OSHA VIII

OSH 2301, Introduction to Workplace Safety 1

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

1. Describe safety-related roles and responsibilities of employees.

2. Identify occupational hazards commonly encountered in industry 2.1 Recognize fire hazards in the workplace.

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

3.1 Describe how leading and lagging indicators are applied in risk management.

4. Discuss safety and health management systems approaches for controlling workplace hazards.

5. Apply adult learning strategies to workplace safety and health training. Required Unit Resources Chapter 17: Fire Safety Chapter 18: Construction Safety In order to access the following resource, click the link below. Occupational Safety and Health Administration. (2016). The use of metrics in process safety management

(PSM) facilities (OSHA Fact Sheet No. DOC FS-3896). U.S. Department of Labor. http://www.osha.gov/sites/default/files/publications/OSHA3896.pdf

Unit Lesson So far, this course has described how a safety management system can be implemented in an organization to reduce health and safety risks.

• Unit I discussed the safety-related roles and responsibilities of individuals working in an organization. Specifically, the role of the safety professional was reviewed, outlining how his or her actions can be critical in getting management’s commitment to safety as well as ensuring that employees are involved.

• Unit II examined hazards commonly encountered in industry including health, chemical, physical, ergonomic, and biological. The Occupational Safety and Health Administration’s (OSHA) requirements for written plans were assessed for specific hazards.

• Unit III went on to describe how conducting a job hazard analysis (JHA) is used to identify hazards in different job scenarios.

• Unit IV introduced the concept of the hierarchy of controls, articulating how they can be applied to control hazards that are identified during the JHA.

• Unit V introduced the process of risk assessment, relating it to the hierarchy of controls by explaining how the controls are used to achieve a desired level of risk reduction.

• Unit VI summarized adult learning strategies, examining how they can be applied to workplace safety and health training. It highlighted how training is a critical component of communicating hazards and their controls to the employees who work with them daily.

UNIT VIII STUDY GUIDE Strategies for Managing Risk

OSH 2301, Introduction to Workplace Safety 2

UNIT x STUDY GUIDE Title

• Unit VII tied the first six units together under the framework of a safety management system. It summarized the key elements of a safety management system and considered how the approach can be used in conjunction with efforts focused on safety behaviors.

• Now, in Unit VIII, we will close the course by looking at risk management techniques. When developing a risk management strategy, the focus should be on reducing the risk of having incidents occur. This would include efforts to reduce the possibility of experiencing the same types of incidents repeatedly by mitigating known risks that cause those incidents, while also identifying previously unknown risks and putting controls in place to mitigate or prevent them before they can occur. An organization can obtain a better understanding of known risks by examining lagging indicators, while unknown risks can be identified by reviewing leading indicators. This unit will describe how leading and lagging indicators are applied in risk management. It will also explain how risk management techniques can be used to reduce workplace safety and health risks. OSHA (2016) defines lagging indicators as a “retrospective set of metrics” (p. 1) or the “rear-view mirror” (p. 2) because they result from a look at what has already happened. The following are examples of where to find lagging indicators:

• experience modification rate (EMR), • injury reports, • employee reported near misses, and • injury rates (Martin & Corcoran, 2018; OSHA, 2016).

As mentioned, these indicators provide information concerning what has already occurred. They can be used in combination with other metrics to assess safety performance and then used to determine the organization’s level of risk. For example, organizations can use injury and illness rates, including total recordable incidence rate (TRIR) and days of restricted work activity or job transfer (DART), to compare themselves to similar organizations in the same industry. If they are performing poorly in comparison to equivalent organizations, risk management techniques would need to be applied. Incident reports such as those being described can be used as the starting point for the application of risk management techniques. As explained in Unit I, injuries and illnesses must be documented with a report on OSHA’s Form 301. This is only the minimum requirement, though, so organizations that are committed to effective risk management should conduct a thorough root cause investigation to define the causal factor for any incident. While root cause investigations can initially be used to implement immediate controls, they can also be useful in identifying recurring issues that point to a deficiency in the safety management system. Past regulatory performance is another lagging indicator that can be used to identify recurring issues. If your organization is cited for the same issues repeatedly, it is likely that a system deficiency exists that must be addressed. Identifying and correcting these internal system deficiencies will result in a reduced risk for the organization. However, while it is important to correct these internal management deficiencies, organizations must also mitigate external risks. A source of external risk that most organizations are required to address is having outside contractors working on their site.

OSH 2301, Introduction to Workplace Safety 3

UNIT x STUDY GUIDE Title

Contractors bring outside employees onto the site, which introduces new hazards to the organization. Before these contractors are permitted into an organization, they should go through a pre-qualification process that should include a review of their safety performance as part of risk management (Martin & Corcoran, 2018). Lagging indicators can be used to assess the contractors’ safety performance by comparing them to their competitors in the same manner as cost or relevant qualifications. As already discussed, TRIR and DART are useful in assessing past safety performance in terms of OSHA recordable injuries. Another metric that is commonly used when assessing a contractor’s safety performance is experience modification rate (EMR); this entails all workers’ compensation history, not only those incidents that met the OSHA recordable requirements (Martin & Corcoran, 2018). EMR can provide a total picture of all injuries that the contractor has experienced; this includes the severity of these injuries since it considers the cost of the injury. EMRs use the workers’ compensation data to produce a numerical score, which indicates the contractor’s level of risk, as shown in the image on the right:

• score less than 1 means the company is less risky than average,

• score of 1 means the company is no more and no less risky than average, and

• score greater than 1 means the company is riskier than average (Martin & Corcoran, 2018).

Hiring contractors who accept less risk than the average in their industry will reduce the level of risk presented to the hosting organization by the contractors brought on- site. Overall, these lagging indicators should be used as a guide to assess the effectiveness of current risk management techniques. This, in turn, will determine if additional efforts are required. OSHA (2016) defines leading indicators as a “preventative set of metrics” (p. 1) or “the road ahead” (p. 2) because they assess processes and procedures that are in place to prevent incidents. Examples of leading indicators found in the workplace include the following. Each type will be briefly explained in the list below:

• written safety programs and audit programs, • hazard identification and reporting programs, • standard operating procedures (SOPs) that include safety requirements, • completed JHAs, • training records and requirements, • mechanical integrity programs, • preventative maintenance procedures, • process hazard analysis (PHA) requirements, and • management of change (MoC) procedures (Martin & Corcoran, 2018; OSHA, 2016).

Written safety programs and audit programs are focused on reducing the risk of incidents. An organization’s written safety programs demonstrate where they desire to be in terms of safety. Are they written with a focus only on compliance with federal, state, and local requirements, or do they strive to go above and beyond by implementing best practices? These standards set the level of expectation for employees. Hazard identification and reporting programs demonstrate that the organization has a proactive mindset and encourages employee involvement in the organization’s safety program. Employees who are involved and have a program for identifying and reporting hazards are likely to have a focus on safety. SOPs with integrated safety requirements demonstrate that an organization is focused on standardizing employee actions while taking steps to reduce risks by making safety a part of the employee’s work. This has employees viewing safety as a part of their jobs, not something that is in addition to their jobs.

(Adapted from Martin & Corcoran, 2018)

OSH 2301, Introduction to Workplace Safety 4

UNIT x STUDY GUIDE Title

Completed JHAs demonstrate that the organization is focused on systematically identifying and mitigating risks. Through the application of JHA findings, employees will be exposed to a lower level of risk while on the job. Training records and requirements demonstrate that the organization’s management is committed to improving the employee’s skills and knowledge by committing the resources to provide training. Well-trained employees will have the skills and abilities that will enable them to work safely. Mechanical integrity programs and preventative maintenance procedures demonstrate that the organization is committed to consistent and efficient operation by ensuring that equipment is in good operating condition, which will result in a reduction of equipment issues. Minimizing equipment issues reduces equipment downtime and emergencies during which employees can be exposed to unnecessary risks due to rushing and frustration. PHA requirements and MoC processes demonstrate the organization’s focus on preemptively identifying risks so that they can be addressed before they are realized and incidents occur. MoC procedures focus on bringing a cross-functional team together to review changes to the organization to identify and mitigate risks to each aspect of the organization, such as safety, quality, environmental, efficiency, and so on. The application of leading indicators as part of an overall risk management program can be seen in fire safety programs. Fire safety programs must include aggressive risk management techniques because of the potential for significant loss. Organizations can prepare written safety plans that go beyond OSHA requirements, implementing best practices developed by the National Fire Protection Association (NFPA). An effective risk management technique is the development of fire safety plans that exceed OSHA requirements.

(Pedneault, 2006)

(Gilfan, 2011) Fire safety programs, which must include aggressive risk management techniques due to the potential for significant loss, often apply leading indicators as part of an overall risk management program.

OSH 2301, Introduction to Workplace Safety 5

UNIT x STUDY GUIDE Title

Self-inspection programs can be established that require employees to routinely assess the organization’s facility for fire hazards. SOPs can be implemented that require all electrical work to be completed by certified electricians who are trained on the National Electric Code (NEC) and the Standard for Electrical Safety in the Workplace, NFPA 70E. This will reduce the risk of electrical fires. Mechanical integrity testing programs and preventative maintenance schedules can be developed to ensure that all equipment remains in compliance with NEC requirements. PHA and MoC procedures can be established to ensure that unexpected changes are not made to the facility that would introduce uncontrolled fire risks. This combined effort of risk management techniques will result in a risk management program that will reduce risk to the employees, the facility, and the organization. Risk management is a critical component of any plan intended to ensure continuous safety improvement in an organization. A successful risk management program requires a combination of rearview mirror self-assessment using lagging indicators in addition to a forward-thinking focus on leading indicators.

References

Dowley, P. (2009, June 20). Electrical safety (3977595441) [Photograph]. Wikimedia Commons.

https://commons.wikimedia.org/wiki/File:Electrical_Safety_(3977595441).jpg Gilfan. (2011, May 2). Fire and safety plan [Photograph]. Wikimedia Commons.

https://commons.wikimedia.org/wiki/File:Fire_and_Safety_Plan.jpg Martin, L. F., & Corcoran, D. (2018). Supervisors’ safety manual (11th ed.). National Safety Council. Occupational Safety and Health Administration. (2016). The use of metrics in process safety management

(PSM) facilities (OSHA Fact Sheet No. DOC FS-3896). U.S. Department of Labor. https://www.osha.gov/Publications/OSHA3896.pdf

Pedneault, S. (2006, October 27). Fire inside an abandoned convent in Massueville, Quebec, Canada

[Photograph]. Wikimedia Commons. https://commons.wikimedia.org/wiki/File:Fire_inside_an_abandoned_convent_in_Massueville,_Quebe c,_Canada.jpg

Suggested Unit Resources This unit’s content addresses the concept of risk management techniques for workplace safety and health risks. It focuses on managing risks during normal operations. However, emergency scenarios can present unique risks for an organization. It is recommended that you read Chapter 19: Emergency Management in the textbook and learn more about what can happen during emergencies as well as what can be done to possibly prevent them. The topics addressed include the following:

• prevention, mitigation, preparedness, continuity, response, and recovery; • OSHA Emergency Plan Requirements and FEMA’s Core Capabilities; and • Incident Command System Training.

Effective risk management for fire safety must include all aspects, including electrical risks. (Dowley, 2009)

OSH 2301, Introduction to Workplace Safety 6

UNIT x STUDY GUIDE Title

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 how you, or your current or former employer (if you have not worked as a safety professional), have used leading and/or lagging indicators to manage risk in your organization. Describe the indicators used. Explain if you believe they were or were not successful, and why.

OSH 2301, Introduction to Workplace Safety 1

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

1. Describe safety-related roles and responsibilities of employees.

2. Identify occupational hazards commonly encountered in industry 2.1 Recognize fire hazards in the workplace.

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

3.1 Describe how leading and lagging indicators are applied in risk management.

4. Discuss safety and health management systems approaches for controlling workplace hazards.

5. Apply adult learning strategies to workplace safety and health training. Required Unit Resources Chapter 17: Fire Safety Chapter 18: Construction Safety In order to access the following resource, click the link below. Occupational Safety and Health Administration. (2016). The use of metrics in process safety management

(PSM) facilities (OSHA Fact Sheet No. DOC FS-3896). U.S. Department of Labor. http://www.osha.gov/sites/default/files/publications/OSHA3896.pdf

Unit Lesson So far, this course has described how a safety management system can be implemented in an organization to reduce health and safety risks.

• Unit I discussed the safety-related roles and responsibilities of individuals working in an organization. Specifically, the role of the safety professional was reviewed, outlining how his or her actions can be critical in getting management’s commitment to safety as well as ensuring that employees are involved.

• Unit II examined hazards commonly encountered in industry including health, chemical, physical, ergonomic, and biological. The Occupational Safety and Health Administration’s (OSHA) requirements for written plans were assessed for specific hazards.

• Unit III went on to describe how conducting a job hazard analysis (JHA) is used to identify hazards in different job scenarios.

• Unit IV introduced the concept of the hierarchy of controls, articulating how they can be applied to control hazards that are identified during the JHA.

• Unit V introduced the process of risk assessment, relating it to the hierarchy of controls by explaining how the controls are used to achieve a desired level of risk reduction.

• Unit VI summarized adult learning strategies, examining how they can be applied to workplace safety and health training. It highlighted how training is a critical component of communicating hazards and their controls to the employees who work with them daily.

UNIT VIII STUDY GUIDE Strategies for Managing Risk

OSH 2301, Introduction to Workplace Safety 2

UNIT x STUDY GUIDE Title

• Unit VII tied the first six units together under the framework of a safety management system. It summarized the key elements of a safety management system and considered how the approach can be used in conjunction with efforts focused on safety behaviors.

• Now, in Unit VIII, we will close the course by looking at risk management techniques. When developing a risk management strategy, the focus should be on reducing the risk of having incidents occur. This would include efforts to reduce the possibility of experiencing the same types of incidents repeatedly by mitigating known risks that cause those incidents, while also identifying previously unknown risks and putting controls in place to mitigate or prevent them before they can occur. An organization can obtain a better understanding of known risks by examining lagging indicators, while unknown risks can be identified by reviewing leading indicators. This unit will describe how leading and lagging indicators are applied in risk management. It will also explain how risk management techniques can be used to reduce workplace safety and health risks. OSHA (2016) defines lagging indicators as a “retrospective set of metrics” (p. 1) or the “rear-view mirror” (p. 2) because they result from a look at what has already happened. The following are examples of where to find lagging indicators:

• experience modification rate (EMR), • injury reports, • employee reported near misses, and • injury rates (Martin & Corcoran, 2018; OSHA, 2016).

As mentioned, these indicators provide information concerning what has already occurred. They can be used in combination with other metrics to assess safety performance and then used to determine the organization’s level of risk. For example, organizations can use injury and illness rates, including total recordable incidence rate (TRIR) and days of restricted work activity or job transfer (DART), to compare themselves to similar organizations in the same industry. If they are performing poorly in comparison to equivalent organizations, risk management techniques would need to be applied. Incident reports such as those being described can be used as the starting point for the application of risk management techniques. As explained in Unit I, injuries and illnesses must be documented with a report on OSHA’s Form 301. This is only the minimum requirement, though, so organizations that are committed to effective risk management should conduct a thorough root cause investigation to define the causal factor for any incident. While root cause investigations can initially be used to implement immediate controls, they can also be useful in identifying recurring issues that point to a deficiency in the safety management system. Past regulatory performance is another lagging indicator that can be used to identify recurring issues. If your organization is cited for the same issues repeatedly, it is likely that a system deficiency exists that must be addressed. Identifying and correcting these internal system deficiencies will result in a reduced risk for the organization. However, while it is important to correct these internal management deficiencies, organizations must also mitigate external risks. A source of external risk that most organizations are required to address is having outside contractors working on their site.

OSH 2301, Introduction to Workplace Safety 3

UNIT x STUDY GUIDE Title

Contractors bring outside employees onto the site, which introduces new hazards to the organization. Before these contractors are permitted into an organization, they should go through a pre-qualification process that should include a review of their safety performance as part of risk management (Martin & Corcoran, 2018). Lagging indicators can be used to assess the contractors’ safety performance by comparing them to their competitors in the same manner as cost or relevant qualifications. As already discussed, TRIR and DART are useful in assessing past safety performance in terms of OSHA recordable injuries. Another metric that is commonly used when assessing a contractor’s safety performance is experience modification rate (EMR); this entails all workers’ compensation history, not only those incidents that met the OSHA recordable requirements (Martin & Corcoran, 2018). EMR can provide a total picture of all injuries that the contractor has experienced; this includes the severity of these injuries since it considers the cost of the injury. EMRs use the workers’ compensation data to produce a numerical score, which indicates the contractor’s level of risk, as shown in the image on the right:

• score less than 1 means the company is less risky than average,

• score of 1 means the company is no more and no less risky than average, and

• score greater than 1 means the company is riskier than average (Martin & Corcoran, 2018).

Hiring contractors who accept less risk than the average in their industry will reduce the level of risk presented to the hosting organization by the contractors brought on- site. Overall, these lagging indicators should be used as a guide to assess the effectiveness of current risk management techniques. This, in turn, will determine if additional efforts are required. OSHA (2016) defines leading indicators as a “preventative set of metrics” (p. 1) or “the road ahead” (p. 2) because they assess processes and procedures that are in place to prevent incidents. Examples of leading indicators found in the workplace include the following. Each type will be briefly explained in the list below:

• written safety programs and audit programs, • hazard identification and reporting programs, • standard operating procedures (SOPs) that include safety requirements, • completed JHAs, • training records and requirements, • mechanical integrity programs, • preventative maintenance procedures, • process hazard analysis (PHA) requirements, and • management of change (MoC) procedures (Martin & Corcoran, 2018; OSHA, 2016).

Written safety programs and audit programs are focused on reducing the risk of incidents. An organization’s written safety programs demonstrate where they desire to be in terms of safety. Are they written with a focus only on compliance with federal, state, and local requirements, or do they strive to go above and beyond by implementing best practices? These standards set the level of expectation for employees. Hazard identification and reporting programs demonstrate that the organization has a proactive mindset and encourages employee involvement in the organization’s safety program. Employees who are involved and have a program for identifying and reporting hazards are likely to have a focus on safety. SOPs with integrated safety requirements demonstrate that an organization is focused on standardizing employee actions while taking steps to reduce risks by making safety a part of the employee’s work. This has employees viewing safety as a part of their jobs, not something that is in addition to their jobs.

(Adapted from Martin & Corcoran, 2018)

OSH 2301, Introduction to Workplace Safety 4

UNIT x STUDY GUIDE Title

Completed JHAs demonstrate that the organization is focused on systematically identifying and mitigating risks. Through the application of JHA findings, employees will be exposed to a lower level of risk while on the job. Training records and requirements demonstrate that the organization’s management is committed to improving the employee’s skills and knowledge by committing the resources to provide training. Well-trained employees will have the skills and abilities that will enable them to work safely. Mechanical integrity programs and preventative maintenance procedures demonstrate that the organization is committed to consistent and efficient operation by ensuring that equipment is in good operating condition, which will result in a reduction of equipment issues. Minimizing equipment issues reduces equipment downtime and emergencies during which employees can be exposed to unnecessary risks due to rushing and frustration. PHA requirements and MoC processes demonstrate the organization’s focus on preemptively identifying risks so that they can be addressed before they are realized and incidents occur. MoC procedures focus on bringing a cross-functional team together to review changes to the organization to identify and mitigate risks to each aspect of the organization, such as safety, quality, environmental, efficiency, and so on. The application of leading indicators as part of an overall risk management program can be seen in fire safety programs. Fire safety programs must include aggressive risk management techniques because of the potential for significant loss. Organizations can prepare written safety plans that go beyond OSHA requirements, implementing best practices developed by the National Fire Protection Association (NFPA). An effective risk management technique is the development of fire safety plans that exceed OSHA requirements.

(Pedneault, 2006)

(Gilfan, 2011) Fire safety programs, which must include aggressive risk management techniques due to the potential for significant loss, often apply leading indicators as part of an overall risk management program.

OSH 2301, Introduction to Workplace Safety 5

UNIT x STUDY GUIDE Title

Self-inspection programs can be established that require employees to routinely assess the organization’s facility for fire hazards. SOPs can be implemented that require all electrical work to be completed by certified electricians who are trained on the National Electric Code (NEC) and the Standard for Electrical Safety in the Workplace, NFPA 70E. This will reduce the risk of electrical fires. Mechanical integrity testing programs and preventative maintenance schedules can be developed to ensure that all equipment remains in compliance with NEC requirements. PHA and MoC procedures can be established to ensure that unexpected changes are not made to the facility that would introduce uncontrolled fire risks. This combined effort of risk management techniques will result in a risk management program that will reduce risk to the employees, the facility, and the organization. Risk management is a critical component of any plan intended to ensure continuous safety improvement in an organization. A successful risk management program requires a combination of rearview mirror self-assessment using lagging indicators in addition to a forward-thinking focus on leading indicators.

References

Dowley, P. (2009, June 20). Electrical safety (3977595441) [Photograph]. Wikimedia Commons.

https://commons.wikimedia.org/wiki/File:Electrical_Safety_(3977595441).jpg Gilfan. (2011, May 2). Fire and safety plan [Photograph]. Wikimedia Commons.

https://commons.wikimedia.org/wiki/File:Fire_and_Safety_Plan.jpg Martin, L. F., & Corcoran, D. (2018). Supervisors’ safety manual (11th ed.). National Safety Council. Occupational Safety and Health Administration. (2016). The use of metrics in process safety management

(PSM) facilities (OSHA Fact Sheet No. DOC FS-3896). U.S. Department of Labor. https://www.osha.gov/Publications/OSHA3896.pdf

Pedneault, S. (2006, October 27). Fire inside an abandoned convent in Massueville, Quebec, Canada

[Photograph]. Wikimedia Commons. https://commons.wikimedia.org/wiki/File:Fire_inside_an_abandoned_convent_in_Massueville,_Quebe c,_Canada.jpg

Suggested Unit Resources This unit’s content addresses the concept of risk management techniques for workplace safety and health risks. It focuses on managing risks during normal operations. However, emergency scenarios can present unique risks for an organization. It is recommended that you read Chapter 19: Emergency Management in the textbook and learn more about what can happen during emergencies as well as what can be done to possibly prevent them. The topics addressed include the following:

• prevention, mitigation, preparedness, continuity, response, and recovery; • OSHA Emergency Plan Requirements and FEMA’s Core Capabilities; and • Incident Command System Training.

Effective risk management for fire safety must include all aspects, including electrical risks. (Dowley, 2009)

OSH 2301, Introduction to Workplace Safety 6

UNIT x STUDY GUIDE Title

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 how you, or your current or former employer (if you have not worked as a safety professional), have used leading and/or lagging indicators to manage risk in your organization. Describe the indicators used. Explain if you believe they were or were not successful, and why.