Model Safety Program

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1 Model Safety Program DATE: SUBJECT: Standard Practice Instruction for Accident Investigation and Reporting REGULATORY STANDARD: OSHA 29 CFR 1904 RESPONSIBILITY: The company is. He/she is solely responsible for all facets of this program and has full authority to make necessary decisions to ensure success of the program. The is the sole person authorized to amend these instructions and is authorized to halt any operation of the company where there is danger of serious personal injury. CONTENTS Standard Practice Instruction for Accident Investigation 1. Written Program. 2. General Requirements. 3. Accident Investigation Team Composition. 4. Accident and Incident Reporting. 5. Accident Investigation. 6. Job Hazard Analysis Review. 7. Administrative Controls. 8. Medical Management. 9. Accident Trend Analysis. 10. Training and Education. 11. Behavior Modification and Attitude.

2 (YOUR COMPANY) Accident Investigation Program 1. Written program. (YOUR COMPANY) will review and evaluate this standard practice instruction on an annual basis, or when changes occur that prompt revision of this document, or when facility operational changes occur that require a revision of this document. Effective implementation requires a written program for job safety, health, that is endorsed and advocated by the highest level of management within this company and that outlines our goals and plans. This written program will be communicated to all required personnel. It encompasses the total workplace, regardless of number of workers employed or the number of work shifts. It is designed to establish clear goals, and objectives. DECISION POINT A company policy should be established that delineates who will perform accident investigation. The accident investigation should be used in conjunction with the job hazards analysis program. Examples of employees that could form an accident investigation team: 1. Safety Officer 2. Supervisors 3. Facility Engineer 4. Safety Committee 5. Employees with knowledge of accident causation, investigation procedures, and knowledge of the job being performed 6. Union Representative 7. Outside Accident Investigations Officer 8. Local Government 2. General requirements. (YOUR COMPANY) will establish accident investigation procedures, and improve operational procedures through the use of this document. Preventing future workplace injuries in our company is the principle purpose of accident investigation. This document will provide a basis for studying and recording the reasons an accident occurred, identifying existing or potential job hazards (both safety and health), and determining the best course of action to take to reduce or eliminate these hazards. 3. Accident investigation team composition. The accident investigation team will be composed of the following:s Title Accident Investigation Team

3 4. Accident and incident reporting. The (YOUR COMPANY) Hazard Report will be used by all employees to report potential or known hazards. The following procedures apply: 4.1 Person reporting hazard: Notify department supervisor of the hazard Accomplish lock out/tag out if required on the machine Fill out required sections of the hazard report Forward report immediately to the safety officer. 4.2 Supervisor: Notify all affected workers of hazard Notify maintenance of hazard, if required Ensure hazard is properly marked and controlled Contact Safety Officer if needed. 5. Accident Investigation. Accident investigation is primarily a fact finding procedure; the facts revealed are used to prevent recurrences of similar accidents. The focus of accident investigation will be to prevent future accidents and injuries to increase the safety and health of all our employees. 5.1 Immediate concerns Ensure any injured person receives proper care Ensure co workers and personnel working with similar equipment or in similar jobs are aware of the situation. This is to ensure that procedural problems or defects in certain models of equipment do not exist Start the investigation promptly. 5.2 Injury and Illness Incident Report. OSHA form 301 or a standardized investigation report form which details specific company requirements for investigation will be

4 developed and used to gather data to determine causes and corrective actions. As a minimum the form will contain the following areas of concern Accident investigation form data. Case Number Injured employee's name Date and time of injury Social Security Number Occupation or task being performed when injured Shift and department Company ID number Employee's address Sex/age/DOB Length of service Length of time at specific job Time shift started Overtime length when injury occurred Physician's and hospital name (if transported) Type of injury Resulting fatalities Description and analysis of accident Complete accident tree Action taken to prevent recurrence and person Employee's statement Witnesses' statement Employer's statement Person completing form and date Person(s) reviewing form and date 5.3 Reviewers. All accident investigation reports will be reviewed by a member of management responsible for the department/section involved to ensure pertinent information in transmitted to all concerned and remedial action(s) taken. Accident Investigation Review Team Title Accident Investigation Team Department Manager Safety Officer Union Committee representative

5 Engineer Supervisor of injured employee 5.4 Accident investigation final report. The final report will be numbered in the upper right hand corner, Page of Pages. The report will include but is not limited to the following Investigation report form and pertinent data Photographs/drawings/exhibits of scene Narrative of accident Sequence of events Contributing information Findings and recommendations of review team Action items and completion dates Responsible persons Follow up procedures to ensure completion Distribution list 6. Job Hazard Analysis. This employer will identify through the use of information sources and screening surveys, jobs that place employees at risk. After any accident or near miss the task or job in question will have a job hazard analyses routinely performed by a qualified person(s). This analysis will help to verify that all required actions are being taken to determine if risk factors for a work position have been reduced or eliminated to the maximum extent feasible. 6.1 The following personnel or job positions are qualified to perform job hazard analysis surveys for this company.

6 Personnel Qualified to Perform Job Hazard Analysis Name Title 6.2 Work Station Analysis. Work station analysis will be conducted to identify risk factors present in each job or workstation. 7. Administrative Controls. Once data has be gathered from the accident investigation report, company administrative controls will be used where needed to eliminate or reduce the frequency, and severity of accidents and near misses. Examples of administrative controls include the following: 7.1 Reducing the production rates and or line speeds where possible. 7.2 Providing rest pauses to relieve fatigued muscle tendon groups. 7.3 Increasing the number of employees assigned to a task to alleviate severe conditions, especially in lifting heavy objects. 7.4 Using job rotation, used with caution and as a preventive measure, not as a response to physical symptoms. The principle of job rotation is to alleviate physical fatigue and stress of a particular set of muscles and tendons by rotating employees among other jobs that use different muscle tendon groups. If rotation is utilized, the job analyses must be reviewed to ensure that the same muscle tendon groups are not used when they are rotated. 7.5 Providing sufficient numbers of standby/relief personnel to compensate for foreseeable upset conditions on the line (e.g., loss of workers). 7.6 Job enlargement. Having employees perform broader functions which reduce the stress on specific muscle groups while performing individual tasks. 7.7 Machine maintenance/guarding. Ensure regular maintenance is performed on machines/tools used by employees are properly guarded and that maintenance is routinely performed. 7.8 Employee training. Ensure all employees are properly trained in the hazards associated with the job before work is performed unsupervised.

7 DECISION POINT OSHA Recommendation Where health care providers are not employed full time, the part time employment of appropriately trained health care providers is recommended. 8. Medical Management. will manage the program. Employees of each work shift should have access to health care providers or designated alternates in order to facilitate treatment, surveillance activities, and recording of information. During accident investigation the medical management program will as a minimum address the following issues: 8.1 Injury and illness recordkeeping. 8.2 Early recognition of problems such as strains and muscle fatigue that could lead to accidents. 8.3 Systematic evaluation and referral. 8.4 Conservative treatment after an accident. 8.5 Conservative return to work after an accident. 8.6 Systematic monitoring. 8.7 Recordability criteria. The accident must be work related. Simply stated, unless the illness was caused solely by a non work related event or exposure off premises, the case is presumed to be work related. 8.8 Occupational injuries. Injuries are caused by instantaneous events in the work environment. To keep recordkeeping determinations as simple and equitable as possible, back cases are classified as injuries even though some back conditions may be triggered by an instantaneous event and others develop as a result of repeated trauma. Any occupational injury involving medical treatment, loss of consciousness, restriction of work or motion, or transfer to another job is to be recorded on the OSHA 300 form. 8.9 Periodic Workplace Walk throughs. Health care providers will conduct periodic, systematic workplace walk throughs on a monthly basis (OSHA recommended) to remain knowledgeable about operations and work practices, to identify potential light duty jobs, and to maintain close contact with employees. Health care providers also should be involved in identifying accident risk factors in the workplace as part of the accident investigation team. A record will be kept documenting the date of the walkthrough, area(s) visited, accident risk factors recognized, and action initiated to correct identified problems. Follow up will be initiated and documented to ensure corrective action is taken when indicated.

8 9. Accident trend analysis. 9.1 After an accident the accident investigation team will, where prudent, routinely review health care facility sign in logs, OSHA 300 forms, and individual employee medical records to monitor trends for accidents in our facilities. This analysis should be made to monitor trends and to substantiate the information obtained from the accident investigation. The analysis will be done by department, job title, work area, etc. 9.2 The information gathered will help to identify areas or jobs where potential accident or injury conditions could or do exist. This information may be shared with anyone in the company, since employees' personal identifiers are not solicited. The analysis of medical records (e.g., sign in logs and individual employee medical records) may reveal areas or jobs of concern, but it may also identify individual workers who require further follow up. The information gathered while analyzing medical records will be of a confidential nature; thus care must be exercised to protect the individual employee's privacy. 9.3 The information gained from the trend analysis will help determine the effectiveness of the various programs initiated to decrease accidents in our facility(s). 9.4 Employee survey. A survey may be used to provide a standardized measure of the extent of progress in reducing work related accidents for each area of the plant or facility, and to determine which jobs are exhibiting problems and to measure progress of the overall safety program Design of the survey. A survey of employees will be conducted to measure employee awareness of work related accident and to report the location, frequency, and type of accidents likely to occur Surveys normally will not include employees' personal identifiers, this is to encourage employee participation in the survey Frequency. Surveys will be conducted as a minimum on an annual basis or anytime deemed necessary by the accident investigation team. Conducting the survey annually should help detect any major change in the prevalence, incidence, and/or location of reported and unreported accidents. 9.5 Low risk jobs. This company will compile a list of light duty jobs. Jobs will be analyzed to determine the physical procedures used in the performance of each job, including lifting requirements, postures, hand grips, and frequency of repetitive motion and general safety requirements of the job. This information will assist health care providers in recommending assignments to light or restricted duty jobs. Supervisors should periodically review and update the lists.

9 Low Risk Job Listing Department Task/Job Date Evaluated 9.6 High risk jobs. This company will compile a list of high risk jobs. Jobs will be analyzed to determine the physical procedures used in the performance of each job, including lifting requirements, postures, hand grips, and frequency of repetitive motion and general safety requirements of the job. This information will assist health care providers in determining jobs from which assignments to light or restricted duty jobs may be necessary. Supervisors should periodically review and update the lists. High Risk Job Listing Department Task/Job Date Evaluated 10. Training and Education. The purpose of accident investigation training and education is to ensure that members of the accident investigation team and all of our employees are sufficiently informed about the accident investigation program Employees will be adequately trained about the (YOUR COMPANY)'s accident investigation program. Proper training will allow managers, supervisors, and employees to understand the procedures to follow to report an accident, hazards associated with a job or production process, their prevention and control, and their medical consequences Training program design. The program will be designed and implemented by. Appropriate special training will be provided for personnel responsible for administering the program.

10 10.3 Learning level. The program will be presented in language and at a level of understanding appropriate for the individuals being trained. It will provide an overview of the potential risk of illnesses and injuries, their causes and early symptoms, the means of prevention, and treatment Training for affected employees will consist of both general and specific job training: General Training. Employees will be given formal instruction on the hazards associated with their jobs and with their equipment. This will include information on the varieties of hazards associated with the job, what risk factors cause or contribute to them, how to recognize and report hazardous conditions, and how to prevent accident with their respective jobs. This instruction will be repeated for each employee as necessary. This training will be conducted on an annual basis. (OSHA's experience indicates that, at a minimum, annual retraining is advisable) Job Specific Training. New employees and reassigned workers will receive an initial orientation and hands on training prior to being placed in a fullproduction job. Each new hire will receive a demonstration of the proper use of and procedures for all tools and equipment prior to assignment 10.5 Training for Supervisors. Supervisors are responsible for ensuring that employees follow safe work practices and receive appropriate training to enable them to do this. Supervisors therefore will undergo training comparable to that of the employees, and such additional training as will enable them to recognize hazardous work practices, to correct such practices, accident reporting/investigation requirements, and to reinforce the ABC safety program Training for Managers. Managers will be made aware of their safety and health responsibilities and will receive sufficient training pertaining to issues at each work station and in the production process as a whole so that they can effectively carry out their responsibilities Training for Engineers and Maintenance Personnel. Plant engineers and maintenance personnel will be trained in the prevention and correction of job hazards through job and work station design and proper maintenance, both in general and as applied to the specific conditions of the facility Employee Training and Education. Company health care providers will participate in the training and education of all employees. This training will be reinforced during workplace walk throughs and the individual health surveillance appointments. All new employees will be given such education during orientation. This demonstration of concern and the distribution of information should facilitate an elimination or reduction

11 in, and early recognition of accident conditions prior to their development, and increase the likelihood of compliance with recognition, prevention and control. 11. Behavior Modification and Attitude External causative or contributing factors. Behavior and attitude are integral to the success of our accident investigation program. When accidents occur, the root cause or causes may not always be external to the individual involved. These external causes can include accidents within our facility(s) caused by: Improperly maintained or defective machinery, equipment, tools, etc Coworker behavior and attitudes Natural phenomenon such as lightening Multiple causative situations Lack of or improper safety training Operational or procedural inadequacies Internal causative or contributing factors. When it is determined that it is improbable that external factors were the principal cause(s) of an accident, behavior and attitude of the individual or group or will be reviewed Affecting attitudinal and behavioral change. An employees attitude affects his or her behavior. Improper behavior can sometimes result in an unsafe act. The unsafe act can sometimes result in injury. Positive and proper attitudes toward safety are the key to reducing unsafe acts and ultimately reducing injury rates. Creating an internal change in individuals who otherwise would perform an unsafe act is the ultimate goal when attempting attitudinal change. If an employee believes he or she has a safe attitude but his or her behavior isn t (or hasn t in the past) been consistent with this belief, the person will usually alter their behavior eventually to be consistent with their self perception. An attitudinal change will occur which causes a behavioral change Creating attitudinal and behavioral change. This company is committed to creating and maintaining a safe work environment. We will demonstrate our commitment by: Promptly conducting accident investigations to determine the cause(s) of accidents. Assigning responsibility for recommended corrective actions to appropriate personnel within this facility.

12 Provide supervisors with the necessary support needed to implement safety changes in their respective areas. Where required, conducting employee training and or retraining promptly following investigations. Providing feedback to employees affected by an accident. Initiating team building efforts. Fostering a work environment which promotes a belief in individual responsibility for safety. Conducting appropriate follow up reviews to assess if recommended safety changes are effective. Conducting employee surveys to solicit recommendations for safety improvements following an accident.

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