Workers Safety

Workers Safety

Table of Contents

Safety Reality Starting Points

Safety Has No Finish Line

Fundamentals And Safety Culture Framework

  1. Board Policy
  2. District Administration Accountability
  3. Senior Administration Commitment
  4. Safety Champion 
  5. Supervisors Commitment
  6. Employee Involvement
  7. Safety Steering Team 
  8. Standards, Activators And Consequences
  9. Communication
  10. Continuous Improvement Evaluation

Behavior-based Safety Elements

  1. Defining Critical Behaviors
  2. Metrics
  3. Recording Observations
  4. Data Mining
  5. Variations And Uses

Administrative And Engineering Controls

  1. Personnel Selection
  2. Hazard Identification
  3. Hazard Control
  4. Incident Analysis

Safety And Health Education And Training

Empowerment And Ongoing Engagement Practices

PESH Information And Compliance

NYS Safety, Loss Consultation And Incentive Programs

Topical References

Helpful Sources

Abbreviations And Glossary Of Terms

 
 
Safety Reality Starting Points

Unsafe behavior also affects the district’s financial bottom line. Whether it’s a minor cut requiring stitches or a broken back, if the injury happens at work, the district is  impacted.  Lost productivity is the most commonly cited indirect cost of systemic safety failure.  Poor safety performance makes it tougher for the district to satisfy all stakeholders.

In a highly reliable culture, effective principles and procedures based on scientific knowledge are deeply embedded in the minds of employees and they willingly embrace their role as “risk owners.”

Misconceptions about employee safety programs lead many districts to waste valuable time and money.  Scientific knowledge is universal and precise; common sense knowledge is vague and should not be counted on to produce consistent results. 

People frequently fall into the trap of believing certain myths related to injury prevention.   The following statements are examples of conventional wisdom that does not hold up under close review of research in behavioral science:

  • We always learn more from our mistakes than our successes.
  • We can never motivate others, only ourselves. 
  • There is always one best way to perform every job.
  • The best use of time is with the least productive employees.
  • Everyone likes to be publicly recognized.
  • Statistics are more powerful as a motivator than personal testimony.
  • Zero injuries should always be a safety goal.
  • Rewards for not having injuries reduce injuries.

Professionals in occupational safety have long recognized that theory, research and tools in psychology are extensive, complex and often overwhelming.   Countless self-help books and tapes address concepts seemingly relevant to injury prevention.  School administrators seldom receive clear guidance about particular approaches or strategies to use.  As a result, many succumb to proposals for programs that sound plausible and appeal to commonsense. Unfortunately, valid theory, principles and procedures founded upon solid research and evidence have not been given the attention they deserve. 

Board of Education policies, aligned with State/Federal regulations, establish the foundation of accountability necessary for the care of students and employees.   The well-being of every employee is directly linked to improving student achievement. Unsafe behaviors consistently lead to medical expense, disability payments, damaged property and diminished productivity. Effective employee health and safety should be a fundamental value of the school organization.

Safety Has No Finish Line

Generally, as people improve their risk intelligence skills they gain the confidence needed to overcome risk aversion on one hand and avoid excessive risk taking on the other hand.   Employees who have an appreciative mindset can help others understand the benefit of doing more of what works and devoting their energies toward positive, prudent activity.   Success in the classroom ultimately depends on effective workplace injury prevention at all levels and across the entire school enterprise.

Successful safety and health programs achieve and maintain safe, healthful workplaces. The key words are achieve and maintain. To achieve something, district leaders set a goal and work to accomplish it. Once a goal is accomplished, it takes additional work to maintain the new level of achievement. The district's health and safety program may have some strong elements and some that need improvement.  

Effective injury prevention preserves employee health, safety, smooth operations and student learning.   Success of the school enterprise depends on safe behaviors - the more, the better.  By maintaining the strong elements and improving the weaker ones, the district safety and health program can be successful which will benefit every school, every  employee and every student.  Implementing an effective injury prevention system will reduce injuries, keep experienced employees on the job, cut costs, improve morale and advance mission of educating students.   

Effective safety and health programs include inter-related elements and practices.   To learn more and understand the action steps that should be taken, click on each of the following:

Fundamentals And Safety Culture Framework
Board Policy

Variations in board policy wordings are common, however, the best practice is to make it clear that the school district upholds employee injury prevention as core value, providing the safest possible work environment for its employees and promoting safe work practices at all times.  

District Administration Accountability

Leaders at the highest level of administration should be consistent in modeling safe behavior and communicating that safety is a core value.   Accountability is not achieved simply through fairness in disciplinary actions for unsafe acts; rather, safety accountability depends on personal commitment by each person to a comprehensive, systematic, evidenced based  program of risk control elements.

Statement of Superintendent

The following is a representative example of many recommended statements:

The safety and health of each employee is my primary concern.  It is my intention that all employees will enjoy a safe and productive work setting and return home each day to family and friends free from injury.  I urge you to remember this safety principle - "No job is so important, and no service so urgent, that we cannot take time to perform our work safely."

 

The goal of the Safety and Health Program is to effectively manage the processes of occupational injury and illness prevention, and to aggressively eliminate the occurrence of unsafe conditions and at-risk behaviors.  The school district will provide the necessary resources so you can perform your job in a safe manner.  Employees are required to comply with all safety rules and are encouraged to participate in identifying ways to make our district a safer place to work.  All personnel must recognize their responsibility to follow our safety policy and understand that accident prevention is as much their obligation as any other phase of their work.

 

Your personal commitment to safety and health practices is reflected in how you perform your work assignments each day.  By looking out for co-employees, following safety instructions, attending training classes and reporting, preventing or eliminating unsafe conditions or practices   and using proper safety equipment, before someone is injured, you help us meet the goals of this program.

 

By accepting responsibility to perform our job safely, we all contribute to the well being of fellow employees, and subsequently, the best interest of our students and the district.

Senior Administration Commitment

The following statements are representative of the specific commitments expected of senior administrators:

  1. Provide a workplace free from recognized hazards.
  2. Delegate authority to supervisors and hold them accountable for Injury prevention and reporting procedures as agreed upon.
  3. Ensure supervisors are trained to implement Injury prevention and reporting procedures as agreed upon.
  4. Ensure that required safety training is provided to employees.  
  5. Ensure an ongoing program of vehicle safety is provided to all employees.
  6. Promptly report the death or probable death of any employee, or the in-patient hospitalization of one or more employees within agreed upon time period (eight hours) .
  7. Provide personal protective equipment as agreed upon to safely accomplish tasks.
  8. Ensure that a Safety Committee is formed and is carrying out its responsibilities as agreed upon.
  9. Follow-up on suggestions made by employees and the Safety Committee.
  10. Ensure that Injuries are fully analyzed and corrective action taken to prevent the hazardous conditions or behaviors from recurring.
  11. Maintain a record of occupational injuries and illnesses.
  12. Provide a safety bulletin board on the work premises.
  13. Review, supervise, and encourage the Injury Prevention Program.
  14. Provide a safe and secure work environment where violence, threats, harassment, and intimidation find no support.

Action item 1: Communicate district commitment to a safety and health program 

A clear, written policy helps you communicate that safety and health is a primary organizational value—critical to the mission of advancing student achievement  and essential for productivity, service quality and stakeholder satisfaction. 

How to accomplish it

  • Communicate the Board policy to all employees and, at appropriate times and places, to relevant parties, including: Contractors, subcontractors, staffing -agencies, and temporary employees at your worksite(s), Suppliers and vendors, other businesses in a multi-tenant building and visitors.

  • Reinforce management commitment by considering safety and health in all business decisions, including contractor and vendor selection, purchasing, and facility design and modification. 

  • Be visible in operations and set an example by following the same safety procedures you expect employees to follow. Begin work meetings with a discussion or review of safety and health indicators and any outstanding safety items on a “to do” list.

Action item 2: Define program goals 

By establishing specific goals and objectives, management sets expectations for managers, supervisors, and employees, and for the program overall. The goals and objectives should focus on specific actions that will improve workplace safety and health. 

How to accomplish it

  • Establish realistic, measurable goals for improving safety and health. Goals emphasizing injury and illness prevention should be included, rather than focusing on injury and illness rates. 

  • Develop plans to achieve the goals by assigning tasks and responsibilities to particular people, setting timeframes, and determining resource needs

Action item 3: Allocate resources  

It is imperative that the district provide the resources needed to implement the safety and health program, pursue program goals, and address program shortcomings when they are identified. Resource needs will vary depending on the district’s size, complexity, hazard types, and program maturity and development. Resource needs may include capital equipment and supplies, staff time, training, access to information and tools (e.g., vendor information, Safety Data Sheets, injury/illness data, checklists, online databases) and access to safety and health experts, including BOCES safety specialists and OSHA’s free and confidential On-site Consultation Program.

How to accomplish it

  • Estimate the resources needed to establish and implement the program.

  • Allow time in employees’ schedules for them to fully participate in the program.

  • Integrate safety and health into planning and budgeting processes, and align budgets with program needs.

  • Provide and direct resources to operate and maintain the program, meet safety and health commitments, and pursue program goals.

Action item 4: Expect performance

District administration leads the program effort by establishing roles and responsibilities and providing an open, positive environment that encourages communication about safety and health.

How to accomplish it

  • Identify a frontline person or persons who will lead the safety program effort, make plans, coordinate activities, and track progress. Define and regularly communicate responsibilities and authorities for implementing and maintaining the program, and hold people accountable for performance.

  • Provide positive recognition for meeting or exceeding safety and health goals aimed at preventing injury and illness (e.g., reporting close calls/near misses, attending training, conducting inspections).

  • Establish ways for the administration and all employees to communicate freely and often about safety and health issues, without fear of retaliation.

Safety Champion

A designated district level safety champion should review all reports looking for any trends, hazardous conditions or hazardous practices, and should be empowered by the Superintendent to investigate any incident, Injury, work practice or element of the employee injury program.   

Supervisors Commitment

Supervisors are responsible for leading injury prevention efforts and creating an atmosphere that clearly demonstrates to employees that safety is a core value for their personal and professional activities.  The following statements are representative of the specific commitments that should be expected of supervisors:

  1. Model safe behavior and safety rule compliance.
  2. Ensure that all safety and health rules, standards, and procedures are observed.
  3. Acknowledge staff members when they employ safe work practices and behavior.
  4. Orient and train employees in safe and efficient work methods, and see that they are practiced.
  5. Make sure that employees receive training and are competent in the safe operation of agreed up tools, equipment, safeguards and personal protection equipment.
  6. Follow-up and act upon suggestions made by employees and the Safety Committee.
  7. Conduct regular inspections of work areas and work practices to eliminate potentially hazardous conditions. Submit corrective action reports to the Safety Committee.
  8. Participate actively in an analysis of all Injuries, regardless of severity. Submit completed Injury/Incident Report forms with preventive suggestions as agreed upon. (within 24 hours, or the next working day, of first awareness.)  
  9. Investigate all reports of unsafe conditions, equipment or unsafe actions, and when appropriate act immediately to correct any hazards or unsafe behaviors. Provide training as necessary.
  10. Use appropriate intervention when an employee appears to be unable to perform assigned duties or  jeopardizes the safety of the employee or others.  
  11. Speak with administration about changes that will improve employee safety.
  12. Encourage and challenge employees to work safely and to communicate safety concerns.

Employee Involvement

To be effective, any safety and health program needs the meaningful participation of employees and their representatives. Employee have much to gain from a successful program and the most to lose if the program fails. They also often know the most about potential hazards associated with their jobs. Successful programs tap into this knowledge base.

Employee participation means that employees are involved in establishing, operating, evaluating, and improving the safety and health program. All employees  at a worksite should participate, including those employed by contractors, subcontractors, and temporary staffing agencies

In an effective safety and health program, all employees:

  • Are encouraged to participate in the program and feel comfortable providing input and reporting safety or health concerns.
  • Have access to information they need to participate effectively in the program.
  • Have opportunities to participate in all phases of program design and implementation.
  • Do not experience retaliation when they raise safety and health concerns; report injuries, illnesses, and hazards; participate in the program; or exercise safety and health rights.

Employee participation is vital to the success of safety and health programs. Where employees are represented by a union, it is important that employee representatives also participate in the program, consistent with the rights provided to employee representatives under the Occupational Safety and Health Act of 1970 and the National Labor Relations Act.

Action item 1: Encourage employees to participate in the program

By encouraging employees to participate in the program, district administration signals that it values their input into safety and health decisions.

How to accomplish it

  • Give employees the necessary time and resources to participate in the program.
  • Acknowledge and provide positive reinforcement to those who participate in the program.
  • Maintain an open door policy that invites employees to talk to managers about safety and health and to make suggestions.

Action item 2: Encourage employees to report safety and health concerns

Employees are often best positioned to identify safety and health concerns and program shortcomings, such as emerging workplace hazards, unsafe conditions, close calls/near misses, and actual incidents. By encouraging reporting and following up promptly on all reports, employers can address issues before someone gets hurt or becomes ill.

How to accomplish it

  • Establish a process for employees to report injuries, illnesses, close calls/near misses, hazards, and other safety and health concerns, and respond to reports promptly. Include an option for anonymous reporting to reduce fear of reprisal.1
  • Report back to employees routinely and frequently about action taken in response to their concerns and suggestions.
  • Emphasize that district administration will use reported information only to improve workplace safety and health and that no employeee will experience retaliation for bringing such information to management's attention. (see Action Item 5).
  • Empower all employees to initiate or request a temporary suspension or shut down of any work activity or operation they believe to be unsafe.
  • Involve employees in finding solutions to reported issues.

Action item 3: Give employees access to safety and health information

Sharing relevant safety and health information with employees fosters trust and helps organizations make more informed safety and health decisions.

How to accomplish it

  • Give employees the information they need to understand safety and health hazards and control measures in the workplace. Some OSHA standards require employers to make specific types of information available to employees, such as:
  • Safety Data Sheets (SDS)
  • Injury and illness data (may need to be redacted and aggregated to eliminate personal identifiers)
  • Results of environmental exposure monitoring conducted in the workplace (prevent disclosure of sensitive and personal information as required)
  • Other useful information for employees to review can include:
    • Chemical and equipment manufacturer safety recommendations
    • Workplace inspection reports
    • Incident investigation reports (prevent disclosure of sensitive and personal information as required)
    • Workplace job hazard analyses

Action item 4: Involve employees in all aspects of the program

Including employee input at every step of program design and implementation improves your ability to identify the presence and causes of workplace hazards, creates a sense of program ownership among employees, enhances their understanding of how the program works, and helps sustain the program over time.

How to accomplish it

  • Provide opportunities for employees to participate in all aspects of the program, including, but not limited to helping:
  • Develop the program and set goals.
  • Report hazards and develop solutions that improve safety and health.
  • Analyze hazards in each step of routine and non-routine jobs, tasks, and processes.
  • Define and document safe work practices.
  • Conduct site inspections.
  • Develop and revise safety procedures.
  • Participate in incident and close call/near miss investigations.
  • Train current employees and new hires.
  • Develop, implement, and evaluate training programs.
  • Evaluate program performance and identify ways to improve it.
  • Take part in exposure monitoring and medical surveillance associated with health hazards.

Action item 5: Remove barriers to participation

To participate meaningfully in the program, employees must feel that their input is welcome, their voices will be heard, and they can access reporting mechanisms. Participation will be suppressed if language, education, or skill levels in the workplace are not considered, or if employees fear retaliation or discrimination for speaking up (for example, if investigations focus on blaming individuals rather than the underlying conditions that led to the incident, or if reporting an incident or concern could jeopardize the award of incentive-based prizes, rewards, or bonuses).

How to accomplish it

  • Ensure that employees from all levels of the organization can participate regardless of their skill level, education, or language.
  • Provide frequent and regular feedback to show employees that their safety and health concerns are being heard and addressed.
  • Authorize sufficient time and resources to facilitate employee participation; for example, hold safety and health meetings during regular working hours.
  • Ensure that the program protects employees from being retaliated against for reporting injuries, illnesses, and hazards; participating in the program; or exercising their safety and health rights. Ensure that other policies and programs do not discourage employee participation.
  • Post the 11(c) fact sheet (found at www.whistleblowers.gov) in the workplace or otherwise make it available for easy access by employees.

Safety Steering Team

This district should organize a Safety Steering Team to help employees and administrators work together to identify safety gaps, develop solutions, review incident reports and evaluate the effectiveness of the safety program.  The following operating practices should be considered:

Composition.  The Steering Team is comprised of an administration representative(s) and employee-elected members representing departments of the school district.

  • Employees in each department elects from among themselves, representatives to be on the committee.
  • The term of employee-elected members is a maximum of one year. There is no limit to the number of terms a representative can serve.  If there is an employee-elected member vacancy, a new member is elected prior to the next scheduled meeting.
  • The number of employer-selected members is equal to or less than the number of employee-elected members.

Chairperson. The Steering Team elects a chairperson.

Responsibilities. The Steering Team duties include but are not limited to:

  • Periodic self-inspections of the workplace.
  • A review of the safety and health inspection reports to assist in correction of identified unsafe conditions or practices.
  • An evaluation of the Injury analysis conducted since the last meeting to determine if the cause of the unsafe act or unsafe condition involved was properly identified and corrected. Review and analyze any oral or written hazard reports.
  • Periodic evaluation of the Injury and illness prevention program. Make recommendations for improvement.
  • Review the safety and health inspection reports to help correct safety hazards.
  • Evaluate the Injury investigations conducted since the last meeting to determine if the cause(s) of the unsafe situation was identified and corrected.
  • Evaluate the workplace Injury and illness prevention program and discuss recommendations for improvement, if needed.
    • Evaluate employee safety suggestions.
    • Encourage safe work practices among co-employees.
    • Make recommendations for employee safety training.
    • Promote, publicize, and develop advocacy for safety for all department staff.

Meeting Management: The Steering Team is responsible for:

  • Determining the frequency of meetings (minimum quarterly).
  • Setting date, hour and location of the meeting.
  • Limiting length of each meeting. (Should not exceed one hour except by majority vote of the committee.)
  • Documenting attendance.

Meeting Minutes: A secretary for the Steering Team is selected in order to ensure that:

  • Minutes of each Team meeting, including attendance, are prepared and maintained according to district records retention policies. (at least one year) and accessible for review by safety and health consultation personnel and  Department of Labor. (A sample form to record meeting minutes is available.)
  • Meeting minutes are distributed to each location for posting on Safety Bulletin Boards.

Standards, Activators And Consequences

Written standards of performance should be published for any matter that has specific time elements or data specifications prescribed by laws, regulations or internal operating agreements.

Intervention techniques to increase safe behaviors or decrease at-risk behaviors are either activators or consequences. Activators are conditions or events preceding operant behavior; consequences are conditions or events following operant behavior.

These six principles will increase the impact of activators:

  1. Specify the behavior.
  2. Maintain salience with novelty.
  3. Vary the message.
  4. Involve the target audience.
  5. Activate close to response opportunity.
  6. Implicate consequences.

Safety activators should be carefully planned so the right safety directives receive the attention and ultimate action they deserve.  The most powerful activators make the person aware of consequences following the performance of a target behavior.

Consequences can be positive or negative, intrinsic or extrinsic to the task and internal or external to the person.  Consequences occurring on an intermittent basis are much more effective at motivating long-term behavior change than consequences occurring on a continuous basis or after every response.  When consequences are improbable, they can lose their influence entirely.  Individuals respond best to consequences that they perceive are “certain and sizable,” and occur “immediately or soon” after the behavior.

The probability of injury can be reduced by the combination of:

  • Increasing positive consequences of safe behavior.
  • Decreasing negative consequences of safe behavior.
  • Decreasing positive consequences of at-risk behavior.
  • Increasing negative consequence of at risk behavior.

When discipline is the only form of consequence used by organizations or when discipline is applied incorrectly, injury prevention efforts will not be effective over time. 

Communication

There should be a system o integrated activities for communicating with employees that includes provisions designed to encourage employees to inform the district of hazards at the worksite without fear of reprisal.  This could be accomplished through meetings, training programs, posting, written communications, instruments for anonymous notification by employees about hazards, and any other means that ensures communication with employees.

Communication and coordination among the district, its contractors, and staffing agencies is also vital.  Effective communication and coordination means that before coming on site, contractors, staffing agencies and their employees are aware of:

  • The types of hazards that may be present.
  • The procedures or measures they need to use to avoid or control their exposure to these hazards.
  • How to contact the host employer to report an injury, illness, or incident or if they have a safety concern.
    • District employees should be are aware of:
  • The types of hazards that may arise from the work being done on site by employees employed by contractors or staffing agencies.
  • The procedures or measures needed to avoid or control exposure to these hazards.
  • How to contact the contract or staffing firm if they have a safety concern.
  • What to do in case of an emergency.

Action item 1: Establish effective communication

The district should establish and implement a procedure to ensure the exchange of information about hazards present on site and the hazard control measures in place. Thus, all employees on the site are aware of worksite hazards, and the methods and procedures needed to control exposures to them.   Information should communicated before on-site work starts and, as needed, if conditions change.

How to accomplish it

  • Communicate with contractors and staffing agencies to determine which among them will implement and maintain the various parts of the safety and health program, to ensure protection of all on-site employees before work begins. These determinations can be included in contract documents that define the relationships between the parties.
  • Establish and implement procedures to exchange information with contractors and staffing agencies about hazards present in the workplace and the measures that have been implemented to prevent or control such hazards.
  • Gather and disseminate information sufficient to enable each employer to assess hazards encountered by its employees and to avoid creating hazards that affect employees on the site.
  • Contractors and staffing agencies regularly give the district any information about injuries, illnesses, hazards, or concerns reported by their employees and the results of any tracking or trend analysis they perform.
  • Each contractor establishes and implements a procedure for providing the district with information about the hazards and control measures associated with the work being done by its employees, and the procedures it will use to protect employees on the site.
  • Give contract employers and staffing agencies the right to conduct site visits and inspections and to access injury and illness records and other safety and health information.
  • Communicate with contractors and staffing agencies and their employees about nonroutine and emergency hazards and emergency procedures.

Action item 2: Establish effective coordination

The district and its contractors, and staffing agencies should coordinate on work planning, scheduling, and resolving program differences to identify and work out any concerns or conflicts that could impact safety or health.   In both temporary employee and multiemployer situations, safety is enhanced if employers establish mechanisms to coordinate their efforts and communicate effectively to afford all employees equal protection against hazards. These mechanisms include measures to ensure that all employees on site (and their representatives) can participate in preventing injuries and illnesses. Failure to take these steps may undermine safety programs. For example, if different employers have inconsistent policies about when and where to wear PPE, employees may mistakenly believe that the equipment is not needed, leading to injury.  Inconsistent safety policies may also cause employees to question the credibility of safety and health programs, resulting in less meaningful employee engagement and participation.

How to accomplish it

  • Include in contracts and bid documents any safety-related specifications and qualifications and ensure that contractors and staffing agencies selected for the work meet those requirements.
  • Identify issues that may arise during on-site work and include procedures to be used by the host employer and contractors and/or staffing agencies for resolving any conflicts before work starts.
  • Coordinate with contractors and staffing agencies to ensure that work is planned and scheduled to minimize impacts on safety.
  • Ensure that staffing agency employees are adequately trained and equipped before arriving on the worksite. Harmonize their safety and health policies and procedures to resolve important differences, so that all employees at the site have the same protection and receive consistent safety information.
  • Work together to deal with unexpected staffing needs by ensuring that enough trained and equipped employees are available or that adequate lead time is provided to train and equip employees.
  • Make sure that administrators with decision-making authority are available and prepared to deal with day-to-day coordination issues.

Continuous Improvement Evaluation

Once a safety and health program is established, it should be evaluated initially to verify that it is being implemented as intended.  After that, periodically, and at least annually, designated administrators should assess what is working and what is not, and whether the program is on track to achieve its goals. Whenever these assessments identify opportunities to improve the program, administrators, managers, and supervisors—in coordination with employees—should make adjustments and monitor how well the program performs as a result. Sharing the results of monitoring and evaluation within the workplace, and celebrating successes, will help drive further improvement.

The scope and frequency of program evaluations will depend on the scope, complexity, and maturity of the program and on the types of hazards it must control. Program evaluations should be conducted periodically (and at least annually) but might also be triggered by a change in process or equipment, or an incident such as a serious injury, significant property damage, or an increase in safety-related complaints.

Program evaluation and improvement includes:

  • Establishing, reporting, and tracking goals and targets that indicate whether the program is making progress.
  • Evaluating the program initially and periodically thereafter to identify shortcomings and opportunities for improvement.
  • Providing ways for employees to participate in program evaluation and improvement.

On-Site Best Practices Audits. An on-site practices audit can reveal the areas of risk management that need improvement, while affirming those good risk management practices you already have. The audit includes review of documentation, record keeping, policies, and procedures. On-site interviews are also conducted. Do you manage disability accommodations, discipline, personnel files, performance evaluations, and terminations the best you can? Our experienced risk auditors can help you with the answers.

Off-Site Best Practices Audit. You never seem to have enough time, do you? You need information and you need it quickly. Our off-site assessments can provide a quick, informative look at common managerial challenges. The audit identifies risk areas in your policies and procedures ... and more.

Policies and Procedures Audits. Good risk management is based upon policies and procedures in an employee handbook that reflect your organization's commitment to excellence and safety. Audit your existing handbook for the presence of everything needed to communicate your expectations to your employees and to prevent injuries.

Action item 1: Monitor performance and progress

The first step in monitoring is to define indicators that will help track performance and progress.   Next, establish and follow procedures to collect, analyze, and review performance data with the involvement of all central office administrators, supervisors, and employees.

Both lagging and leading indicators of performance should be used.  Lagging indicators generally track employee exposures and injuries that have already occurred. Leading indicators track how well various aspects of the program have been implemented and reflect steps taken to prevent injuries or illnesses before they occur. 

Indicators can be either quantitative or qualitative. Whenever possible, select indicators that are measurable (quantitative) and that will help you determine whether you have achieved your program goals. The number of reported hazards and near hits would be a quantitative indicator. A single employee expressing a favorable opinion about program participation would be a qualitative indicator.

How to accomplish it

  • Develop and track lagging indicatorsof progress toward established safety and health goals, such as:
    • Number and severity of injuries and illnesses
    • Results of employee exposure monitoring that show that exposures are hazardous
    • Employees' compensation data, including claim counts, rates, and cost.
  • Develop and track leading indicators, such as:
    • Level of employee participation in program activities
    • Number of employee safety suggestions
    • Number of hazards, near misses and first aid cases reported
    • Amount of time taken to respond to reports
    • Number and frequency of management walkthroughs.
    • Number and severity of hazards identified during inspections.
    • Number of employees who have completed required safety and health training.
    • Timely completion of corrective actions after a workplace hazard is identified or an incident occurs.
    • Timely completion of planned preventive maintenance activities.
    • Employee opinions about program effectiveness obtained from a safety climate or safety opinion survey.
  • Analyze performance indicators and evaluate progress over time.
  • Share results with employees and invite their input on how to further improve performance.
  • When opportunities arise, share and compare results among similar schools and similar, with other relevant organizations and associations.

Action item 2: Verify that the program is implemented and is operating

Initially and at least annually, employers need to evaluate the program to ensure that it is operating as intended, is effective in controlling identified hazards, and is making progress toward established safety and health goals and objectives. The scope and frequency of program evaluations will vary depending on changes in OSHA standards; the scope, complexity, and maturity of the program; and the types of hazards it must control.

How to accomplish it

  • Verify that the core elements of the program have been fully implemented.
  • Involve employees in all aspects of program evaluation, including:
    • reviewing information (such as incident reports and exposure monitoring results);
    • establishing and tracking performance indicators;
    • identifying opportunities to improve the program.
  • Verify that the following key processes are in place and operating as intended:
    • Reporting injuries, illnesses, incidents, hazards, and concerns;
    • Conducting workplace inspections and incident investigations,
    • Tracking progress in controlling identified hazards and ensuring that hazard control measures remain effective;
    • Collecting and reporting any data needed to monitor progress and performance.
  • Review the results of any compliance audits to confirm that any program shortcomings are being identified. Verify that actions are being taken that will prevent recurrence.

Action item 3: Correct program shortcomings and identify opportunities to improve

Whenever a problem is identified in any part of the safety and health program, designated administrators in coordination with supervisors, managers, and employees should take prompt action to correct the problem and prevent its recurrence.

How to accomplish it

  • Proactively seek input from administrators, supervisors, employees and other stakeholders about how to improve the program.
  • Determine whether changes in equipment, facilities, materials, key personnel, or work practices trigger any need for changes in the program.
  • Determine whether the performance indicators and goals are still relevant and, if not, how they could be changed to more effectively drive improvements in workplace safety and health.
Behavior-based Safety Elements

“Behavior Based Safety works to reduce injuries.” – E. Scott Geller, PhD

Behavior Based Safety (BBS) refers to a program structure with integrated elements designed to influence employee actions toward safer outcomes, ideally by preventing an accident or injury before it occurs.     When infused into the framework of the district’s safety culture and implemented correctly, the elements of BBS can provide positive activators and consequences to change unsafe behavior, reduce job-related injuries, minimize lost production, and improve workplace morale.  BBS elements are essential  for sustainable injury prevention.

BBS matters because upwards of 80% of all accidents occur due to the choices people make and make and how they act.   Unsafe acts, rather than unsafe conditions, are the root cause of most incidents.  Injury prevention is to a great extent under each person’s own control.  It is beneficial for employees to practice safe behaviors in the workplace because incidents and injuries have a human cost.    It is the human impact—personal injury, loss of livelihood, the wellbeing of others—which prompts concern about behavioral choices in the workplace. 

BBS can mean very different things to different people and evoke very different feelings. Some organizations have reported very positive feelings and success stories about programs they think of as BBS programs. Others have been disappointed. Critics may say that BBS is "feel good safety stuff,” that it is outdated, that it is mechanistic or that it has been used by management teams that do not want to take "management" responsibility. 

OSHA does not specifically require organizations to implement a BBS program.  OSHA however has recommended practices for safety and health programs that includes the involvement of employees and managers in safety and hazard identification and assessment.   

Observing, adjusting and then evaluating behaviors are the core elements of BBS.  BBS elements are most effective when treated as a continuous loop, constantly adapting to needs of employees and the district. The following elements should be working in unison: 

  • Leadership’s willingness to admit that there’s a better way and to start over.
  • Dedicated involvement from every employee (especially the Superintendent); including contractors and sub-contractors.
  • Non-intrusive method for collecting and evaluating data on safe behaviors.
  • Mechanisms for instituting change to policies, procedures, and systems.

BBS elements also assist by creating multiple opportunities for employees and managers to interact in the safety process and to assist in assessing and identifying hazards.

Defining Critical Behaviors

Simply stated, behaviors are acts or actions by a person that can be observed by another person or persons.  Critical behaviors can be defined as:

A.1  At-risk or unsafe behaviors that actually resulted in substantial number of near hits or injuries in the past;

A.1 Safe behaviors that could have prevented these incidents;

B.1 At risk or unsafe behaviors that could potentially contribute to an injury (or fatality);  

B.2 Safe behaviors that could prevent such an incident.

When defining critical behaviors, a district can look beyond its own experience and also learn from the experience of other districts.

Recording Observations

There are several methods that can be used  for recording observations. Each methods results in a large amount  information  collected about employee habits. Collecting and analyzing data can be done with the help of simple forms and planning.  Software is also available to improve consistency and information sharing. 

Metrics

Metrics are a natural starting point for analyzing the district’s data.  There should be  at least one leading indicator.    A leading indicator can be created by selecting some or all of the lagging indicators, adding them together, then dividing the sum by the total number of unique observations performed. The resulting number will be a score showing the total percentage of observations that align with your program objectives. This metric will serve as a barometer as to the direction and momentum of district efforts.

The following metrics are all based on lagging indicators of safety performance.

  • Observation Target Rate: Set a goal to observe and provide feedback to a set number of people in your operations on a monthly or weekly basis. This goal will change based on your corporate culture and the program’s maturity. The goal is typically set at a number of unique people observed, rather than number of observations recorded
  • CAPA Closure Rate: BBS observations should be generating Corrective and Preventative Actions (CAPAs). Just like in any other CAPA system, you should be measuring the number of created actions as well as closed actions
  • Program Participation Rate: Participation is paramount, so you should be tracking how many trained individuals are actually conducting the number of observations requested of them. Follow up with those that are falling short of their observation goals. 
  • Program Awareness Rate: This metric is a bit outside of the norm and requires some leg work, but it’s a necessity if you are to understand the overall effectiveness of your program. To track this metric count the people who know the observations you are focusing on, they should be able to name the top few. 
  • Safe Observations Rate: Self-explanatory - the average percentage of safe observations for your behaviors.
  • Observations Performed by Title: Make sure every level of the organization is involved, from C-Suite all the way to the night cleaning crew.
Data Mining 

Data mining involves techniques for finding anomalies, patterns and correlations within large data sets to predict outcomes. This activity goes beyond data analysis to identify  why certain behaviors are occurring.  Using word clouds is one method that can be used to help evaluate the feedback and comments associated with the observations. Staff interviews can be used to dig deeper into issues.   When probable underlying causes for behaviors are uncovered, it is important to use  basic scientific methods to produce and test a solution. BBS elements are evidenced based, thus requiring a hypothesis and feedback on any  proposed solution.  Practices should be adjusted as needed in order to change unsafe behavior and reinforce the desired behavior.  

Variations and Additions

BBS elements may be introduced and expanded over time based on evidence of changes in observed behaviors from the experience of the district over time district and from comparable organization.   Some of the practices to consider include:

  • Establishment of a task force for the process.
  • Addition “safety spotters.”
  • Development of behavioral checklists that identify standardized "safe" or "at risk" behaviors.
  • Training for management and observers to include methods and options for communication of concerns.
  • Consideration of alternatives for data collection and use of findings.
  • Competition between teams.
  • Incorporation of “risk ownership practices” 

These and other practices can help overcome challenges that may result from:

  • Difficulty prioritizing what behaviors need to be modified.
  • Reluctance to change.
  • Flaws in the change management process.
  • Flaws in the program design (e.g. negative reinforcement or prizes).
  • Shortcomings in employee engagement in the process.
  • Lack of a leading indicator for the program.
  • Complex and/or labor intensive processes.

BBS elements implemented properly can be effective at helping districts discover unsafe behaviors and core organizational systemic sources of risk.  BBS elements are effective when they:

  • Renew focus on the human side of safety;
  • Clearly define safe and unsafe behaviors;
  • Encourage safe behaviors; 
  • Involve employees in safety;
  • Enhance accountability for safety in the management tier;
  • Engender commitment and passion, especially in the early phases.

Eight Steps for Inclusion of BBS in District Employee Injury Prevention Program

A sound approach begins with an in-depth knowledge of how to change human behavior. The laws and principles of behavioral psychology can be applied to the specific situation and extended to all the behaviors.  These eight steps should be followed:  

 

  1. Build a Design Team:  This team should consist of administrators, managers and employees, serving as volunteers and ultimately, as advocates. This team will lead the design of BBS, however all employees will be involved in implementation.
  2. Target behaviors are chosen from safety incidents, near hit reporting, safety audits and observation. First, the design team picks targeted areas of improvement using data from safety audits, employees comp statistics, accident investigations, information from safety meetings, and informal interviews with staff. The team determines prevention efforts for reportable injuries; if it is not immediately obvious the team use methods like discussing how increased situational awareness might have affected the situation. From this analysis, the team will identify critical safe behaviors for an observation checklist.
  3. Use a critical observational checklist.  This should be developed using a list of safe behaviors identified in the previous step. These lists can be shortened according to importance of safety, frequency of occurrence, observability, and overlap with other items on the list. Lists should be no more than 1 sheet of paper. It helps to have definitions for everything that is being measured on the back of the checklist. – try not to leave anything up to subjective interpretation. The best way to know if the checklist is useable is to observe an employee working, and see if all categories on the list can be filled out in an observation. The list will need to be revised a number of times before it can be considered ready-to-use, and so should be tested.
  4. Ensure that there is a measurement system.  One measurement system for an observation program is a simple frequency count of safe and risky behaviors during observation. With effective measurement, leadership can create an environment in which people actually want to be measured. Ideally, positive reinforcement of observed behavioral promotes engagement.  When employees receive specific, positive feedback, and are rewarded, there’s a direct correlation supporting the program.
  5. Carry out behavioral observations.  Data shows that the most beneficial system is to have all employees involved in the observation process. Behavioral observations increase safety behaviors of the observed but also the observer; encouraging employees to conduct observations on each other will benefit all employees. The team will need to decide how often observations will be conducted, whether they will occur across or within departments,  whether a single task or employee will be observed, or a work area.  To include contractors,  recruitment should begin in the design phase.
  6. Deliver feedback.  The feedback process requires careful training of employees. The observer should be able to summarize significant positive safety behaviors areas that require change. Feedback should be delivered as soon as possible after the observation. Describe the behavior observed, discuss the potential impact and listen to the observed employee – this formula can be used for both positive and corrective feedback. In addition to individual feedback by the observer, overall site feedback should be reported. Leadership should discuss the results of the observations categorically, not personally at group meetings, and provide visual feedback. The easiest and most effective way to do this is through creation of a graph. Visual feedback helps measure organizational progress and helps with goal setting. Leaders should respond with positive feedback about improvements, and should encourage objective problem solving.
  7. Make use of the data. With valuable data, teams can enact well-informed, safety-focused process changes. Review and reporting of data should be on a regular basis, along with communication related to safety process changes; employees need to know that they are both the source of data and reason for change.
  8. Set improvement goals.  Employees should be encouraged to participate in goal setting and goals should be realistic and based on current data. Set short term goals and ensure that each employee knows what behavior or process they need to work on to reach the goal. Remember to focus on the safety process itself and not the results – attempting to manage results will ruin the integrity of the program. Instead of setting goals to increase or decrease results, set goals around the behaviors that lead to these results.

Proponents of BBS have pointed out these piftalls to successful design and implementation:

  • Thinking that observation and participation are the core of behavior-based safety.
  • Failing to apply positive reinforcement systematically and effectively.
  • Making behavior-based safety the primary responsibility of the employees.
  • Changing only the hourly employees.
  • Failing to train managers, supervisors and hourly employees in the core principles of behavior change technology.
  • Trying to fit an activities-based "program" to your organization.

Behavior based interventions should be instructional, supportive and motivational.

Administrative And Engineering Controls

Engineering controls are equipment designs or hazard repairs that protect employees using a physical separation or barrier, including equipment guards and electrical panel locks. Appropriate engineering controls are critical during repairs to physical facilities. 

A method of following up on recommended corrective actions such as a work order system is essential to ensure engineering controls and hazard remediation are completed in a timely manner. In addition, the review of equipment purchases from the standpoint of appropriate mechanical guards or state of the art electrical lockouts is an important function of engineering controls.   

Administrative Controls are procedures, work methods, instructions, memos, visual means,   and wearable articles that protect employees from potential hazards.   Examples include, wet floor warning signs, step stools, ladders, gloves and other types of personal protective equipment. (PPE)   Items that may included are eye and face protection, foot protection, hand protection, head protection, hearing protection and protection from blood borne pathogens. 

Special attention is needed for Personal Protective Equipment  (PPE). The first step in any PPE program is a hazard assessment of each job performed within the district. The assessment deals with the entire job and not just those parts dealing chemical hazards.   PPE required by this evaluation should be documented for each job. Training for each job should include the proper usage of PPE. Frequency of training specific to the job and use of PPE should   be agreed upon. (annually.) The completion of training should be documented. 

Personal protective equipment should not be used as a substitute for engineering controls. All other means of protecting the employee should be used prior to requiring personal protective equipment.  Whenever possible, use of an engineering control should take precedence over PPE.

Operating procedures should be issued for each job or work area with the administrative controls specified.  These types of administrative controls should be included as part of job hazard analysis.

Personnel Selection

Good risk management begins with smart hiring decisions. Advertising, interviewing, screening, and hiring can be simple, but should be done with risk avoidance in mind. A comprehensive cadre of smart hiring components is designed as the foundation for  effective loss control program. 

Job Descriptions: Drafting & Consulting

Job descriptions are one of the most vital management tools for preventing injuries. Job descriptions that contain all the mental and physical essential functions of each job can assist in preventing and managing many challenging aspects of employee relations-on issues such as hiring, disability, performance appraisals, and discrimination claims. 

Existing job descriptions should be checked to see if they were current and if they actually reflected the jobs your employees are doing.  Descriptions should be specific and include clearly define the required physical capabilities.  (ADA compliant)

Pre-employment Screening

It is possible to prevent some potential injuries by conducting thorough pre-employment screenings. Verification of employment and educational history are two tests of applicants’ veracity. Driving record checks as well as criminal background checks are means for minimizing the chances for risks in employment. Perform background checks on every job applicant. Obtain valuable and necessary background information without violating privacy laws or other legal requirements. Obtain reference information about job applicants without creating liability for the district.

Job Hazard Analysis

A job hazard analysis is a technique promoted used to encourage identification of hazards before they occur. A job hazard analysis looks at the relationship between the employee, the task, the tools and equipment, and the work environment. By identifying potential hazards, the district can take steps to eliminate or reduce them to an acceptable risk level.

Hazard Identification

Inspections

Periodic walk-throughs and use of checklists are common techniques that can be used to identify physical and engineering vulnerabilities.    

Loss Run Review

A loss run is a listing of injuries, which have been reported to the district’s insurer or third party claims administrator. This claims listing can provide information concerning trends that may need to be addressed. A designated coordinator should review the information for accident trend identification and follow-up with appropriate claim staff with questions. Analysis should include the following:

  1. Principal or department manager review; Intimate knowledge of their area of responsibility may provide useful information that would not have otherwise been noticed.   
  1. Differences between similar schools in the district.
  1. Increase in frequency of injuries over a period of time may show a trend that needs to be addressed.
  1. Employees with multiple injuries within a short period of time. This information should all be reviewed to determine problems with specific employees.

Loss run reviews also serves the purpose of identifying any injury that was incorrectly coded to the district that actually occurred at another school district or employer.

External Benchmarking

A comparison of the loss experience with similar districts should provide an indication of frequency or severity problems.   A useful means of comparison is the frequency rate of injuries, expressed as the number of injuries requiring medical attention per million dollars of payroll.  The calculation is: Injuries/(payroll/million)   

To identify and assess hazards, administrators, supervisors and employees:

  • Collect and review information about the hazards present or likely to be present in the workplace.
  • Conduct initial and periodic workplace inspections of the workplace to identify new or recurring hazards.
  • Investigate injuries, illnesses, incidents, and close calls/near misses to determine the underlying hazards, their causes, and safety and health program shortcomings.
  • Group similar incidents and identify trends in injuries, illnesses, and hazards reported.
  • Consider hazards associated with emergency or nonroutine situations.
  • For each hazard identified, determine the severity and likelihood of incidents that could result, and use this information to prioritize corrective actions.
  • Some hazards, such as housekeeping and tripping hazards, can and should be fixed as they are found. Fixing hazards on the spot emphasizes the importance of safety and health and takes advantage of a safety leadership opportunity. Fixing other hazards identified using the processes described here will be addressed in the next section, “Hazard Prevention and Control.”

Action item 1: Collect existing information about workplace hazards

Information on workplace hazards may already be available to employers and employees from both internal and external sources.

How to accomplish it

  • Collect, organize, and review information with employees to determine what types of hazards may be present and which employees may be exposed or potentially exposed. Information available in the workplace may include:
    • Equipment and machinery operating manuals.
    • SDSs provided by chemical manufacturers.
    • Self-inspection reports and inspection reports from insurance carriers, government agencies, and consultants.
    • Records of previous injuries and illnesses, such as OSHA 300 and 301 logs and reports of incident investigations.
    • Employees’ compensation records and reports.
    • Patterns of frequently occurring injuries and illnesses.
    • Exposure monitoring results, industrial hygiene assessments, and medical records (appropriately redacted to ensure patient/employee privacy).
    • Existing safety and health programs (lockout/tagout, confined spaces, process safety management, PPE, etc.).
    • Input from employees, including surveys or minutes from safety and health committee meetings.
    • Results of job hazard analyses (JHAs, also known as job safety analyses or JSAs).
  • Information about hazards may be available from outside sources, such as: OSHA, National Institute for Occupational Safety and Health (NIOSH), and Centers for Disease Control and Prevention (CDC) websites, publications, and alerts.
  • Trade associations.
  • Labor unions, state and local occupational safety and health committees/coalitions (“COSH groups”), and employee advocacy groups.
  • Safety and health consultants.

Action item 2: Inspect the workplace for safety hazards

Hazards can be introduced over time as workstations and processes change, equipment or tools become worn, maintenance is neglected, or housekeeping practices decline. Setting aside time to regularly inspect the workplace for hazards can help identify shortcomings so that they can be addressed before an incident occurs.

How to accomplish it

  • Conduct regular inspections of all operations, equipment, work areas, and facilities. Have employees participate on the inspection team, and talk to them about hazards that they see or report.
  • Be sure to document inspections so you can later verify that hazardous conditions are corrected. Take photos or video of problem areas to facilitate later discussion and brainstorming about how to control them, and for use as learning aids.
  • Include all areas and activities in these inspections, such as storage and warehousing, facility and equipment maintenance, purchasing and office functions, and the activities of on-site contractors, subcontractors, and temporary employees.
  • Regularly inspect both plant vehicles (e.g., forklifts, powered industrial trucks) and transportation vehicles (e.g., cars, trucks).
    • Use checklists that highlight things to look for. Typical hazards fall into several major categories, such as those listed below; each workplace will have its own list:
  • General housekeeping
  • Slip, trip, and fall hazards
  • Electrical hazards
  • Equipment operation
  • Equipment maintenance
  • Fire protection
  • Work organization and process flow (including staffing and scheduling)
  • Work practices
  • Workplace violence
  • Ergonomic problems
  • Lack of emergency procedures

Before changing operations, workstations, or workflow; making major organizational changes; or introducing new equipment, materials, or processes, seek the input of employees and evaluate the planned changes for potential hazards and related risks.

Many hazards can be identified using common knowledge and available tools.   Employees can be a very useful internal resource, especially if they are trained in how to identify and assess risks.

Action item 3: Identify health hazards

Identifying employees’ exposure to health hazards is typically more complex than identifying physical safety hazards. For example, gases and vapors may be invisible, often have no odor, and may not have an immediately noticeable harmful health effect. Health hazards include chemical hazards (solvents, adhesives, paints, toxic dusts, etc.), physical hazards (noise, radiation, heat, etc.), biological hazards (infectious diseases), and ergonomic risk factors (heavy lifting, repetitive motions, vibration).   

How to accomplish it

Identify chemical hazards—review SDSs and product labels to identify chemicals in your workplace that have low exposure limits, are highly volatile, or are used in large quantities or in unventilated spaces. Identify activities that may result in skin exposure to chemicals.   

Identify physical hazards—identify any exposures to excessive noise (areas where you must raise your voice to be heard by others), elevated heat (indoor and outdoor), or sources of radiation (radioactive materials, X-rays, or radiofrequency radiation).

Identify biological hazards—determine whether employees may be exposed to sources of infectious diseases, molds, toxic or poisonous plants, or animal materials (fur or scat) capable of causing allergic reactions or occupational asthma.   Identifying and assessing health hazards may require specialized knowledge. 

Identify ergonomic risk factors—examine work activities that require heavy lifting, work above shoulder height, repetitive motions, or tasks with significant vibration.

Conduct quantitative exposure assessments, when possible, using air sampling or direct reading instruments.

Review medical research and claims data to identify cases of musculoskeletal injuries, skin irritation or dermatitis, hearing loss, or lung disease that may be related to school workplace exposures.

Action item 4: Identify hazards associated with emergency and nonroutine situations

Emergencies present hazards that need to be recognized and understood. Nonroutine or infrequent tasks, including maintenance and startup/shutdown activities, also present potential hazards. Plans and procedures need to be developed for responding appropriately and safely to hazards associated with foreseeable emergency scenarios and nonroutine situations.

How to accomplish it

Identify foreseeable emergency scenarios and non-routine tasks, taking into account the types of material and equipment in use and the location within the facility. Scenarios such as the following may be foreseeable:

  • Fires and explosions
  • Chemical releases
  • Hazardous material spills
  • Startups after planned or unplanned equipment shutdowns
  • Nonroutine tasks, such as infrequently performed maintenance activities
  • Structural collapse
  • Disease outbreaks
  • Weather emergencies and natural disasters
  • Medical emergencies
  • Workplace violence

Action item 5: Characterize the nature of identified hazards, identify interim control measures, and prioritize the hazards for control

The next step is to assess and understand the hazards identified and the types of incidents that could result from employee exposure to those hazards. This information can be used to develop interim controls and to prioritize hazards for permanent control (see “Hazard Prevention and Control”).

How to accomplish it

  • Evaluate each hazard by considering the severity of potential outcomes, the likelihood that an event or exposure will occur, and the number of employees who might be exposed.
  • Use interim control measures to protect employees until more permanent solutions can be implemented.
  • Prioritize the hazards so that those presenting the greatest risk are addressed first. Note, however, that employers have an ongoing obligation to control all serious recognized hazards and to protect employees.
Hazard Control

To effectively control and reduce hazards, the district should:

  • Involve employees, who often have the best understanding of the conditions that create hazards and insights into how they can be controlled.
  • Identify and evaluate options for controlling hazards, using a “hierarchy of controls.”
  • Use a hazard control plan to guide the selection and implementation of controls, and implement controls according to the plan.
  • Develop plans with measures to protect employees during emergencies and nonroutine activities.
  • Evaluate the effectiveness of existing controls to determine whether they continue to provide protection, or whether different controls may be more effective. Review new technologies for their potential to be more protective, more reliable, or less costly.

Action item 1: Identify control options

A wealth of information exists to help administrators examine options for controlling identified hazards. Before selecting any control options, it is essential to solicit employees’ input on their feasibility and effectiveness.

How to accomplish it

  • Review sources such as OSHA standards and guidance, industry consensus standards, NIOSH publications, manufacturers’ literature, and engineering reports to identify potential control measures. Keep current on relevant information from trade or professional associations.
  • Investigate control measures used in other workplaces and determine whether they would be effective at your workplace.
  • Get input from employees who may be able to suggest and evaluate solutions based on their knowledge of the facility, equipment, and work processes.
  • For complex hazards, consult with safety and health experts, including OSHA’s On-site Consultation Program.

Action item 2: Select controls

Employers should select the controls that are the most feasible, effective, and permanent.

How to accomplish it

  • Eliminate or control all serious hazards (hazards that are causing or are likely to cause death or serious physical harm) immediately.
  • Use interim controls while you develop and implement longer-term solutions.
  • Select controls according to a hierarchy that emphasizes engineering solutions (including elimination or substitution) first, followed by safe work practices, administrative controls, and finally PPE.
  • Avoid selecting controls that may directly or indirectly introduce new hazards. Examples include exhausting contaminated air into occupied work spaces or using hearing protection that makes it difficult to hear backup alarms.
  • Review and discuss control options with employees to ensure that controls are feasible and effective.
  • Use a combination of control options when no single method fully protects employees.

Whenever possible, select equipment, machinery, and materials that are inherently safer based on the application of “Prevention through Design” (PtD) principles. Apply PtD when making your own facility, equipment, or product design decisions. For more information, see the link to the NIOSH PtD initiative on the recommended practices Web page.

Action item 3: Develop and update a hazard control plan

A hazard control plan describes how the selected controls will be implemented. An effective plan will address serious hazards first. Interim controls may be necessary, but the overall goal is to ensure effective long-term control of hazards. It is important to track progress toward completing the control plan, and periodically (at least annually and when conditions, processes, or equipment change) verify that controls remain effective.

How to accomplish it

  • List the hazards needing controls in order of priority.
  • Assign responsibility for installing or implementing the controls to a specific person or persons with the power or ability to implement the controls.
  • Establish a target completion date.
    • Plan how you will track progress toward completion.
    • Plan how you will verify the effectiveness of controls after they are installed or implemented.

Action item 4: Select controls to protect employees during nonroutine operations and emergencies

The hazard control plan should include provisions to protect employees during nonroutine operations and foreseeable emergencies. Depending on the workplace, these could include fires, explosions, chemical releases, hazardous material spills, unplanned equipment shutdowns, infrequent maintenance activities, natural and weather disasters, workplace violence, terrorist or criminal attacks, disease outbreaks (e.g., pandemic influenza), or medical emergencies. Non-routine tasks, or tasks employees don’t normally do, should be approached with particular caution. Prior to initiating such work, review JSAs/JHAs with any employees involved and notify others about the nature of the work, work schedule, and any necessary precautions.

How to accomplish it

  • Develop procedures to control hazards that may arise during nonroutine operations (e.g., removing machine guarding during maintenance and repair).
  • Develop or modify plans to control hazards that may arise in emergency situations.
  • Procure any equipment needed to control emergency-related hazards.
  • Assign responsibilities for implementing the emergency plan.
  • Conduct emergency drills to ensure that procedures and equipment provide adequate protection during emergency situations.

Note: Depending on your location, type of business, and materials stored or used on site, authorities including local fire and emergency response departments, state agencies, the U.S. Environmental Protection Agency, the Department of Homeland Security, and OSHA may have additional requirements for emergency plans. Ensure that your procedures comply with these requirements.

Action item 5: Implement selected controls in the workplace

Once hazard prevention and control measures have been identified, they should be implemented according to the hazard control plan.

How to accomplish it

  • Implement hazard control measures according to the priorities established in the hazard control plan.
  • When resources are limited, implement measures on a “worst-first” basis, according to the hazard ranking priorities (risk) established during hazard identification and assessment. (Note, however, that regardless of limited resources, employers have an obligation to protect employees from recognized, serious hazards.)
  • Promptly implement any measures that are easy and inexpensive—such as general housekeeping, removal of obvious tripping hazards such as electrical cords, and basic lighting—regardless of the level of hazard they involve

Action item 6: Follow up to confirm that controls are effective

To ensure that control measures are and remain effective, employers should track progress in implementing controls, inspect and evaluate controls once they are installed, and follow routine preventive maintenance practices.

How to accomplish it

  • Track progress and verify implementation by asking the following questions:
    • Have all control measures been implemented according to the hazard control plan?
    • Have engineering controls been properly installed and tested?
    • Have employees been appropriately trained so that they understand the controls, including how to operate engineering controls, safe work practices, and PPE use requirements?
    • Are controls being used correctly and consistently?
  • Conduct regular inspections (and industrial hygiene monitoring, if indicated) to confirm that engineering controls are operating as designed.
  • Evaluate control measures to determine if they are effective or need to be modified. Involve employees in the evaluation of the controls. If controls are not effective, identify, select, and implement further control measures that will provide adequate protection.
  • Confirm that work practices, administrative controls, and PPE use policies are being followed.
  • Conduct routine preventive maintenance of equipment, facilities, and controls to help prevent incidents due to equipment failure.
Incident Analysis

Workplace incidents—including injuries, illnesses, close calls/near hits, and reports of other concerns—provide a clear indication of where hazards exist.  The purpose of analysis must always be to identify the root causes (and there is often more than one) of the incident or concern, in order to prevent future occurrences.

An Injury is broadly defined as an undesired event that results in physical harm to a person or damage to property and/or the interruption of a process.  It also includes events that result in a non-injury, a near hit, an occupational illness, or exposure to a hazardous substance. Districts encourage Injury prevention through aggressive incident analysis as a defense against hazards in the workplace. 

Analysts (such as supervisors, safety champion Steering Team members, external loss control specialists, witnesses, employee representatives) must determine the possible consequences that could take place if the situation is not corrected and take appropriate action based upon those findings (i.e. investigate, report, correct, etc.).

The first objective of Injury analysis is to find the facts.  The facts will then serve as a guide to the conditions that caused the Injury.  The facts should identify the “why” of the Injury as well as the “who, what, when and where.”  Since every Injury includes a sequence of contributing causes, it is possible to prevent a recurrence by recognizing and eliminating those causes. The removal of just a single cause can prevent a recurrence of an Injury/incident.

An analysis should be made as soon after the Injury as possible.  A delay of only a few hours may result in important evidence to be destroyed or removed by mistake.  A sample Injury Analysis   form is available.

Start with reviewing the Injury scene.  Reconstruct the events that led up to the Injury.  If necessary, consider taking pictures, measure, and draw a diagram.  Get a list of witnesses and interview the employee directly involved.  The following information lists a variety of subject areas that should be included in an Injury analysis.  Review the following items:

  • Work Characteristics- What is the type of work activity? How many employees are involved?
  • Environment- Was the weather a contributing factor?
  • Time Factors- The time of day, and how it relates to the shift?
  • Employee Characteristics- What is the age, health, gender, work experience? How often is the work activity repeated?  How often has the employee engaged in such work?  How much training and when was the last training?
  • A Narrative Description- Explain what the person was doing. What objects were involved?  What actions and movements led to the Injury?
  • Equipment Characteristics- If equipment is involved, describe the type, brand, model, size, and any distinguishing features, its condition, and the specific part of the equipment involved.
  • Characteristics of the Task- The general task being performed (removing a tire from bus) and the specific activity (using a power impact wrench). The posture and location of employee (kneeling in front of left front tire).  Working alone or with others.
  • Preventive Measures- What personal protective equipment was being worn? What kind of training did the employee receive for the task he or she was performing?  Did procedures exist?  Were they written?  Were they followed? Where was the supervisor at the time of the Injury?
  • Injury Severity- The nature of the injury or injuries and parts of the body affected.

After reviewing these statements, the final analysis should suggest specific corrective action or actions that will prevent recurrences of the sequence of events that led to the Injury.  Corrective action must focus on such things as eliminating unsafe conditions (mechanical or physical hazard) and correcting unsafe acts (employee deviates from instruction, policy, procedure or work practice).  The following steps should be followed in the analysis process:

Near Hits

A near-hit Injury is defined as an unplanned event where damage resulted but there was no personal injury to employees or where damage did not result but the likelihood of personal injury to the employee was great. If the conditions which permitted the near-hit or "close call" to exist are not eliminated, they will continue to exist, making it likely that additional Injuries could occur which could eventually result in personal injury to the employee.  Whenever there is an incident that did not, but could have, resulted in serious injury to an employee, the incident will be investigated by the school district Safety Officer and the area supervisor. 

Minor Injuries (Requiring doctor/outpatient care)-

After the emergency actions following an Injury, an analysis of the Injury should be conducted by the immediate supervisor in conjunction with any witnesses to the Injury, to determine the causes. The findings of the analysis should be documented and attached to the Injury/Incident form and submitted to Human Resources (HR will forward a summary to the Safety Steering).

Major Injuries (Fatality or hospitalization)-

The superintendent and a human resources representative must be notified immediately by the person in charge.  An analysis under the direction of the HR  Director and/or Safety Champion must be conducted.  The analysis team may include a risk manager, loss control specialist, supervisor of the injured person(s), a representative from the Safety Steering Team, and an employee representative.

In the case of death, probable death or the inpatient hospitalization of one or more employees, Human Resources should contact the Department of Labor.

The Safety Steering Team reviews the Injury reports at each of its regularly scheduled meetings.

How to accomplish it

  • Develop a clear plan and procedure for conducting incident analysis so that it can begin immediately when an incident occurs. The plan should cover items such as:
    • Who will be involved.
    • Lines of communication.
    • Materials, equipment, and supplies needed.
    • Reporting forms and templates.
  • Train investigative teams on incident investigation techniques, emphasizing objectivity and open-mindedness throughout the investigation process.
  • Conduct investigations with a trained team that includes representatives of both management and employees.
  • Investigate close calls/near hits.
  • Identify and analyze root causes to address underlying program shortcomings that allowed the incidents to happen.
  • Communicate the results of the investigation to managers, supervisors, and employees to prevent recurrence.

OSHA/PESH has special reporting requirements for work-related incidents that lead to serious injury or a fatality (29 CFR 1904.39). OSHA/PESH must be notified within 8 hours of a work-related fatality, and within 24 hours of an amputation, loss of an eye, or inpatient hospitalization.

Effective incident analysis does not stop at identifying a single factor that triggered an incident.    If a piece of equipment fails, a good analysis asks: “Why did it fail?” “Was it maintained properly?” “Was it beyond its service life?” and “How could this failure have been prevented?” Similarly, a good incident analysis does not stop when it concludes that a employee made an error. It asks such questions as: “Was the employee provided with appropriate tools and time to do the work?” “Was the employee adequately trained?” and “Was the employee properly supervised?”

Safety And Health Education And Training

Education and training provides administrators, managers, supervisors, and employees with:

  • Knowledge and skills needed to do their work safely and avoid creating hazards that could place themselves or others at risk.
  • Awareness and understanding of workplace hazards and how to identify, report, and control them.
  • Specialized training, when their work involves unique hazards.

People need both education and training to improve.    Because some people intuitively understand the difference between education and training, misusing these terms can actually lead to problems.  Employee may perceive training as a step-by-step procedure or program with no room for individual creativity, ownership, or empowerment.   Educating employees about the principle or rationale behind a particular safety policy, program or process will encourage them to participate fully.  They will perceive the program as an opportunity to make a difference, rather than as a requirement.

Education will influence attitudes, beliefs, values, intentions and perceptions, whereas training influences behaviors. Together, they encourage employees to be members of an actively caring community and empowered to go beyond the call of duty for safety.   It is important that plans recognize that teaching styles are not the same for education and training.  Also, employees learn in different ways.

Training is necessary to follow up safety education. The district should conduct job specific safety training for new employees and those transferred from another department before a person is assigned tasks that requires that training.  Standard approaches to safety and health training may include the following topics.  These should be organized in tables or matrices adapted to the specific work area:

  1. Aerial Platform Safety
  2. Agricultural Tractors
  3. Asbestos Awareness
  4. Back, Spine and Torso
  5. Bloodborne Pathogens
  6. Bullying Prevention/Intervention
  7. Chemical Hygiene Officer
  8. Confined Space Entry
  9. Defensive Driving
  10. Emergency Procedures
  11. Ergonomics Awareness
  12. Fall Protection
  13. Fire Extinguisher Use
  14. First Aid/CPR/AED
  15. Forklift Operations
  16. Hand and Portable Power Tools
  17. Hazardous Chemicals
  18. Hearing Conservation
  19. Heat Illness Prevention
  20. Ladders
  21. Lead Paint         
  22. Lockout/Tag Out
  23. Materials Handling
  24. Medically Fragile Children
  25. Office Safety
  26. Personal Protective Equipment
  27. Pesticide Application
  28. Power Lawnmowers
  29. Respiratory Protection
  30. Restraint Training
  31. Safe Student Transfers (lifting)
  32. Scaffolds
  33. Slip and Fall Prevention
  34. Sprain/Strain Prevention
  35. Stress Management
  36. Welding
  37. Workplace Violence/Harassment

Both the employee and the supervisor should document any job specific required training. The Human Resources department should maintain records of such training.   

Various training materials are available, including videos, slide presentations, web-based courses, fact sheets, exercises and games.

Additional training may be needed depending on the roles assigned in the program. For example, employers, managers, and supervisors may need specific training to ensure that they can fulfill their roles in providing leadership, direction, and resources for the safety and health program. Employees assigned specific roles in the program (e.g., incident investigation team members) may need training to ensure their full participation in those functions.

Effective training and education can be provided outside a formal classroom setting. Peer-to-peer training, on-the-job training, and worksite demonstrations can be effective in conveying safety concepts, ensuring understanding of hazards and their controls, and promoting good work practices.

Action item 1: Provide program awareness training

Managers, supervisors, and employees all need to understand the program’s structure, plans, and procedures. Having this knowledge ensures that everyone can fully participate in developing, implementing, and improving the program.

How to accomplish it

  • Provide training to all managers; supervisors; employees; and contractor, subcontractor, and temporary agency employees on:
    • Safety and health policies, goals, and procedures
    • Functions of the safety and health program
    • Whom to contact with questions or concerns about the program (including contact information)
    • How to report hazards, injuries, illnesses, and close calls/near misses
    • What to do in an emergency
    • The employer’s responsibilities under the program
    • Employees’ rights under OSHA/PESH.
  • Provide information on the safety and health hazards of the workplace and the controls for those hazards.
  • Ensure that training is provided in the language(s) and at a literacy level that all employees can understand.
  • Emphasize that the program can only work when everyone is involved and feels comfortable discussing concerns; making suggestions; and reporting injuries, incidents, and hazards.
  • Confirm, as part of the training, that all employees have the right to report injuries, incidents, hazards, and concerns and to fully participate in the program without fear of retaliation.

Action item 2: Train employers, managers, and supervisors on their roles in the program

Employers, managers, and supervisors are responsible for employees’ safety, yet sometimes have little training on safety-related concepts and techniques. They might benefit from specific training that allows them to fulfill their leadership roles in the program.

How to accomplish it

  • Reinforce employers, managers, and supervisors’ knowledge of their responsibilities under the OSH Act and the employees’ rights guaranteed by the Act.
  • Train employers, managers, and supervisors on procedures for responding to employees’ reports of injuries, illnesses, and incidents, including ways to avoid discouraging reporting.
  • Instruct employers, managers, and supervisors on fundamental concepts and techniques for recognizing hazards and methods of controlling them, including the hierarchy of controls (see “Hazard Prevention and Control”).
  • Instruct employers, managers, and supervisors on incident investigation techniques, including root cause analysis.

Action item 3: Train employees on their specific roles in the safety and health program

Additional training may be needed to ensure that employees can incorporate any assigned safety and health responsibilities into their daily routines and activities.

How to accomplish it

  • Instruct employees on how to report injuries, illnesses, incidents, and concerns. If a computerized reporting system is used, ensure that all employees have the basic computer skills and computer access sufficient to submit an effective report.
  • Instruct employees assigned specific roles within the safety and health program on how they should carry out those responsibilities, including:
    • Hazard recognition and controls (see Action item 4)
    • Participation in incident investigations
    • Program evaluation and improvement
  • Provide opportunities for employees to ask questions and provide feedback during and after the training.
  • As the program evolves, institute a more formal process for determining the training needs of employees responsible for developing, implementing, and maintaining the program.

Action item 4: Train employees on hazard identification and controls

Providing employees with an understanding of hazard recognition and control, and actively involving them in the process, can help to eliminate hazards before an incident occurs.

How to accomplish it

  • Train employees on techniques for identifying hazards, such as job hazard analysis (see OSHA Publication 3071).
  • Train employees so they understand and can recognize the hazards they may encounter in their own jobs, as well as more general work-related hazards.
  • Instruct employees on concepts and techniques for controlling hazards, including the hierarchy of controls and its importance.
  • Train employees on the proper use of work practice and administrative controls.
  • Train employees on when and how to wear required PPE.
  • Provide additional training, as necessary, when a change in facilities, equipment, processes, materials, or work organization could increase hazards, and whenever a employee is assigned a new task.
Empowerment And Ongoing Engagement Practices
  1. SHARED VISION AND PRINCIPLES
  2. MISSION STATEMENT
  3. CRITICAL HUMAN ELEMENT
  4. ACTIVE CARING and PERSON-BASED INJURY PREVENTION
  5. GROWTH MINDSETS and EMOTIONAL INTELLIGENCE
  6. “SAFETY SPOTTERS”
  7. BUILDING AND SUSTAINING MOMENTUM
  8. ACHIEVEMENT ORIENTATION
  9. GROUP PROBLEM SOLVING
  10. BOTTOM UP INVOLVEMENT
  11. SYSTEMS APPROACH
  12. FACT FINDING
  13. PROACTIVITY
  14. POSTER CAMPAIGNS
  15. OVERCOMING RESISTANCE TO CHANGE
  16. SOCIAL RESPONSIBILITY
PESH Information And Compliance

The Public Employee Safety and Health Bureau (PESH), created in 1980, enforces safety and health standards promulgated under the United States Occupational Safety and Health Act (OSHA) and several state standards.

The district is required to maintain the PESH 300 Log. This is a record of all employees that require medical treatment as defined by PESH. Staff members at each School and Department should be trained to maintain the required records. The specific requirements are:

  1. The log must be kept separate for each establishment (building).
  2. The log must be maintained on a calendar year basis.
  3. The log must be posted in each establishment during the month of February, March and April for the previous year. Directions for posting are on the form. Personnel information should not be posted.
  4. The log for each establishment must be available in that establishment.
  5. The requirements to record an injury in the log are defined in the guidelines. It is a requirement to record illnesses as well as deaths.

Record keeping guidelines are available from PESH.  Assistance can be obtained from PESH for interpreting the reporting instructions. 

The Total Case Incident Rate (TCIR) is defined as the number of work-related injuries per 100 full-time employees during a one year period. It is often also referred to as the OSHA incident rate or total recordable incident rate (TRIR). The TCIR and TRIR are calculated the same way and can be used interchangeably. OSHA uses the TCIR to monitor high-risk industries.   Districts can track the frequency of workplace injuries and illnesses over time and discover patterns across different departments or facilities. The TCIR or TRIR by using the following formula:    (Number of OSHA Recordable injuries and illnesses X 200,000) / Employee total hours worked = Total Case Incident Rate

To break this formula down, districts multiply the number of OSHA Recordable injuries and illnesses occurring throughout the year by 200,000. 

The OSHA Recordkeeping Guide explains how to determine an OSHA recordable injury.

Important Links:

https://labor.ny.gov/employeeprotection/safetyhealth/DOSH_PESH.shtm

https://www.osha.gov/

Public Employee Safety and Health Bureau
The Public Employee Safety and Health Bureau (PESH) was created in 1980 to give occupational safety and health protection to all public sector employees. As a unit within the NYS Dept. of Labor, Division of Occupational Safety and Health (DIOSH), it enforces safety and health standards promulgated under the United States Occupational Safety and Health Act and several state standards. To learn more go to:
Public Employee Safety and Health Bureau

PESH Explained

PESH "Essentials"

Fact Sheet - Employee Rights

NYS Safety, Loss Consultation And Incentive Programs

COMPULSORY WORKPLACE SAFETY AND LOSS CONSULTATION PROGRAM

The New York Compulsory Workplace Safety and Loss Consultation Program is a program administered by the Department of Labor that requires employers with poor safety records to hire consultants to identify safety issues and then implement a plan to remedy those issues. Carriers shall impose a 5% premium surcharge on an employer subject to the Compulsory Workplace Safety and Loss Consultation Program for failure to initiate a required safety program or implement the recommendations of a certified loss consultant. Note: An additional 5% charge shall be made in each successive year of noncompliance (e.g., first year, 5%; second year, 10%; third year, 15%; etc.)

217

WORKPLACE SAFETY AND LOSS PREVENTION INCENTIVE PROGRAM

The New York State Workplace Safety and Loss Prevention Incentive Program (WSLPIP) is a program administered by the Department of Labor that grants premium credits, as set forth by the NYS Department of Financial Services, to eligible employers who implement one or more of the following programs:

  1. Safety Incentive Program - Insurance carriers will apply a premium credit to qualified employers for the implementation of an approved safety incentive program.
  2. Drug and Alcohol Prevention Program - Insurance carriers will apply a premium credit to qualified employers for the implementation of an approved drug and alcohol prevention program.
  3. Return to Work Program - Insurance carriers will apply a premium credit to qualified employers for the implementation of an approved return to work program.
Topical References

ESSENTIAL DISTRICT WIDE RISK IMPROVEMENT PROGRAMS

ERGONOMICS

Ergonomics is the science and practice of designing jobs or workplaces to match the capabilities and limitations of the human body. A goal of ergonomics is to reduce work-related musculoskeletal disorders by adapting the work to fit the person, instead of forcing the person to adapt to the work. Careful study of relationships between environment and behaviors is the first step in ergonomics. Actions plans for adjustments of working conditions and/or equipment may follow.  An effective ergonomics initiative consists of the following four elements:

  • Worksite analysis: a safety and health review that identifies jobs and workstations (including computer/desk workstations) that may contain musculoskeletal hazards, the risk factors that pose the hazards, and the causes of the risk factors.
  • Hazard prevention and control: eliminating or minimizing the hazards identified in the workplace analysis by changing the jobs, workstations, tools or environment to fit the worker.
  • Medical management: the effective use of available health-care resources to prevent or manage work-related musculoskeletal disorders.
  • Training and education: a method to give both workers and supervisors an understanding of the potential risk of injuries, their causes, symptoms, prevention and treatment.

District employees should report suspected, potential, or known ergonomic hazards to their supervisor or to the district Safety Champion.  An employee who feels that they are experiencing symptoms of an ergonomics injury should report the injury to their supervisor. Once a suspected, potential, known ergonomic hazard or an injury has been reported, the employee's supervisor will insure an investigation is conducted to determine what can be done to reduce symptoms or eliminate the hazard.

If a job activity is determined as having an ergonomic hazard, the hazardous condition will be reduced below the hazard level or to the degree technologically and economically feasible.

PREVENTION PRACTICES FOR SPECIFIC TOPICS 

The topics for injury prevention practices are wide ranging. Helpful information is available from numerous sources. 

AERIAL LIFTS

Aerial lifts are vehicle-mounted, boom-supported aerial platforms, such as cherry pickers or bucket trucks, used to access utility lines and other aboveground job sites. The major causes of fatalities are falls, electrocutions, and collapses or tip overs. Employers must take measures to ensure the safe use of aerial lifts by their employees if they are required to use this equipment in the course of their employment.

Employees using aerial lifts can be injured or killed if they don’t know how to operate them safely. According to the Center for Construction Research and Training (CPWR) about 26 employees die every year using aerial lifts. Causes range from electrocutions, falls and tip-overs to being caught between the bucket or guardrail and an object.

First steps

Before attempting to use an aerial lift bucket, CPWR states, employees should thoroughly inspect all operating and emergency controls, as well as guardrails, fall protection gear and any other items specified by the machine’s manufacturer. Check that the lift has no missing or broken parts. Then, survey the area where the lift will be used. Aerial lifts should be used on level surfaces that won’t shift. Look for hazards such as overhead power lines, drop-offs, holes and other obstructions. Finally, be sure to set outriggers, wheel chocks and brakes, even if the lift is on a level surface.

Supervisors should ensure any aerial lift operator or employee is trained, qualified and experienced with the model he or she will be using.

Incident prevention

When operating an aerial lift or working in a lift bucket, ensure the platform’s chains or doors are closed, don’t exceed the lift’s load capacity limits, and place warning cones and signs around the lift when working near traffic. Other tips from CPWR:

Prevent electrocutions: Stay a minimum of 10 feet away from overhead power lines, and be aware that insulated buckets won’t protect a employee if electricity has another path to the ground, such as a employee touching another wire.

Prevent falls: OSHA requires either a full-body harness or other positioning device on bucket trucks or boom lifts.

Prevent tip-overs: Never drive when the lift platform is elevated, unless the manufacturer specifically states otherwise, and refrain from exceeding reach limits

Safe Work Practices

  • Make sure that employees who operate aerial lifts are properly trained in the safe use of the equipment.
  • Maintain and operate elevating work platforms according to the manufacturer's instructions.
  • Never override hydraulic, mechanical, or electrical safety devices.
  • Never move the equipment with employees in an elevated platform unless this is permitted by the manufacturer.
  • Do not allow employees to position themselves between overhead hazards, such as joists and beams, and the rails of the basket. Movement of the lift could crush the employee(s).
  • Maintain a minimum clearance of at least 10 feet, or 3 meters, away from the nearest energized overhead lines.
  • Always treat power lines, wires and other conductors as energized, even if they are down or appear to be insulated.
  • Use a body harness or restraining belt with a lanyard attached to the boom or basket to prevent the employee(s) from being ejected or pulled from the basket.
  • Set the brakes and use wheel chocks when on an incline.
  • Use outriggers, if provided.
  • Do not exceed the load limits of the equipment. Allow for the combined weight of the employee, tools and materials.

https://www.osha.gov/Publications/aerial_lifts_safety.html

https://www.osha.gov/Publications/aerial-lifts-factsheet.html


BACK, TORSO AND SPINE CARE

Back injuries can strike just anyone regardless of the job.  Lifting is the most common task associated with low-back injuries.   


BLOOD BORNE PATHOGENS

Blood borne pathogens are infectious microorganisms in human blood that can cause disease in humans. These pathogens include, but are not limited to, hepatitis B (HBV), hepatitis C (HCV) and human immunodeficiency virus (HIV). Needle sticks and other sharps-related injuries may expose employees to blood borne pathogens. Employees in many occupations, including first responders, housekeeping personnel in some industries, nurses and other healthcare personnel, all may be at risk for exposure to blood borne pathogens.

In order to reduce or eliminate the hazards of occupational exposure to blood borne pathogens, the district must implement an exposure control plan for the worksite with details on employee protection measures. The plan must also describe how the district will use engineering and work practice controls, personal protective clothing and equipment, employee training, medical surveillance, hepatitis B vaccinations, and other provisions as required by OSHA's Blood borne Pathogens Standard (29 CFR 1910.1030).

Engineering controls are the primary means of eliminating or minimizing employee exposure and include the use of safer medical devices, such as needleless devices, shielded needle devices, and plastic capillary tubes.

For  schools with a  clinic or nurses on staff, and there is a possibility of exposure to blood borne pathogens there must be a blood borne pathogens exposure control plan. This plan may require the use of needleless sharps or sharps with engineered controls to protect employees and the public, as well as specific reporting requirements, medical treatment, and post-exposure follow up for needle stick incidents. Employee training in the proper use of sharps, personal protective equipment, personal hygiene, handling of contaminated sharps or laundry, and other actions to reduce the risk of a needle stick incident are also included in the blood borne pathogens exposure control plan.

https://www.osha.gov/SLTC/bloodbornepathogens/


BURN PREVENTION

While burn exposure is common in school kitchens, there are also many other workplaces with exposure to thermal, chemical, and electrical burns.  Sun burn prevention is also important for school employees and teachers. Three essential elements of prevention are described below.

Initial Training

Training should cover not only the hazards that the employee might face on their worksite, but also an overview of OSHA standards and how to identify hazards that may not have been covered. OSHA 10-hour training is a great way to get a baseline of safety standards training before an employee ever even starts receiving worksite-specific training. Then, employers should make sure that the employees are trained on their specific job functions, including in-depth safety training with any machinery, chemicals or other worksite hazards specific to their job.

Refresher Training

In addition to training before ever even starting a job, districts should regularly update training so that employees are kept up-to-date with standard changes and  important concepts are kept at top-of-mind. Certificate training courses are a great way to re-train employees, and our online standards training topics can be taken 100% online for efficient and inexpensive refresher training.

Hazard Communication

Color codes, posters, labels or signs to warn employees of potential hazards are an employer requirement under the OSH Act, and these vital pieces of Hazard Communication are extremely important in burn prevention. Employees should be trained on how to recognize symbols and other hazard communication codes, and GHS communication standards should be used to identify material hazards in a consistent and easily recognizable way. When hazardous chemicals are found in the workplace, employers are also required to produce and provide a written Hazard Communication plan. These requirements, as well as an overview of GHS and the symbols now utilized in the United States are available.

Types of Workplace Burns

Thermal Burns — Thermal burns are burns caused by the heat from liquids (called "scalding" burns), open flames, hot objects and explosions. The most important priority with thermal burns is controlling and stopping the burning process. Thermal burns can be prevented by wearing Personal Protective Equipment, using fire prevention tactics, and by having procedures and emergency action plans related to fire detection and protection.

Chemical Burns — Chemical burns are the result of skin or eyes coming into contact with strong acids, alkaloids or other corrosive or caustic materials that eat away or "burn" skin and deeper tissue. In the workplace, these accidents can occur after exposure to industrial cleaners (such as rust removers or drain cleaners), chemicals in laboratories or manufacturing workplaces. One of the best ways to prevent chemical burns is to make sure all employees are well-versed in Hazard Communication, which covers the symbols and labels that will communicate chemical risk. These labels will also include the important information on the steps employees can take to prevent burns if they come into contact with dangerous chemicals. Employee who will come into contact with chemicals should consider Hazard Communication training and should also take refresher courses as these standards can be updated often.

Electrical Burns — Current travels through body and meets resistance in tissue, resulting in heat burn injuries. To avoid burns from electrical sources, high-voltage areas and machinery should be clearly marked. Employees should also make sure to identify live wires, avoid contact with water while working with electricity, and wear the personal protective equipment necessary to avoid burns by electricity. Additional information about the types of electrical hazards   OSHA standards is available.

Sun Exposure Burns — While these could technically be considered a thermal burn, sun exposure burns are worthy of special consideration. Employees who work under the sun should be well versed in the sun safety practices that will keep them safe, and should take precaution to reduce hours under harsh direct sun, seek shade if possible, and wear sun-protective work clothing, hats and sunscreen to reduce the risk of burns from sun exposure.

Burn Severity

  1. First Degree: First-degree burns cause minimal skin damage and are considered superficial since they affect the top layer of the skin. A mild sunburn is an example of this type of burn, where the burn site is red, painful, dry and without blister.
  2. Second Degree: The damage from a second-degree burn extends beyond the top layer of the skin and can often cause the skin to blister or become extremely red and sore.
  3. Third Degree: Third-degree burns destroy both the epidermis and the dermis, and they can also go as deep as to destroy tissue underneath. These burns can appear white or charred.
  4. Fourth Degree: In a fourth-degree burn, all skin layers are affected, and there is also potential for damage to muscle, tendons and bone. Skin grafts do not work on these severe burns, so much so that fourth-degree burns may require amputation if injury occurs in a limb or extremity.


CHEMICAL HYGIENE

A Chemical Hygiene Plan (CHP) provides for and supports procedures, equipment, personal protective equipment, and work practices to protect personnel from the potential health and physical hazards of laboratory work with hazardous chemicals, and complies with PESH.  Instilling a general understanding of safety in the school laboratory is the responsibility of the teacher. It is imperative to create a culture of safety in the science classroom from the first meeting of the class.  There are many resources to guide the educator in adopting an appropriate set of safety rules for a given laboratory setting. The list of rules can be extensive. The list for the students should be manageable and specific for a particular class and setting.  Guidelines should be given and explained to students. Providing a safety contract for the students and their parents (or guardians) to sign reinforces their commitment to safety.

IMPORTANT LINKS and DOCUMENTS

CDC School Chemistry Laboratory Safety Guide 
Mercury Report – Children's Exposure to Elemental Mercury 
EPA's Schools Chemical Cleanout Campaign

American Chemical Society

https://www.acs.org/content/acs/en/chemical-safety/basics.html


CHEMICAL STORAGE 

Safety Data Sheets (SDS)

SDSs provide students, researchers, employees, and emergency personnel with the proper procedures for handling a pure chemical, as well as information for what to do in an emergency situation involving the chemical.

Chemical manufacturers, distributors, or importers are required by the Occupational Safety and Health Administration (OSHA) to provide an SDS for any potentially hazardous chemical substance.  SDSs are part of the Globally Harmonized System for Hazard Communication (GHS). The GHS sets internationally agreed-to standards for hazard testing, warning pictograms, and more.

Purpose of an SDS

SDSs are designed to educate employees on how to prevent exposure and reduce workplace incidents involving chemicals. They are meant to always be consulted before working with a material or developing a new process.  If an exposure or incident does occur while using a product, the SDS for that product will have information about what to do.  An SDS is useful in this context only if a single chemical is involved. Many accidents occur as a result of mixtures of chemicals. Accidental mixtures of chemicals are not in the purview of SDSs.

How to Find an SDS

In general, one of the easiest ways to find an SDS for a specific chemical is through Google search. Enter:

  • Chemical name (e.g., sodium chloride)
  • "safety data sheet"
  • Manufacturer's name, if you have it.

So, a search will look something like this: "sodium chloride safety data sheet fisher scientific.” Chemical formulations can vary. If you're looking for an SDS for a specific consumer product, it's important to find the one from the manufacturer of that product.

Information Included in SDS

OSHA requires that every SDS provide information outlined in all of the following 16 categories:

  1. Identification
  2. Hazard(s) identification
  3. Composition/information on ingredients
  4. First-aid measures
  5. Fire-fighting measures
  6. Accidental release measures
  7. Handling and storage
  8. Exposure controls/personal protection
  9. Physical and chemical properties
  10. Stability and reactivity
  11. Toxicological information
  12. Ecological information
  13. Disposal considerations
  14. Transport information
  15. Regulatory information
  16. Other information

Uses for SDS

Any employee working in a laboratory using chemicals will need to use SDSs.  Outside of a laboratory, SDSs are only required for occupational use.   A district is required to maintain them for employees who will be working with a  hazardous chemical.

More About Safety Data Sheets

School Chemical Management and Storage Guidelines

Several publications are important for proper assessment, use and storage of chemicals.

The Chemical Guidance Manual was developed in cooperation with the New York State Department of Conservation and provides a framework to accomplish a complete assessment and inventory of the chemicals used and stored by a school district. It also provides guidance on a sustainable chemical management system and chemical hygiene plan.

The School Chemistry Laboratory Safety Guide produced by the The Consumer Product Safety Commission (CPSC) / National Institute for Occupational Safety and Health (NIOSH) School Chemistry Laboratory Safety Guide includes information related to safety in the high school chemistry laboratory.

Chemical Storage Guidelines is a NYSED publication that is intended to provide school faculty and staff with chemical storage guidelines pursuant to New York State Education Law, '305(19) Chapter 627 of the Laws of 1989.

Mercury

The New York State Department of Environmental Conservation (DEC) law applies to the presence and use of mercury and mercury added products in all New York State elementary and secondary schools.  Specific questions regarding the impact on schools due to this law are addressed in the Q & A document. Included are directions and information on the disposal of mercury and mercury added products presently used in schools across New York State.

New York State School Chemical Management Guidance Manual  

Chemical Storage Guidelines 

NIOSH Publication No. 2007-107: School Chemistry Laboratory Safety Guide, November 2006

Mercury in Schools - Q & A for Schools 


CONFINED SPACE ENTRY
CUT PREVENTION 
HAND AND PORTABLE POWER TOOLS
HAZARDOUS MATERIALS
HEARING CONSERVATION

Noise is defined as an unpleasant or unwanted sound; however, it can be much more than that. Noise can be a severe health hazard, because exposure to loud noise over a prolonged period of time can cause loss of hearing or a permanent ringing sound in one’s ear. This training course describes the hazards associated with high noise levels, identifies related responsibilities of both employees and employers, and describes the purpose of hearing tests. The various types of hearing protection devices are identified, and the process for selecting, fitting, using, caring for, and cleaning of those devices is reviewed.


HEAT ILLNESS
INDOOR AIR QUALITY
LADDER SAFETY
LEAD PAINT
LIFTING/MATERIAL HANDLING
LOCK-OUT/ TAG-OUT

Lockout/tagout is a safety procedure for de-energizing, disconnecting, and shutting down power sources to equipment so that it can be maintained or repaired without hazard to the employees authorized to work on this equipment. This course discusses procedure associated with lockout/tagout.


MACHINE GUARDING

Machine guarding is necessary for hazards associated with operating moving machinery and guides participants through scenarios to determine if common industrial machinery is properly/improperly guarded. Machinery discussed includes: Grinders, Saws, Power Presses and  


MOTOR VEHICLE OPERATION

All employees who are required to drive during the course of their work must have a valid driver's license appropriate to the type of vehicle(s) operated.  Any employee who does not hold a valid driver's license will not be allowed to operate a school district vehicle until such time he/she obtains a valid license.  All employees who are required to drive during the course of their work must have an acceptable driving record.

Employees will not engage in any activity which could interfere with their ability to operate a vehicle in a safe manner while on school district business.  Employees should follow all motor vehicle laws, posted signs and speed limits and take sufficient breaks when driving for extended periods of time.

The use of seat belts is required whenever a district employee operates or is a passenger in a district-owned, privately-owned, or rented vehicle while on official district business.  This requirement is based on the Washington Seat Belt Law as found in RCW 46.61.688.  The shoulder harness shall be worn over the shoulder and not placed under the arm.

Employees who operate district vehicles should perform a pre-operational inspection to check the readiness of the vehicle before the trip begins.  Employees should visually inspect the inside and outside of the vehicle and immediately report any defects, deficiencies, or damage.  If problems arise during operation, they should be reported when the vehicle is returned to the motor pool supervisor.

A master record is maintained on each district vehicle to record all expenses, mileage, maintenance and repairs.  Regular maintenance is scheduled based on the manufacturer’s recommendations. 

Any Injury and/or damage to a Motor Pool vehicle or any Injury and/or damage caused by a Motor Pool vehicle to another vehicle or property, however minor, must be reported to the Motor Pool administration as soon as possible after the occurrence.  For further information on vehicle Injurys see Section 6.

Use of Cellular Phones While Driving

Washington state law (RCW 46.61.667) makes both text messaging and cell phone use without a hands free device while driving a primary traffic offense. 

If an employee needs to make or receive a phone call while driving, the employee should make sure the vehicle is stopped and that he/she is parked in a lawfully designated parking area for the call.

Employees who use hands-free cellular phones are encouraged to keep business conversations brief while driving, and are encouraged to stop the vehicle and park in a proper parking area if the conversation becomes involved, traffic is heavy, or road or weather conditions are poor.

School Bus Operations

It shall be the responsibility of employees whose assignment includes operation of a school bus to meet and continue to meet the requirements set forth for School Bus Drivers in New York.

Employees who are required to have a commercial driver’s license to perform their job responsibilities are subject to drug and alcohol testing in compliance with the Federal Highway Administration, Department of Transportation, Federal Testing regulations (49 CFR Part 382). 

Tractors

Any employee who operates an agricultural tractor should be informed of the operating practices listed below and of any other practices dictated by the work environment. This   information should be provided to the employee at the time of initial assignment and at least annually thereafter.

Employee Operating Instructions:

  1. Securely fasten your seat belt if the tractor has a roll-over protection structure.
  2. Where possible, avoid operating the tractor near ditches, embankments and holes.
  3. Reduce speed when turning, crossing slopes and on rough, slick or muddy surfaces.
  4. Stay off slopes too steep for safe operation.
  5. Watch where you are going, especially at row ends, on roads and around trees.
  6. Passengers, other than persons required for instruction or machine operation, shall not be permitted to ride on equipment unless a passenger seat or other protective device is provided.
  7. Operate the tractor smoothly -- no jerky turns, starts, or stops.
  8. Hitch only to the drawbar and hitch points recommended by tractor manufacturers.
  9. When tractor is stopped, set brakes securely and use park lock if available.

The district will ensure that every employee who operates an agriculture tractor is trained specifically in the operation of the tractor to be used. The training must include an orientation of the operator to the topographical features of the land where the tractor will be operated. Training must emphasize safe operating practices to avoid rollover.

Riding Power Lawnmowers

Employee Operating Instructions

  • Understand all instructions for operating the mower that are in the manufacturer's instructions and on the machine.
  • Be thoroughly familiar with the controls and proper use of the mower before starting it.
  • Make sure the proper guards, plates, grass catcher or other safety devices are in place before starting the mower.


PERSONAL PROTECTIVE EQUIPMENT 

A hazard assessment will determine if personal protective equipment (PPE) is needed for a job or task.  A Hazard Assessment form is found with the PPE written program is available. 

PPE alone should not be relied on to provide protection until all other reasonable means of reducing hazards have been examined.  If the hazard assessment indicates a need for the use of PPE, the district should select and provide the appropriate equipment.  Personal protective equipment may include eye and face protection, foot protection, hand protection, head protection, hearing protection and protection from bloodborne pathogens. The school district Personal Protective Equipment program should be in a written program.

During the initial orientation and safety training, all employees whose position requires the use of personal protective equipment should be provided instruction by their supervisor or other designated employee.  Each affected employee should be trained to know at least the following:

  • When PPE is necessary
  • What PPE is necessary
  • How to put on, take off, adjust, and wear PPE
  • Limitations of PPE
  • Proper care, maintenance, useful life, and disposal of PPE

Each employee, before being allowed to perform work requiring the use of PPE should be able to demonstrate an understanding of the training provided and demonstrate the ability to use PPE correctly.  This training should be documented in writing.


PESTICIDE APPLICATION
POWERED INDUSTRIAL TRUCKS

Only forklift certified operators are allowed to operate the forklift.  These persons must f fulfill the training requirements   specified in [NY State regulation].  For more information regarding forklift operations see  “Powered Industrial Truck Safety”


RESPIRATORY PROTECTION
RESTRAINT TRAINING
SAFE STUDENT TRANSFERS
SCAFFOLDS
SLIP, TRIP & FALL PREVENTION
STUDENT FIGHT INTERVENTION 
WELDING
WORKPLACE VIOLENCE

Helpful Sources

Among the many outstanding resources for program development are the following:

OSHA

https://www.osha.gov/shpguidelines/employee-participation.html

Psychology of Safety, E. Scott Geller, 2001, CRC Press, LLC

Leading People Based Safety, E. Scott Geller, 2008, Coastal Training Technologies Corp.

Selected School Risk Sharing Entities:

  • Association of Schools for Cooperative Insurance Purchasing (CA)
  • ESD 112 Risk Management Fund (WA)
  • Missouri United Schools Insurance Council
  • New Jersey Schools Insurance Group
  • Pennsylvania School Boards Insurance Association
  • Schools Insurance Authority (CA)
Abbreviations And Glossary Of Terms

Abbreviations

CDC     Centers for Disease Control and Prevention

NIOSH National Institute for Occupational Safety and Health

OSHA   Occupational Safety and Health Administration

PPE      Personal Protective Equipment

PtD      Prevention through Design

SDS      Safety Data Sheet

SHARP Safety and Health Achievement Recognition Program

VPP      Voluntary Protection Programs 

Glossary of Terms

Close Call/Near Miss or Near Hit: An incident that could have, but did not, result in death, injury, or illness. They signal that hazards are not being adequately controlled or that new hazards have arisen.

Contractor: An individual or firm that agrees to furnish materials or perform services at a specified price.

Elimination: A change in process or workplace condition that removes the hazard or ensures that no employee can be exposed to a hazard under any foreseeable circumstances.

Hierarchy of Controls: A system for selecting and implementing the most effective control solutions for workplace hazards that includes:

  • Engineering controls.
  • Administrative controls.
  • Personal protective equipment.

This is known as the “hierarchy of controls” because they should be considered in the order presented. Controls at the top of the hierarchy are potentially more effective and more protective than those lower in the hierarchy.

Host Employer: An employer who has general supervisory authority over the worksite, including controlling the means and manner of work performed and having the power to correct safety and health hazards or require others to correct them.

Industrial Hygiene: The science of protecting and enhancing the health and safety of people at work and in their communities.

Job Hazard Analysis: A technique that focuses on job tasks as a way to identify hazards before they occur. It focuses on the relationships among the employee, the task, the tools, and the work environment.

Joint-employed Employee: A employee hired and paid by a staffing agency and assigned to Work for a host employer, whether or not the job is actually temporary.

Lagging Indicators: Measures of the occurrence and frequency of events in the past such as the number or rate of injuries, illnesses, and fatalities.

Leading Indicators: Measures intended to predict the occurrence of events in the future. Leading indicators are proactive, preventative, and predictive measures that provide information about the effective performance of safety and health program activities that can drive the control of workplace hazards.

Metrics: Measures of performance.

Multiemployer Worksite: Any worksite where two or more employers are present. See OSHA’s Multiemployer Citation Policy.

Non-routine Operations: Operations that do not occur frequently or that occur as a result of an emergency. peer-to-peer training: A type of on-the-job training where employees exchange information about hazards, controls, reporting procedures, and work procedures that are relevant to  the safety and health program.

Prevention through Design: A NIOSH national initiative to prevent or reduce occupational injuries, illnesses, and fatalities through the inclusion of prevention considerations in all designs that impact employees. PtD encompasses all of the efforts to anticipate and design out hazards to employees in facilities, work methods and operations, processes, equipment, tools, products, new technologies, and the organization of work.

Quantitative Exposure Assessment: Techniques used to quantitatively measure employees’ exposure to hazards, particularly health hazards, such as sampling for chemicals, dusts, biological organisms, noise, radiation, or other assessments. The purpose of such assessments is to quantify the level of employees’ exposure to a hazard. Also known as exposure monitoring.

“Risk”:  The uncertainty arising from hazard and exposure. Risk can be reduced by controlling or eliminating the hazard, or by reducing employees’ exposure to hazards. An assessment of risk helps employers understand hazards in the context of their own workplace, and prioritize hazards for permanent control.

Root Cause Analysis: A collective term that describes a wide range of approaches, tools, and techniques used to uncover causes of problems

Safety and Health Achievement An OSHA program that recognizes small business employers Recognition Program: who have used OSHA's On-site Consultation Program services and operate an exemplary injury and illness prevention program.

Safety Data Sheet: Written or printed material used to communicate the hazards of substances and chemical products to employees prepared in accordance with paragraph (g) of OSHA’s Hazard Communication standard.

Serious Hazards: Hazards that are causing or are likely to cause death or serious physical harm. See OSHA’s Field Operations Manual, Chapter 4.

Shortcoming: A fault, deficiency, or gap that results in a failure to meet program design criteria.

Staffing Agency: A firm that provides temporary employees to host employers. A staffing agency hires its own employees and assigns them to support or supplement a client’s workforce in situations involving employee absences, temporary skill shortages, seasonal workloads, and special projects.

Substitution: The replacement of toxic or hazardous materials (or the equipment or processes used with them) with ones that are less harmful.

Work Practices: A set of procedures for performing a specific work assignment safely.

 


©2018 Church Mutual Insurance Company. All rights reserved. CM Regent Insurance Company is a registered trademark of Church Mutual Insurance Company. NAIC #12356.

This material may include only a general description of insurance coverages and does not include all terms, conditions, and limitations found in CM Regent Insurance Company (“CM Regent”) policies. The insurance policy, not any general descriptions of coverage that many be found in this material, will form the contract between the insured and CM Regent. Neither CM Regent nor its employees, representatives, or agents shall be liable to any party for the use of any information of statements made or contained herein.