SAFE4035 Safety Program Management Paper

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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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