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Identifying and Controlling Hazards

Oregon OSHA Online Course 104

This material is for training purposes only. Its purpose is to inform Oregon employers of best practices in occupational safety and health and general Oregon OSHA compliance requirements. This material is not a substitute for any provision of the Oregon Safety Employment Act or any standards issued by Oregon OSHA. For more information on this online course and other OR-OSHA online training, visit the Online Course Catalog.

MODULE 3: IDENTIFYING HAZARDS

Introduction
The first step in controlling workplace hazards is to first identify them. We want to determine what hazards are present. Once hazards are identified, you'll conduct an analysis to examine more closely the nature of the hazard. Analysis requires that each item or component be examined to see how it relates to or influences the whole.

Safety inspections should do more than simply identify hazardous conditions. They should provide useful data for the purpose of effective analysis and evaluation of the safety management system.


There are five basic methods you can use to identify workplace hazards:
  • informal observations, and formal observation programs;
  • comprehensive company-wide surveys;
  • individual interviews;
  • walk-around inspections; and
  • documentation review.
As we'll learn, observing work each day is extremely important in identifying hazards. Surveys take advantage of employee awareness of the presence of workplace hazards. Interviews are valuable in uncovering hazardous conditions, unsafe work practices, and their root causes. Walk-around inspections are useful to locate hazardous conditions and, to a lesser degree, unsafe work practices in the workplace. Reviewing documentation such as the OSHA 200 Log, safety committee minutes and accident reports also helps to determine workplace hazards. Now, let's take a look at each of these five methods or "tools" to identify hazards.

Informal observation/Formal Observation Program (FOP)

An informal observation process is nothing more than being watchful for hazards and unsafe behaviors throughout the work shift. No special procedure is involved. All employees should be expected to look over their work areas once in a while.

One of the most effective proactive methods to collect useful data about the hazards and unsafe behaviors in your workplace is the Formal Observation Program (FOP) the includes a written plan and procedures. For example, safety committee members or other employees may be assigned to complete a minimum number of observations of safe/unsafe behaviors during a given period of time. This data is gathered and analyzed to produce graphs and charts reflecting the current status and trends in employee behaviors. Posting the results of these observations tends to increase awareness and lower injury rates. But, more importantly, the data gives valuable clues about safety management system weaknesses.

Observation, is important because it can be a great tool to effectively identify behaviors that account for a majority of all workplace injuries because it considers how these behaviors interact with the hazardous conditions. The walkaround inspection, as a method for identifying hazards, just can't identify unsafe behaviors as effectively as observation.

Note: An important policy for successful formal observation procedures is that they are not, in any way, linked to discipline. To make sure this occurs, formal observers should be employees, not supervisors or other managers. Supervisor/manager roles and responsibilities as observers may quite confusing to those being observed. It's fine for observers to express appreciation when safe behaviors are observed, and warn employees that are not performing safe procedures. Observers should not discipline or "snitch" on employees: To do so ensures the formal observation program will fail as an accurate fact-finding tool.

Comprehensive surveys

Comprehensive surveys are not the same as interviews or inspections. An interview is a verbal exchange conducted one-on-one, preferably in private, and has the potential to gather more information. An inspection is often done by employees at the workplace who walk around observing the workplace and asking questions in public.

Comprehensive surveys ideally should be performed by people who can bring to your worksite fresh vision and extensive knowledge of safety, health, or industrial hygiene. Because there are few professional consultants equipped to do comprehensive surveys in all three areas, the best approach is to use a team consisting of outside specialists: a safety professional and an industrial hygienist.

We encourage you to take advantage of Oregon OSHA's excellent safety and health consultative services. Just call you local Oregon OSHA field office and schedule a visit. Workers' compensation insurance providers and other insurance companies offer expert services to help their clients evaluate safety and health hazards. Private consultants may also provide excellent specialized services to help determine workplace hazards.

For the industrial hygiene survey you should, at a minimum, inventory all chemicals and hazardous materials in the plant, review your hazard communication program, and analyze air samples. For many industries, a survey of noise levels and a review of the respirator program also will be vital.

Interviewing employees

Outside experts may or may not conduct interviews during their comprehensive surveys. If they do, that's great. If they don't, it becomes important for someone in-house to do so. A wealth of information, over and above what might be possible from a survey, may be obtained by conducting one-on-one interviews with employees.

When conducting the interview keep the following tips in mind:
  • Put the person at ease.

  • Keep the purpose of the interview in mind: It's to get the employee's help in determining the types of hazards that exist in his or her work area. Go to the work area to conduct the interview. Just because you are familiar with the location or the employee's job, don't assume that things are always the same.

  • Explain the purpose and your role. Tell the employee exactly why you are conducting the interview to reduce any initial reluctance to participate.

  • Stress that the information given is important. It may help eliminate hazards that have the potential to kill, injure or produce illness. Information given may also help to make the work procedure more efficient too.

  • Be friendly, understanding, and open minded. Try to keep the interview informal. Your approach is important. Make sure they sense that you care about their safety.

  • Be calm and unhurried. If you're agitated, or in a hurry to get the interview over, you'll be sending a negative message that the employee will pick up.

  • Let the individual talk. Don't interrupt while they are talking. It's easy to think you have all the information. Many important facts may not be uncovered if you cut them off.

  • Ask background information, name, job, etc . . . This just helps to smoothly transition into the actual interview. Small talk...then get to business.

  • The key initial statement. Ask the witness to tell you about the hazards they are aware of. Don't ask them if they know of any hazards: they could easily just say "no."

  • Don't ask leading questions. They are not on trial.

  • Ask follow-up questions. This will help to clarify particular areas or get specifics.

  • Do not put the person on the defensive. If there are hazards present, don't in any way question the employee in a manner that might accuse or blame them of wrong doing.

  • Try to avoid yes and no answer questions. Ask open-ended questions. One effective question is..."Tell me about the procedures for..."

  • Actively listen. Repeat the information given. Rephrase. Communicate to understand.

  • Take notes. Notes should be taken very carefully, and as casually as possible. Let the individual read them if desired.

  • Use a tape recorder. But always get permission from the employee first. Offer to give them a copy of the tape if they hesitate.

  • Thank the employee. Conclude the interview with a statement of appreciation for their contribution.

  • Be available. Ask them to contact you if they think of anything else.

  • Provide feedback. If possible, advise the person the outcome of the interview
Workplace inspections

Inspections are the best understood and most frequently used tool of assess the workplace for hazards. Much has been written about them, and many inspection checklists are available in various OR-OSHA publications. The term "inspection" means a general walk-around examination of every part of the worksite to locate conditions that do not comply with safety standards. This includes routine industrial hygiene monitoring and sampling.

Sometimes the term, "audit" is substituted for the term "inspection." Actually, an audit is a little different. The audit is more of an evaluation tool because the process involves giving a numerical rating of some kind to items that are being audited. While inspections involve locating hazardous conditions, audits more generally involve locating ineffective or missing safety programs.

Inspection Frequency

The regular site inspection is done at specified intervals. According to OAR 437, Division 1, Rule 760(7)(a), the employer must inspect as often as the type of operation or character of equipment requires. Think about the most hazardous operation or location in your company. How often are safety inspections conducted there?



OAR 437, Div 1, Rule 760(7)(a) Inspections


All places of employment shall be inspected by a qualified person or persons as often as the type of operation or the character of the equipment requires. Defective equipment or unsafe conditions found by these inspections shall be replaced or repaired or remedied promptly.




In Oregon, safety committees play an important role in the success of the hazard identification and control program in accordance with OAR 437, Div 1, Rule 765(d).


OAR 437, Div 1, Rule 765 (d) Hazard assessment and control


(A) The safety committee shall assist the employer in evaluating the employer's accident and illness prevention program, and shall make written recommendations to improve the program where applicable. Additionally, the safety committee shall:
(i) Establish procedures for workplace inspections by the safety committee inspection team to locate and identify safety and health hazards;

(ii) Conduct workplace inspections at least quarterly; and

(iii) Recommend to the employer how to eliminate hazards and unsafe work practices in the workplace.
(B) The inspection team shall include employer and employee representatives and shall document in writing the location and identity of the hazards and make recommendations to the employer regarding correction of the hazards.

(C) Quarterly inspections of satellite locations shall be conducted by the committee team or by a person designated at the location.


I'm sure you can see from the above discussion that a quarterly inspection by the safety committee may not be sufficient to ensure hazards are effectively identified. Oregon OSHA recommends that, at a minimum, medium and large fixed worksites be inspected completely at least every quarter, with some part of the inspection occurring each month. For construction sites, Oregon OSHA recommends site inspections at least weekly because of the rapidly changing nature of the site and its hazards.

At small fixed worksites, the entire site should be inspected at one time. And even for the smallest worksite, inspections should be done at least quarterly. If the small worksite uses hazardous materials or involves hazardous procedures or conditions that change frequently, inspections should be done more often.

What should we inspect?

A methodical inspection will follow a checklist based on the inventory of hazards and the preventive actions and controls designed to reduce or eliminate worker exposure. Regular site inspections should be designed to check each one of those controls to make sure that hazards are contained.

Do not overlook areas outside of the production mainstream. Your search for common hazards and Oregon OSHA standards violations should cover the entire worksite, including all office areas. Refer to Oregon OSHA's Self-Inspection Checklists for the Workplace to see examples of model inspection checklists.

Who Should Inspect?

From your reading earlier, you already know that the safety committee is responsible for conducting quarterly safety inspections. But is that where it ends? Shouldn't be. Others should be conducting safety inspections on a regular basis.
Supervisors. Employers should make it the supervisor's responsibility to inspect his/her work area at the beginning of every shift to ensure equipment and personnel are ready to work safely. This can be particularly helpful when other shifts use the same area and equipment or when after-hours maintenance and cleaning are routinely done.

Employees. Oregon OSHA recommends involving employees in all aspects of the safety and health program, including hazard identification and control.

Get educated in hazard identification

Safety and health staff. Safety staff who specialize in safety and health can be an excellent source of help in providing the necessary education and training on hazard identification. In a small business, the specialist may be the Human Resources Director or another member of management with many important duties in addition to safety and health.
What training should inspectors receive?
Employees. All employees should have training in the hazards that they may be exposed to during work. When they are responsible for workstation inspections, employees also should have specific training in how to inspect. On-the-job training with the supervisor goes farthest to ensure adequate education (understanding of consequences) and training occur.

Supervisors. All supervisors should have training in the hazards that workers under their supervision are likely to encounter, plus training on how to control these hazards. When they are responsible for area inspections, supervisors also should have specific training in how to inspect. Formal course work may not be necessary, but the training should be provided by someone who is qualified (has experience and training).

Safety committee members and employees. All safety committee members and employees should understand the potential hazards to which they might be exposed and the ways they can protect themselves and their fellow workers. Those who are involved in inspections need training in recognizing and controlling all the potential hazards of the worksite. They will also need written guidance, tips for inspecting, and some on-the-job training by safety and health staff or other specialists.
Written Inspection Reports

In all but the smallest and least dangerous of workplaces, written inspection reports are necessary to record hazards discovered, responsibility assigned for correction, and tracking of correction to completion. Quarterly safety committee inspections must include a written report with recommendations for corrective action.

A written record will help ensure:

  • Assignment of responsibility for hazard correction.
  • Tracking of correction to completion.
  • Identification of problems in the controls system when the same type of hazards keep appearing even after correction is verified.
  • Identification of problems in the accountability system.
  • Identification of hazards for which no prevention or control has been planned.
Of course, having such written records will be most helpful if they are read by someone knowledgeable in the safety and health program. This person then can provide top managers with summaries of problems.

Beware of "tunnel vision"

If you use experts from within your company, be on guard for "tunnel vision," which can lead to a failure to spot hazards in areas not directly related to your firm's primary function. You want your maintenance shop, for example, to be just as safe as your production line. Oregon OSHA frequently finds unguarded saws and grinders, non-code electrical wiring, and other basic safety hazards in areas that are outside the main production process but regularly used by employees.

Review Documents

Assessing the workplace wouldn't be complete without thoroughly reviewing existing documents to determine what kind of hazards have existed in the workplace prior to the assessment. Actually, document review may considered both an assessment tool and an analysis tool. Not only are we able to determine the hazards that have caused accidents in the past, we can analyze to uncover trends in the types, locations, date/time, etc. for accidents.

Review these documents to assess workplace hazards
  • OSHA 300 Log (of course)
  • WCD Form 801, First Report of Injury
  • Maintenance work orders
  • Accident reports
  • Safety committee minutes
  • Safety suggestions
  • Training evaluations
Last Words

Well, that's a lot of important information. All these activities to identify hazards in the workplace are so important to the overall effectiveness of your safety management system. Be sure you integrate these activities into the line positions...employees, supervisors and managers...safety is a line responsibility! It's time to take your first module quiz.
Module Quiz

16. The identification process determines ______________:
a. who is liable
b. what hazards are present
c. what a hazard looks like
d. where a hazard can be found
17. An analysis process examines ______________:
a. where hazards can be found and how to find it
b. each part to determine its impact on the whole
c. performance to judge its effectiveness
d. culture to evaluate how well it supports safety
18. Which of the following is not discussed in this module as one of the five basic actions you can take to identify workplace hazards?
a. observation
b. surveys
c. interviews
d. evaluations
19. ______________ is/are considered one of the most effective proactive methods to collect useful data about the hazards and unsafe behaviors in your workplace.
a. Employee interviews
b. Surveys
c. Formal observation
d. Safety Committee inspections
20. Comprehensive surveys ideally should be performed by people ___________________:
a. with fresh vision and extensive knowledge
b. from unrelated functional areas
c. with little interest in the outcome
d. who do not have preconceived ideas
21. An important policy for successful formal observation procedures is that they are always linked to discipline.
a. True
b. False
22. According to the text, this method for identifying hazards just can't identify unsafe behaviors as effectively as observation.
a. interviews
b. surveys
c. observation
d. inspections
23. What is a major weakness of the walk-around safety inspection?
a. Does not adequately identify unsafe behaviors
b. Does not adequately identify hazardous conditions
c. Requires both employee and management participation
d. Takes too much time
24. Comprehensive safety surveys are best conducted by in-house experts.
a. True
b. False
25. According to ________________ all places of employment shall be inspected by a qualified person or persons as often as the type of operation or the character of the equipment requires.
a. OAR 437, Div 1, Rule 760
b. OAR 436, Div 1, Rule 765
c. OAR 435, Div 2, Rule 760
d. OAR 438, Div 2, Rule 761
Congratulations on completing the third module! I'm sure you'll agree that using any and all methods to identify hazards is important. Continue on to the next module to learn more about the various methods to analyze the workplace for hazard. If you have any questions or comments, just drop me an email at email.


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