A Guide to Safety Evaluation :A Guide to Safety Evaluation By Dr. Deryck D. Pattron, Ph.D. Public Health & Safety Consultant 66 J Endeavour Extension Road Chaguanas, Trinidad, West Indies Email: drpattron@gmail.com


Introduction :Introduction Safety specialist and industrial hygienists will review working conditions to determine if the facility complies with OSHA standards, and if not what the cause may be (for example; lack of training, failure to conduct inspections, lack of funds for correction, etc.).


1. Supervisors :1. Supervisors Have you seen any policy statements on occupational safety and health? From whom? Does your performance evaluation have an element for occupational safety and health? In what way does company measure your safety and health performance (i.e. reduction in injuries, training courses, etc.). Do employees ever report unsafe or unhealthful conditions to you? How do you get the condition corrected? Who selects your employees personal protective equipment? Does it have to be approved by the safety office before it is purchased? Have you received any safety and health training? When? From whom? What was the subject?


2. Employee Representatives :2. Employee Representatives Have you ever seen any policy statements on occupational safety and health? From whom? What type of personal protective equipment are you issued? Do you feel you need any other type? Does management consult with employee representative about the occupational programme? Do employee representatives accompany inspectors during inspection? Do inspectors question employees privately? Have you received any occupational safety and health training? When? From whom? What was the object and how long was the training?


3. Employees :3. Employees Have you ever seen any information about the occupational safety and health at this facility? Where? What was it? Do you know of anyone who has gotten into trouble for making a safety or health complaint? Do you know what you can do if you see an unsafe condition? Have you ever reported a safety hazard? Who did you report it to? Was it taken care of? How long did it take? Have you ever any training about your agency’s occupational safety and health program or about the hazards of your job? When? Who gave it? What subjects were covered?


How Top Management demonstrates its support for safety programme? :How Top Management demonstrates its support for safety programme? 1. Policy Statements (a) Have policy statements been received from the agency head or other top managers? (b) Has the facility manager issued any policy statements. (c) Are supervisors aware of any policy statements? From whom? (d) Are employees aware of any policy statements? From whom?


How Top Management demonstrates its support for safety programme? (Cont’d) :How Top Management demonstrates its support for safety programme? (Cont’d) 2. Programme Documentation (a) Has the agency transmitted written programme documentation to the facility? (b) Has the facility developed additional programme documentation? If so, is it consistent with 29 CFR part 1960? (c) Are employees aware of availability of standard, agency’s program requirements, etc.?


How Top Management demonstrates its support for safety programme? (Cont’d) :How Top Management demonstrates its support for safety programme? (Cont’d) 3. Personal Participation (a) Does the facility manager participate in the programme? (Give examples; accompanies inspectors, issues memos, attends safety meetings, etc.).


How Top Management demonstrates its support for safety programme? (Cont’d) :How Top Management demonstrates its support for safety programme? (Cont’d) 4. Accountability (a) Are managers and supervisors evaluated on their occupational safety and health performance? Is it a critical element? Has merit pay ever been denied for occupational safety and health reasons? (b) Do supervisors correct hazards and enforce safety and health standards, rules and regulations in the workplace? For example, are employees wearing PPE? Are guards on machines in place?


How Top Management demonstrates its support for safety programme? (Cont’d) :How Top Management demonstrates its support for safety programme? (Cont’d) 5. Resources (a) Have sufficient staff been provided to administer the programme? Findings should list the number of OSH staff by job titles. (b) Have other resources been used? (NIOSH, contractor, etc.). (c) Have adequate financial resources been provided to abate hazardous conditions? Which abatements were delayed beyond 6 months? Are any abatements dates outstanding? Explain? (d) Is adequate and appropriate personal protective equipment provided at the facility?


How Top Management demonstrates its support for safety programme? (Cont’d) :How Top Management demonstrates its support for safety programme? (Cont’d) 6. Recordkeeping (a) Is a log of injuries and illnesses maintained at the facility? (b) Is a summary posted for 30 days beginning within 45 days of the close of the fiscal year? (c) Is a supplementary record of injuries and illnesses maintained? Completed in 6 working days? (d) Are injury/illness reports compared on OWCP claims filed? (e) Are OSHA required codes completed on compensation forms?


How Top Management demonstrates its support for safety programme? (Cont’d) :How Top Management demonstrates its support for safety programme? (Cont’d) 7. Inspections (a) Who conducts inspections of the facilities, and how often? (b) Has the facility identified high risk areas? Are they inspected more frequent? (c) Are inspectors qualified to recognize hazards for the workplace involved? (d) Are thorough investigations made of all fatalities or accidents requiring hospitalizations of five or more employees? Is DOL notified within 48 Hours? (e) Do inspectors review hazard reports, injury/illness records, previous inspection reports? (f) Do inspectors question employees or supervisors privately? (g) Are inspectors provided necessary equipment? (h) Do inspectors issue Notices of Unsafe or Unhealthful Working Conditions? Are these posted for appropriate times? (I) Do employee representatives accompany inspectors? (j) Is a closing conference conducted with the official in charge and employee representatives?


How Top Management demonstrates its support for safety programme? (Cont’d) :How Top Management demonstrates its support for safety programme? (Cont’d) 8. Hazard Abatement (a) Does the facility have written abatement procedures? (b) Are abatement dates set? Met within the specified time frames? (c) Does the facility follow required procedures when abatement cannot be achieved in specified time limits? (d) What are your procedures for tracking abatement? (e) Are imminent danger conditions abated immediately? (f) How does the facility assure that private contractors do no expose Federal employees to unsafe conditions? (g) Do you request preoccupancy inspections from GSA? If so, are the results acceptable? (h) Are there written procedures to make written reports of unsafe/unhealthful conditions to other agencies, e.g. GSA, which are responsible for their correction? (i) Have there been any reports of unsafe or unhealthful conditions that were referred to GSA? If so, were they investigated? (j) How does the facility coordinate with GSA to ensure that safety and health problems still outstanding are resolved prior to renogotiations of leases?


How Top Management demonstrates its support for safety programme? (Cont’d) :How Top Management demonstrates its support for safety programme? (Cont’d) 9. Standards Compliance (a) Does the facility generally comply with OSHA standards? (b) Are alternate or supplementary standards in use? (c) Were alternate standards approved by the Secretary of labour?


How Top Management demonstrates its support for safety programme? (Cont’d) :How Top Management demonstrates its support for safety programme? (Cont’d) 10. Programme Evaluations (a) Has the facility participated in an evaluation conducted by agency headquarters? (b) Does the facility receive feedback from agency headquarters about its performance?


References :References The Occupational Safety and Health Act, Section 19. Executive Order 12196, Occupational Safety and Health Programme for Federal Employees, Section 1-401. Basic Programme Elements for Federal Employee Occupational Safety and Health Programmes (29 CFR Part 1960.80). Chapter XIII of the Field Operations Manual (FOM). http://www.osha.gov http://www.dol.gov THE END