D.27 Small Business Safety and Health Handbook.pdf

Small Business Handbook

Small Business Safety and Health Management Series

OSHA 2209 02R 2005

Employers are responsible for providing a safe and healthy workplace for their employees. OSHA’s role is to promote the safety and health of America’s working men and women by setting and enforcing standards; providing training, outreach and educa-tion; establishing partnerships; and encouraging continual improvement in workplace safety and health.

About this Handbook

This handbook is provided to owners, propri-etors and managers of small businesses by the Occupational Safety and Health Administration (OSHA), an agency of the U.S. Department of Labor. For additional copies of this publication, write to the U.S. overnment Printing Office, ( PO), Superintendent of Documents, Mail Stop SDE, 732 N. Capitol Street, NW, Washington, DC 20401, or call the OSHA Publications Office at (202) 693-1888, or fax (202) 693-2498 for ordering infor-mation. Please note that the entire text of the Small Business Handbook is available on OSHA’s website at http://www.osha.gov/Publications/ osha2209.pdf.

The handbook should help small business em-ployers meet the legal requirements imposed by the Occupational Saf ty and H alth Act of 1970 (the Act), and achieve an in-compliance status before an OSHA inspection. An excellent resource to accom-pany this information is OSHA’s Safety and Health Program Management uidelines, (54 Federal Register 3904-3916, January 26, 1989), also avail-able on OSHA’s website.

This handbook is not a legal interpretation of the provisions of the Act and does not place any addi-tional requirements on employers or employees.

Employers cannot be cited under the eneral Duty Clause in Section 5(a)(1) of the Act for failure to fol-low recommendations in this handbook.

The materials in this handbook are based upon

Federal OSHA standards and other requirements in effect at the time of publication and upon generally accepted principles and activities within the job safety and health field. They should be useful to small business owners or managers and can be adapted easily to individual establishments.

It is important to point out that 24 states, Puerto

Rico and the Virgin Islands operate their own OSHA-approved safety and health programs under Section 18 of the Act. While the programs in these State Plan States may differ in some respects from Federal OSHA, this handbook can be used by employers in any state because the standards imposed by State Plan States must be at least as effective as Federal OSHA standards. A list of states that operate their own safety and health pro-grams can be found on OSHA’s website at www.osha.gov.

Material in this publication is in the public domain and may be reproduced, fully or partially, without permission. Source credit is requested but not required.

This information will be made available to sen-sory impaired individuals upon request by voice phone (202) 693-1999 or teletypewriter (TTY) (877) 889-5627.

Please Note: The small business employer seeking information on procurement or contracting with the Department of Labor or OSHA should contact the Department of Labor’s Office of Small Business Programs, 200 Constitution Avenue, NW, Room C- 2318, Washington, DC 20210.

http:www.osha.gov http://www.osha.gov/Publications

Small Business Handbook Occupational Safety and Health Administration U.S. Department of Labor

OSHA 2209-02R

U.S. Department of Labor www.osha.gov

Contents

PREFACE 4

Office of Small Business Assistance 4 Cooperative Programs 4 State Plans 4 Office of Training and Education 4 OSHA’s Website Safety and Health Add Value 5

INTRODUCTION: The Value of a Safety and Health Management System 6 A Profit and Loss Statement 6 Developing a Profitable Strategy for Handling Occupational Safety and Health 6

A FOUR-POINTWORKPLACE PRO RAM: The Basis of a Plan 8 Using the Four-Point Program 8

MANA EMENT COMMITMENTAND EMPLOYEE INVOLVEMENT 8

WORKSITEANALYSIS 9

HAZARD PREVENTIONAND CONTROL 9

TRAININ FOR EMPLOYEES, SUPERVISORSAND MANA ERS

DocumentingYour Activities 11 Safety and Health Recordkeeping 11

INJURY/ILLNESS RECORDS 11

EXPOSURE RECORDSAND OTHERS 12

STARTIN A SAFETYAND HEALTH MANA EMENT SYSTEM: Creating a Plan 13 Decide to Start Now 13 Designating Responsibility 13 Ask for Help 13 Organize the Workplace 14 Start athering Specific Facts About Your Situation 14 Establish a Four-Point Safety and Health Program Develop and Implement Your Action Plan 15

SELF-INSPECTION 17

PERSONAL PROTECTIVE EQUIPMENTAND CLOTHIN

POWDER-ACTUATEDTOOLS

Self-Inspection Scope 17 Self-Inspection Checklists 18

EMPLOYER POSTIN 18

RECORDKEEPIN 18

SAFETYAND HEALTH PRO RAM 18

MEDICAL SERVICESAND FIRSTAID 19

FIRE PROTECTION 19

ENERALWORK ENVIRONMENT 20

WALKWAYS 21

FLOORANDWALL OPENIN S 21

STAIRSAND STAIRWAYS 22

ELEVATED SURFACES 22

EXITIN OR E RESS - EVACUATION 22

EXIT DOORS 23

PORTABLE LADDERS 23

HAND TOOLSAND EQUIPMENT 24

PORTABLE (POWER OPERATED) TOOLSAND EQUIPMENT 24

ABRASIVEWHEEL EQUIPMENT RINDERS 24

MACHINE UARDIN 25

LOCKOUT/TA OUT PROCEDURES 26

WELDIN , CUTTIN AND BRAZIN 27

COMPRESSORSAND COMPRESSEDAIR 28

COMPRESSORS/AIR RECEIVERS 28

COMPRESSED AS CYLINDERS 29

HOISTANDAUXILIARY EQUIPMENT 29

INDUSTRIALTRUCKS - FORKLIFTS 29

SPRAYIN OPERATIONS 30

ENTERIN CONFINED SPACES 30

ENVIRONMENTAL CONTROLS 31

FLAMMABLEAND COMBUSTIBLE MATERIALS 32

HAZARDOUS CHEMICAL EXPOSURE 33

HAZARDOUS SUBSTANCES COMMUNICATION 34

ELECTRICAL 35

NOISE 37

FUELIN 37

IDENTIFICATION OF PIPIN SYSTEMS 37

MATERIALS HANDLIN 38

TRANSPORTIN EMPLOYEESAND MATERIALS 38

CONTROL OF HARMFUL SUBSTANCES BYVENTILATION 38

SANITIZIN EQUIPMENTAND CLOTHIN 39

TIRE INFLATION 39

ASSISTANCE IN SAFETYAND HEALTH FOR SMALL BUSINESSES 40

OSHA Assistance 40

OSHA’S OFFICE OF SMALL BUSINESSASSISTANCE 40

ON-SITE CONSULTATION 40

OTHER COOPERATIVE PRO RAMS 41

VOLUNTARY PROTECTION PRO RAMS (VPP) 42

OSHA STRATE IC PARTNERSHIP PRO RAM (OSPP) 42

OSHAALLIANCE PRO RAM 42

States with Approved Plans 42 OSHA Publications 42 Other Sources of Assistance 43

VOLUNTARY PROTECTION PRO RAMS PARTICIPANTS’ ASSOCIATION (VPPPA) 43

SMALL BUSINESS DEVELOPMENT CENTERS 43

NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETYAND HEALTH (NIOSH) 44

WORKERS’ COMPENSATION CARRIERSAND OTHER INSURANCE COMPANIES 44

TRADEASSOCIATIONSAND EMPLOYER ROUPS 44

TRADE UNIONSAND EMPLOYEE ROUPS 44

THE NATIONAL SAFETY COUNCIL AND LOCAL CHAPTERS 44

PROFESSIONALASSOCIATIONS 44

SPECIFIC MEDICAL CONSULTATION 44

YOUR LOCAL LIBRARY 45

FINANCIN WORKPLACE IMPROVEMENT 45

ADDITIONALWEB PA ES OF INTERESTTO SMALL BUSINESSES 45

Appendix A: Overall Action PlanWorksheet 46

Appendix B: Model Policy Statements 48

Appendix C: Codes of Safe Practices 49

Appendix D: OSHA Job Safety and Health Standards, Regulations and Requirements 50

Appendix E: Small Business Regulatory Enforcement FairnessAct of 1996 (SBREFA) 51

OSHA Regional Offices 52

OSHA’s Non-Retaliation Policy inside back cover

4 PREFACE

American employers and workers want safe and healthful places in which to work. They want everyone on the job to go home whole and healthy each day. Determined to make that dream possi-ble, OSHA is committed to assuring – so far as pos-sible – that every working man and woman in the nation has safe and healthful working conditions.

OSHA believes that providing workers with a safe workplace is central to their ability to enjoy health, security and the opportunity to achieve the American dream.

OSHA seeks to cut unnecessary rules, regula-tions and red tape. It is eliminating thousands of pages of outdated regulations and continues to rewrite standards in plain English. OSHA is paring down its regulatory agenda so that it more accu-rately reflects realistic goals that best serve the needs of American employers and employees.

Confronted by the realities and demands to keep pace with the workforce and problems of the future, OSHA is developing new strategies to reduce occupational fatalities, injuries and illness-

es. Coupled with strong, effective and fair enforce-ment, OSHA strives to provide improved outreach, education and compliance assistance to America’s employers and employees.

Office of Small Business Assistance

OSHA wants to provide quality service to our small business customers. In October 2002, OSHA created the Office of Small Business Assistance to provide small business direction, to facilitate infor-mation sharing and to help in finding and achieving regulatory compliance. The office also works to educate small businesses on using up-to-date tools and materials, and facilitates opportunities to com-ment on OSHA’s regulatory agenda. The Office of Small Business Assistance maintains OSHA’s spe-cialized small business web pages found at http:// www.osha.gov/dcsp/smallbusiness/index.html.

The Office of Small Business Assistance can be contacted by telephone at (202) 693-2220 or by writing to: Director, Office of Small Business Assistance, 200 Constitution Avenue, N.W., Room N-3700, Washington, DC 20210.

Cooperative Programs

Years of experience show us that voluntary col-laborative relationships between OSHA, the private sector and other government entities lead to improved safety and health. As a result, OSHA continues to expand its cooperative programs which currently include the free and confidential Consultation Program, the Voluntary Protection Programs, the Strategic Partnership Program and OSHA’s newest addition, Alliances. For a more detailed description of each of these programs, please see pages 40- 42.

Small businesses are encouraged to investigate the full array of cooperative programs offered by OSHA. Participation can be on an individual com-pany basis or through an industry association.

Detailed information on each program is also avail-able on OSHA’s website at www.osha.gov, by con-tacting any OSHA office, or by calling (800) 321-

OSHA.

State Plans

OSHA has important partnerships with the 24 states, Puerto Rico and the Virgin Islands that oper-ate their own OSHA-approved safety and health programs. State workplace safety and health pro-grams frequently lead the way in developing inno-vative approaches to making America’s workplaces safer and healthier.

States that operate their own worker safety and health plans must provide worker protection that is “at least as effective as” the Federal program.

However, because their standards and other proce-dures may vary, businesses should become famil-iar with their state regulations and agencies. See OSHA’s website for a list of State Plan States.

Office of Training and Education

OSHA’s Office of Training and Education provides training and instruction in all facets of occupational safety and health. OSHA’s Training Institute, located in Arlington Heights, IL, provides training for OSHA compliance safety and health officers as well as for the general public and safety and health staff from other Federal agencies. In addition to OSHA’s Training Institute, there are 32 additional education sites located throughout the country. These OSHA education centers operate in conjunction with universities, colleges and learning centers to conduct OSHA courses for the private sector and other Federal agencies, making safety and health training and education more accessible

OSHA HANDBOOK FOR SMALL BUSINESSES

www.osha.gov/dcsp/smallbusiness/index.html to those who need it. There are tuition fees for pri-vate sector students. For more information about OSHA’s Training Institute, OSHA’s education cen-ters, or to obtain training catalogs with course schedules, write the OSHA Training Institute, 2020 South Arlington Heights Road, Arlington Heights, IL 60005 or call (847) 297-4810. The information is also fully accessible on the Internet at www.osha.gov.

OSHA’s Website

OSHA has made every effort to continuously expand and improve its website. OSHA’s extensive website provides employers and employees with practical, easy-to-understand and up-to-date guid-ance on regulations, compliance assistance and learning how to identify and control hazards. Each OSHA cooperative program has individual web pages describing program elements and highlight-ing successes of the participants. Several pages are devoted to small business, technical links, news items, publication lists and an inventory of compli-ance assistance tools, including expert advisors and eTools. eTools are “stand-alone” interactive, web-based training tools on occupational safety and health topics. Regulations, standards, direc-tives and interpretations relating to OSHA can be found as well. There is a Spanish version of the OSHA website, and many posters and some publi-cations are also available in Spanish.

OSHA’s web pages include MyOSHA, which allows users to create their own personalized OSHA web page with customized content and links. Quick Start is another tool on OSHA’s Compliance Assistance web page that allows the user to identify many of the major OSHA require-ments and guidance materials that apply to their individual workplaces or industry sectors.

Through its website, OSHA invites citizens to e-mail questions that can be routed to appropriate agency officials for response. Any communication conducted via the “Contact Us” link on the OSHA website is considered an informational exchange rather than an official communication with the Department of Labor. For an official response to a question or concern, inquiries should be submitted in writing.

If you would like to receive regular updates from OSHA about new programs, tools, best prac-tices and other useful information, subscribe to the agency’s e-news memo, QuickTakes. QuickTakes is issued twice monthly to subscribers and is always available online. You can subscribe to OSHA’s QuickTakes at www.osha.gov.

Safety and Health Add Value

Addressing safety and health issues in the work-place saves the employer money and adds value to the business. Recent estimates place the business costs associated with occupational injuries at close to $170 billion–expenditures that come straight out of company profits.

When workers stay whole and healthy, the direct cost-savings to businesses include:

� lower workers’ compensation insurance costs;

� reduced medical expenditures;

� smaller expenditures for return-to-work programs;

� fewer faulty products;

� lower costs for job accommodations for injured workers;

� less money spent for overtime benefits.

Safety and health also make big reductions in indirect costs, due to:

� increased productivity;

� higher quality products;

� increased morale;

� better labor/management relations;

� reduced turnover;

� better use of human resources.

Employees and their families benefit from safety and health because:

� their incomes are protected;

� their family lives are not hindered by injury;

� their stress is not increased.

Simply put, protecting people on the job is in everyone’s best interest–our economy, our commu-nities, our fellow workers and our families. Safety and health add value to businesses, workplaces and lives.

Occupational Safety and Health Administration

6 INTRODUCTION: The Value of a Safety and Health Management System

A Profit and Loss Statement

As a small business owner, you are, by nature, a risk taker. You wager your business acumen against larger, perhaps more heavily financed cor-porate groups and other free-spirited, self-employ-ed individuals like yourself. There is excitement and challenge in such a venture, but to succeed you need good management information, an ability to be a good manager of people and the intelli-gence and inner strength to make the right deci-sions.

Thousands of workers die each year and many, many more suffer injury or illness from conditions at work. But how often does an owner or manager like you actually see or even hear about work-relat-ed deaths, serious injuries or illnesses in the busi-nesses with which you are familiar? How often has your business actually sustained this type of loss?

In most small businesses, the answer is rarely.

For this reason, many owners or managers do not understand why there is controversy about the Occupational Safety and Health Administration (OSHA), job safety and health standards, inspec-tions, citations, etc.

But others have learned why. Unfortunately, they have experienced a loss. These owner/man-agers will tell you that it is too late to do anything once a serious accident happens. They have learn-ed that prevention is the only real way to avoid this loss.

Reducing losses is a goal that you as an owner or manager share with us in OSHA. While we may see this goal in a slightly different light, it remains a common bond.

We have learned from small employers, like you, that you place a high value on the well-being of your employees. Like many small businesses, you may employ family members and personal acquaintances. And, if you don’t know your em-ployees before they are hired, then chances are that the very size of your workplace will promote the closeness and concern for one another that small businesses value.

Assuming that you are committed to safe and healthful work practices, OSHA wants to work with you to prevent all losses. We believe that, when you make job safety and health a real part of your every-day operations, you will not lose in the long run.

Investing in safety and health activity now will better enable you to avoid possible losses in the future.

Developing a Profitable Strategy for Handling Occupational Safety and Health

Nobody wants accidents to happen in his or her business. A serious fire, a permanent injury, or the death of an employee or owner can cause the loss of profit or even an entire business. To prevent such losses, you don’t have to turn your business upside down. You may not have to spend a lot of money, either. You do need to use good business sense and apply recognized prevention principles.

There are reasons why accidents happen.

Something goes wrong somewhere. It may take some thought, and maybe the help of friends or other trained people, to figure out what went wrong, but an accident always has a cause–a rea-son why. Once you know why an accident hap-pened, it is possible to prevent future incidents.

You need some basic facts and perhaps some help from others who already know some of the an-swers. You also need a plan–a plan to prevent accidents.

Not all dangers at your worksite depend on an accident to cause harm, of course. Worker expo-sure to toxic chemicals or harmful levels of noise or radiation may happen in conjunction with rou-tine work as well as by accident. You may not real-ize the extent of the exposure or harm that you and your employees face. The effect may not be imme-diate. You need a plan that includes prevention of these health hazard exposures and accidents. You need a safety and health management system.

It is not difficult to develop such a plan. Basi-cally, your plan should address the types of acci-dents and health hazard exposures that could hap-pen in your workplace. Because each workplace is different, your program should address your spe-cific needs and requirements.

There are four basic elements to all good safety and health programs. These are as follows:

1. Management Commitment and Employee Involvement. The manager or management team leads the way, by setting policy, assigning and sup-porting responsibility, setting an example and in-volving employees.

2.WorksiteAnalysis. The worksite is continually ana-lyzed to identify all existing and potential hazards.

3. Hazard Prevention and Control. Methods to pre-

OSHA HANDBOOK FOR SMALL BUSINESSES

vent or control existing or potential hazards are put in place and maintained.

4.Training for Employees, Supervisors and Managers. Managers, supervisors and employees are trained to understand and deal with worksite hazards.

Regardless of the size of your business, you should use each of these elements to prevent work-place accidents and possible injuries and illnesses.

Developing a workplace program following these four points is a key step in protecting you and your workers’ safety and health. If you already have a program, reviewing it in relation to these elements should help you improve what you have.

Following this four-point approach to safety and health in your business may also improve efficien-

cy. It may help you reduce insurance claims and other costs. While having a safety and health plan based on these four elements does not guarantee compliance with OSHA standards, the approach will help you toward full compliance and beyond.

It will certainly give you a way to express and doc-ument your good faith and commitment to protect-ing your workers’ health and safety.

This approach usually does not involve large costs. Developing a health and safety protection plan does not have to be expensive and generally does not require additional employees, especially in smaller businesses. Safety and health can be integrated into your other business functions with modest effort on your part.

The key to the success of a safety and health plan is to see it as a part of your business opera-tion and to see it reflected in your day-to-day oper-ations. As you implement the plan and incorporate it into your business culture, safety and health awareness will become second nature to you and your employees.

The next section provides short descriptions and illustrations of each element. Since most employers, like you, are pressed for time, these descriptions will assist you in getting started on your own approach.

Occupational Safety and Health Administration

8 A FOUR-POINTWORKPLACE PRO RAM: The Basis of a Plan

The Four-Point Workplace Program described here is based upon the Safety and Health Program Management uidelines issued by OSHA in January 1989. (For a free copy of the guidelines, go to OSHA’s website at www.osha.gov, write to OSHA Publications, U.S. Department of Labor, P.O.

Box 37535, Washington, DC 200013-7535, or call

(202) 693-1888.) Although voluntary, these guide-lines represent OSHA’s policy on what every work-site should have in place to protect workers from occupational hazards. The guidelines are based heavily on OSHA’s experience with its Voluntary Protection Programs (VPP), which recognize excel-lence in workplace safety and health management.

For more information on these guidelines and OSHA’s cooperative programs, contact OSHA’s Office of Small Business Assistance, U.S.

Department of Labor, 200 Constitution Avenue, NW, Room N-3700, Washington, DC 20210, (202) 693-2220.

Using the Four-Point Program

As you review this publication, we encourage you to use the Action Plan Worksheet in Appendix A to jot down the things you want to do to make your workplace safe for your employees. Noting those actions as you go along will make it easier to assemble the total plan you need.

MANA EMENT COMMITMENTAND

EMPLOYEE INVOLVEMENT

As the owner or manager of a small business, your attitude toward job safety and health will be reflected by your employees. If you are not inter-ested in preventing employee injury and illness, your employees will probably not give safety and health much thought either.

Therefore, it is essential that you demonstrate at all times your personal concern for employee safety and health, and the priority you place on them in your workplace. Your policy must be clear. Only you can show its importance through your own actions.

You can demonstrate the depth of your commit-ment by involving your employees in planning and carrying out your efforts. If you seriously involve your employees in identifying and resolving safety and health problems, they will bring their unique insights and energy to achieving the goals and objectives of your program. The men and women who work for you are among the most valuable assets you have. Their safety, health and goodwill are essential to the success of your business. Hav-ing them cooperate with you in protecting their safety and health not only helps to keep them healthy–it makes your job easier.

Here are some actions to consider:

� Post your policy on worker safety and health next to the Job Safety and Health Protection Poster where all employees can see it. (See Appendix B, Model Policy Statements.)

� Hold a meeting with all employees to commu-nicate your safety and health policy, and dis-cuss your objectives for safety and health.

� Make sure that your support is visible by get-ting personally involved in the activities that are part of your safety and health program.

For example, personally review all inspection and accident reports and ensure that follow-up occurs when needed.

� Ensure that you, your managers and your supervisors follow all safety requirements that apply to all employees, even if you are only in an area briefly. If, for instance, you require a hard hat, safety glasses and/or safety shoes in an area, wear them yourself when you are in that area.

� Take advantage of your employees’ special-ized knowledge and encourage them to buy into the program by having them make in-spections, conduct safety training, or investi-gate accidents.

� Make clear assignments of responsibility for every part of your safety and health program, and make sure everyone understands them.

The more people who are involved, the better.

A good rule of thumb is to assign safety and health responsibilities in the same way you assign production responsibilities. Make it a special part of everyone’s job to work safely.

� ive those with safety and health responsibili-ty enough people, time, training, money and authority to get the job done.

� Don’t forget your safety and health program after you make assignments; make sure the job gets done. Recognize and reward those who do well and correct those who don’t.

� At least once a year, review what you have accomplished in meeting your objectives and reevaluate whether you need new objectives or program revisions.

� Institute an accountability system where all personnel will be held accountable for not fol-lowing work rules designed to promote work-place safety and health.

WORKSITEANALYSIS

It is your responsibility to know what items or substances you have in your workplace that could hurt your workers. Worksite analysis is a group of processes that helps you make sure that you know what you need to keep your workers safe. For help in getting started with these processes, you can call on your state on-site Consultation Program and have an experienced health and safety professional visit your workplace for free and confidentially.

Locations for each state are listed on OSHA’s web-site. Also, OSHA’s booklet, Job azard Analysis, may be helpful. (See OSHA Publications at page 42 for ordering information.)

Here are some actions to consider:

� Request a consultation visit from your state on-site Consultation Program covering both safety and health to get a full survey of the hazards that exist in your workplace and those that could develop. You can also contract for such services from expert private consultants if you prefer.

� Establish a way to get professional advice when you make changes to procedures or equipment, to ensure that the changes are not introducing new hazards into your workplace.

Find ways to keep current on newly recog-nized hazards in your industry.

� Periodically review with employees each job, analyzing it step-by-step to see if there are any hidden hazards in the equipment or procedures.

� Set up a self-inspection system to check your hazard controls and evaluate any new haz-ards. The checklists (at pages 18-39) provide a starting point. Your state consultant can assist you in establishing an effective system.

� Make sure your employees feel comfortable in alerting you or another member of manage-ment when they see things that look danger-ous or out of place.

� Learn how to conduct a thorough investiga-tion when things go wrong. This will help you develop ways to prevent recurrences. Exten-sive information can be found on OSHA’s website under “Accident Investigation” in the index.

� Review several years of injury or illness rec-ords to identify patterns that can help you devise strategies to improve your safety and health program. Periodically review several months of experience to determine if any new patterns are developing.

HAZARD PREVENTIONAND CONTROL

Once you have identified your existing and potential hazards, you are ready to implement the systems that prevent or control those hazards.

Your state Consultation Program can help you do this. Whenever possible, hazards should be elimi-nated. Sometimes that can be done through sub-stitution of a less toxic material or engineering con-trols. When you cannot eliminate hazards, systems should be established to control them.

Here are some actions to consider:

� Set up safe work procedures based on an analysis of the hazards in your workplace and ensure that employees understand and follow them. It is a good idea to involve employees in the analysis that results in those procedures.

(See Appendix C, Codes of Safe Practices.)

� Be ready to enforce the rules for safe work procedures. Ask your employees to help you establish a disciplinary system that will be fair and understood by everyone.

� Where necessary, ensure that personal protec-tive equipment (PPE) is used and that your em-ployees know why they need it, how to use it and how to maintain it.

� Provide for regular equipment maintenance to prevent breakdowns that can create hazards.

Ensure that preventive and regular mainte-nance are tracked to completion.

� Plan for emergencies, including fire and natu-ral disasters. Conduct frequent drills to en-sure that all employees know what to do under stressful conditions.

� Ask your state consultant to help develop a medical program that fits your worksite. In-volve nearby doctors and emergency facilities by inviting them to visit your workplace and help you plan the best way to avoid injuries and illness during emergency situations.

� Ensure the ready availability of medical per-sonnel for advice and consultation on matters of employee health. This does not mean that you must provide health care, but you must be prepared to deal with medical emergencies or health problems connected to your work-place.

To fulfill the above requirements, consider the following:

� Develop an emergency medical procedure to handle injuries, transport ill or injured workers and notify medical facilities. Posting emer-gency numbers is a good idea.

� Survey the medical facilities near your place of business and make arrangements for them to handle routine and emergency cases. Co-operative agreements may be possible with nearby larger workplaces that have on-site medical personnel and/or facilities.

� Ensure that your procedure for reporting injuries and illnesses is understood by all employees.

� Perform routine walkthroughs of the worksite to identify hazards and to track identified haz-ards until they are corrected.

� If your business is remote from medical facili-ties, you are required to ensure that adequate-ly trained personnel are available to render first aid. First-aid supplies must be readily available for emergency use. Arrangements for this training can be made through your local Red Cross chapter, your insurance carri-er, your local safety council, and others.

� Check battery charging stations, maintenance operations, laboratories, heating and ventilat-ing operations and any corrosive materials areas to make sure the required eyewash facil-ities and showers are operational.

� Consider retaining a local doctor or an occu-pational health nurse on a part-time or as-needed basis for advice on medical and first aid planning.

TRAININ FOR EMPLOYEES, SUPERVISORS

AND MANA ERS

An effective accident prevention program re-quires proper job performance from everyone in the workplace.

As an owner or manager, you must ensure that all employees know about the materials and equip-ment they work with, known hazards and how to control the hazards.

Each employee needs to know that:

• no employee is expected to undertake a job until he or she has received job instructions on how to do it properly and is authorized to perform that job. Also,

• no employee should undertake a job that appears unsafe.

You may be able to combine safety and health training with other training, depending upon the types of hazards in your workplace.

Here are some actions to consider:

� Ask your state consultant to recommend train-ing for your worksite. The consultant may be able to conduct training while he or she is there.

� Make sure you have trained your employees on every potential hazard that they could be exposed to and how to protect themselves.

Then verify that they really understand what you taught them.

� Pay particular attention to your new employ-ees and to employees who are moving to new jobs. Because they are learning new opera-tions, they are more likely to get hurt.

� Train your supervisors to understand all the hazards faced by the employees and how to reinforce training with quick reminders and refreshers, or with disciplinary action if neces-sary.

� Make sure that your top management staff understand their safety and health responsibil-ities and how to hold subordinate supervisory employees accountable for theirs.

DocumentingYour Activities

Document your activities in all elements of the Four-Point Workplace Program. Essential records, including those legally required for workers’ com-pensation, insurance audits and government in-spections must be maintained as long as the actual need exists or as required by law. Keeping records of your activities, such as policy statements, training sessions, safety and health meetings, information distributed to employees, and med-ical arrangements made, is greatly encouraged.

Maintaining essential records also will demonstrate sound business management as supporting proof for credit applications, for showing “good faith” in reducing any proposed penalties from OSHA inspections, for insurance and other audits, and aid efficient review of your current safety and health activities for better control of your operations and to plan improvements.

Safety and Health Recordkeeping

Records of sales, costs, profits and losses are essential to all successful businesses. They enable the owner or manager to learn from experience and to make corrections for future operations.

Records of accidents, related injuries, illnesses and property losses can serve the same purpose, if they are used in the same way. The primary purpose of OSHA-required recordkeeping is to retain informa-tion about accidents that have happened to help determine the causes and develop procedures to prevent a recurrence.

INJURY/ILLNESS RECORDS

OSHA rules for recording and reporting occupa-tional injuries and illnesses affect 1.4 million estab-lishments. Small businesses with 10 or fewer employees throughout the year are exempt from most of the requirements of the OSHA recordkeep-ing rules, as are a number of specific industries in the retail, service, finance, insurance and real estate sectors that are classified as low-hazard.

Detailed information about OSHA recordkeeping rules can be found at http://www.osha.gov/record-keeping/index.html or refer to 29 Code of Federal Regulations (CFR) 1904 for the specific exceptions.

OSHA recordkeeping can help the small busi-ness employer evaluate the success of safety and health activities. Success can be measured by a reduction or elimination of employee injuries and illnesses during a calendar year.

The OSHA recordkeeping system has five steps:

1. Obtain a report on every injury or job-related ill-ness requiring medical treatment (other than basic first aid).

2. Record each injury or job-related illness on OSHA Form 300 (Log ofWork-Related Injuries and Illnesses) using the instructions provided.

3. Prepare a supplementary record of occupational injuries and illnesses for recordable cases on OSHA Form 301 (Injury and Illness Incident Report).

4. Every year, prepare an annual summary using OSHA Form 300A (Summary of Work-Related Injuries and Illnesses). Post it no later than February 1, and keep it posted until May 1. A good place to post it is next to the OSHA Workplace Poster.

5. Retain these records for at least five years.

Periodically review these records to look for any patterns or repeat situations. These records can help you to identify high-risk areas that require your immediate attention.

Basic OSHA recordkeeping requirements address only injuries and illnesses, so you might consider expanding your own records to include all

Occupational Safety and http://www.osha.gov/record incidents, including those where no injury or illness resulted. This information may assist you in pin-pointing unsafe conditions and/or procedures.

Safety councils, insurance carriers and others can assist you in instituting such a system.

The employer is required to report to OSHA within eight hours of the accident, all work-related fatalities or multiple hospitalizations that involve three or more employees.

Even if your business is exempt from routine recordkeeping requirements, you may be selected by the Federal Bureau of Labor Statistics (BLS) or a related state agency for inclusion in an annual sample survey. You will receive a letter directly from the agency with instructions, if you are selected.

EXPOSURE RECORDSAND OTHERS

In addition to injury/illness records, certain

OSHA standards require records on the exposure of employees to toxic substances and hazardous exposures, physical examination reports and employment records.

As you identify hazards, you will be able to determine whether these requirements apply to your workplace. Your records should be used in conjunction with your control procedures and with your self-inspection activity. They should not be considered merely as bookkeeping.

13 STARTIN A SAFETYAND HEALTH MANA EMENT SYSTEM: Creating a Plan

You can use this handbook to create a basic plan of action for starting a safety and health management system at your business. The action plan described in this section provides the most direct route to getting yourself organized to com-plete the Four-Point Program outlined in the previ-ous section.

Decide to Start Now

The time to start your safety and health man-agement system is now. You have a better picture of what constitutes a good safety and health pro-gram. Now you can address the practical concerns of putting these elements together and coming up with a program to suit your workplace.

Hopefully, you have been taking notes for your action plan as you reviewed the preceding de-scription of the Four-Point Program. You should now be ready to decide what you want to accom-plish and to determine what steps are necessary to achieve your goals. Next you need to deter-mine how and when each step will be done and who will do it.

Your plan should consider your company’s immediate needs and provide for ongoing, long-lasting worker protection. Once your plan is designed, it is important to follow through and use it in the workplace. You will then have a pro-gram to anticipate, identify and eliminate condi-tions or practices that could result in injuries and illnesses.

If you have difficulty deciding where to begin, a phone call to your state Consultation Program will help get you started. A state consultant will survey your workplace for existing or potential hazards.

Then, if you request it, he or she will determine what you need to make your safety and health pro-gram effective. The consultant will work with you to develop a plan for making these improvements and to keep your program effective.

Whether you choose to work with a consultant or to develop your program yourself, many publi-cations are available from your state on-site Con-sultation Program or from OSHA that spell out in greater detail the steps you can take to create an effective safety and health program for your work-place. The rewards for your efforts will be an effi-cient and productive workplace with a low level of loss and injury.

Designating Responsibility

You must decide who in your company is the most appropriate person to manage your safety and health system. Who can ensure that the pro-gram will become an integral part of your busi-ness? In many cases it will be you, the owner.

Sometimes it will be a plant manager or key super-visor. It could even be an engineer, personnel spe-cialist, or other staff member.

Whoever you choose should be committed to workplace safety and health, have the time to de-velop and manage the program, and be willing to take on the responsibility and accountability that goes with operating an effective program. The individual will need your full cooperation and sup-port, but the ultimate responsibility for safety and health in your workplace rests on you.

Ask for Help

Federal occupational safety and health law allows a state to develop and operate its own occu-pational safety and health program in place of the Federal OSHA program. It is possible that the reg-ulatory aspect of the law (setting of mandatory minimum standards and conducting inspections of workplaces) is being operated by your state gov-ernment as opposed to Federal OSHA.

One of the first things to learn is which branch of government, Federal or state, has current juris-diction over your business. If you are not sure what agency is responsible for administering work-place safety and health in your state, contact the nearest OSHA Area Office to find out. (See www.osha.gov). You will need certain Federal OSHA publications (or comparable state publica-tions) for use in your safety and health activities, such as:

� Job Safety and Health Protection - OSHA 3165. You must display the Federal or state OSHA poster in your workplace. This poster is also available in Spanish (Job Safety and ealth Protection OSHA 3167).

� OSHA standards that apply to your business.

You need to have a copy of all OSHA stan-dards that apply to your type of business available for reference. (See Appendix D.)

Occupational Safety and

Standards are the regulations that OSHA uses to inspect for compliance and should be the baseline for your inspections in determining what to do when hazards are identified. Most businesses fall under OSHA’s eneral Industry Standards. If you are involved with construc-tion or maritime operations, you will need the standards that apply to these classifications.

(In states with state-run occupational safety and health programs, use the appropriate state standards.)

� Recordkeeping requirements and the neces-sary forms.

� Occupational Safety and ealth Act of 1970.

You may want a copy of this legislation for reference.

Organize the Workplace

Poor housekeeping can contribute to low morale and sloppy work. Most safety action pro-grams start with an intensive cleanup campaign in all areas of the workplace.

et rid of unecessary items; provide proper waste containers; store flammables properly; make sure exits are not blocked; mark aisles and pas-sageways; provide adequate lighting, etc.

et everyone involved and impress upon em-ployees that you want to make your workplace safer, more healthful and more efficient.

Start athering Specific Facts About Your Situation

Before making changes in your safety and health operations, you should gather information about the current conditions and business practices that comprise your safety and health program.

This information can help you identify problems and determine what is needed to solve them.

Your workplace assessment should be conduct-ed by the person responsible for your safety and health management system and/or a professional safety and health consultant. The assessment con-sists of two major activities:

1. A comprehensive safety and health survey of your entire facility will identify any existing or potential safety and health hazards. This initial sur-vey should focus on evaluating workplace condi-tions with respect to safety and health regulations and generally recognized safe and healthful work practices. It should include checking on the use of any hazardous materials, observing employee work habits and practices, and discussing safety and health problems with employees. See the Self- Inspection Checklists (at pages 18-39), to help you get a good start on creating this initial survey.

2. The second major activity is to assess your existing safety and health program and identify areas that work well and those that need improve-ment. You should gather as much information as you can that relates to safety and health manage-ment in your workplace. You should include the following in this review:

� Safety and health activities. Examine ongoing activities as well as those tried previously, company policy statements, rules (both work and safety), guidelines for proper work prac-tices and procedures, and records of training programs.

� Equipment. List your major equipment, what it is used for and where it is located. Special attention should be given to inspection sched-ules, maintenance activities, and plant and office layouts.

� Employee capabilities. Make an alphabetical list of all employees, showing the date hired, their job descriptions, and experience and training.

� Accident and injury/illness history. Review first-aid cases and workers’ compensation insurance payments and awards, and review your losses. Compare your insurance rate with others in your group. ive special atten-tion to recurring accidents, types of injuries, etc.

After gathering facts, see if any major problem areas emerge such as interruptions in your normal operations, too many employees taking too much time off due to illness or injury, too many damaged products, etc. eneral help with this kind of prob-lem identification can often be obtained from com-pensation carriers, local safety councils, trade asso-ciations, state agencies, major suppliers or similar-ly situated businesses in the same industry.

If you discover a major problem, see what can be done to solve it. Once a problem is identified, you can work on the corrective action or a plan to control the problem. Take immediate action and make a record of what you have done. Even if you find no major problems, don’t stop there. Now it is time to develop a comprehensive safety and health program to avoid any major problems in the future.

Establish a Four-Point Safety and Health Program

The success of any workplace safety and health program depends on careful planning. This means that you must take the time to analyze what you want to accomplish and develop an action plan in order to attain your goals. From this standpoint, you can design a step-by-step process to take you from the idea stage to an effective safety and health management system.

The best way to create a safe and healthful workplace is to institute the Four-Point Program discussed at page 8 of this handbook.

Establish your management commitment and involve your employees. No safety and health program will work without this commitment and involvement. The first step is to designate a person to be responsible for your safety and health program.

Involve your employees as widely as possible from the beginning. They are most in contact with the potential and actual safety and health hazards at your worksite and will have constructive input on the development of your program. The ultimate success of your safety and health program will depend on their support.

Make sure your program assigns responsibility and accountability to all employees in your organi-zation. A good safety and health program makes it clear that each and every employee, from you through the supervisory levels to the line worker, carries responsibility for his or her part of the pro-gram. Make safety and health duties clear and hold every individual accountable for his or her safety- and health-related duties.

Refer to the recommended actions to take in the

Worksite Analysis paragraph at page 9. These will help start your program off on the right track. You will be building the foundation for a successful safety and health program.

Establish and regularly conduct a worksite analysis. A successful safety and health program depends on an accurate identification of all the haz-ards and potential hazards in your workplace. This is an ongoing process that includes routine self-inspections.

Create systems and procedures to prevent and control hazards identified through your worksite analysis. OSHA standards can be helpful because they address controls in order of effectiveness and preference. The hierarchy of controls is engineer-ing, administrative, work practice and PPE. When-ever feasible, engineering, administrative or work practice controls should be instituted even if they do not eliminate the hazard or reduce exposure.

Use of such controls in conjunction with PPE will help reduce the hazard or exposure to the lowest practical level. Where no standard exists, creative problem-solving and consultant resources may help you create effective controls. The basic for-mula for controlling workplace hazards, in order of preference, includes:

� Eliminating the hazard from the machine, the method, the material or the facility.

� Abating the hazard by limiting exposure or controlling it at its source.

� Training personnel to be aware of the hazard and to follow safe work procedures to avoid it.

� Prescribing PPE for protecting employees against the hazard and ensuring that they not only use it, but that they know how to use it correctly.

Establish and provide ongoing training for employees, supervisors and managers to ensure that everyone at your worksite can recognize haz-ards and how to control them.

These points are crucial to a safe and healthful workplace for you and your employees, making it more difficult for accidents to occur and for work-related health problems to develop.

Develop and Implement Your Action Plan

Developing an action plan to build a safety and health program around the four points can serve as a “road map” to take your program to where you want it to be. An action plan tells you what has to be done, the logical order in which to do it, who is responsible and where you want to be when you finish. It describes problems and solutions, but is not ironclad. An action plan can and should be changed to correspond with changes in the work-place.

A good action plan has two parts:

1. A list of major changes or improvements to make your…