Accident Investigation Techniques

OSH 4308, Advanced Concepts in Environmental Safety Management 1

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

2. Explain important laws, codes, and regulations related to occupational safety and health and the environment. 2.1 Identify various regulations for safety topics, including confined spaces, fall protection, hearing

conservation, electrical safety, and hazard communication through online sources and through written form.

2.2 Identify various categories of penalties that an OSHA director may impose for violations of safety and health standards.

2.3 Identify the major components of various standards.

4. Perform appropriate calculations regarding the measurement, evaluation, and control of safety, health, and environmental hazards. 4.1 Calculate total case incident rates (TCIRs), days away restricted or transferred (DARTs), and

severity rates.

Course/Unit Learning Outcomes

Learning Activity

2.1 Unit I Quiz

2.2 Unit I Quiz

2.3 Unit I Quiz

4.1 Unit I Quiz

Reading Assignment Chapter 2: Regulations Chapter 13: Statistics for the Safety Professional

Unit Lesson This course provides you with an opportunity to further engage in areas about how a safety and health professional makes decisions—informed decisions. It is one thing to be familiar with a standard; however, an advanced knowledge about the intentions behind the standard is necessary to make key leadership decisions. It is not enough to be aware of ventilation practices. Instead, an advanced professional possesses the ability to find, recite, and calculate the details of a circumstance involving ventilation. Advanced safety professionals also know more than surface-level details about radiation safety. Hazardous noises are easy to overlook; however, an advanced safety professional knows what to do, what to look for, and how to prevent hearing loss. A mediocre safety professional knows something about varying temperatures and how they affect an environment, yet an advanced safety professional knows how to detect the slightest indicator of thermal stressors. The study of hydrostatics and hydraulics is certain to enhance your decisions in most environments. Regular safety professionals have cursory awareness of fire protection and prevention, yet an advanced safety professional is able to resolve the most detailed issues. The study of ergonomics contains several minute details that allow advanced safety professionals to resolve unnecessary strenuous activity. The purpose of this course is to introduce these concepts to you in order to improve your ability with

UNIT I STUDY GUIDE

Safety Regulations and OSHA Record Keeping

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protection, prevention, and response actions. Knowing and applying these concepts could be the difference between a mediocre safety program and a stellar safety program. OSHA The Occupational Safety and Health Administration (OSHA) was established in 1970 and signed into law by President Richard M. Nixon. This agency operates under the direction of the Department of Labor and more specifically, the Under Secretary of Labor. As listed by Yates (2015), the primary purposes of OSHA are:

 Encourage employers and employees to reduce workplace hazards and to implement new or improve existing safety and health programs.

 Provide research in occupational safety and health to develop innovative ways of dealing with occupational safety and health problems.

 Establish “separate but dependent responsibilities and rights” for employers and employees for the achievement of better safety and health conditions.

 Maintain a reporting and record keeping system to monitor job-related injuries and illnesses.

 Establish training programs to increase the number and competence of occupational safety and health personnel.

 Develop mandatory job safety and health standards and enforce them effectively; and

 Provide for the development, analysis, evaluation, and approval of state occupational safety and health programs. (p. 15-16)

Understanding the Code of Federal Regulations Every standard or law written by an administrative agency is written (or codified) into the Code of Federal Regulations. The Code of Federal Regulations (CFR) is divided into 50 different titles. Each title represents a different administrative agency. To reference a standard there are several parts to the citation. For example:

The example above can be read as: Title 29 CFR Part 1910, Section 1200. Twenty-nine (29) refers to the Occupational Safety and Health Administration (OSHA). CFR stands for Code of Federal Regulations. The third component labeled 1910 represents an individual part of the code. In this case, the individual part is General Industry. Finally, 1200 represents the section or the standard number. This standard number (i.e., 1200) is Hazard Communication, which is the name of the standard number. Some of the more common standards you will encounter in the safety, health and environmental programs are as follows:

 Title 29 Occupational Safety and Health Administration

 Title 40 Environmental Protection Agency

 Title 49 Department of Transportation

 Title 10 Energy (Covers Nuclear Regulatory Commission) Vertical and Horizontal Standards

29 CFR 1910.1200

Title

Code of Federal Regulation

Part

Section

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One helpful way to think about standards is how they apply to organizations. Certain standards only apply to a select group of organizations or employers, and they are referred to as vertical standards. On the other hand, other standards apply to many or all organizations and those standards are called horizontal standards. For instance, see the illustration below where each cube represents an industry.

Yates (2015) refers to fire suppression systems as a good example of a horizontal standard.

Reflection Question What is an example of a vertical standard in your industry or another industry?

General Duty Clause If you think you found a loophole related to how OSHA issues citations for hazards, think again. The general duty clause is an umbrella statement requiring all employers to maintain safe working conditions for all employees, even if specific standards are not established. As a general regulation, the general duty clause enforces a responsibility for employers to provide safe working conditions. This is OSHA’s way of saying we want organizations, as well as safety professionals, to be proactive participants in the establishment of safety at the workplace. Without this effort from employers, unique hazards are likely to occur. As you read through the material in this course, continuously think about the advanced safety practices and their relationship with existing regulations and standards. The general duty clause serves the vital purpose of complementing those existing regulations and standards, especially for working conditions that my fall between commonly recognized regulations and standards. Safety professionals, employees, and employers should be safe in all working conditions, not just the ones enforced by law, and the general duty clause embraces that idea. Categories of Penalties When an OSHA compliance officer visits an organization, there is a tendency for that role to think about five categories of penalties (Yates, 2015). By examining these categories, you have the opportunity to establish a safety program with items in place to accommodate OSHA visitations. With such a program, the visitations are likely to go smoothly and OSHA compliance officers are likely to recognize significant effort toward safety. The following list contains these six categories of penalties:

1. Other-than-serious violation—hazardous instance that is likely to cause less than serious harm. 2. Serious violation—hazardous instance likely leading to serious injuries or death. 3. Willful violation—hazardous instance occurring and the employer acknowledges its existence.

Horizontal Standards

Vertical Standards

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4. Repeated violation—after two or more inspections, the hazardous instance still exists. 5. Failure to abate violation—after an inspection, the hazardous instance exists longer than the

timeframe provided to resolve it. 6. Potential other penalties—any other hazardous instance that does not belong in the other four

categories. OSHA 300 Log What is the OSHA 300 Log? Yates (2015) refers to it within a section of his book titled Record Keeping, and it summarizes the purpose of those documents well. Regulations require organizations to record and archive all occupational hazards and illnesses on forms provided by the government: OSHA 300 form, OSHA 300-A form, and OSHA 301 form. The following list is three of the most important items to know about the OSHA 300 Log:

1. Seven days—how soon to record an incident. 2. Privacy incidents—how to facilitate the details of private information. 3. Annual summary—each year, an annual report should be posted by an organization.

The Advanced Practice of Record Keeping—Reports OSHA requires most employers to maintain records such as the previously mentioned OSHA 300 Log, and those records are very important. This course does not cover the required sense of record keeping in great detail. Instead, record keeping is briefly introduced as a launch pad allowing you to expand upon what is required. And, that is what advanced safety professionals do—take their responsibilities, including record keeping, to the next level. In this course, you are asked to complete a comprehensive report and the report should include important details, such as why an inspection or investigation was requested, the results from the inspection, and the recommendations for proceeding. These inspections are performed by you, the safety professional, and the goal is to keep everyone safe in the immediate future, as well as distant future. The future has a tendency to present unexpected events and challenges, and that is exactly why record keeping is so important for a safety professional. Whether you are serving as a consultant, a contracted worker, or a full-time safety manager, it is always important to include all of the details about an inspection or an incident. With more details in a report, you can provide better service to organizations, including their workers, by keeping them safe from past and future incidents. The details in a report should support your recommendations, so if anyone ever decided to read your report months or even years later, they have an opportunity to interpret a clear connection between the data you gathered and the recommendations you reported. So, as you compose the details of each report for the Comprehensive Report, hold yourself accountable to maintain your own professionalism and to provide safe working conditions for your friends and neighbors. Math Review and Calculations The remainder of this course asks you to practice the act of calculating data to make informed decisions as safety professionals. So, now is a good time to skim through “Chapter 3: Math Review” in the textbook by Yates (2015). By enrolling into this course, it is recommended that you are already familiar with these skills. Take at least one or two hours to review these math skills; by doing so, you will avoid falling behind in the rest of the coursework. There is also a Self-Assessment Activity (Non-Graded) for you to complete as part of the math review. Look for it in the section of the study guide labeled “Learning Activities (Non-Graded).”

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In a previous class, you were introduced to some basic statistical concepts to include normal distributions, measures of central tendency, and measures of dispersion. You may recall discussing the bell curve; determining the median, mode, and mean of a group of numbers; and calculating the standard deviation. Given that incident rates are themselves related to measures of central tendency (reflecting the number of injuries and illnesses in a year for 100 workers), this course unit will build on the concepts presented in the paragraph above and will introduce two tools for comparing samples of a given population. These two tools are the student t-test and the chi-square analysis. The t-test is what is known as a comparison of means test. It is a basic statistical test for determining if one can be confident in saying two samples (typically smaller samples) are the same or different from each other based on a given parameter (such as height, for instance). A question one might ask is whether or not the samples belong to the same population or different populations. For instance, imagine that you have taken a measurement of height from a sample of randomly selected adult male individuals who live in Georgia and compare it to a sample of individuals who live in Alabama and find that the average height of the former is 5’9” compared to 5’8 ¾” for the latter. Would you feel confident that the difference is big enough to argue that there is a distinct difference, or would you figure that the difference was due to random chance reflected in the samples you selected? Most likely you would choose the latter, but what if one group was 5’2” and the other was 5’9”? In this case, you would probably think that this is not random or that something is up! A t-test can help you to make a case for this. Typically, you would use a two-sample t-test for this example. Alternatively, you may want to compare the Alabama sample to the known average height of all adult males. In this instance, you would only need to collect the Alabama sample to compare against the known mean average. For this you would use a single sample t-test. You will be asked to calculate a single-sample t- statistic in your assessment for this unit. A different test known as the chi-square test can be very helpful, too—except that, instead of comparing means, it comes in handy when you are looking at something like the incidence or percentage of an occurrence in one group compared to what you would expect based on the larger population. For instance, is the incidence of occupational fatalities in businesses from a specific industry in Texas statistically different from what would be expected based on national occupational rates for that industry as a whole? Note that in this case we are comparing proportions or frequencies of occurrence with what would be expected rather than a measured value such as height. Statistics are helpful in that they can apply the principles of probability to the situation and generate a value that one can use to determine the degree of confidence one has in making a call when comparing two groups. One can typically get to a point where an assertion can be made such as “I am 95% confident that the differences between the samples did not occur by random chance alone.” Statistical tests like the t-test and the chi-square test help people to make assertions such as this and test their assertions through the process known as hypothesis testing. Of course, there are a lot more tools available for conducting statistical tests than just the t-test and the chi- square test mentioned here. You will have an opportunity to review several in your readings. Also, if you have the inclination, there are a plethora of tutorials available on YouTube and other sources such as Khan Academy that can help a person understand the fundamentals of making statistical comparisons and statistical calculations and how to do the math. Go to YouTube, for instance, and type in something like “chi square tutorial” or “single-sample t-test tutorial” as a search term, and you will find more than a few tutorials to choose from. Also, please note that a basic statistics book is available in our library that can help you out as well and is identified as a suggested reading in your syllabus. Finally, please review this short tutorial on interpreting statistical test results.

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Reference Yates, W. D. (2015). Safety professional’s reference and study guide (2nd ed.). Boca Raton, FL: CRC Press.

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. Click here to access a PDF of the Math Review Self-Assessment Learning Activity.