is thoroughly completed.
9. Review of all accident/incident forms will be done by leadership, the public safety director and the safety committee to determine if corrective action has been implemented.
XIII. AWAIR COMMUNICATION
A. Policy
An essential element of St. Catherine University’s safety program is good communications. This will be accomplished in a variety of ways. Our
goal is to keep employees informed and to encourage their participation and cooperation with university safety policies and procedures. St. Catherine University feels it is all employees’ responsibility to report
safety concerns they may have and are encouraged to speak up about their health and safety on the job. All employee safety concerns will be given the highest priority by the public safety director and leadership.
The following methods will be used to keep employees informed of issues
affecting their safety and health.
1. The Update
2. Safety Committee
3. Safety Suggestion System
4. Employee Handouts 5. Employee Training Sessions
6. Postings on University Bulletin Boards.
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7. Interaction with Supervisors, Leadership and Safety Committee
Members 8. Posters and Signs
XIV. SAFETY COMMITTEE
A. Policy
An important element of our workplace safety program is having an
effective safety committee.
SCU safety committee shall be comprised of representatives from those areas on campus most likely to deal with safety issues. Safety committee representatives shall include leadership, supervisors and staff including,
but not limited to, the public safety director and coordinator, director of facilities, the trade’s manager, custodial/grounds supervisor, director of
the O’Shaughnessy and employees from designated areas on campus, including Art, Biology, and Chemistry.
B. Objectives
1. Set a Good Example - Members must maintain safe work
practices and a positive attitude towards safety.
2. Review Safety Inspections - All workplace hazard inspections will
be reviewed by the safety committee for input and recommendations. The unsafe acts and conditions identified should be discussed and assignments made to correct the
problem. It is important to verify that corrective action has been taken promptly, so that these problems do not contribute to future
accidents and injuries.
3. Report Unsafe Acts/Conditions - Members must lead the way in
informing leadership/supervisors of workplace hazards at all
times. This should be done formally in writing as well as immediate on-site discussions.
4. Review Accident Investigation Reports - Once an accident
investigation report is completed, the safety committee will review
the report for completeness and clarity. The main goal is to ensure that proper corrective steps were taken to prevent recurrence of a similar accident. If preventative actions are not adequate, the
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committee should recommend additional or alternate control measures.
5. Hold Regular Meetings - Meetings should be conducted on a
regular basis. The public safety director will have the following
duties:
a. Set the date for the meeting
b. Document the meeting activities c. Review safety inspections. d. Gather/review accident reports prior to the meeting
e. Inform leadership of the safety committee activities f. Develop method of selecting the committee members
g. Make assignments to the members h. Keep the meeting on track to ensure problems are solved
6. Act on Employee Safety Suggestions - Make a concerted effort to
resolve/correct safety concerns raised by employees and give feedback to the person(s) concerned.
C. Safety committee member’s responsibility
1. Attend all scheduled safety committee meetings
2. Make recommendations in regards to accident/injury investigations discussed in the safety committee meeting.
3. Make recommendations in regards to unsafe conditions discussed in the safety committee meeting.
4. Lead by example, by following all safety rules including the use of
personal protective equipment (PPE).
5. Be aware of safety issues in their work area.
6. Report safety hazards found in their work area.
7. Take reports from other employees in regards to safety hazards/concerns on the production floor.
8. Observe daily operations being aware of safety issues, notifying employees in their work area of safety hazards, unsafe actions, and
safety rule violations. 9. Complete incident reports on near miss incidents occurring in their
work area.
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10. Conduct an annual evaluation of losses and changes in the exposures to employees and determine if the AWAIR program is
adequate or needs modification. (See Appendix F)
D. Safety committee member guidelines for notifying employees of safety hazards,
unsafe actions and safety rule violations.
If a safety committee member observes any safety hazard, unsafe action or a safety rule violation, they will at their discretion talk with the person or persons involved with the safety hazard, unsafe action or safety rule
violation. If the safety committee member is not comfortable with talking directly to the persons involved, they will immediately report to that
person or person’s supervisor in regards to the safety hazard, unsafe action, or safety rule violation. The supervisor will then have the responsibility to address the safety concern for that person or persons. If
further action is required, the public safety director will be notified of the safety issue. The public safety director will then follow up with all employees involved in the safety hazard, unsafe action or safety rule
violation.
At the discretion of a safety committee member or supervisor, immediate action may be taken to prevent serious injury on the campus.
All accident/injury reports, near miss reports, unsafe condition reports and any safety concerns will be discussed at the next scheduled safety
meeting.
XV. EMPLOYEE TRAINING
A. Policy
On-going safety training will be provided for all employees in an effort to maintain the lowest accident/injury rate possible, and to maintain
compliance with applicable state and federal safety regulations. Accident prevention will be the number one priority and will be presented as a positive, desirable and integral part of the everyday activity of any
employee while on the job.
B. Procedure
St. Catherine University will provide a systematic training program. The program will provide new-employee orientation prior to any new
employee starting a new job, on going on the job training, and safety and health training focusing on safety rules and requirements. Applicable state and federal regulations dictate training for several topics. All
applicable required state or federal training will be completed as prescribed in the regulations.
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XVI. NEW EMPLOYEE ORIENTATION (See Appendix E)
A. Policy
New employees and temporary employees are particularly susceptible to
accidents and injuries due to their unfamiliarity with company processes and the work environment. Therefore, it is essential that all new employees receive a thorough orientation of the facility, their job duties,
potential hazards on the job, and their responsibilities related to our safety program.
B. Procedure
Supervisors are responsible for the safety orientation of the employees in
their department. This orientation must be completed on the first day of employment and must be documented using the New Employee Safety Orientation Checklist (See Appendix E) and placed in the employee's
personnel file. No employee may start on the job without first going through new employee orientation.
XVII. ENFORCING SAFE WORK PRACTICES AND RULES A. To ensure safe work practices and that rules are consistently enforced,
leadership and supervisors in coordination oversee: 1. Enforcing safe work practices and rules consistently among St.
Catherine University employees
2. Retraining employees if initial training appears to be ineffective
3. Enforcing and documenting progressive discipline program
B. Safety Policy Enforcement
All St. Catherine University’s employees are obligated to observe the safety rules. The following guidelines have been developed to assure any
corrective discipline that may be required is administered in a fair and consistent manner:
1. Safety is everyone’s responsibility. Failure to enforce the safety rules is in itself an infraction and will be treated as such utilizing corrective discipline to encourage behavioral change.
28
2. All employees, including leadership and supervisors, participating in or condoning an unsafe act shall receive equal corrective
discipline.
3. The unsafe act performed and previous events shall determine the
level of corrective discipline received, not the extent of injury or damage incurred.
4. Documentation of corrective disciplinary actions and case
interviews may become part of the employee's personnel records.
5. All documented corrective disciplinary action will be approved by
the Department Leader and the Human Resources Director with
input from the Director of Public Safety to assure consistent application of this policy.
XVIII. DEPARTMENT RESPONSIBILITIES
A. The following academic and administrative departments have been
identified as those with employees that may be exposed to potential
hazards or requiring special training and/or equipment as outlined in this plan.
Art
Athletics
Audio-visual
Biology
Bookstore
Chemistry
Computing services
Custodial
Exercise and sports medicine
FCNS
Grounds
Health and wellness
Holistic health studies
Nursing
Occupational science and occupational therapy
Occupational therapy assistant
O’Shaughnessy
Phlebotomy
Physical therapy
Radiography
Respiratory care
Safety and Security
Sonography
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Theater
Telecommunications
Trades
B. Department responsibilities with regard to safety in the classroom and
on the job:
1. Provide hazard assessments on all jobs that expose employees to
potentially hazardous materials or working conditions, and provide and document safety training to all jobs above.
2. Provide MSDS (Material Safety Data Sheets) as required.
3. Provide appropriate safety training in the classroom for all classes that may expose students to potentially hazardous material or activities, and properly document safety training in the syllabus,
and elsewhere as deemed appropriate.
4. Clearly document all incidents of injury to students in the
classroom, and forward such documentation to supervisors and the director of public safety.
XIX. MATERIAL SAFETY DATA SHEETS
A. Purpose
The purpose of this policy is to set guidelines for the management and updates of OSHA mandated Material Safety Data Sheets (MSDS).
B. Policy
The University is mandated to maintain MSDS’s in a central location for all materials in inventory that are deemed to require them. The only approved
repository for such data is the web based ―Damarco Solutions, LLC‖. It shall be the policy of the University that all departments will insure that all materials with attached MSDS’s received in inventory for use by the University employees
are properly posted in the SCU database.
C. Procedure
The Public Safety Department has been charged with the responsibility of managing the MSDS process. The administrator of the program is the Director of Public Safety.
MSDS’s contained in the SCU database are filed by department.
There shall be one person from each department responsible for monitoring the receipt of all materials, and insuring that they are entered in the manner
30
described below.
How to enter materials in the database: The person responsible shall access the Damarco Solutions Online website at
http://www.demarco.com or in an emergency by calling
612-617-0999, Option 2
Enter assigned user name and password in the upper right corner.
Once logged on, there is a search screen that allows a search of the MSDS Online master database of over two million MSDS. This database is used to
find materials for the SCU database. When the search is successful, there is a checkbox to be checked which sends a message to the administrator requesting that the material be added to the University inventory or if assigned an
administrator password, add the material.
The administrator shall routinely check the website to insure that the additions requested above are added to the University database. In addition to adding them to the database, the administrator shall also insure that they are
classified according to department to simplify subsequent searches.
How to access MSDS: University MSDS can be accessed over the web at:
http://www.damarco.com/default.asp?cmd=login&Username=stkateemplo
yee&Password=154MSDS9
At this site, a user can view SCU current inventory, click on ―Inventory.‖ A user can also click on individual departments under ―Inventory‖ and see a list
of all MSDS for that department. Finally, a user could use the search screen to look for a specific product.
SCU employees may also access the toll free hotline
1-877-451-6919
to obtain a MSDS if they do not have access to a computer, or to speak to a medical professional regarding health issues or concerns due to use or exposure to a chemical.
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XX. DISCIPLINARY PROCEDURES
A. Policy
The following procedures have been established to ensure that corrective action resulting from violation of company safety standards and training is
administered in a consistent and systematic manner. Employees who fail to comply with company safety standards or safety training requirements will be subject to disciplinary action up to and including termination.
Disciplinary procedures must include the employee’s immediate supervisor and
department leader approval and will be placed in the employees file. The disciplinary steps are outlined below:
STEP ONE: Verbal Counseling - Following the violation of established safety procedures or failure to attend mandatory safety training, a discussion must be held with the employee in question, citing the inappropriate behavior and
explaining any corrective action required. This must be documented in the employee's personnel file.
STEP TWO: Written Warning - Safety violations or failures to attend mandatory safety training which are repeated require that a (Written Warning
Notice be given to the employee, clearly outlining the problem and specifying corrective action.) This warning shall be signed and dated by the employee
and the immediate supervisor, with a copy placed in the employee's personnel file.
STEP THREE: Suspension without Pay - Continued violation of established safety procedures or failures to attend mandatory safety training, following a Written Warning Notice or serious violations, which demonstrate reckless
behavior, subject the employee to a suspension of employment without pay. This suspension shall be for a minimum of one (1) workday and not to exceed
five (5) workdays. The reason for the suspension must be discussed with the employee and a copy of the Notice of Suspension placed in the employee's personnel file.
STEP FOUR: Termination - Repeated violations of company safety procedures or extreme violations or failures to attend mandatory safety
training may constitute grounds for dismissal.
Progressive discipline may but does not necessarily have to follow the above steps. There can be circumstances causing the company to waive the above steps because of the severity of the act or actions.
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Termination requires the approval of University leadership and must include the reason for the termination and is so documented in the employee's
personnel file.
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Appendix A
St. Catherine University Hazard Assessment
Department: Job Title/Function:
Equipment Used:
Chemicals Used:
Source Hazard Assessment Controls
34
Notes:____________________________________________________________ __________________________________________________________________ ___________________________________________________________________________________________________________________
___________________________________________________________________________________________________________________ ___________________________________________________________________________________________________________________
___________________________________________________________________________________________________________________ ___________________________________________________________________________________________________________________
___________________________________________________________________________________________________________________ ___________________________________________________________________________________________________________________
___________________________________________________________________________________________________________________ ___________________________________________________________________________________________________________________
___________________________________________________________________________________________________________________ ___________________________________________________________________________________________________________________
___________________________________________________________________________________________________________________
PPE Requirements for Department:________________________________ ___________________________________________________________________________________________________________________ ___________________________________________________________________________________________________________________
___________________________________________________________________________________________________________________ ___________________________________________________________________________________________________________________
___________________________________________________________________________________________________________________ ___________________________________________________________________________________________________________________
___________________________________________________________________________________________________________________ ___________________________________________________________________________________________________________________
___________________________________________________________________________________________________________________ ___________________________________________________________________________________________________________________
___________________________________________________________________________________________________________________
Date Assessed: Assessor:
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Appendix B
Hazardous Materials Inspection Report
Department of Public Safety
St. Catherine University
INSPECTION DATE: ____________INSPECTION OFFICER: _____________________________________
Location: ________________________________________________________________________________
Area Supervisor/Title/Phone: ____________________________________________________________
Problems Noted During Inspection: The following deficiencies have been noted during a routine inspection of the hazardous
materials/waste storage in your area of responsibility. Corrective action must be taken as soon as possible, or as noted in the comments section below, by the department listed below. Record any corrective action taken and return to the Public Safety office, mail #
4030. Please call X8672 or X8888 or email the Public Safety Coordinator with any questions or concerns – [email protected]
A. Storage Containers C. Waste Management 1. Weekly Inspections 1. Adequate Aisle Space 2. Container Condition/Closed 2. Accumulation Limits 3. Accumulation Start Date 3. Storage Time Limit 4. ―Hazardous Waste‖ Marking 5. Descriptive Name Clearly Labeled D. Preparedness and Prevention 6. Containers Compatible with Waste 1. Emergency/Spill/Fire Equipment 7. Incompatible Wastes Separated 2. Equipment Maintenance 3. MSDS Availability B. Storage Area 1. Overall Condition E. Miscellaneous 2. Room Access 1. Training Records 3. Spills/Leaks 4. Floor – Cracks or Drains __________________________________________________________________________________________________
__________________________________________________________________________________________________
__________________________________________________________________________________________
Inspector’s Signature: ___________________________________________________________________________
Corrective Action:
Department responsible for corrective action: Public Safety Generator Facilities
__________________________________________________________________________________________________
__________________________________________________________________________________________________
Corrective Action Completed By: (sign and date) __________________________________________________
Failure to follow through with corrective action in a timely manner may result in disciplinary action.
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St. Catherine University Appendix C
Date:
Report of Unsafe Condition
Department:
Location:
Safety Concerns
Unsafe Conditions:
Recommendations:
Action Taken:
Follow UP
Date:
Supervisor/Manager:
Follow-Up Action:
Employee Signature
Date:
Supervisor/Manager Signature Date:
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Appendix D
Supervisor’s Accident Investigation Report
I.
gen
eral
in
form
atio
n
Department Shift
Employee Name Job Title
Employee Number Sex (M/F)
Date of Accident Time of Accident A.M. P.M.
Type of Accident/Illness
Type of Injury
Part of Body Injured Treatment
First Aid Medical
Did Employee Return to Work the Same Day?
Yes No
II.
des
crip
tion
Where and How did Accident Happen?
III.
ca
use
s
Specify Machine, Tool, Substance or Object Connected with the Accident
Unsafe Mechanical/Physical/Environmental Condition at Time of Accident
Personal Factors (Attitude, Lack of Knowledge or Skill, Slow Reaction, Fatigue)
Personal Protective Equipment Required?
Was Injured Employee Using Required Equipment?
IV.
reco
mm
end
atio
ns
Action Plan to Prevent Recurrence (Modification of Machine, Mechanical Guarding, Environment, Training)
_________________________________ ________________________
Supervisor Signature Date
V.
fo
llow
-up
Actions Taken on Recommendations (Include Date Completed)
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Please Print or Type Report. See Reverse for Instructions.
Appendix E
Instructions for Completing Accident Report
Please Print or Type All Information. Complete Report in as much Detail as Possible.
I. GENERAL INFORMATION
Fill in all information requested—Name of person injured, date, exact location, job title, job being performed, etc. For description of type of accident/illness, injury and body part, see the following:
II. DESCRIPTION OF ACCIDENT
Describe in as much detail as possible where and how the accident happened. This section is for facts, not opinions. Statements the injured or witnesses made should be detailed. Use an additional piece of paper if more space is needed. Include sketches or photos if they help explain what happened.
III. CAUSES
Identify and describe in detail the type of equipment, tools, processes, etc., unsafe conditions (mechanical, physical, environmental) and/or personal factors involved in the accident. Discuss the use and requirements regarding any personal protective equipment.
IV. RECOMMENDATIONS
Once causes are identified, action must be taken to prevent the same thing from happening again. Realistic yet effective recommendations should be implemented. The form should be signed and dated by the appropriate supervisor.
V. FOLLOW-UP
List actions that have been taken and their respective completion date. Proper follow-up should continue on any incomplete recommendations.
A. Type of Accident/Illness - Slip/fall - Struck by/against - Caught in/on/between - Contact with/by - Over-exertion/lifting - Burn by - Cut by - Amputation
B. Type of Injury - Cut - Sprain - Bruise - Burn - Puncture - Irritation - Abrasion - Swelling - Strain - Fracture
C. Part of Body Injured (Select as many as needed) - Thumb/finger/hand/wrist - Elbow/arm/shoulder - Toe/Foot/Ankle - Leg/knee/hip - Head/neck/face - Nose/eye/ear/throat - Chest/abdomen - Upper back/lower back
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Appendix F
St. Catherine University New Employee Safety Orientation Checklist
Employees Name: _____________________________
Job Function: _________________________________
Department: ______________________________________
Date Hired: _______________________________________
This checklist is a guideline for conducting employee safety orientation for new employees. Once
completed with the orientation the employee and supervisor or trainer must sign the orientation sheet. The signed orientation checklist will serve as documentation that INITIAL SAFETY TRAINING has
taken place
.
General overview of the University’s
operations, procedures and methods as they relate to the specific jobs and duties of
employees.
University Safety Program (AWAIR)
A. Initial orientation
B. On-the-job training C. Safety meetings annually
D. Accident reporting and investigation
E. Function of Safety Committee
immediately reporting accidents and hazards
A. St. Catherine University Accident/Injury
reporting policy
B. St. Catherine University Auto accident
reporting policy
C. Accident/Incident form
St. Catherine University’s Safety Rules
A. General CSC safety rules
B. Department safety rules
C. Driving safety rules
A. Emergency evacuation
B. Use of emergency equipment
A. Call 911 for emergencies
B. First aid kits
C. Eye wash stations
Requirements (see PPE program) A. Safety glasses
B. Safety boots (recommended)
C. Leather work boot (required)
D. Protective clothing and gloves
8. Hazard Communications A. Chemicals used
B. MSDS sheets
C. Labeling
D. Chemical Safety
E. Chemical storage
9. Back Injury Prevention: Proper lifting
techniques
A. Purpose B. Requirements
C. Equipment available
11. Chemical Handling
A. PPE use
B. Spill control C. Proper handling/Mixing
NOTE: DO NOT CHECK OFF AREAS THAT WERE NOT COVERED. The signature below documents that the employee safety orientation has been completed, and the above topics have been discussed to
the satisfaction of both parties, and that both the supervisor/trainer and the employee accept
responsibility for maintaining a safe and healthful work environment.
Employee Signature: _______________________________________________________Date: __________________
Supervisor Signature: ______________________________________________________ Date: __________________
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Appendix G
SAFETY PROGRAM EVALUATION SUMMARY – (YEAR)
A. INCIDENT RATE CALCULATION
LDC = Total number of lost workday cases
LD = Total number of lost workdays
H = Total hours worked by all employees
Frequency rate = (LDC/H) x 200,000
Severity rate = (LD/H) x 200,000
* Industry frequency rate
* Industry severity rate
(* From Bureau of Labor Statistics)
Results /Conclusions
1.
2.
3.
4.
5.
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B. PRIMARY ACCIDENT TRENDS, EMPLOYEE INJURIES
TYPE OF INJURY
# OF
INCIDENTS
# OF
LDC
# OF
LD
Lifting/material handling
Cumulative trauma
Miscellaneous strains
Slips/trips/falls
Cuts/bruises
Caught in machinery
Burns
Object in eye
Occupational disease
Struck by object
Vehicle accident
Others (please specify):
Results/conclusions
1.
2.
3.
4.
5.
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C. OTHER TREND CONSIDERATIONS
YES NO
Are the same employees involved in multiple accidents?
Did most accidents occur in one (1) or two (2) departments?
Did most accidents happen on the same shift/time of day?
Was the same equipment a problem in a number of injuries?
Did most accidents occur away from the premises?
Were newly hired employees involved in most accidents?
Others (please specify):
Results/conclusions
1.
2.
3.
4.
5.
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Appendix H
Hazard Identification/Inspection
I. Slip Trip and Fall Hazards
Common slip, trip and fall hazards result from:
Contaminant Source
Rain water Transmitted internally from open
external doors or from the feet, coats or umbrellas of pedestrians or from
building leaks
Water or other fluids From spills, plumbing leaks,
cleaning, ices machines
Floor cleaning products Resulting from failure to follow appropriate cleaning protocol
Body fluids Blood, vomit, sweat
Condensation Variations in temperature
Dusts Natural or from stored materials
Debris Bags, paper, food residues, soil, cardboard boxes
A. Wet or contaminated floors (e.g. grease liquids, ice, oil, dust, fine
powders, etc.). B. Uneven walking surfaces, holes, changes in level, broken or loose floor
tiles, defective or wrinkled carpet or uneven steps/thresholds. C. Mats or rugs not laying flat on the floor. D. Obstructions and accumulation of objects in walkways (e.g. hoses,
cords, cables, debris, etc.). E. Unguarded platforms, walkways, and work areas 30 inches above
ground.
F. Inadequate illumination.
II. Higher Risk Areas
For purposes of this Guide, an area where slip, trip, or fall hazards may
likely arise during a typical work shift is considered a ―higher risk area‖. Examples of higher risk areas include:
A. Dining room kitchens—wet or greasy floor B. Locker rooms—wet floor
C. Loading docks—elevated locations
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III. Inspections
Inspections to identify slip, trip and fall hazards are recommended at least annually, ideally prior to the wet season. For higher risk areas, a formal
inspection is recommended at least on a quarterly basis or more frequently depending on the likelihood for changing conditions.
Recommended inspections should minimally include evaluation of the following:
A. Condition of floors, carpets and steps
B. Floor maintenance protocol C. Housekeeping practices D. Lighting levels
E. Presence and condition of guardrails/handrails at elevated work surfaces.
