Chapter 4, 26
SAFE 4035
Procedure Development and
Permit-to-Work Systems
•
29 CFR 1926.32(f) states: "Competent person" means on who is capable of
identifying existing and predictable hazards in the surroun- dings or working
conditons, which are unsanitary, hazardous, or dang- erous to employees, and
who has authorization to take prompt corrective measures to eliminate them.
•
29 CFR 1926.32(l) states: "Qualified" means one who, by possession of a
recognized degree, certificate, or profess- ional standing, or who by extensive
knowledge, training and experience, has successfully demonstrated his ability
to solve or resolve problems relating to the subject matter, the work, or the
project.
Dept. of Safety Sciences
•
Certified - certification from an accredited testing organization, an operator
must be certified
– These definitions provide that a competent person must have
authorityto take prompt measures to eliminate hazards at the work site
and have the experience to be capable of identifying these hazards. This
is the reason a competent person is required under inspection
requirements in 29 CFR 1926.650 and 29 CFR 1926.651.
– The definitions provide that a qualified person must have a recognized
degree, certificate, etc., or extensive experience and ability to solve the
subject problems, at the worksite. This is the reason why 29 CFR
1926.651(f) requires that supporting systems design shall be by aqualified
person. There may be a requirement for more technical or engineering
knowledge here.
Dept. of Safety Sciences
What is a Permit to Work system?
• Formal written system used to
control certain types of work
which are identified as potentially
hazardous
• Means of communication between
site and installation management,
plant supervisors and operators
and those who carry out the work
Essential features of Permit to Work
System:
– clear identification of who may authorize particular jobs
(and any limits to their authority)
– who is responsible for specifying the necessary
precautions
– training and instruction in the issue and use of permits
– monitoring and auditing to ensure that the system works
as intended
What is a Permit to Work system?
• The terms “permit” or “work permit”
– certificate or form which is used as part of an overall
system of work and which has been devised by a company
to meet its specific needs
• A Permit to Work System aims to ensure that proper planning
and consideration is given to the risks of a particular job
• The permit is a written document which
– authorizes certain workers to carry out specific work, at a
– At certain time and place
– sets out the main precautions needed to complete the job
safely
Objectives and Functions Permit to Work system
– ensuring the proper authorization of designated work
(this may be work of certain types, or work of any type
within certain designated areas, other than normal
operations)
– Clear communication to people carrying out the work
• the exact identity
• nature and extent of the job and the hazards involved
• any limitations on the extent of work and time during which the job
may be carried out
– specifying the precautions to be taken
• including safe isolation from potential risks such as hazardous
substances and energy sources
When are Permit to Work systems needed?
• Before conducting work that involves
– energy systems
– ground disturbance or excavations in locations
where buried hazards may exist
– log out/tag out (LOTO)
– hot work in potentially explosive environments
– Confined space
– Hot Tap procedure
confined space entry permit
– defines scope of the work
– identifies hazards and assesses risk
– establishes control measures to eliminate or mitigate
hazards
– links the work to other associated work permits or
simultaneous operations
– is authorized by the responsible person(s)
– communicates above information to all involved in the
work
– ensures adequate control over the return to normal
operations
Lockout Tagout
• Documented
– Energy Control
– Release From Lockout
– Testing of Machines
Dept. of Safety Sciences
29 CFR 1910.147(d)(1)-(6)
Application of Energy Control
• Lockout/Tagout procedures shall cover the
following elements in the following sequence:
1. Preparation for shutdown
2. Machine/equipment shutdown
3. Machine/equipment isolation
4. Lockout/tagout device application
5. Release of stored energy
6. Verification of isolation
29 CFR 1910.147(e)(1)-(3)
Release from Lockout/Tagout
• Prior to restoring energy, the following
procedures are required
1. Inspect machine and equipment
2. Safe positioning and notification of
employees
3. Removal of lockout/tagout device by
4. May only be removed by authorized
employee who applied device
12
29 CFR 1910.147(f)(1)
Testing of Machines
• When lockout/tagout devices must temporarily
be removed for testing/ positioning:
1.
2.
3.
4.
5.
Clear machine of tools
Remove employees
Remove lockout/tagout device
Energize and test
Deenergize and reapply energy control
measures
Hot Work
Dept. of Safety Sciences
Hot Work
• What is Hot Work?
― Any work that is done in an area that contains flammable
or combustible materials and involves the use of a
source of heat, e.g. welding arc, torch, sparking or arcing
equipment, grinding, brazing, torch cutting, grinding,
soldering, etc.
• Hot Work Permit - required for any operation involving open
flames or producing heat and/or sparks and must be
completed by a Competent Hot Work Supervisor and posted
at the site
Hot Work
• An effective and efficient hot work permit system should
ensure that:
― The work is authorized by a responsible officer
― Hazards are properly identified, isolated,
removed/disconnected as required
― The operator is well trained in order to ensure complete
safety at work
― Appropriate personal protective equipment are used
― Appropriate warning system and fire fighting equipments
should be put in place
Dept. of Safety Sciences
Personnel Involved In Hot Work Permit Processes
• Department Supervisors:
– required to oversee the Hot Work Permit program for hot
work operations that come directly under their supervision
– responsible for designating employees who can be placed as
Permit Authorizing Individuals who will issue Hot Work
Permits
• Permit Authorizing Individual:
– inspects hot work sites before the start of hot work
operations, using the checklist found on the Hot Work
Permit Form
– required to designate an employee to serve as Fire Watch
when one is required
– Once all requirements provided on the form have been
satisfied and the form document becomes a Hot Work
Permit and must be posted in the area where hot work is
to be performed
•
1910.252(a)(2)(ii)Fire extinguishers. Suitable fire extinguishing equipment
shall be maintained in a state of readiness for instant use. Such equipment
may consist of pails of water, buckets of sand, hose or portable extinguishers
depending upon the nature and quantity of the combustible material
exposed.1910.252(a)(2)(iii)Fire watch.
•
1910.252(a)(2)(iii)(A)Fire watchers shall be required whenever welding or
cutting is performed in locations where other than a minor fire might develop,
or any of the following conditions exist:
•
1910.252(a)(2)(iii)(A)(1)Appreciable combustible material, in building
construction or contents, closer than 35 feet (10.7 m) to the point of
operation.
•
1910.252(a)(2)(iii)(A)(2)Appreciable combustibles are more than 35 feet
(10.7 m) away but are easily ignited by sparks.
•
1910.252(a)(2)(iii)(A)(3)Wall or floor openings within a 35-foot (10.7 m)
radius expose combustible material in adjacent areas including concealed
spaces in walls or floors.
Dept. of Safety Sciences
• 1910.252(a)(2)(vi)(C)In the presence of explosive atmospheres
(mixtures of flammable gases, vapors, liquids, or dusts with air), or
explosive atmospheres that may develop inside uncleaned or
improperly prepared tanks or equipment which have previously
contained such materials, or that may develop in areas with an
accumulation of combustible dusts.
• A fire watch shall be maintained for at least a half hour (period of 30
minutes) after completing hot work. If work is to be conducted in or
near storage areas or other areas where a deep seated fire could
develop, an extended fire watch should be required. This can be up
to 3 ½ additional hours.
• Recommendations
• 10 ABC Fire Extinguisher Welding
• 20 lb ABC Fire Extinguisher Cutting Operations
Dept. of Safety Sciences
Personnel Involved In Hot Work Permit Processes
• Hot Work Operators - employees who perform hot work
operations
– A HWO must always obtain a Hot Work Permit before
beginning any hot work.
• Fire Watch: A fire watch should be posted in order to monitor the
safety of hot work operations and watch for fires
– Fire Watches are posted if required one, during hot work, and
for at least half an hour after work has been completed
– Any employee who has successfully completed hot work safety
training can serve as the Fire Watch
• Individuals who get involved in hot work are required to
undergo complete hot work training (including Supervisors,
Permit Authorizing Individuals, Hot Work Operators and Fire
Watch personnel)
Designated Hot Work Rooms
• A designated hot work room should be a permanent location
that has been exclusively designed for hot work
• Such rooms do not require a hot work permit to perform hot
work
• For a room to be classified as a designated hot work room, it is
expected to meet the following requirements:
– It must be constructed from noncombustible fire-resistive
bricks or any other material, and must be free of flammable
contents
– It must be appropriately isolated or segregated from adjacent
areas
– It must be equipped with fire extinguishers and other fire
fighting equipments
– It must be periodically inspected and approved by the safety
department before beginning of hot work
Hot Work
Flow chart describing the processes involved in obtaining a hot
work permit system
A hot work operator determines a need for hot work.
The hot work operator ensures the area around hot work activities is in
compliance with the safety requirements of the Hot Work Permit.
The hot work operator contacts a Permit Authorizing Individual.
The Permit Authorizing Individual inspects the hot work site and
completes the Hot Work Permit Form.
The Permit Authorizing Individual posts a Fire Watch if the situation
requires one.
Once all permit safety guidelines are satisfied, the Permit Authorizing
Individual signs and posts the permit.
The hot work operator can then begin hot work.
Hot Work- Permit Forms
Dept. of Safety Sciences
Dept. of Safety Sciences
Hot Work- Permit Caution Signs
Dept. of Safety Sciences
Confined Space
Permit-Required Confined Space
• A permit-required confined space is a
confined space which has the following
characteristics:
– Having the potential to contain a hazardous atmosphere
– Containing material that has the potential for engulfing an
entrant
– Having an internal configuration that might cause an
entrant to be trapped or asphyxiated by inwardly
converging walls or by a floor that slopes downward and
tapers to a smaller cross section
– Containing any other recognized serious safety or health
hazards
Requirements Permit-Required Confined Space Entry
• OSHA [29 CFR 1910.146] - employer is expected to perform
certain actions before entry into a permit-required confined
space
– Follow all the general requirements of the OSHA [29 CFR
1910.146(c)] standard
– Have a Permit-Required Confined Space Program that complies
with all the OSHA [29 CFR 1910.146(d)] standard
– Follow all the permit system requirements of the OSHA [29 CFR
1910.146(e)] standard
– Complete the entry permit as required in OSHA [29 CFR
1910.146(f)] regulation
– Comply with employee training requirements in OSHA [29 CFR
1910.146(g)] standard
Requirements Permit-Required Confined Space Entry
• Enable that all the authorized entrants,
attendants, and entry supervisors and other
personnel know their responsibilities as required
in OSHA [29 CFR 1910.146(h)], [29 CFR 1910.146(i)]
and [29 CFR 1910.146(j)]
• Provide for rescue and emergency services as
stated in OSHA [29 CFR 1910.146(k)] regulation
• Ensure that employees are allowed participation in
these processes as required in OSHA [29 CFR
1910.146(l)] standard
Requirements Permit-Required Confined Space Entry
• Employers must evaluate the workplace to determine if
spaces are permit-required confined spaces or not
• When there are permit spaces in the work area, the employer
must inform exposed employees of the existence, location,
and danger posed by the spaces
• Posting of danger signs, labels, barricades or other effective
means could be used to inform employees
• In situations where employees are not required to enter and
work in permit spaces, it is important for employers to take
effective measures to prevent their employees from entering
the permit spaces
Requirements Permit-Required Confined Space Entry
• If employees are expected to enter permit spaces,
employers must comply with all requirements of the
OSHA standard and regulations
• Entry into any confined space cannot proceed
unless:
– All other options have been ruled out
– Permit is issued with authorization by a responsible person(s)
– Permit is communicated to all affected personnel and posted, as
required
– All persons involved are competent to do the work
– All sources of energy affecting the space have been
– Isolated testing of atmospheres is conducted, verified and
repeated as often as defined by the risk assessment
– Stand-by person is stationed
– Unauthorized entry is prevented
Confined Space Entry Permits
Dept. of Safety Sciences
Atmospheric Testing and Monitoring
• Atmospheric monitoring is required for all procedural and
permit-required confined spaces
• This monitoring must be performed by personnel who have
been well trained in the use of gas-detecting instruments
– Confined space atmospheric testing requires knowledge of test
instruments, test result interpretation as well as actions to take after
testing and during continuing monitoring
• During testing for atmospheric hazards, oxygen test is first
conducted, then testing is done for flammable gases and
vapors, and finally for toxic gases and vapors in
accordance with OSHA [29 CFR 1910.146(d)5(iii)] standard
• Initial testing of the atmosphere must be done from
outside the confined space prior to any entry in order to
determine if acceptable entry conditions exist before
beginning entry operations.
Atmospheric Testing and Monitoring
• In order to achieve and maintain a safe atmosphere, one or
more of the following actions may have to be taken to render
the space safe for human occupancy:
– Isolation: precautions taken to prevent release of material and/or
energy into the space (could be achieved through blinding,
blanking, disconnecting, lockout/tagout, or removal of incoming
pipes or related energy sources)
– Ventilation: purging, inserting, flushing, or otherwise ventilating
the space with fresh air (the replacement air will displace the
contaminated air allowing for safe entry, by removing ports and
openings or by mechanically ventilating the vessel)
– Separation: where there is a possibility of external hazards, the
space may require barricades to protect the entrants from falling
objects or from unauthorized entry
Atmospheric Testing and Monitoring
• It is necessary for an authorized attendant to be present to
monitor entry at all times
• Equipment required for permit required confined space entry
includes:
– Testing, monitoring and ventilation devices
– Radios for communication between the entrant and
attendant, and for summoning rescue
– Personal protective equipments
– Lighting, and barriers/shields for openings
– Means of ingress and egress
– Any other equipment necessary for safe entry and rescue
Permit-Required Confined Space Training
• Only trained and qualified employees may be
authorized as entrant, attendant, entry supervisor,
or in-house rescue team members
• OSHA standards require the employer to provide proper
training for all workers intending to work in permit
spaces before initial work assignment begins
• Additional training shall be required when:
–
–
–
–
The job duties change
There is a change in the permit-space program
The permit space operation presents a new hazard
An employee’s job performance shows deficiencies or inadequacies
in the employee's knowledge of the program
• When training is completed, each employee shall be
given a certificate of training
Confined Space Emergencies
• In emergency situations, a confined space
emergency/rescue entry permit may be required
Confined Space Emergencies
• OSHA standard requires the employer to ensure
that rescue service personnel are made available
and trained in the proper use of personal
protective and rescue equipment
• It is necessary for all rescuers to be trained in first
aid and cardiopulmonary resuscitation (CPR)
• The employer must also ensure that practice rescue
exercises or emergency drills are performed
periodically, and that rescue services are provided
access to permit spaces so that they can practice
rescue operations
• Rescuers must also be informed of the hazards of the
permit space
Confined Space Emergencies
• Where necessary, authorized entrants must wear a
chest or full body harness with a retrieval line
attached to the center of their backs near shoulder
level, or above their heads
• The employer must ensure that the other end of the
retrieval line is attached to a mechanical device or to a
fixed point outside the permit space
• A mechanical device must be available to retrieve
personnel from vertical type permit spaces more than
five feet deep
• If an injured entrant is exposed to a substance for
which a Material Safety Data Sheet (MSDS), the
information must be made available to the medical
facility treating the Dept.
exposed
of Safetyentrant
Sciences
Confined Space Labels
• Confined spaces must be surveyed and posted with
several of the signs, barricades or labels
• Special labeling requirements are needed for spaces
whose entrances are in roadways, sidewalks, etc.,
and subject to vehicular and foot traffic
Dept. of Safety Sciences
OSHA Excavation V tools
• https://www.osha.gov/dts/vtools/cons
truction/trench_fnl_eng_web.html
• https://www.osha.gov/dts/vtools/cons
truction/soil_testing_fnl_eng_web.htm
l
Dept. of Safety Sciences
Excavation
• OSHA Regulation 29CFR1926.650-652
• Excavation protection requirement depths at or
greater than 5 ft. below ground surface.
• Why is excavation important to a safety professional?
(80-100 fatalities per year
• Soil Issues to consider
–
–
–
–
–
–
Soil Particle Characteristics
Soil Stress and Strain
Soil Compressibility
Soil Compaction
Soil Failure – Stable Rock and Types A, B and C
Soil Physics
IHS-500 Occupational Safety Engineering
Excavation
Dept. of Safety Sciences
IHS-500 Occupational Safety Engineering
Excavation
Dept. of Safety Sciences
IHS-500 Occupational Safety Engineering
Excavation
Dept. of Safety Sciences
IHS-500 Occupational Safety Engineering
Excavation
Dept. of Safety Sciences
IHS-500 Occupational Safety Engineering
Excavation
Dept. of Safety Sciences
• http://www.excavationsafetynews.com
/2011/06/soils-classification-part2testing-and-re-testing-is-a-key-tosafety/
Dept. of Safety Sciences
Osha V tool Scaffold
• https://www.osha.gov/dts/vtools/con
struction/scaffolding_fnl_eng_web.ht
ml
Dept. of Safety Sciences
SCAFFOLDING
•
“A temporary structure from which persons
can gain access to a place in order to carry out
building operation”
•
“ A temporary frame usually constructed from
steel or aluminum alloy tubes clipped or
coupled together to provide a means of access
to high-level working areas as well as providing
as a safe platform from which to work.”
•
Inspect scaffold before each shift and after
alterations
FUNCTIONS
• As a working platform- so that the worker can stand on the
platform do the work easily & safely
• As a platform for placing material & logistic needed by the
workers to carry out their job
• As a platform and walking passage- scaffolding support the
platform that been used by the worker as their walking path
to transport the material & logistic
Scaffold can be made of the following materials:
• Tubular steel
• Tubular aluminum alloy
• Timber or bamboo
DOUBLE
COUPLER
STANDARD
BASE PLATE
Dept. of Safety Sciences
OSHA V tool Ladders
• https://www.osha.gov/dts/vtools/con
struction/ladder_powerline_fnl_eng_w
eb.html
Dept. of Safety Sciences
Aerial Lift Safety
• Only trained & authorized persons shall
operate an aerial device.
• A daily inspection of the truck and aerial lift
is required prior to operation.
• Lift controls shall be tested each day prior to
use to determine that such controls are in safe
working condition.
• Check the lift identification plate on the
vehicle to ensure that the annual inspection is
current. Do not use the aerial lift if not
current.
Aerial Lift Safety – Inspect Work Area
•
Do a visual inspection of the area prior to beginning
work. Look for and be aware of existing hazards or
conditions that could change and create new hazards.
•
Location of power lines.
•
Clearance
•
Overhead obstructions
•
Hazards further or down the line.
Dept. of Safety Sciences
Aerial Lift Safety – Safe Practices
• Belting off to an adjacent pole, structure,
or equipment while working from an
aerial lift shall NOT be permitted.
• Climbers shall not be worn while
performing work from an aerial lift.
• Boom and platform/bucket load limits
specified by the manufacturer shall not be
exceeded.
Dept. of Safety Sciences
Aerial Lift Safety – Avoid Falling
There are many possible causes for falling.
Here are some common examples:
•
Over Reaching.
•
Swinging under over hanging limbs, structures or
lines.
•
Stumbling over tools inside the basket.
•
Suddenly reversing boom direction without stopping
first.
Dept. of Safety Sciences
OVERHEAD AND GANTRY CRANE
SAFETY
▪ Ensure that all loads are lifted high enough to clear
obstructions before moving the bridge or trolley.
Whenever possible, maintain a minimum clearance
of one foot above loads and to the sides. Raise the
load only to the height necessary to clear lower
objects.
▪ Never pull a hoist by the pendant cable.
Dept. of Safety Sciences
OVERHEAD AND GANTRY CRANE
OPERATION
▪ Disconnect power to a hoist that is unsafe or in
need of repair. Arrange to have the
disconnect switch locked and the control
panel tagged with and “Out of Order”
or “Do Not Operate” tag. Never operate
a hoist that has been tagged with an
“Out of Order” or “Do Not Operate”
tag, or is your opinion, UNSAFE TO
OPERATE…
Dept. of Safety Sciences
HOISTS / CRANES
Daily Inspection Checklist
▪ Check all hooks. Hooks should not be cracked,
stretched, bent, or twisted. Each hook must have
a safety latch that automatically closes the
throat of the hook. If the latch is bent, spring is
broken, or is otherwise damaged the latch must
be repaired before use. Hooks should rotate
freely in block assembly without any “grinding”
felt or heard.
Dept. of Safety Sciences
HOISTS / CRANES
Daily Inspection Checklist
▪
Check the condition and capacity
of nylon or synthetic web slings.
Capacity ratings must be legible
on the manufacturer’s label. The
capacity of the sling being used
must be adequate for the load and
attachment method. Replace
slings immediately if excessive
wear occurs.
Dept. of Safety Sciences
SAFE 4035
OSHA Recordkeeping
Dept. of Safety Sciences
Critical component of an effective safety
and health program – allows for trend
analysis
Way to benchmark and measure progress
Companies audited by OSHA
Potential large OSHA fines and criminal
prosecution
Oct. 12, 2004 – GM Powertrain Corp., Massena,
N.Y.
2 willful violation citations for 98 instances of
failure to record hearing loss and other cases.
($140,000)
2 other-than-serious citations for improper
recording of injuries and illnesses ($8,000)
6 serious citations – obstructed exit, improper
machine guarding, no load rating elevated work
platform, and failure to assess the need for PPE
($12,000)
Dept. of Safety Sciences
University of Central Missouri
Aug. 3, 2004 – Weyerhaeuser subsidiary, W.Va.
Failure to record 38 cases – 24 injuries, 9
sprains, a fractured wrist, a lacerated lip, a
hearing loss and rash and a CTS case.
Settled as two unclassified violations - one for
$70,000
(failure to record) and a second for $7,000
(“company executive” had not certified the log).
Dept. of Safety Sciences
University of Central Missouri
Regulations
Frequently Asked Questions
Interpretation Letters
Dept. of Safety Sciences
University of Central Missouri
What is the effect of workers’ compensation reports on the
OSHA records?
“. . . (R)ecording an injury or illness neither affects a
person’s entitlement to workers’ compensation nor proves
a violation of an OSHA rule.
The rules for compensability under workers’ compensation
differ from state to state and do not have any effect on
whether or not a case needs to be recorded on the OSHA
300 log.
Many cases will be OSHA recordable and compensable
under workers’ compensation.
However some cases will be compensable but not OSHA
recordable, and some cases will be OSHA recordable but
not compensable under workers’ compensation.”
Dept. of Safety Sciences
University of Central Missouri
There must be a procedure for employees to
report work-related injuries and illnesses.
Must inform employees of the procedure.
§1904.35
Suggestion: Incorporate into the orientation
process. Document communication of the
reporting procedure.
Dept. of Safety Sciences
University of Central Missouri
All employers must report
◦ All work-related fatalities within 8 hours.
◦ All work-related inpatient hospitalizations, all amputations
and all losses of an eye within 24 hours.
You can report to OSHA by
Calling your closest Area Office during normal
business hours.
Using the new online form that will soon be available.
◦ Calling OSHA's free and confidential number at 1-800321-OSHA (6742).
◦ Only fatalities occurring within 30 days of the work-related
incident must be reported to OSHA. Further, for an in-patient
hospitalization, amputation or loss of an eye, these incidents must
be reported to OSHA only if they occur within 24 hours of the
work-related incident.
Certain covered employers are required to prepare and
maintain records of serious occupational injuries and
illnesses using the OSHA 300 Log.
Two classes of employers that are partially exempt from
routinely keeping injury and illness records.
First, employers with ten or fewer employees at all times
during the previous calendar year are exempt from
routinely keeping OSHA injury and illness records. OSHA's
revised recordkeeping regulation maintains this
exemption.
Establishments in certain low-hazard industries are also
partially exempt from routinely keeping OSHA injury and
illness records. Starting on January 1, 2015 there will be a
new list of industries that will be partially exempt from
keeping OSHA records.
Dept. of Safety Sciences
University of Central Missouri
Table 1: New List of Partially Exempt Industries
NAICS Code and Industry Description
4412
5151
5412
6213
4431
5172
5413
6214
4461
5173
6215
4471
5415
6244
4481
5181
5416
7114
4482
5182
5417
7115
4483
5418
7213
Other Motor Vehicle Dealers
Radio and Television Broadcasting
Accounting, Tax Preparation, Bookkeeping, and Payroll Services
Offices of Other Health Practitioners
Electronics and Appliance Stores
Wireless Telecommunications Carriers (except Satellite)
Architectural, Engineering, and Related Services
Outpatient Care Centers
Health and Personal Care Stores
Telecommunications Resellers
Medical and Diagnostic Laboratories
Gasoline Stations
Computer Systems Design and Related Services
Child Day Care Services
Clothing Stores
Internet Service Providers and Web Search Portals
Management, Scientific, and Technical Consulting Services
Agents and Managers for Artists, Athletes, Entertainers, and Other Public Figures
Shoe Stores
Data Processing, Hosting, and Related Services
Scientific Research and Development Services
Independent Artists, Writers, and Performers
Jewelry, Luggage, and Leather Goods Stores
Advertising and Related Services
Rooming and Boarding Houses
Dept. of Safety Sciences
University of Central Missouri
The new reporting requirements will be phased in over two
years:
Establishments with 250 or more employees in industries
covered by the recordkeeping regulation must submit
information from their 2016 Form 300A by July 1, 2017
change December 1, 2017. These same employers will be
required to submit information from all 2017 forms (300A,
300, and 301) by July 1, 2018. Beginning in 2019 and
every year thereafter, the information must be submitted
by March 2.
Establishments with 20-249 employees in certain highrisk industries must submit information from their 2016
Form 300A by July 1, 2017 change December 1, 2017 ,
and their 2017 Form 300A by July 1, 2018. Beginning in
2019 and every year thereafter, the information must be
submitted by March 2.
Dept. of Safety Sciences
University of Central Missouri
OSHA is officially seeking to rescind two major parts of
its Improve Tracking of Workplace Injuries and Illnesses
final rule, according to a notice published in the July
30 Federal Register.
In the proposed rule, the agency states that it would
require covered establishments with 250 or more
employees or those with 20 to 249 employees in certain
high-hazard industries to submit Form 300A data
electronically, but would no longer require submission of
Forms 300 or 301 injury and illness data. OSHA states that
the move is intended to “protect sensitive worker
information from potential disclosure under the Freedom
of Information Act,” and the reporting “burden” on
employers is “unjustified given the uncertain benefits of
collecting the information.”
Dept. of Safety Sciences
University of Central Missouri
OSHA has already started on this path
by stating on its website that it would not
accept Forms 300 and 301. That action
caused Public Citizen, the American Public
Health Association, and the Council of State
and Territorial Epidemiologists to file a
lawsuit July 25 in the U.S. District Court for
the District of Columbia.
Dept. of Safety Sciences
University of Central Missouri
On July 27, 2018, OSHA announced proposed changes to its “Improve Tracking of
Workplace Injuries and Illnesses” recordkeeping rule. The current version of the
rule, published in 2016, requires establishments with 250 or more employees that
are currently required to maintain injury and illness records to electronically
submit information to OSHA from the following:
OSHA Form 300 – Log of Work-Related Injuries and Illnesses
OSHA Form 300A – Summary of Work-Related Injuries and Illnesses
OSHA Form 301 – Injury and Illness Incident Report
OSHA is now proposing to eliminate the requirement to electronically submit
information from Form 300 and Form 301 for establishments with 250 or more
employees.
Under OSHA’s proposed rule, establishments with 250 or more employees, and
establishments with 20-249 employees in certain designated industries, would be
required to electronically submit information only from Form 300A.
The deadline for electronic submission of Calendar Year (CY) 2017 information
from OSHA Forms 300 and 301 was July 1, 2018, but the agency is not currently
accepting Form 300 or 301 data and will not enforce the deadline for these two
forms without further notice while the rulemaking is underway. But the July 1,
2018 deadline did apply to Form 300A data.
Dept. of Safety Sciences
University of Central Missouri
Why was the rule changed?
OSHA is stating that it wants to remove the requirement to
electronically submit information from Forms 300 and 301
because of privacy concerns associated to personally identifiable
information or data that could be re-identified with a particular
individual. OSHA could be forced to potentially disclose such
data under Freedom of Information Act (FOIA) requests from the
public, the agency says.
While OSHA Form 300A only includes information on the types
and numbers of injuries and illnesses, Forms 300 and 301
include more detailed information that OSHA deems to be
sensitive. For example, Form 301 includes information on the
employee’s full name, address, date of birth, etc.
While concerns over privacy constitute a major justification
officially stated for the proposed change, another main motive is
deregulation.
Dept. of Safety Sciences
University of Central Missouri
Event or
Exposure
Injury/Illness
Work Related
Dept. of Safety Sciences
University of Central Missouri
General Recording Criteria
◦ Medical Treatment, Restricted Work Activity, Day(s)
Away from Work, Loss of Consciousness, Death
Special Rules for significant Diagnosed
Injury/Illness
◦ Cancer, Chronic Irreversible, Disease, Fracture,
Punctured Eardrum
Other Special recordkeeping rule
◦ Needle sticks and Sharps, Medical Removal, Hearing
Loss, Tuberculosis
9 Exceptions to Work Relationship
Dept. of Safety Sciences
University of Central Missouri
Was There an Event or Exposure?
Dept. of Safety Sciences
University of Central Missouri
Event = instantaneous incident
Exposure = longer than instantaneous
The event or exposure must be reported
If nothing happens, there’s no case to
analyze (e.g., purely preventative activities
when there’s been no event or exposure).
Dept. of Safety Sciences
University of Central Missouri
Who: Something must happen to:
An employee of the facility.
Visiting employees from another Company establishment.
§1904.30(b)(4)
Temporary employees – If you obtain employees from a
temporary help service, employee leasing service, etc.,
record them on your Logs “if you supervise them on a dayto-day basis.” §1904.31(b)(2). And maintain OSHA 301
Forms. Interpretation Letter Even if temp agency says that
they keep a Log. §1904.31(b)(4).
When: Cases are recordable during the 5 year
retention/updating period. If a case occurs after
employment, record in the year that the injury or illness
occurred or the last day of employment. 1904.33 and FAQ
7-20.
Dept. of Safety Sciences
University of Central Missouri
Did the Employee Experience an Injury or
Illness?
Dept. of Safety Sciences
University of Central Missouri
Injuries include cases such as, but not limited to,
cuts, fractures, sprains, or amputations. Illnesses
include such cases as a skin diseases, respiratory
disorders, or poisoning. §1904.46
General guide
◦ think “instantaneous = injury.”
◦ “Cases resulting from anything other than an
instantaneous
◦ event or exposure are considered illnesses.” FAQ 31-1.
Note – under the recordkeeping rules, injuries
and illnesses are analyzed in the same manner.
§1904.46
Dept. of Safety Sciences
University of Central Missouri
FAQ 29-5 – When the employee states that
symptoms first arose at some unspecified
date in the past, the date that the employee
reported the symptoms or received treatment
must be used.
Dept. of Safety Sciences
University of Central Missouri
Is the Case Work--Related?
Dept. of Safety Sciences
University of Central Missouri
The Big Circle §5(b)(3)
Travel rules
Work at home
Significant aggravation
Dept. of Safety Sciences
University of Central Missouri
When an injury or illness occurs on the
premises of an employer that either caused
or contributed to the employee’s condition,
there is a geographic presumption that the
case is work related. §1904.5(b)(1)
Think of the employer’s premises as a Big
Circle. Anything that is reported to have
happened in the Big Circle is presumed to be
work related.
Dept. of Safety Sciences
University of Central Missouri
Acts of God
Drug-impaired acts
Violence
Horseplay
Dept. of Safety Sciences
University of Central Missouri
Interpretation Letter to B. Principe (1/13/04).
“In each of the eight scenarios . . . the activity
engaged in by the employee at the time of
the injury (walking, tripping, climbing a
staircase, sneezing, bending down) is an
"event" which would trigger application of the
presumption.
In the absence of evidence to overcome the
presumption, the injury is work-related.
Dept. of Safety Sciences
University of Central Missouri
In the absence of evidence to overcome the
presumption, an ankle injury caused by a trip that
occurred while the employee was walking down a
level seamless hallway at work is considered workrelated, regardless of whether the accident is
attributable to a defect in the hall.
If the activity of walking down a hallway caused the
employee's knee to buckle or to sprain the ankle, the
injury is work-related.
If an injury or illness did not result from an
identifiable event or exposure
the work environment, but only manifested itself
during work, the injury is not work-related.”
Dept. of Safety Sciences
in
University of Central Missouri
An employee experienced an injury or illness in the
work environment before they clocked in for the day.
Is the case work related even if the employee was not
on the clock?
“Yes. For purposes of OSHA recordkeeping injuries
and illnesses occurring in the work environment are
considered work-related. Punching in and out . .
Does not affect the outcome for determining workrelatedness.”
Note: an exception applies if 1) the injury occurs
outside of working hours and 2) the employee is
present in the workplace as a member of the general
public.
Dept. of Safety Sciences
University of Central Missouri
Question One day, as Bob is walking across
the Company break area, lightning strikes the
building and an overhead light falls and
injures Bob.
The Company safety manager argues that the
case is not recordable due to an “Act of God”
and due to the fact that Bob was in the
process of going to eat lunch.
Is the safety manager correct?
Dept. of Safety Sciences
University of Central Missouri
The Company safety manager argues that the
case is not recordable due to an “Act of God”
and due to the fact that Bob was in the
process of going to eat lunch.
Is the safety manager correct?
Answer No.
Dept. of Safety Sciences
University of Central Missouri
Work-relatedness is presumed for cases resulting
from events or exposures occurring in the work
environment, unless an exception in
§1904.5(b)(2) specifically applies. §1904.5(a)
1. Employee present in the work environment as
a member of the general public.
2. Symptoms surface at work but result from
non-work-related event/exposure that occurs
outside the work environment.
Dept. of Safety Sciences
University of Central Missouri
Question: Let’s say that an employee has a
pre-existing epileptic seizure condition and
one day at work, the employee has a seizure
and falls. When he hits the floor, he breaks
his arm.
I know that the pre-existing seizure is not
work related, but what about the broken arm?
Dept. of Safety Sciences
University of Central Missouri
Answer: “Because epileptic seizures are not
work related, injuries resulting solely from
the seizures, such as the broken arm in the
case in question, are not recordable.” FAQ 58.
Dept. of Safety Sciences
University of Central Missouri
3. Cases resulting solely from voluntary
participation in a wellness program, medical,
fitness or recreational activity, or blood
donation, flu shot, etc.
4. Cases resulting from employee preparing
or consuming food. (Note, if an employee
gets sick from eating food contaminated by
workplace contaminants or gets “food
poisoning” from food supplied by the
employer, the case is considered work
related.)
Dept. of Safety Sciences
University of Central Missouri
5. Cases resulting from employee doing personal
tasks unrelated to work at the establishment,
outside assigned working hours.
Personal tasks totally unrelated to the
employee’s job. For example, using the Company
break area to work on a child’s science fair
project. FAQ 5-5.
(Smoke breaks taken outside during work and
employee fights in the parking lot before work
do not meet this exception.)
See Interpretations
Dept. of Safety Sciences
University of Central Missouri
If an employee stays at work after normal work hours
to prepare for the next day’s tasks and is injured, is
the case work-related? For example, if an employee
stays after work to prepare air-sampling pumps and
is injured, is the case work-related?
“A case is work-related any time an event or
exposure in the work environment either causes or
contributes to an injury or illness or significantly
aggravates a pre-existing injury or illness, unless one
of the exceptions in section 1904.5(b)(2) applies. . . .
The case in question would be work-related if the
employee was injured as the result of an event or
exposure at work, regardless of whether the injury
occurred after normal work hours.”
Dept. of Safety Sciences
University of Central Missouri
6. Cases resulting from employee’s personal
grooming or self-medication for a non-work
related condition, or intentionally selfinflicted injuries or illnesses. See FAQ 5-3.
Dept. of Safety Sciences
University of Central Missouri
What activities are considered “personal grooming”
for purposes of the exception to the geographic
presumption of work-relatedness in section
1904.5(b)(2)(vi)?
“Personal grooming activities are activities directly
related to personal hygiene, such as combing and
drying hair, brushing teeth, clipping fingernails and
the like.
Bathing or showering at the workplace when
necessary because of an exposure to a substance at
work is not within the personal grooming exception
in1904.5(b)(2)(vi). Thus, if an employee slips and falls
while showering at work to remove a contaminant to
which he has been exposed at work, and sustains an
injury that meets one of the general recording criteria
listed in section 1904.7(b)(1), the case is recordable.”
Dept. of Safety Sciences
University of Central Missouri
7. Common colds or flu.
8. Cases caused by motor vehicle accident in
the company parking lot or access road while
employee commutes to/from work.
See FAQ 5-9: Employee “A” drives to work,
parks her car in company parking lot and is
walking across the lot when she is struck by a
car driven by employee “B”, who is
commuting to work. Both employees are hurt.
Neither injury is work-related.
Dept. of Safety Sciences
University of Central Missouri
start
Dept. of Safety Sciences
University of Central Missouri
How does OSHA Define a “company parking
lot” for purposes of recordkeeping?
“Company parking lots are part of the
employer’s premises and therefore part of the
establishment. These areas are under the
control the employer . . . .” Shared parking
lots or public parking are not part of the
establishment, except for the owner of the
building or lot, and therefore NOT a parking
lot for recordkeeping purposes.
Dept. of Safety Sciences
University of Central Missouri
9. Mental illness - not work-related unless
employee voluntarily provides opinion of
LHCP with appropriate training and
experience (e.g., psychiatrist, psychologist,
psychiatric nurse practitioner, etc.) stating
employee has work-related mental illness. •
§1904.5• FAQ 5-12
Dept. of Safety Sciences
University of Central Missouri
Is work-related stress recordable as a mental
illness case?
“Mental illnesses, such as depression or anxiety
disorder, that have work-related stress as a
contributing factor, are recordable if the
employee voluntarily provides the employer with
an opinion from a physician or other licensed
health care professional with appropriate training
and experience (psychiatrist, psychologist,
psychiatric nurse practitioner, etc.) state that the
employee has a mental illness that is workrelated, and the case meets one or more of the
general recording criteria. See sections
1904.5(b)(2)(ix) and 1904.7.
Dept. of Safety Sciences
University of Central Missouri
Evaluate the employee’s work duties and
environment to decide if they either caused or
contributed to the resulting injury or illness or
significantly aggravated a non-work related
condition.
“A case is work related if it is more likely than
not that an event or exposure in the work
environment was a cause of the injury or illness.
The work event need only be one of the causes;
it need not be the sole or predominant cause.”
See Interpretation Letters
Dept. of Safety Sciences
University of Central Missouri
Cases that occur to employee on travel status are
work-related if employee was engaged in work
activities “in the interest of the employer.”
Travel outside the United States and its territories are
not covered by the recordkeeping regulation.
Three Exceptions to Travel Status Work-Relatedness:
◦ Work-relationship ends when employee checks into hotel –
until employee re-enters work environment.
◦ Travel status is not work-related if employee takes a detour
for personal reasons, e.g., a side trip. Interpretation Letters
◦ If employee establishes “home-away-from-home” –
commute between temporary residence and job each day is
not considered work-related. §1904.5(b)(6)
Dept. of Safety Sciences
University of Central Missouri
Morning Commute
Office
Airport
Home
Restaurant
Hotel
Costumer/Client
Sales call
Home
Office
Dept. of Safety Sciences
University of Central Missouri
Cases occurring while working at home are work-related if the
employee is performing work for pay in the home, and if the
case is directly related to the performance of work rather than to
the home environment.
Tripping over dancing dog to answer work call, electrical shock
due to faulty home wiring – not work-related.
Dropping box of documents on foot, burning arm building
fireworks in basement factory – work-related. §1904.5(b)(7)
Employees who telecommute from home or field sales people
(with no fixed work establishment) should be linked to one of
your covered establishments. §1904.46(3)
Injuries to employees who voluntarily take work home and are
not work-related unless the employee is being paid for working
at home and if the injury is related to the performance of work.
Dept. of Safety Sciences
University of Central Missouri
There are two types of aggravation cases:
1. “Significant” aggravation of a preexisting,
non-work-related condition §1904.5(b)(4)
2. Aggravation of a prior, work-related
condition § 1904.6(a)(2)
Dept. of Safety Sciences
University of Central Missouri
There must be a pre-existing, non-work
related condition.
An event or exposure occurs in the work
environment
The existing status changes or the level of
treatment is increased
◦ 1st aid medical treatment
◦ Medical treatment restricted work activity
◦ Restricted work activity day(s) away from work
Dept. of Safety Sciences
University of Central Missouri
There is a prior, work-related condition that is
resolved
An event or exposure occurs in the work
environment
This constitutes a new case that may be OSHArecordable if one of the following applies:
◦
◦
◦
◦
◦
Medical treatment
Restricted work activity
Day(s) away from work
Loss of consciousness
Death
Dept. of Safety Sciences
University of Central Missouri
All signs and symptoms disappear
No medical treatment
No restricted work activity or day(s) away
from work
An employee has “completely recovered,”
when the employee is “fully healed,” or
“cured.” If the symptoms disappear for a day
and reappear the next day, OSHA would
consider that “strong evidence” that the
employee was not completely healed. FAQ 61
Dept. of Safety Sciences
University of Central Missouri
Question Jones had a back injury in 2002 that
was recorded in 2002.
By late 2002, the case had resolved.
In 2003, Jones re-injured his back as a result
of a fall at work and was given medical
treatment.
The company doctor said the case can be
filed under the claim from 2002.
Should a new case be entered on the 2003
OSHA Log?
Dept. of Safety Sciences
University of Central Missouri
Answer Yes. Jones had “recovered completely
(all signs and symptoms had disappeared)”
from the 2002 case, and an event in the work
environment caused the signs or symptoms
to reappear. 1904.6(a)(2).
Dept. of Safety Sciences
University of Central Missouri
Employers are not required to seek the advice
of a physician or other LHCP (PLHCP). But,
once advice is sought, the PLHCP’s
recommendation must be followed.
If two or more PLHCP disagree, the employer
may rely on the “most authoritative”
recommendation (“best documented, best
reasoned, or most authoritative”) and record
based on that recommendation.
§1904.6(b)(3)
Dept. of Safety Sciences
University of Central Missouri
Is the Case Recordable?
Dept. of Safety Sciences
University of Central Missouri
One of the 5 general recordkeeping criteria?
Or,
The definition of “significant injury or
illness”? Or,
One of the 4 special recordkeeping criteria?
Dept. of Safety Sciences
University of Central Missouri
Medical treatment beyond first aid
Restricted Work Activity (RWA) or job transfer
Days Away From Work (DAFW)
Loss of consciousness
Death
Dept. of Safety Sciences
University of Central Missouri
All first aid treatments are listed at §1904.7(b)(5)(ii).
Any treatment not covered by the first aid list
Status of person providing treatment is not
relevant.
§1094.7(b)(5)(iv).
“Medical Treatment” does not include:
◦ Visits to LHCP solely for observation or counseling.
◦ Diagnostic procedures such as x-rays, blood tests, and use
of prescription medication solely for diagnostic purposes,
e.g., eye drops to dilate pupils. §1904.7(b)(5)(i)
“I don’t need no stinkin’ medical treatment.”
§1904.7(b)(5)(v) Interpretation Letter
Dept. of Safety Sciences
University of Central Missouri
One chart lists all “First Aid”
Any treatment not on chart is “Medical Treatment”
1. Using non-prescription medication at nonprescription strength (recommended use of nonprescription medication at prescription strength =
medical treatment, including Ibuprofen at > 467 mg,
Diphenhydramine at greater than 50 mg, Naproxen
Sodium at greater than 220 mg, and Ketoprofen at
greater than 25 mg, per FAQ 7-8)
2. Administering tetanus immunizations (other
immunizations, such as Hepatitis B vaccine or rabies
vaccine, are considered medical treatment);
3. Drinking fluids for relief of heat stress (but
intravenous administration of fluids is medical
treatment);
Dept. of Safety Sciences
University of Central Missouri
Cleaning, flushing, or soaking wounds on the surface
of the skin;
5. Wound coverings, e.g., bandages, Band-Aids™,
gauze pads, etc.; or using butterfly bandages or
Steri-Strips™ (wound closing devices such as sutures,
staples, etc. are medical treatment);
◦ NOTE: Surgical glue is considered a wound closure device
and thus is “medical treatment.” See Interpretation Letter
◦ But, Band-Aid Brand Liquid Bandages are first aid. See
Interpretation Letter
6. Hot or cold therapy;
7. Any non-rigid means of support, e.g., elastic
bandages, wraps, non-rigid back belts, etc. (Devices
with rigid stays or systems designed to immobilize
body parts are medical treatment.);
Dept. of Safety Sciences
University of Central Missouri
8. Temporary immobilization devices used to
transport accident victims (e.g., splints, slings,
neck collars, back boards, etc.);
9. Drilling of a fingernail or toenail to relieve
pressure, or draining fluid from a blister;
10. Using eye patches;
11. Removing splinters or foreign material from
areas other than the eye by irrigation, tweezers,
cotton swabs or other simple means (e.g.,
needles, pins or small tools – See FAQ 7-11);
Dept. of Safety Sciences
University of Central Missouri
12. Removing foreign bodies from the eye using only
irrigation or a cotton swab;
13. Using finger guards;
14. Using massages (physical therapy or chiropractic
treatment are considered medical treatment for
recordkeeping purposes). • §1904.7(b)(5)(ii)
Oxygen – administration of oxygen as a purely
precautionary measure to an employee who exhibits
no signs or symptoms of an injury or illness is not
recordable. However, if an employee exposed to a
substance exhibits signs or symptoms of an injury or
illness, the administration of oxygen makes the case
recordable.
Dept. of Safety Sciences
University of Central Missouri
Dept. of Safety Sciences
University of Central Missouri
RWA occurs when: employer or PLHCP
recommends that employee not perform one
or more routine functions of the job, or not
work the full workday that employee would
otherwise have been scheduled to work.
Routine functions: those work activities the
employee regularly performs at least once per
week.
Dept. of Safety Sciences
University of Central Missouri
An employee hurts his or her left arm and is told by
the doctor not to use the left arm for one week. The
employee is able to perform all of his or her routine
job functions using only the right arm (though at a
slower pace and the employee is never required to
use both arms to perform his or her job functions.
Would this be considered restricted work?
“No. If the employee is able to perform all of his or
her routine job functions (activities that the employee
performs regularly at least once a week), the case
does not involve restricted work. Loss of productivity
is not considered restricted work. ”
Dept. of Safety Sciences
University of Central Missouri
If an employee who routinely works ten hours a day is
restricted from working more than eight hours
following a work-related injury, is the case
recordable?
“Generally, the employer must record any case in
which an employee’s work is restricted because of a
work-related injury. A work restriction . . . Occurs
when the employer keeps the employee from
performing one or more routine functions of the job,
or from working the full workday the employee would
otherwise have been scheduled to work.
The case in question is recordable if the employee
would have worked 10 hours had he or she not been
injured.”
Dept. of Safety Sciences
University of Central Missouri
Begin count on next day.
Count calendar days. 180 day cap on RWA days or
combination of DAFW and RWA.
Do not record RWA or job transfers that are only for the
day the injury occurred or illness began.
When the PLHCP issues the restriction – assess it to
determine if, in fact, it affects routine job functions.
Evaluate the restrictions in light of the routine functions of
the job.
Working more slowly ¹ RWA. §1904.7(b)(4)
If PLHCP recommends a restriction that does qualify as
RWA and the employee ignores it, record as RWA.
§1904.7(b)(4)(viii)
Dept. of Safety Sciences
University of Central Missouri
“Take it easy for week” or “light duty” – or other
vague instructions, call LHCP and ask – can
employee perform: (1) all routine functions of the
job, or (2) for all of the normally assigned work
shift.
◦ If yes to both, do not record;
◦ If “no” to either, record;
◦ If no answer, record. §1904.7(b)(4)(vii)
Job transfer = RWA. If transfer becomes
permanent and eliminates the routine functions
that employee was restricted from performing –
stop the count. Must record at least one day.
§1904.7(b)(4)(x) and (xi)
Dept. of Safety Sciences
University of Central Missouri
An employee has a work related shoulder injury
resulting in days of restricted work activity. While
working on restricted duty, the employee sustains a
foot injury which results in a different work
restriction. How would the employer record these
cases?
“. . . (T)he employer would stop the count of the days
of restricted work activity due to the first case, the
shoulder injury, and enter the foot injury as a new
case and record the number of restricted work days.
If the restriction related to the second case, the foot
injury, is lifted and the employee is still subject to the
restriction related to their shoulder injury, the
employer must resume the count of days of restricted
work activity for that case.”
Dept. of Safety Sciences
University of Central Missouri
Begin count on next day. If extended
absence, enter an estimate and update.
Count calendar days – weekends, holidays,
vacations.
If PLHCP advises DAFW – count the days, even
if employee comes in. Dueling Doctors.
If PLHCP advises return to work, stop the
count, even if the employee does not return.
You may cap the total DAFW (plus the total
RWA days) at 180.
Dept. of Safety Sciences
University of Central Missouri
Stops the count if unrelated to injury or illness.
FAQ 7-21 provides that the employer must count
at least one day away from work (or, if
applicable, restricted work activity day).
If termination is related to the injury or illness,
use a good faith estimate and then update when
the actual day count is known. Note – drug test
termination following an accident resulting in
injury – termination is considered related to
injury. FAQ 7-9. §1904.7(b)(3)
Temporary employees
Dept. of Safety Sciences
University of Central Missouri
1904.7(b)(3)(ii) and 1904.7(b)(4)(viii) provide: “If you
receive recommendations from two or more . . .LHCPs
(regarding the need for DAFW or RWA), you may make a
decision as to which is the most authoritative, and record
based upon that recommendation.”
FAQ 7-10a (issued in 12/04) provides: “If there are
conflicting contemporaneous recommendations regarding
medical treatment, or the need for DAFW or RWA, but the
medical treatment is not actually provided and no DAFW or
days of RWA have occurred, the employer may determine
which recommendation is the most authoritative and
record on that basis. In the case of prescription
medications, OSHA considers the medical treatment is
provided once a prescription is issued.”
“. . . Once medical treatment is provided . . . or days away
from work or work restriction have occurred, the case is
recordable.”
Dept. of Safety Sciences
University of Central Missouri
1904.7(b)(3)(v) How do I record a case in which a
worker is injured or becomes ill on a Friday (or before
scheduled time off such as a holiday or vacation) and
reports to work on a Monday (or immediately after
the scheduled time off), and was not scheduled to
work on the weekend? You need to record this case
only if you receive information from a physician or
other licensed health care professional indicating that
the employee should not have worked, or should
have performed only restricted work, during the
weekend (or scheduled time off). If so, you must
record the injury or illness as a case with days away
from work or restricted work, and enter the day
counts, as appropriate. See also,
1904.7(b)(3)(vi).
Dept. of Safety Sciences
University of Central Missouri
All work-related loss of consciousness cases
must be recorded, regardless of the length of
time that the employee remains unconscious.
§1904.7(b)(6)
Exception No. 2 applies if the loss of
consciousness is the symptom of a non
work-related event or exposure that merely
surfaces at work.
Dept. of Safety Sciences
University of Central Missouri
Report any work-related fatality (or in-patient hospitalization of
1 employee) to OSHA within 8 hours. Report hospitalization of 1
employee, amputation or loss of eye within 24 hours.
Report to the Area Office nearest the incident – or call the toll
free number 1-800-321-6742. Can I fax, send e-mail or leave a
voice mail of the report? No.
Do not report motor vehicle accidents on public streets or
highways (outside construction zones). Do not report fatalities
caused by commercial airplane, train, subway or bus accident.
(BUT YOU MUST RECORD THE CASE). (Review state plan rules).
Report work-related fatality caused by heart attack. FAQ 39-1.
Time limitation – report each fatality or multiple hospitalization
incident that occurs within 30 days of an incident. §1904.7(b)(2)
and §1904.39
Dept. of Safety Sciences
University of Central Missouri
The same analysis is applied to all injuries and
illnesses except “significant injuries or illnesses”
diagnosed by a PLHCP.
Work-related “cancer, chronic irreversible
disease, a fractured or cracked bone, or
punctured eardrum” must be recorded at the
time of initial diagnosis even if med. treatment,
RWA, or DAFW are not recommended.
§1904.7(b)(7)
Chipped or broken teeth are considered a
significant injury or illness when diagnosed by a
physician or health care professional.
FAQ 7-17.
Dept. of Safety Sciences
University of Central Missouri
Hearing Loss Cases
Needlesticks, Sharps
and Bloodborne
Pathogens
Medical Removal Cases
Tuberculosis Cases
Dept. of Safety Sciences
University of Central Missouri
audiometric zero - Audiology A value
arbitrarily assigned to 0 dB–decibel hearing
level, the average hearing acuity for a normal
population, which corresponds to 24.5 dB
SPL–sound pressure level at 250 Hertz
audiometric zero A value arbitrarily assigned
to 0 dB (decibel) hearing level, the average
hearing acuity for a normal population, which
corresponds to 24.5 dB sound pressure level
(SPL) at 250 Hertz.
Dept. of Safety Sciences
University of Central Missouri
Two part test:
1. The case must reflect a 25 dB hearing level or
more above audiometric zero (averaged at 2000,
3000 and 4000Hz) in the same ear (or both ears);
and,
2. There must be a STS in hearing (a shift of an
average of 10 dB or more at 2000, 3000, and
4000 hertz in one or both ears). (Age Adjusted).
§1904.10(a) and (b)(3) Compare STS to
employee’s baseline audiogram. If the employee
had previous recordable hearing loss, compare
the current audiogram with employee's revised
baseline audiogram (the audiogram reflecting the
employee's previous recordable hearing loss
case). See Interpretation Letter
Dept. of Safety Sciences
University of Central Missouri
Initial Baseline
Year 1
Year 2
Year 3
Year 4
4 db
14 db
24 db
26 db
34 db
Dept. of Safety Sciences
University of Central Missouri
If a retest will be provided within 30 days, you
can wait to record until after retest. (7 days to
record if retest confirms the loss). §1904.10(b)(4)
If a PLHCP determines that the case is neither
work-related nor a non-work-related case that
was significantly aggravated by occupational
noise, do not record. §1904.10(b)(6)
If subsequent testing (after the 30 day retest
period) reveals that the STS is not persistent, the
case may be lined out or erased. §1904.10(b)(4)
See also, Interpretation Letter
Special hearing loss Column (M)(5), effective
1/1/04.
Dept. of Safety Sciences
University of Central Missouri
If an employee suffers a Standard Threshold
Shift (STS) in only one year, may the employer
revise the baselines for both ears?
“No. A Standard Threshold Shift, or STS, is
defined in the occupational noise exposure
standard at 29 CFR 1910.95(g)(10)(i) as a
change in hearing threshold, relative to the
baseline audiogram for that employee, of an
average of 10 decibels (dB) or more at 2000,
3000, and 4000 hertz (Hz) in one or both
ears. The employer is permitted only to revise
the baseline in the ear where the employee
suffered an STS change in hearing threshold.”
Dept. of Safety Sciences
University of Central Missouri
Which baseline is used to determine if a
recordable Standard Threshold Shift (STS) has
occurred?
“Employers should use the same baseline that
they would use to comply with OSHA’s Noise
Standard, Part 1910.95. If the employer chose
to revise an employee’s baseline due to a
previous STS, then the employer would use
the same revised baseline when determining
recordability under section 1904.10 of the
recordkeeping regulation.”
Dept. of Safety Sciences
University of Central Missouri
Needlesticks or sharps injuries are automatically
recordable as injuries if they are contaminated
with blood or Other Potentially Infectious Material
(OPIM).
If injury case later results in an infectious disease
diagnosis, update entry and change classification
from injury to illness.
If there is a splash with blood or OPIM, record as
illness if case results in diagnosed bloodborne
disease or death,
DAFW, RWA, job transfer, medical treatment or
loss of consciousness.
Enter “privacy case” in lieu of employee’s name
on Log.§1904.8 and .29
Dept. of Safety Sciences
University of Central Missouri
If an employee is medically removed under
the medical surveillance requirements of an
OSHA standard (e.g., lead, cadmium), record
the case as either a RWA case or a DAFW
case, as appropriate.
If case involves a chemical exposure, record
as a Column (M)(4) “poisoning” case.
If case involves voluntary medical removal,
before a standard requires it, do not record.
§1904.9
Dept. of Safety Sciences
University of Central Missouri
If an employee is occupationally exposed to
known case of TB and develops TB (positive
skin test or diagnosis) – record as Column
(M)(3) respiratory condition.
Line-out the case if:
Public Health Dept. identifies worker as a
contact of an individual with a case of TB
unrelated to work;
Medical investigation shows infection was
caused by exposure to TB away from work; or
Employee is living with someone diagnosed
with active TB. §1904.11
Dept. of Safety Sciences
University of Central Missouri
Dept. of Safety Sciences
University of Central Missouri
Dept. of Safety Sciences
University of Central Missouri
Dept. of Safety Sciences
University of Central Missouri
Entering the Case on the OSHA
300 Log, the 301 Form, and
Including it on the 300A
Summary
Dept. of Safety Sciences
University of Central Missouri
Privacy Concern Cases” are a special category of cases in
which the words “privacy case” are entered on 300 Log
instead of employee’s name. Maintain a separate,
confidential list of these cases by name and case number.
1904.29(b)(6)
The following are privacy concern cases:
Injury or illness to intimate body part or reproductive
system;
Injury or illness resulting from sexual assault;
Mental illness;
HIV infection, hepatitis, or tuberculosis;
Needlestick/sharps injuries contaminated with blood or
OPIM;
Other illness where employee voluntarily requests
(including
MSDs).
§1904. 29(b)(7)
Dept. of Safety Sciences
University of Central Missouri
7 calendar days to complete the OSHA 300 Log
and OSHA 301 Form (or an equivalent form).
§1904.29(b)(2) and (3)
Save the OSHA 300 Log, the annual summary, the
OSHA 301 Log and any privacy case lists for 5
years following the end of the calendar year they
cover.
Update stored logs to include newly discovered
cases and to show changes in classification or
description of recorded cases. No requirement to
update annual summary or 301 Reports.
§1904.33
If business changes ownership, must transfer
records to new owner.§1904.34
Dept. of Safety Sciences
University of Central Missouri
Government asks for §1904 forms – copies within 4
hours. §1904.40
Employee, former employee, or employee rep.
requests current or stored OSHA 300 Logs for the
facility the employee worked (or for their own OSHA
301 form) – provide “relevant” Logs by end of next
business day. See §1904.35, FAQ 35-2 and
Interpretation Letter
Collective bargaining agent asks for copies of all
OSHA 301 forms for establishment agent represents,
provide within 7 calendar days. But, employer need
only provide “Tell us about the case” part of 301
form.
No charge for one set of copies. §1904.35
OSHA does not believe that HIPAA provides a basis
for employers to remove employee names from the
Log before providing access. OSHA Interpretation
Letter
Dept. of Safety Sciences
University of Central Missouri
At year’s end, “verify” that Logs are correct.
§1904.32(a)(1)
Company executive must certify “to the best
of my knowledge” the entries on the OSHA
300A Form are “true, accurate and complete.”
Company executive = owner, corp. officer,
highest ranking company official at the
establishment or that person’s supervisor.
Post the 300A Summary (not the actual OSHA
300 Log) in conspicuous place where notices
are posted - February 1 – April 30.
§1904.32(b)(3) – (6) See Interpretation Letter
Dept. of Safety Sciences
University of Central Missouri
There must be a system to collect all relevant data in
a single place.
All internal treatments and restrictions
All external treatments and restrictions
Information from off shifts
Separation from worker’s comp analysis
Use individual calendars (or computerized) to count
DAFW/RWA days
Periodic training for designated record-keeper.
Periodic audits of your recordkeeping system.
Safety incentive programs.
Trend analysis.
Appropriate employee medical care should drive
recordkeeping – recordkeeping should not drive
employee medical care.
Dept. of Safety Sciences
University of Central Missouri
Safety Management
Dan Peterson
New safety culture
• Safety is a people problem
• To achieve substantial breakthroughs in
accident prevention we must focus on people
– Line worker – to worried about security of job to
remember to test respirator
– Supervisor - concerned with production
schedules that time is not available to follow up
on training new employees
– Manager – pressured for immediate financial
results and decides to hire two new sales people
rather than invest in safer machinery
Upper management support
• Through their words and more importantly
through their actions, upper management sets
tone for safety in the organization.
• In a good safety culture, management
frequently expresses vocal support for safety by
taking positive visible actions that let each
employee know that safety is a key value.
• Upper management sets the tone
Active Middle Management
Involvement
• Middle managers must create a uniform set
of policies and procedures that support and
nurture the safety culture.
• There must be consistency throughout the
management team that leaves no doubt
about the seriousness of the commitment
Forced supervisor performance
• Strong management commitment deals with
the day-to-day activities at the supervisory
level.
• In positive safety culture supervisor is always
concerned with safe behavior of employees
• Major component of supervisors own
performance appraisal must focus specifically
on how well this job is being accomplished
High level of participation
• In good safety culture, each member of the
company participates fully in the various safety
activities.
• Safety is no longer thought of as an activity that
someone else is in charge of.
• Each manager, supervisor and line worker feels
personally responsible for safety and take an
active role in promoting it.
Program flexibility
• A good safety culture will allow each group
within a company to handle their safety
issues according to their own particular
needs and circumstances.
• The right way to achieve safety is the way that
works in your operation.
Positive perception among employees
• In good safety culture, employees will have a
positive perception about the various
activities.
• They will have confidence that safety is always
being addressed and that their voice will be
heard in making decisions relating to safety
Dan Peterson
Dan Peterson
Steps for change
• Assess your current safety culture
• Identify the needed changes
• Plan and implement specific changes
Role of Safety Professional
• Safety Professional will be involved in the entire process most of the activities will be managed and performed by
others.
• Safety Professional is facilitator or coach for people who
carry out the work.
• Facilitator is content expert for overall process, trainer for
the required tools and techniques, and motivator to keep
process moving.
• Being facilitator is quite different from being “in charge”
and while adjustment may require some effort, the rewards
can be enormous. Successful facilitators derive satisfaction
not form their individual accomplishments, but from creating
the opportunity for the entire company to function at peak
performance.
Perception Survey
• Predefined set of 100 questions design to
specifically measure how your employees
perceive the company’s performance in 21
safety categories
• Survey should create a graph showing which
categories employees perceive as being most in
need of improvement
• Survey should highlight different perceptions
held by managers, supervisors and employees
• Change process only works when all members of
the organization agree on the nature of the
safety problems to be addressed.
Perception Survey
• Safety categories that show markedly different
perception scores for the three groups are
areas where a renewed communications effort
will be extremely important.
Interview Method
• Alternate to perception survey – goal of both
techniques are the same
• One-one-one discussions are held with
number of employees to determine what
areas of the safety program need
improvement
• Interview method will deliver more
information, but its success is directly
dependent upon skill level of interviewer.
Change
• Identify the needed changes
– Identify specific actions that should be taken to
correct problem areas
– Approach is employee-based, problem-solving work
groups for each of the low rated safety categories
– Task to identify and recommend solutions
• Plan and implement specific changes
• Implement the specific recommendations
– Many will be simple and can be implemented as
soon as possible
– Others may require significant expenditure of funds
or demand coordination of large number of people
• In these cases necessary to put together written project plan
that describes and coodinate steps need for implementation
• “Everyone should know
that their answers to the
survey will remain
confidential and
anonymous”
Likert
•
•
•
•
•
•
The format of a typical five-level Likert item is:
Strongly disagree
Disagree
Neither agree nor disagree
Agree
Strongly agree
Peterson copyrighted
Peterson copyrighted
SCRAPE
• System of Counting and Rating Accident
Prevention Effort is purely a systematic method
of measuring accident prevention effort.
• Indicates amount of work done by supervisor
and by company to prevent accidents in a given
period
• Purpose to provide tool for management that
show, before accidents, whether positive means
are being used regularly to control losses
• System includes: inspections, investigation,
injury records
Inspection
• Most important reason for inspection is to
measure manager/supervisor performance
• If used as measurement tool supervisor/line
manger will conduct more inspections to
ensure conditions remain safe and that fewer
unsafe acts will occur
• Inspections preformed by staff professionals
should be for purpose of auditing supervisor
effectiveness and be a direct measurement of
supervisor performance
Investigation
• Primary accident investigation function has
always been the supervisor’s.
• Tools we give should lead to determination of
some of the many underlying cause
• Proper that line supervisor should investigate
and be allowed to determine what really
happened
• Form used should force identification of at
least five causes and encourage dealing with
all of them
Injury records
• Records should be designed so that they
measure the line manager, and to measure
the results of the line manager’s safety
performance
• Should be set up so that:
– Accident records are kept by the supervisor
(department)
– Give some insight as to how the accidents seem to
be happening (agency, body part, event, etc.)
– Conform to any legal and insurance requirements
Occupational Safety And Health
Six Addition
David L. Goetsh
https://www.youtube.com/watch?v=jA3Stu-Dj5k
Workplace Violence
America has been hard at work in the past 10 days and here is
what happened: A Federal Express pilot took a claw hammer
and attacked three others in the cock-pit, forcing one of
them to put the fully loaded DC-10 cargo plane through a series
of violent rolls and nose dives in a melee that brought the whole
crew back bleeding.
A purchasing manager in suburban Chicago stabbed his
boss to death because police say, they couldn’t agree on how to
handle some paperwork.
And a technician who quit because he had trouble working
for a woman sneaked back inside the fiber optics laboratory,
pulled out a 9-mil semiautomatic pistol and started firing
at workers, who ducked or fled and curled up in closets and file
cabinets. By the time he finished the job, two were dead, two
injured; he walked upstairs to an office and shot himself in the
head.
Workplace Violence
Emerged as a critical safety and health issue
According to Bureau of Labor Statistics, homicide is the second
leading cause of death to American Workers
16 percent of the 6,588 fatal work injuries in the U.S.
80 percent of homicide victims are men
Workplace homicide is the leading cause of death on the job for
women in the U.S. (remaining 20%)
Almost one million people are injured or killed in the workplace-
violence incidents every year in the year in U.S.
According to U.S. Department of Justice, the workplace is the
most dangerous place to be in the U.S.
Workplace Violence
Prevention of workplace violence is a natural
extension of the responsibilities of safety and health
professionals
hazard analysis
records analysis and tracking
trend monitoring
incident analysis
emergency response and employee training
prevention of strategies based on administrative and
engineering controls
Definitions
Workplace violence – violent acts, behavior, or threats
that occur in the workplace. Acts are harmful or potentially
harmful to people, property, or organizational capabilities
Occupational violent crime – intentional battery, rape,
or homicide during course of employment
Employee – individual with employment-related
relationship with the victim of a workplace-violent incident
Outsider – individual with no relationship of any kind
with the victim of a workplace-violence incident or with
the victim’s employer
Definitions
Employee-related outsider – individual with some
type of personal relationship with an employee, but
who has no work-related relationship with employee
Customer – and individual who receives products or
services from the victim of a workplace-violence
incident or form the victim’s employer
Workplace Violence - Size of problem
No longer amounts to just isolated incidents that
are simply aberrations
Should be considered a common hazard worthy of
the attention of safety and health professionals
High Risk Occupations and People
Taxicab drivers
Retail workers
Police and security officers
Finance,
Insurance
Real estate
Health care
Community service employees
Employee 65 years and older more likely to be victims
than are younger employees
Workplace Violence – Summary in One year
Fireman – gun attack killing wife at home killed four supervisors at
work
Fired employee – killed 5 former coworkers
Fired employee – held 5 coworkers hostage including former boss
Former mental patient - beating and stabbing nuns killing two of four
Fired employee - early 50’s male killed 3 employees
Male protesting closure of electronics store set clothing store on fire
and shot and killed 8 individuals
Fired employee – following charges of sexual harassment – 1 year later
forced way into homes of former coworkers fatally shooting 4
individuals
Workplace Violence – Summary in One year
Young accountant 28 year old Asian male- on job for 6
weeks shot and killed female supervisor 32 year old –
occurred one day after first performance counseling session
Postal worker (53 year old white male) reported to work
with handgun and shot 2 coworkers who he claimed were
his friends
City electrician (42 years old) shot and killed four
supervisors – targeted four employees because “he felt he
was being picked on and single out”
Quiet postal worker (58 years old) shot and killed
supervisor
Workplace Violence – Summary in One year
Classic loner just fired (47 years old) – returned next
day with rifle and pistol killed 3 workers
Man distraught over marital problems (35 year old
white male) open fired in crowded grocery store killing
3 people
Housing authority employee fired (38 years old) –
went to automobile returned with handgun and
returned to kill supervisor and a coworker (females
ages 47 and 24 years)
Total 14 cases
Survey – Society for Human Resource Management
Violent incidents 33 % of managers experience at least 1 violent
incident
54 % reported 2 to 5 acts of violence in 5 years prior
to survey
Violence of experienced 75 % fistfights, 17 % shootings, 8 % stabbings, 6 %
sexual assaults
Gender of perpetrator –
80 % males
Injuries sustained 22 % serious harm, 42 % medical intervention
Survey – Society for Human Resource Management
Reasons for violent incidents 38 % personality conflicts
15 % marital or family problems
10 % drug and alcohol abuse
7 % nonspecific attribution, 7 % firings and layoffs
Regarding crisis management program
28 % program in place prior to violent incident
12 % implemented program after violent incident
Regarding effect of violent incident on the workplace
41 % reported increased stress levels
20 % reported higher levels of paranoia
18 % reported increased distrust among employees
Legal Considerations
Revolve around competing rights of violent employees and their
coworker
Conflicting rights create potential liabilities for employers
Logic suggest that in potentially or violent situations the only concern
would be for protection of other employees
Even violent employees have rights (enforcement officials must
advise potential criminals of their rights)This does not mean that an
employer cannot take the immediate action necessary to prevent a
violent act or the recurrence of such and act.
Failure to act prudently can subject employer to charges of
negligence
Before taking long-term action that will adversely affect employment,
employers should follow applicable laws, contracts, policies, and
procedures
Employer Liability for Workplace Violence
In cases of workplace violence, as long as the violence
occurs within the scope of the victim’s employment, the
employer is protected from civil lawsuits and the excessive
jury verdicts that have become so common
Key to protection of the exclusivity of provision of
workers compensations laws lies in determining that
violence-related injuries are within the scope of the
victim’s employment (a more difficult undertaking
than one might expect)
If violent act occurs at work but resulted from a no-work-
related dispute?
What if the dispute was work related, but violent act
occurred away from the workplace?
Making Work-Related Determinations
NIOSH developed following guidelines for
categorizing an injury as being work related
If violent act occurred on the employer’s
premises, it is considered on-the-job event if
victim
Engage in work activity, apprenticeship, or
training
On break, in hallways, restrooms, cafeteria, or
storage areas
In employer’s parking lots while working,
arriving at, or leaving work
If violent act occurred off the employer’s premises, it is still
considered an on-the-job event, if victim
Working for pay or compensation at the time, including
working at home
Working as volunteer, emergency services worker, law
enforcement officer, or firefighter
Working in a profit-oriented family business, including
farming
Traveling on business, including to and from customer-
business contacts
Victim was engage in work activity in which the vehicle is part
of the work environment (taxi, truck, and so on)
Risk-Reduction Strategies
Natural Surveillance –
Designing, arranging, and operating the workplace in way that
minimizes secluded areas
Make all areas inside and outside the facility easily observable
Control of Access Control outsiders from entering the workplace and harming others
Control access to workplace channeling the flow of outsiders to an
access-control station requiring visitor’s passes, issuing access
badges to employees, and isolating pickup and delivery points
Establishment of territoriality Give employees control over workplace – employees move freely
within their established territory but are restricted in other areas
Employees come to know everyone who works in their territory and
can, as a result, immediately recognize anyone who shouldn’t be
there
Risk-Reduction Strategies
Activity support Involves organizing work flow and natural traffic
patterns in ways that maximize the number of
employees conducting natural surveillance
The more employees observing the activity in the
workplace, the better
Administrative Controls Establishing polices
Conducting background checks
Providing training for employees
Contributing Social and Cultural Factors
Managers need to understand social and cultural factors (individual
and environmental)
Understand predictors of potential violence
Employees with one or more of the following factors may respond to
anger, stress, or anxiety in a violent way
Record of violence – background checks
Membership in a hate group
Psychotic behavior – incessantly talk to themselves, express fears
concerning conspiracies against them, say they hear voices, become
increasingly disheveled over time may be violence prone
Romantic Obsessions - entanglements or love interest gone awry
persist in making unwelcome advances may eventually respond
to rejection with violence
Depressions – those who suffer are prone to hurt themselves
or someone else
Employee who becomes increasingly withdrawn or overly
stressed may be suffering from depression
Finger Pointers – refusal to accept responsibility is factor
often exhibited by perpetrators of workplace violence.
Unusual frustration levels – workplace has become a
competitive, stressful, and sometimes frustrating place
Obsession with weapons – employee who's interest in
weapons is unusually intense and focused
Drug dependence- should cause concern not only for all the
usual reasons but also its association with violence on the job
Environmental Factors Associated with Violence
Dictatorial management overly authoritative management that shuts employees out of the decision-making process
can cause them to feel powerless
Role Ambiguity employees need to know they are responsible, how they will be held accountable, how
much authority they have
Partial, inconsistent supervision –
supervisors who play favorites engender resentment in employees who aren’t the favorite
Unattended hostility –
supervisors who ignore hostile situations or threatening behavior are unwittingly fiving
them their tacit approval
No Respect for Privacy –
management that goes through desks, files, tool boxes, and work areas of employees
without first getting their permission may feel invaded or violated
Insufficient training –
holding accountable for performance without providing the training needed can
cause feeling of inadequacy
OSHA Voluntary Guidelines – Two Key Points
The guidelines are advisory in nature and
informational in content.
The guidelines do not add to or enhance in any way the
requirements of the general duty clause of the OSH Act.
Guidelines were developed with night retail
establishments in mind.
They have service-orientated emphasis
Much of the advice contained in guidelines can be
adapted for use in manufacturing, processing, or other
settings
OSHA Voluntary Guidelines – Management Commitment and
Employee Involvement
Fig 13-4 explains management commitment in practical
terms
Hands-on involvement of executive management in
developing and implementing prevention strategies
Sincere, demonstrated concern for protection
Balanced commitment to employees and customers
Inclusion of workplace –violence prevention in job
descriptions
Inclusion of workplace prevention criteria in performance
evaluations
Assignment of responsibility for coordination and leadership
Provision of resources needed to prevent workplace violence
effectively
Provision of guaranteed access to medical counseling and
trauma-related care
Implementation of violence-prevention recommendation
OSHA Voluntary Guidelines – Management Commitment and
Employee Involvement
Fig 13-5 describes practical application
Staying informed concerning all aspects of organizations
workplace-violence program
Voluntarily complying-in both letter and spirit-with workplaceviolence prevention strategies
Making recommendations-through proper channels-concerning
ways to prevent workplace violence and other hazardous conditions
Prompt reporting of all threatening of potentially threatening
incidents
Accurate and immediate reporting of all violent or threatening
incidents
Voluntary participation on committees, task forces, and focus
groups concerned with preventing workplace violence
Voluntary participation in seminars, workshops, and other
educational programs relating to the prevention of workplace
violence
OSHA Voluntary Guidelines – Management Commitment and
Employee Involvement
Fig 13-6 checklist for ensuring violence prevention becomes
standard component of organization
Include prevention of workplace violence in S&H in organization’s
strategic plan
Adopt, disseminate, and implement policy to protect employees
from reprisals when they report violent, threatening, or potentially
threatening situations
Procedure for reporting violent and threatening incidents
Procedures for making recommendation's for preventing workplace
violence
Procedure for monitoring reports so trends can be identified and
incidents predicted and prevented
Develop comprehensive prevention program containing operation
procedures and standard practices
Develop a work-place violence component to the organization’s
emergency response plan
Train all employees in application for standard procedures
Conduct periodic emergency-response drills for employees
OSHA Voluntary Guidelines –
Workplace Analysis –
Same process used by S&H professionals to identify
potentially hazardous conditions unrelated to workplace
violence
Establish a threat-assessment team with representatives
from all departments and led by chief S&H professional
OSHA Voluntary Guidelines –
Trend monitoring and incident analysis –
may provide help in determining patterns of violence
Employee Surveys and Focus Groups Where are we vulnerable?
What practices put employees at risk?
Security Analysis –
Physical factors that make employees vulnerable (lighting, isolated,
etc.)
Are strategies already implemented working?
Is training provided having a positive effect?
Is more training needed?
Are there situations with employees with substantial amounts of
money in possession on or off-site?
Are there situations which employees are responsible for highly
valuable equipment or materials late at might at isolated locations?
OSHA Voluntary Guidelines – Hazard Prevention and Control
Engineering controls
Devices that give employees complete view of
surrounding (mirrors, glass or clear plastic, etc.)
Surveillance cameras and TV screens
Adequate lightning
Pruning or removing growth around buildings
Installing fencing so routes of egress and ingress to
property can be channeled for better control
Arranging outdoor facilities and materials outside
facility for maximum visibility
OSHA Voluntary Guidelines – Hazard Prevention and Control
Proper work practices
Monitoring Feedback
Adjustments and modifications
Enforcement
OSHA Voluntary Guidelines – Post Incident Response
Same as post incident response relating to traumatic
accidents
First step - provide immediate medical treatment for
traumatized employees
Second step - involves providing psychological
treatment for traumatized employees
Even more important in cases of work-place violence
than with accidents
Even employees working in area that did not witness
event may experience symptoms of psychological
trauma
Training and Education
Fundamental to prevention of workplace-violence
Complete S&H training program should include
comprehensive component covering all aspects of
workplace violence (workplace analysis, hazard
prevention, proper work practices, and emergency
response)
Training should be provided on a mandatory basis for
supervisors, managers, and employees
Record Keeping and Evaluation
Maintaining accurate, comprehensive, up-to-date records
is just as important when dealing with violent incidents as
it is when dealing with accidents and nonviolent incidents
Record evaluation can determine how effective violence
prevention strategies are, where deficiencies exist and what
changes need to be made
Types of records –
OSHA log of injury and illness
Medical reports
Incidents of Abuse
Minutes of safety meetings
Records of all training programs
Records Evaluation Bottom pg. 372
Conflict Resolution and Workplace Violence
There are increasing numbers of workplace violence due to
internal company problems
A violence-prevention program is not complete without the
elements for conflict management and anger management
Conflict Management –
Establish conflict guidelines
Help employees develop conflict prevention and resolution
skills
Help all employees develop anger management skills
Establish Conflict Guidelines – establish ground rules
for discussing and debating differing points of view,
differing ideas, and differing opinions
Develop Conflict Prevention and Resolution Skills
Explore the Other Person’s Viewpoint
Establish that goal at this point is mutual
understanding
Elicit the other person’s complete point of
vies
Listen nonjudgmentally and do not
interrupt
Ask for clarification if necessary
Paraphrase others person’s point of view
and restate it to show that you understand
Ask for other person to correct your
understanding if it appears to be
incomplete
Explain Your view point
Ask for same type of fair hearing on your point
of view
Describe how person’s point of view affects you
Explain point of view accurately and completely
Ask other party to paraphrase and restate what
you have said
Correct the others party’s understanding if
necessary
Review and compare two positions
Agree on a resolution
Reaffirm mutual understanding
Confirm both parties are ready and willing
to consider options for acceptable solution
If it appears differences cannot be resolved
satisfactorily
Take time to reflect, agree to third party
arbitration or neutral mediation, etc.
Develop Anger Management Skills
Develop Anger Management Skills
Anger occurs when people feel one or more of fundamental
needs are being threatened
Need for approval, Need to be evaluated, Need to be
appreciated, Need to be in control, and Need for self-esteem
Normal human response is to become angry responding in
one of four ways
Attacking, Retaliating, Isolating, and Coping
Following strategies to help manage anger by better coping
Avoid use of anger-inducing words and phrased (but, you
should, you made me, always, never, I can’t, you can’t)
Admit that others don’t make you angry (you allow self to
become angry)
Don’t let pride get in the way of progress
Drop your defenses when dealing with people
Relate to other people as equals regardless to position or rank)
Avoid the human tendency to rationalize your angry
responses
Do’s and Don’ts for Supervisors
Don’t –
Try to diagnose personal, emotions, or psychological
problems
Discuss employer’s drinking unless it occurs on job
(restrict to job performance)
Preach to employees (counsel on attendance, tardiness,
and job performance)
Cover up for employees or make excuses for
inappropriate behavior
Create jobs to get problem employees out of the way
Ignore warning signs
Do –
Remember that chemical dependence and emotional
problems tend to be progressive
Refer problem employees to employee assistance
program or other mental health service providers
Make it clear to employees that job performance is the
key issue
Make it clear that inappropriate behavior will not be
tolerated
Emergency Preparedness Plan – Crisis Management Team
Team should have only one mission-immediate response to
violent acts on the job-and be chaire...
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