OSHA VII

OSH 2301, Introduction to Workplace Safety 1

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

4. Discuss safety and health management systems approaches for controlling workplace hazards. 4.1 Describe how the safety management systems approach can be used in conjunction with

efforts focused on safe behaviors. 4.2 Identify the challenges to effective employee involvement in safety and health programs.

Required Unit Resources Chapter 3: Human Performance and Safety Culture, pp. 41–48, 71–74 Chapter 5: Employee Involvement In order to access the following resources, click the links below. Read pp. 109–110 of the following article. Meiling, J. H., Sandberg, M., & Johnsson, H. (2014). A study of a plan-do-check-act method used in less

industrialized activities: Two cases from industrialized housebuilding. Construction Management and Economics, 32(1/2), 109–125. https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direc t=true&db=bsu&AN=95004459&site=ehost-live&scope=site

Read pp. 3–8, 11–14, and 27–29 of the following report. Occupational Safety and Health Administration. (2016). Recommended practices for safety and health

programs (OSHA Report No. 3885). https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf

UNIT VII STUDY GUIDE Safety Management Systems

OSH 2301, Introduction to Workplace Safety 2

UNIT x STUDY GUIDE Title

Unit Lesson This course has covered several key elements for managing safety and health. Unit I covered the roles and responsibilities of the safety professional. In Units II and III, the concept of hazard identification was presented. Units IV and V discussed the various controls that can be put into place to reduce the risk of the identified hazards. Unit VI explained how to develop an effective program for training adult employees on those controls. In this unit, we will tie these elements together under the framework of a safety management system. Like any other critical aspect of business, safety must be managed. Numerous organizations have published frameworks for developing an effective safety management system. Several of these frameworks come in the form of consensus standards that organizations can choose to follow. These include the American National Standards Institute (ANSI) and American Society of Safety Professionals (ASSP) publication American National Standard for Occupational Health and Safety Management Systems Z-10, the British Standards Institution’s (BSI) Occupational Health and Safety System Standard OHSAS-18001, and the International Organization for Standardization’s Occupational Health and Safety Management Systems. Guidelines for implementing safety management systems have also been published. These include the National Safety Council’s Nine Elements of a Successful Safety & Health System and the Occupational Health and Safety Administration (OSHA) publications Safety and Health Program Management Guidelines and Recommended Practices for Safety and Health Programs. While these all differ in their levels of complexity and content, they all focus on similar elements:

• management commitment, • employee participation, • hazard identification and assessment, • hazard control, • safety and health training, and • commitment to continuous improvement.

These elements should sound familiar since they have all been covered to some extent in this course. Let’s look at each one in more detail and examine how they are all interrelated. In most—if not all—organizations, you will see posters, banners, or policy statements that reference a commitment to zero injuries, or posters and signs stating mottos and slogans such as “All employees will go home the same way they came to work.” Does that alone demonstrate management commitment to employee safety and health? No, it does not—it is only one component of it. While management’s commitment to safety and health must be clearly stated, it must also state that safety and health is as important as all other components of the business including quality, profit, production, and so on (OSHA, 2015). The statement must also include a commitment of resources to support health and safety improvements, noting that the highest levels of senior management will be responsible for safety and health performance. To back up the written statement, management must establish goals for which they will hold themselves accountable. These goals should be focused on specific actions, not general injury and illness performance (OSHA, 2015). The goal of zero injuries should be obvious; no member of management ever wants employees injured at work. However, what specific goals are management committed to achieving in order to reduce the risk of employees being exposed to workplace hazards? An example goal might state, “Encourage employees to report workplace hazards by ensuring that they are free from retaliation and by providing a system that will track the controls put into place to mitigate the risk of the reported hazards.” Goals such as this also demonstrate management’s commitment of resources to safety and health—another critical requirement. Finally, management must hold all levels of the organization accountable for achieving the goals that they have set. All employees must be made aware of their roles and responsibilities with a clear explanation of what is expected from them (OSHA, 2015). Both positive and constructive feedback must be given to ensure that employees are continually aware of whether their actions and behaviors align with the organization’s commitment to safety.

OSH 2301, Introduction to Workplace Safety 3

UNIT x STUDY GUIDE Title

Without management commitment, a safety management system is not possible. However, an effective safety management system cannot be implemented in a top-down approach—the employees must be involved. Employees must be engaged in all aspects of the system, from program development through its implementation and continuous improvement. If employees are involved in the program, they will take ownership of it and want it to succeed. Engaged employees are more likely to provide feedback that will provide insight concerning where the program should focus its efforts as part of its continuous improvement. They are also more likely to fully participate in the program’s initiatives, including hazard reporting, incident investigations, and training (OSHA, 2015). When a management team committed to reducing safety and health risks is combined with the support of an engaged workforce, hazards can be effectively identified and assessed. An important part of this is conducting quality investigations of incidents when they occur. This includes those incidents that result in an injury or illness as well as high-potential near misses or other conditions that identify a clear hazard (OSHA, 2015). Remember, an effective safety and health management system is concerned with more than injuries and illness alone; it strives to reduce the risk of their occurrence. It is vital that employees are engaged so that they report near misses and other unsafe conditions proactively, before they are found because of an injury or illness. The purpose and focus of these investigations cannot be to assign blame. If that happens, employee trust will be lost, and the workforce may become disengaged. In addition to being counterproductive, assigning blame will not remove the hazard. Incident investigations must focus on the possibility of root causes, plural, because there may be more than one (OSHA, 2015). Outside of incident investigations, other tools such as a job hazard analysis (JHA) can also be used to identify hazards. Once hazards are identified, controls must be put into place. This provides important feedback for the employees and demonstrates that the hazards they are reporting are indeed being addressed. If no action is taken, the employees will likely feel that their input is being ignored, causing them to lose interest and stop reporting hazards. As covered in Units IV and V, control strategies should be based on the hierarchy of controls. Employees must be involved in the application of these controls. Preference should be given to the higher level of controls of elimination, substitution, and engineering controls, which will have a greater impact in terms of risk reduction than the lower levels of controls—administrative controls and personal protective equipment (PPE). Management can demonstrate commitment to employee safety and health by supporting the higher levels of controls, even though these will generally cost more to apply and implement than the lower levels. This support, despite increased costs, demonstrates to the workforce that management’s commitment to the safety and health management system is more than just a written statement. Once hazards have been identified and appropriate controls have been put into place, this information must be communicated to employees. Health and safety training that increases hazard awareness and educates employees on the applicable controls is a critical component of an effective safety management system (OSHA, 2015). As discussed in Unit VI, a needs assessment must be completed so that focused objectives can be developed to meet the specific needs of the employees who require the training. In establishing a safety management system, all levels of the organization will have a need for some level of awareness training so that a consistent message is delivered. The objectives of this training should be clear:

• communicate the goals of the safety management system, • explain the safety and health policy for the organization, • reinforce management’s commitment to safety and health, • describe the importance of employee participation, • encourage the reporting of unsafe acts and conditions, and • define the roles and responsibilities of each level of the organization.

Once implemented, the organization is not finished with the design and development of the safety management system; it must enter a process of continuous improvement. According to Meiling et al., (2014),

OSH 2301, Introduction to Workplace Safety 4

UNIT x STUDY GUIDE Title

continuous improvement is a process of applying the Plan–Do–Check–Act (PDCA) cycle to make incremental enhancements to a process as the need for them becomes evident:

• Plan: plan an action to address a current deficiency. • Do: apply the action. • Check: evaluate how effective the action is at correcting the deficiency. • Act: respond to the evaluation and return to the planning stage if the action was not effective.

The PDCA cycle can be applied to ensure continuous improvement of a safety management system.

Do—This step involves turning these objectives into plans, polices, procedures, and workplace improvements.

Plan—Planning should focus on creating specific objectives that support the goal established under the safety management system.

Check—The results of these plans, polices, procedures, and improvements must be checked using key performance indicators (KPIs) that include both leading and lagging values.

Testing critical KPIs provides feedback during the Check step of the PDCA cycle. (Group of Diverse, 2018)

The PDCA cycle starts with planning to determine objectives and actions that support established goals of the safety management system being developed. (Reyes, 2018)

Plans, policies, procedures, and improvements outlined in the planning stage are implemented during the Do step of the PDCA cycle. (LaRochelle, 2017)

During the Act step of the PDCA cycle, actions are taken to fully implement policies, procedures, and workplace improvements that have proven effective. (Bruckner, 2018)

Visual depiction of the PDCA cycle outlines the steps in the Plan-Do-Check-Act process (Meiling et al., 2014, p. 110)

OSH 2301, Introduction to Workplace Safety 5

UNIT x STUDY GUIDE Title

Act—If the KPIs demonstrate that the objectives were met, the actions become standards, formalizing them in the organization. If the KPIs demonstrate that an objective was not met, the cycle reverts to the planning stage to make improvements on the action before trying it again. Unit VII brought together the concepts covered in the first six units of this course, tying them to the essential elements of a safety management system. The unit content demonstrates how the safety and health concepts covered in this course can be organized around the framework of a safety management system for implementation in any organization.

References Bruckner, E. (2018, April 17). Gate, fence, sign and sunlight [Photograph]. Unsplash.

https://unsplash.com/photos/o1jqBoyB9qY Group of diverse people having a business meeting [Photograph]. (2018). Rawpixel.

https://www.rawpixel.com/image/414143/group-diverse-people-having-business-meeting LaRochelle, M. (2017, October 8). Welding, welder, mask and burning [Photograph]. Unsplash.

https://unsplash.com/photos/c-vWdiICscA Meiling, J. H., Sandberg, M., & Johnsson, H. (2014). A study of a plan-do-check-act method used in less

industrialized activities: Two cases from industrialized housebuilding. Construction Management and Economics, 32(1/2), 109–125. https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direc t=true&db=bsu&AN=95004459&site=eds-live&scope=site

Occupational Safety and Health Administration. (2015). OSHA safety and health program management

guidelines: November 2015 draft for public comment. https://www.osha.gov/shpmguidelines/SHPM_guidelines.pdf

Reyes, A. (2018, July 12). Bulletin board with flow chart [Photograph]. Unsplash.

https://unsplash.com/photos/qWwpHwip31M

OSH 2301, Introduction to Workplace Safety 6

UNIT x STUDY GUIDE Title

Suggested Unit Resources In order to access the following resource, click the links below. Access the document listed below to learn about the components the Occupational Safety and Health Administration (OSHA) believes are important to safety management as well as implementation tools and resources. The information provided will be useful when establishing, implementing, maintaining, and improving safety and health programs. Occupational Safety and Health Administration. (2015). OSHA safety and health program management

guidelines: November 2015 draft for public comment. https://www.osha.gov/shpmguidelines/SHPM_guidelines.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. Think about safety measures put into place where you work or have worked in the past. Prepare a one-page essay that aligns these safety measures with the key elements of a safety management system. Provide specific examples; for example, fire extinguisher training would fit in the category of safety and health training. Briefly describe how each of the safety measures relates to and supports each of the others across the elements. If you cannot provide an example of a safety measure implemented at your workplace for any of the elements, describe how your workplace could implement a safety measure under that element. If you are not currently working, describe examples of safety measures that could be put into place under each element.

OSH 2301, Introduction to Workplace Safety 1

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

4. Discuss safety and health management systems approaches for controlling workplace hazards. 4.1 Describe how the safety management systems approach can be used in conjunction with

efforts focused on safe behaviors. 4.2 Identify the challenges to effective employee involvement in safety and health programs.

Required Unit Resources Chapter 3: Human Performance and Safety Culture, pp. 41–48, 71–74 Chapter 5: Employee Involvement In order to access the following resources, click the links below. Read pp. 109–110 of the following article. Meiling, J. H., Sandberg, M., & Johnsson, H. (2014). A study of a plan-do-check-act method used in less

industrialized activities: Two cases from industrialized housebuilding. Construction Management and Economics, 32(1/2), 109–125. https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direc t=true&db=bsu&AN=95004459&site=ehost-live&scope=site

Read pp. 3–8, 11–14, and 27–29 of the following report. Occupational Safety and Health Administration. (2016). Recommended practices for safety and health

programs (OSHA Report No. 3885). https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf

UNIT VII STUDY GUIDE Safety Management Systems

OSH 2301, Introduction to Workplace Safety 2

UNIT x STUDY GUIDE Title

Unit Lesson This course has covered several key elements for managing safety and health. Unit I covered the roles and responsibilities of the safety professional. In Units II and III, the concept of hazard identification was presented. Units IV and V discussed the various controls that can be put into place to reduce the risk of the identified hazards. Unit VI explained how to develop an effective program for training adult employees on those controls. In this unit, we will tie these elements together under the framework of a safety management system. Like any other critical aspect of business, safety must be managed. Numerous organizations have published frameworks for developing an effective safety management system. Several of these frameworks come in the form of consensus standards that organizations can choose to follow. These include the American National Standards Institute (ANSI) and American Society of Safety Professionals (ASSP) publication American National Standard for Occupational Health and Safety Management Systems Z-10, the British Standards Institution’s (BSI) Occupational Health and Safety System Standard OHSAS-18001, and the International Organization for Standardization’s Occupational Health and Safety Management Systems. Guidelines for implementing safety management systems have also been published. These include the National Safety Council’s Nine Elements of a Successful Safety & Health System and the Occupational Health and Safety Administration (OSHA) publications Safety and Health Program Management Guidelines and Recommended Practices for Safety and Health Programs. While these all differ in their levels of complexity and content, they all focus on similar elements:

• management commitment, • employee participation, • hazard identification and assessment, • hazard control, • safety and health training, and • commitment to continuous improvement.

These elements should sound familiar since they have all been covered to some extent in this course. Let’s look at each one in more detail and examine how they are all interrelated. In most—if not all—organizations, you will see posters, banners, or policy statements that reference a commitment to zero injuries, or posters and signs stating mottos and slogans such as “All employees will go home the same way they came to work.” Does that alone demonstrate management commitment to employee safety and health? No, it does not—it is only one component of it. While management’s commitment to safety and health must be clearly stated, it must also state that safety and health is as important as all other components of the business including quality, profit, production, and so on (OSHA, 2015). The statement must also include a commitment of resources to support health and safety improvements, noting that the highest levels of senior management will be responsible for safety and health performance. To back up the written statement, management must establish goals for which they will hold themselves accountable. These goals should be focused on specific actions, not general injury and illness performance (OSHA, 2015). The goal of zero injuries should be obvious; no member of management ever wants employees injured at work. However, what specific goals are management committed to achieving in order to reduce the risk of employees being exposed to workplace hazards? An example goal might state, “Encourage employees to report workplace hazards by ensuring that they are free from retaliation and by providing a system that will track the controls put into place to mitigate the risk of the reported hazards.” Goals such as this also demonstrate management’s commitment of resources to safety and health—another critical requirement. Finally, management must hold all levels of the organization accountable for achieving the goals that they have set. All employees must be made aware of their roles and responsibilities with a clear explanation of what is expected from them (OSHA, 2015). Both positive and constructive feedback must be given to ensure that employees are continually aware of whether their actions and behaviors align with the organization’s commitment to safety.

OSH 2301, Introduction to Workplace Safety 3

UNIT x STUDY GUIDE Title

Without management commitment, a safety management system is not possible. However, an effective safety management system cannot be implemented in a top-down approach—the employees must be involved. Employees must be engaged in all aspects of the system, from program development through its implementation and continuous improvement. If employees are involved in the program, they will take ownership of it and want it to succeed. Engaged employees are more likely to provide feedback that will provide insight concerning where the program should focus its efforts as part of its continuous improvement. They are also more likely to fully participate in the program’s initiatives, including hazard reporting, incident investigations, and training (OSHA, 2015). When a management team committed to reducing safety and health risks is combined with the support of an engaged workforce, hazards can be effectively identified and assessed. An important part of this is conducting quality investigations of incidents when they occur. This includes those incidents that result in an injury or illness as well as high-potential near misses or other conditions that identify a clear hazard (OSHA, 2015). Remember, an effective safety and health management system is concerned with more than injuries and illness alone; it strives to reduce the risk of their occurrence. It is vital that employees are engaged so that they report near misses and other unsafe conditions proactively, before they are found because of an injury or illness. The purpose and focus of these investigations cannot be to assign blame. If that happens, employee trust will be lost, and the workforce may become disengaged. In addition to being counterproductive, assigning blame will not remove the hazard. Incident investigations must focus on the possibility of root causes, plural, because there may be more than one (OSHA, 2015). Outside of incident investigations, other tools such as a job hazard analysis (JHA) can also be used to identify hazards. Once hazards are identified, controls must be put into place. This provides important feedback for the employees and demonstrates that the hazards they are reporting are indeed being addressed. If no action is taken, the employees will likely feel that their input is being ignored, causing them to lose interest and stop reporting hazards. As covered in Units IV and V, control strategies should be based on the hierarchy of controls. Employees must be involved in the application of these controls. Preference should be given to the higher level of controls of elimination, substitution, and engineering controls, which will have a greater impact in terms of risk reduction than the lower levels of controls—administrative controls and personal protective equipment (PPE). Management can demonstrate commitment to employee safety and health by supporting the higher levels of controls, even though these will generally cost more to apply and implement than the lower levels. This support, despite increased costs, demonstrates to the workforce that management’s commitment to the safety and health management system is more than just a written statement. Once hazards have been identified and appropriate controls have been put into place, this information must be communicated to employees. Health and safety training that increases hazard awareness and educates employees on the applicable controls is a critical component of an effective safety management system (OSHA, 2015). As discussed in Unit VI, a needs assessment must be completed so that focused objectives can be developed to meet the specific needs of the employees who require the training. In establishing a safety management system, all levels of the organization will have a need for some level of awareness training so that a consistent message is delivered. The objectives of this training should be clear:

• communicate the goals of the safety management system, • explain the safety and health policy for the organization, • reinforce management’s commitment to safety and health, • describe the importance of employee participation, • encourage the reporting of unsafe acts and conditions, and • define the roles and responsibilities of each level of the organization.

Once implemented, the organization is not finished with the design and development of the safety management system; it must enter a process of continuous improvement. According to Meiling et al., (2014),

OSH 2301, Introduction to Workplace Safety 4

UNIT x STUDY GUIDE Title

continuous improvement is a process of applying the Plan–Do–Check–Act (PDCA) cycle to make incremental enhancements to a process as the need for them becomes evident:

• Plan: plan an action to address a current deficiency. • Do: apply the action. • Check: evaluate how effective the action is at correcting the deficiency. • Act: respond to the evaluation and return to the planning stage if the action was not effective.

The PDCA cycle can be applied to ensure continuous improvement of a safety management system.

Do—This step involves turning these objectives into plans, polices, procedures, and workplace improvements.

Plan—Planning should focus on creating specific objectives that support the goal established under the safety management system.

Check—The results of these plans, polices, procedures, and improvements must be checked using key performance indicators (KPIs) that include both leading and lagging values.

Testing critical KPIs provides feedback during the Check step of the PDCA cycle. (Group of Diverse, 2018)

The PDCA cycle starts with planning to determine objectives and actions that support established goals of the safety management system being developed. (Reyes, 2018)

Plans, policies, procedures, and improvements outlined in the planning stage are implemented during the Do step of the PDCA cycle. (LaRochelle, 2017)

During the Act step of the PDCA cycle, actions are taken to fully implement policies, procedures, and workplace improvements that have proven effective. (Bruckner, 2018)

Visual depiction of the PDCA cycle outlines the steps in the Plan-Do-Check-Act process (Meiling et al., 2014, p. 110)

OSH 2301, Introduction to Workplace Safety 5

UNIT x STUDY GUIDE Title

Act—If the KPIs demonstrate that the objectives were met, the actions become standards, formalizing them in the organization. If the KPIs demonstrate that an objective was not met, the cycle reverts to the planning stage to make improvements on the action before trying it again. Unit VII brought together the concepts covered in the first six units of this course, tying them to the essential elements of a safety management system. The unit content demonstrates how the safety and health concepts covered in this course can be organized around the framework of a safety management system for implementation in any organization.

References Bruckner, E. (2018, April 17). Gate, fence, sign and sunlight [Photograph]. Unsplash.

https://unsplash.com/photos/o1jqBoyB9qY Group of diverse people having a business meeting [Photograph]. (2018). Rawpixel.

https://www.rawpixel.com/image/414143/group-diverse-people-having-business-meeting LaRochelle, M. (2017, October 8). Welding, welder, mask and burning [Photograph]. Unsplash.

https://unsplash.com/photos/c-vWdiICscA Meiling, J. H., Sandberg, M., & Johnsson, H. (2014). A study of a plan-do-check-act method used in less

industrialized activities: Two cases from industrialized housebuilding. Construction Management and Economics, 32(1/2), 109–125. https://libraryresources.columbiasouthern.edu/login?url=http://search.ebscohost.com/login.aspx?direc t=true&db=bsu&AN=95004459&site=eds-live&scope=site

Occupational Safety and Health Administration. (2015). OSHA safety and health program management

guidelines: November 2015 draft for public comment. https://www.osha.gov/shpmguidelines/SHPM_guidelines.pdf

Reyes, A. (2018, July 12). Bulletin board with flow chart [Photograph]. Unsplash.

https://unsplash.com/photos/qWwpHwip31M

OSH 2301, Introduction to Workplace Safety 6

UNIT x STUDY GUIDE Title

Suggested Unit Resources In order to access the following resource, click the links below. Access the document listed below to learn about the components the Occupational Safety and Health Administration (OSHA) believes are important to safety management as well as implementation tools and resources. The information provided will be useful when establishing, implementing, maintaining, and improving safety and health programs. Occupational Safety and Health Administration. (2015). OSHA safety and health program management

guidelines: November 2015 draft for public comment. https://www.osha.gov/shpmguidelines/SHPM_guidelines.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. Think about safety measures put into place where you work or have worked in the past. Prepare a one-page essay that aligns these safety measures with the key elements of a safety management system. Provide specific examples; for example, fire extinguisher training would fit in the category of safety and health training. Briefly describe how each of the safety measures relates to and supports each of the others across the elements. If you cannot provide an example of a safety measure implemented at your workplace for any of the elements, describe how your workplace could implement a safety measure under that element. If you are not currently working, describe examples of safety measures that could be put into place under each element.