OSHA DB V

OSH 2301, Introduction to Workplace Safety 1

Course Learning Outcomes for Unit V Upon completion of this unit, students should be able to:

2. Identify occupational hazards commonly encountered in industry. 2.1 Identify hazards given workplace scenarios.

3. Apply hazard identification and analysis techniques to workplace scenarios.

3.1 Combine the process of risk assessment with the application of the hierarchy of controls. Required Unit Resources Chapter 15: Materials Handling and Storage Chapter 16: Electrical Safety, pp. 414–418, 422–439, 444–452 In order to access the following resource, click the link below. Please read pages 35-40 in the following article: Lyon, B. K., & Popov, G. (2017, November). Communicating & managing risk: The key result of risk

assessment. Professional Safety, 35–44. https://www.assp.org/docs/default-source/psj- articles/f2_1117.pdf?sfvrsn=2

Unit Lesson In Unit IV, the concept of hierarchy of controls was introduced. The controls applied in Unit III were then classified within the hierarchy of controls. Now, in Unit V, we will combine the process of risk assessment with the application of the hierarchy of controls in order to customize control strategies with the appropriate level. When looking at a risk to employee health and safety, the first approach should always be to eliminate that risk. This is consistent with the first level of the hierarchy of controls—elimination that attempts to completely remove the hazard—making the likelihood of occurrence or exposure to that hazard impossible. Recall the tire-changing task from Unit III. The following steps and hazards were identified in the Job Hazard Analysis (JHA):

Step Task Hazards 1. Loosen the lug nuts on the tire. Injury from the employee applying force in an

awkward position to loosen the lug nuts if done by hand Physical hazards in the form of excessive noise and high-pressure air if done with power tools

2. Use a jack to lift the car off the ground Car falling off the jack 3. Remove the damage tire and replace it

with a new tire Pulling and lifting in an awkward position

4. Lower the car to the ground using the jack

Car falling off the jack

5. Tighten the lug nuts. Same as Step 1

UNIT V STUDY GUIDE Managing Risk

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The risk posed by each hazard for causing an injury or illness to an employee must now be analyzed. This risk analysis is performed by evaluating the potential severity of the injury or illness that the hazard could bring, combined with the likelihood of the hazard causing that injury or illness, based on the employee’s exposure. A risk assessment matrix, such as the one provided in Lyon and Popov (2017), is used to conduct the risk analysis. The risk analysis will identify a risk level for each hazard, usually defined as low, medium, serious, or high. The level of risk assigned to a hazard can then be used to determine the level of urgency and priority that should be placed on the implementation of controls. Expanding on the example of changing a tire, think about the hazards that were defined for each step. For step one, the ergonomic hazard from the employee applying force in an awkward position to loosen the lug nut by hand would be assessed using a risk assessment matrix. The severity of an MSD could be defined as critical because of the recurring pain and potential loss of work time for an employee. The likelihood of occurrence could be defined as probable because the mechanic routinely performs this job. Using the risk assessment matrix provided in Lyon and Popov (2017) would result in a high-risk level. With a high level of risk, it is likely that this hazard would be required to be addressed. The hazard could be eliminated with the use of power tools for this step, such as an air impact wrench. However, this now presents a new set of physical hazards in the form of excessive noise and high-pressure air. Each of these hazards would now be required to be subjected to the risk analysis process to ensure that the corrective action taken did not introduce the same or even a higher level of risk.

As an example, the noise could be determined to be probable. Based on repeated exposure, it is likely to cause a critical injury because hearing loss is permanent. A probable and critical analysis would result in a high level of risk when applying the risk-assessment matrix. Because this is at the same level as removing the lug nuts by hand, it is not an acceptable alternative unless the risk level can be reduced. The outcome of hearing loss cannot be reduced in severity. However, the likelihood of occurrence could be reduced by reducing exposure. Adding additional controls, such as getting a low-noise air impact wrench, reducing the mechanic’s exposure time to the noise, or establishing an effective hearing conservation program that requires the use of hearing protection, offers the potential to reduce exposure, which would then lower the risk level to remote. A remote and

critical analysis would result in a medium level of risk, according to the risk assessment matrix provided in Lyon and Popov (2017). The physical hazard posed by the high-pressure air would need to be assessed in the same way. For example, the failure of the air hose would be the hazard, which would likely be critical because of the injuries it could cause to the employee. However, the likelihood could be remote, if the hose used was rated at 200 pounds per square inch (psi) when the compressor operating the air wrench only produced 150 psi. A remote and critical analysis would result in a medium level of risk, according to the risk assessment matrix provided in Lyon and Popov (2017). This same analysis could be applied to step five with tightening the lug nuts. In this example, the use of the JHA was able to reduce the risk of steps one and five of changing the tire from high to medium. The analysis

Adding controls such as establishing an effective hearing conservation program that requires the use of hearing protection can lower the risk of hearing loss caused by noise. Wearing eye protection further reduces risk of injury. (Voltamax, 2016)

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must be repeated for steps two, three, and four in order to complete the JHA. The example of changing the tire was a simplistic one, but it demonstrates the systematic way in which performing a JHA can be used to reduce potential risk in a job. In another, more complex example, think about employees working in a production facility on an assembly line, manually bagging granulated lawn care weed remover and fertilizer. Imagine that JHAs were completed for each of the three tasks in this bagging process, with the following findings.

• For the first task, one employee must manually place the bag under a loading spout that pours the granulated weed remover and fertilizer into the bag. The highest priority hazard for this task comes from exposure to dust from the material poured that presents a potential health hazard due to the chemicals it contains.

• For the second task, the employee on the assembly line uses a machine to heat seal the bag after it has been filled. The highest priority hazard for this employee is exposure to the equipment used to heat seal the bag.

• For the third task, the employee at the end of the assembly line lifts each bag off the assembly line and stacks it on a pallet. The highest priority hazards identified were ergonomic hazards involving the employee routinely lifting a 60-pound bag from the assembly line, twisting to the side while holding the bag, and bending over to stack the bag on the pallet.

In the process of completing the JHA, a review of past injury and illness data reveals the following:

• there have been numerous complaints about respiratory irritation from the employees who place bags under the spout,

• an employee experienced a second-degree burn when using the equipment to heat seal the bag, and • three employees experienced lost-time accidents because of back injuries caused by lifting the bags

from the assembly line and stacking them on the pallet. A risk assessment indicated that the hazard each employee is exposed to presents an unacceptable level of risk. While there are numerous controls that could be applied to each of the highest priority hazards for each task that would ultimately reduce the risk, eliminating it would be preferred.

(National Institute for Occupational Safety and Health, n.d.)

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Elimination The risks inherent in all three tasks could be eliminated by replacing the manual assembly-line process with an automated bagging system. This system would utilize robots to complete the tasks previously completed by the employees. While this option would require a significant upfront investment, it would eliminate all tasks since employees would no longer perform them and, therefore, eliminate the likelihood of occurrence or exposure to the hazard, thus totally eliminating the risk. As alternative solutions to elimination, lower levels on the hierarchy of controls could be applied in the form of substitution, engineering, administrative controls, or personal protective equipment (PPE). These controls could be added to each task to reduce the likelihood of exposure to that task’s hazard. However, these measures would only reduce the risk, not eliminate it. As long as employees are still performing the tasks and interacting with their work environment, there will always be some level of risk. We have already determined that replacing workers with robots would completely eliminate all risk in our example above. However, total elimination of risk is not always possible. Let’s take a look at how lower-level controls could be applied to reduce a task’s risk to an acceptable level.

Substitution Substitution is the next highest level in the hierarchy of controls, immediately below elimination. While elimination focuses on the exposure portion of the risk assessment matrix, substitution focuses on the severity component. When applying substitution in an ideal scenario, a hazardous process, chemical, material, or product would be replaced with one that is nonhazardous or, at a minimum, less hazardous. An example of this would be employees working in a machine shop removing parts, cleaning them, completing the repair, and then reinstalling them. A JHA completed for this task identified parts cleaning as the step with the highest hazard because of the solvent used to clean the parts. A review of the safety data sheet (SDS) revealed that this solvent will cause contact dermatitis and respiratory irritation with acute exposure. The risk increases to possible kidney damage with chronic exposure. A review of past injury and illness data reveals that two employees have been treated for severe skin irritation caused by use of this solvent. A risk assessment indicated that this hazard presents an unacceptable level of risk to the employees in the machine shop. The process of cleaning the parts cannot be eliminated because it is required in order for the parts to be repaired correctly. A review of alternative solvents reveals one that has the potential for mild skin irritation without the potential for respiratory irritation or kidney damage. This alternative solvent was demonstrated and worked as effectively as the original, more hazardous product. The alternative solvent still has the potential for mild skin irritation; therefore, the hazard is not eliminated. However, the severity of the hazard has been reduced from contact dermatitis to mild skin irritation without respiratory irritation or kidney damage, thus reducing the risk. It is possible that lower levels of the hierarchy of controls could be applied to this task in the form of engineering or administrative controls or PPE to reduce the likelihood of occurrence or exposure to that hazard. These controls might further reduce the risk.

Engineering Controls Engineering controls are the next step after elimination and substitution have been applied to the extent feasible without an acceptable level of risk being achieved. Engineering controls can be applied in a variety of ways, all with the intent of isolating the hazard to reduce the likelihood of harm from the occurrence or employee exposure to the hazard. A simple, common example of an engineering control is adding machine guarding for a table saw in a wood shop. Imagine that during the process of completing a JHA on the use of this table saw, a review identified engineering control requirements that include the following:

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• a self-adjusting guard at the point of operation to prevent accidental contact with the blade,

• an enclosure area under the saw to prevent employees from contacting the lower portion of the blade

or the power transmission of the saw, and

• anti-kickback fingers to prevent the material being sawed from being kicked back toward the

employee operating the saw.

Even with the controls mentioned, the hazards presented by the saw blade, power transmission, and potential for kickback of the wood still exist, so the hazards have not been eliminated. However, the likelihood of occurrence or exposure to the hazards has been reduced, thus reducing the risk. Lower levels of the

Saw blade with a self-adjusting guard (Occupational Safety and Health Administration [OSHA], 2003c)

Table saw with an enclosed saw and power transmission apparatus below the table (OSHA, 2003b)

Anti-kickback fingers (OSHA, 2003a)

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hierarchy of controls could be applied in the form of administrative controls and PPE to further reduce the likelihood of occurrence or exposure to the hazards. It may further reduce the risk, but still not completely eliminate it.

Administrative Controls After elimination, substitution, and engineering controls have been applied to the extent feasible, if the acceptable level of risk has not yet been achieved, administrative controls are the next step. Administrative controls can be applied in a variety of ways, all with the intent of isolating the employee from the hazard in an effort to reduce the employee’s likelihood of exposure to that hazard. Administrative controls attempt to establish procedures, programs, and policies that employees must follow to isolate themselves from hazards. For examples of administrative controls, please review the video, Scenarios at the Workplace; the link to this video is also provided in this unit’s required unit resources. Which scenarios, defined by industry, are examples of administrative controls? Administrative controls presented in the video include the following items.

• Construction—Corrective action in this scenario focuses on procedures. The hazards present when using equipment on a construction site still exist, but the procedure of designating areas for storing tools to remove potential tripping hazards was put into place to reduce the likelihood of occurrence or exposure to the hazards, thus reducing the risk.

• Healthcare—Corrective action in this scenario focuses on programs. For example, the hazard of workplace stress still exists, but an improved program for employee counseling was put into place to reduce the likelihood of occurrence or exposure to the hazards, thus reducing the risk.

• Hospitality—The corrective action focuses on policies. The hazard of hot oil still exists, but a policy was put into place that required increased supervision to reduce the likelihood of occurrence or exposure to the hazard, thus reducing the risk (ClickView Pty Limited, 2010).

Why is the retail scenario in the video not an example of an administrative control? The workplace was changed, and additional shelving was added to reduce the likelihood of occurrence or exposure to the hazard, thus reducing the risk. The site was redesigned, which engineered out the hazard by reducing the requirement for the employee to routinely bend over. The control does not rely on the employee following procedures, programs, or policies. As with engineering controls, when administrative controls are applied, the hazards still exist. However, the likelihood of occurrence or exposure to the hazards has been reduced through procedures, programs, and policies. Lower levels of the hierarchy of controls could be applied in the form of PPE to further reduce the likelihood of occurrence or exposure to the hazards, though it still will not totally eliminate it.

Personal Protective Equipment PPE is the next step after elimination, substitution, engineering, and administrative controls have been applied to the extent feasible, and the acceptable level of risk has not yet been achieved. There are many forms of PPE, all with the intent of preventing the hazard from causing adverse impacts to the employee, while accepting the fact that the employee has already been, or has the potential to be, exposed to the hazard. A common example would be the use of a shaded lens in a welding shield. When an employee is required to weld, he or she is going to be exposed to bright light that can damage the eyes. While it is accepted that the employee doing the welding will be exposed to the hazard of the bright light, the likelihood of harm from the occurrence or exposure to the hazard is reduced using PPE in the form of the properly shaded lens. OSHA also requires additional protection in the form of safety glasses worn under the welding helmet to protect the employee from flying materials such as slag, chips, and other particles.

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PPE must be combined with administrative controls that establish policies that require its use as well as training programs to educate employees on its proper use. Using the welding example, administrative controls must be in place in the form of a policy that requires the use of the properly shaded lens in combination with a program to train the employees on the proper use of the shaded lenses. Unit V built on the concepts covered in Units III and IV, combining the process of hazard identification and application of the hierarchy of controls with risk assessment. Examples were provided that demonstrated how control strategies could be customized by applying the appropriate level of the hierarchy of controls to reduce risk.

References ClickView Pty Limited (Producer). (2010). Scenarios at the workplace (Segment 5 of 7) [Video]. In Workplace

health and safety. Films on Demand. https://libraryresources.columbiasouthern.edu/login?auth=CAS&url=http://fod.infobase.com/PortalPla ylists.aspx?wID=273866&xtid=129322&loid=459284

Jakhar, A. (2018, May 17). Photography of a person wearing welding mask 1098402 [Photograph]. Pexels.

https://www.pexels.com/photo/photography-of-a-person-wearing-welding-mask-1098402/ Lyon, B. K., & Popov, G. (2017, November). Communicating & managing risk: The key result of risk

assessment. Professional Safety, 35–44. https://www.assp.org/docs/default-source/psj- articles/f2_1117.pdf?sfvrsn=2

National Institute for Occupational Safety and Health. (n.d.). Hierarchy of controls [Graphic]. Centers for

Disease Control and Prevention. https://www.cdc.gov/niosh/topics/hierarchy/images/HierarchyControls.jpg

Occupational Safety and Health Administration. (2003a). Antikickback fingers [Photograph].

https://www.osha.gov/SLTC/etools/machineguarding/images/antikickback_fingers.jpg

(Pixabay, 2016a)

(Pixabay, 2016b) (Jakhar, 2018)

Personal protective equipment (PPE) is the next step after elimination, substitution, engineering, and administrative controls have been applied to the extent feasible, and the acceptable level of risk has not yet been achieved.

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Occupational Safety and Health Administration. (2003b). Enclosed blade [Photograph]. https://www.osha.gov/SLTC/etools/machineguarding/images/enclosedblade.jpg

Occupational Safety and Health Administration. (2003c). Fig. 11: Machine guarding [Image].

https://www.osha.gov/SLTC/etools/machineguarding/images/fig_11.jpg Pixabay. (2016a). Person wearing white suit holding white container [Photograph]. Pexels.

https://www.pexels.com/photo/action-adult-boots-boxes-209230/ Pixabay. (2016b). Woman holding mop [Photograph]. Pexels. https://www.pexels.com/photo/adult-building-

business-clean-209271/ Voltamax. (2016). [Woman wearing hearing protection] [Photograph]. Pixabay.

https://pixabay.com/photos/industrial-security-logistic-1636403/ Suggested Unit Resources If you are unfamiliar with electricity or would like a refresher on its concepts, it is recommended that you review the following pages in the textbook that can be found in in Chapter 16: Electrical Safety:

• 405–413, • 419–421, • 440–443, and • 453–455.

In order to access the following resources, click the links below. National Institute for Occupational Safety and Health. (2015, January 13). Hierarchy of controls: Overview.

Centers for Disease Control and Prevention. https://www.cdc.gov/niosh/topics/hierarchy/default.html ClickView Pty Limiited (Producer). (2010). Scenarios at the workplace (Segment 5 of 7) [Video]. In Workplace

health and safety. Films on Demand. https://libraryresources.columbiasouthern.edu/login?auth=CAS&url=http://fod.infobase.com/PortalPla ylists.aspx?wID=273866&xtid=129322&loid=459284

For a transcript of this segment, click the Transcript tab next to the video in the Films on Demand database. To learn more about the information provided on the risks of hazardous materials, please read the following OSHA Brief. It outlines the sections of safety data sheets (SDSs) and describes the information that they provide. This document will not only be helpful now but may also be useful as a future resource. Occupational Safety & Health Administration. (2012). Hazard communication standard: Safety data sheets

(OSHA Brief No. DSG BR–3514). U.S. Department of Labor. https://www.osha.gov/Publications/OSHA3514.pdf

Learning Activities (Nongraded) Nongraded Learning Activities are provided to aid students in their course of study. You do not have to submit them. If you have questions, contact your instructor for further guidance and information. Hierarchy of Controls How can using a combination of administrative controls and PPE be less effective at protecting workers from hazards than applying engineering controls alone? You may practice by preparing a one-page essay that addresses this question. Provide examples to support your response.