Written Programs For Compliance

by David Blustein

Written program requirements are needed to come into compliance. Here is an overview of what required written programs must contain

What are the written program requirements needed to come into compliance? What is the overview of what required written programs must contain? How can you modify this program to meet your company needs?

The Occupational Safety and Health Administration (OSHA) is currently looking very closely at written compliance programs. Its intent is to enforce a safe and healthful workplace for every employee. Carefully written programs indicate to the OSHA inspector that there is a viable system in place to carry out safe work practices. Often, however, the end result of an OSHA inspection can be companies and employers being cited and penalized hundreds or thousands of dollars for not having these programs or for deficiencies in existing programs.

John Chandler, a chemist, scrimped for ten years to save enough money to open a small plating business. With his background in chemistry, John felt confident that he managed his new plant in a safe manner. However, OSHA came to inspect and even though at the closing conference the compliance officer gave him helpful advice to improve his safety program, John was amazed two weeks later to receive a $2,000 fine for lacking a written Hazard Communication Program. John could have saved himself a lot of money, not to mention time and hassle, if he had known that OSHA requires companies to develop a written program to show how chemical hazards of the workplace must be communicated to the employees. There are four parts to this plan:

1. Material Safety Data Sheets (MSDSs) available from the manufacturer. They must be readily available to employees.
   
2. Labeling of containers as to the contents, name of manufacture and address of manufacturer.
   
3. Training of employees must be explained as to frequency and method.
   
4. The written plan itself, as to where it is located and its availability to employees.

Lockout/Tagout
A second required written program is Lockout/tagout. Not long ago, Lou, an outside contractor, was working on repairing the heating unit for a steam table in the cafeteria of a well known major corporation. He had turned off the power before beginning work on the unit. Lacking written Lockout/tagout procedures, however, he received a shocking surprise when he reached for one end of a wire and discovered it was live! An internal maintenance person had re-wired the electrical source improperly, and since the unit was not locked and tagged, the energy source had not been fully disconnected. Fortunately, the amperage was low enough that Lou survived, unharmed, but the proper program could have prevented this incident from ever occurring.

Maintenance or service work on machines must be done with the machine or equipment stopped, and all sources of energy disconnected to prevent accidental start up. The written program must indicate how the hazards from potential and actual energy are controlled. The written program must include affected employees, maintenance employees, types of energy of each machine with type of energy isolation that is used. The parts to the written programs are:

1. List of affected employees, those operators of the machines that will be locked out when the machines are serviced or maintained.
   
2. List of authorized employees i.e. maintenance people that will have the locks and will be servicing and maintaining the equipment.
   
3. List of equipment and machines with disconnect means and type of energy.
   
4. Employee training should include:
   • Hazards of energy sources.
     
   • Purpose and use of lockout program.
     
5. Energy control procedures i.e. how the energy will be turned off and locked in the off position.
   
6. Periodic inspection of program to ensure that it is being followed.

Chemical Hygiene Plan
The third written program is the Chemical Hygiene Plan for Laboratories. This is to be used by laboratories where relatively small quantities of hazardous chemicals are used on a non-production basis. The required elements for this written program are:

1. Safety and Health considerations workers must take when working with hazardous materials.
   
2. Control measures used to reduce hazards such as engineering controls, personal protective equipment and hygiene practices.
   
3. Inspection and maintenance of fume hoods and other protective equipment to ensure they are functioning properly.
   
4. Employee training provisions shall include:
   • Methods for detecting chemical releases.
     
   • The hazards of the specific laboratory chemical.
     
   • Hazard protection measures that the employer has taken and the employees can take to lower their risks.
     
   • Applicable details of written chemical hygiene plan.
     

Bloodborne Pathogens Exposure Control Plan
The fourth written program required by OSHA is the Bloodborne Pathogens Exposure Control Plan. It is required of all employers that can "reasonably anticipate exposure or contact" of employees with blood, body fluids and/or other infectious materials while performing their job duties. (OSHA has not issued a list of specific occupations where exposures are likely to occur.) This program is of particular importance when first aid is being administered by a non-professional, i.e. not a nurse, paramedic or physician.

A potentially hazardous situation occurred during clean up after treating an employee with a small laceration. The person administering the first aid was not specifically trained in that capacity, which is not unusual in a small company treating a small injury. After sending the employee back to work, the first aid person began removing his protective latex gloves by pulling on each of the fingers of one glove, then, bare handed, pulling finger by finger on the remaining glove with an unprotected hand. Proper training should have taught him to turn each glove inside out during removal, isolating any contamination.

The program includes the following provisions:

1. Job classifications and exposure determinations
   
2. Compliance methods
   
3. Engineering and work practice controls
   
4. Personal protective equipment
   
5. Cleaning of contaminated areas
   
6. Employee hygiene and housekeeping
   
7. Hepatitis B vaccination and post-exposure follow-up
   
8. A sample form for an employee to decline a hepatitis B vaccine
   
9. Method of communication of hazards to employees
   
10. Employee training
11. Record keeping

Confined Space Entry Procedure
OSHA designed the fifth program to protect employees in general industry from the hazards of entering confined spaces. OSHA estimates that these regulations will prevent 85 deaths a year and over 10,949 injuries. OSHA defines a confined space as an area that is large enough for an employee to work in, yet has limited means of entry and exist. The area is not designed for continuous and routine job tasks. A "permit-required confined space" is a confined space that could be hazardous, either by closing in and asphyxiating the worker or by containing a material that is toxic or flammable, or any other recognized serious hazard.

The last time Steve, the quality control manager of ABC Plating, went into the manhole to test effluent. He became dizzy from the fumes and was barely able to get out into the fresh air before passing out. What really scared him was that he had been alone at the time of the incident. Steve got permission to call in an environmental consultant who was able to set up a written program of procedures that put Steve's mind at ease.

A written confined space program must contain the following:

1. Identify and evaluate potential hazards.
   
2. Inspection and evaluation procedures of confined spaces on site to determine if they are "permit-required confined space".
   
3. Requirements for when confined space entry permit is required.
   
4. Establish procedures for safe entry into confined spaces.
   
5. Instructions for completing the confined space permit.
   
6. Pre-entry confined space permit checklist (i.e. what environmental tests will be done, will auxiliary ventilation be provided?).
   
7. Sample entry permit.
   
8. Method of issuing permits to employees who work in confined spaces.
   
9. Method of preventing unauthorized entry.
   
10. Establish procedures to test and monitor environmental conditions of the confined space.
    
11. Method of communication with worker in confined space to summon rescuers if required.
    
12. Rescue procedures.
    
13. Permit-required confined space decision flow chart.
    

Written Respirator Program
Plant manager Dave Carson was proud that his employees took their safety seriously, always wearing their respirators while working on the line with hydrochloric acid mist. What he didn't know, nor did his men, was that since the respirators were not stored in a clean area, away from the line, and not cleaned on a daily basis to remove the acid, they did not provide the amount of protection they should have.

OSHA requires employers who require and provide respirators to employees for use while working with a hazardous material, to develop a written respirator program. The program is for the selection, safe use, inspection and maintenance of respirators. The written program should include the following.

1. Safe use of respirators in normal and emergency operations.
2. Employee Training:
   • Trained on proper use, cleaning, storage, maintenance and inspection of respirators.
     
   • Trained on the basis of selection of the appropriate respirator for the potential hazards.
     
3. Respirator program evaluation checklist.

Emergency Action Plan
The purpose of this plan is to eliminate or minimize hazards to employees in the event of a fire or other emergency.

Newly hired as safety director, Bill was anxious to comply with local fire officials and scheduled a fire drill. Unfortunately, the evacuation proved haphazard and dangerous because employees were unaware of safety procedures, clogging some exits and ignoring alternate safe exit routes. Following this fire drill fiasco, Bill, with the help of an environmental specialist, drew up and posted an emergency action plan. The next drill went well, and eighteen months later, when the company had a real fire, the evacuation went smoothly and without injury to any of the employees. An acceptable emergency action plan must contain the following:

1. Where the plan is kept (i.e. posted on safety bulletin board).
   
2. Emergency escape procedures and escape routes.
   
3. Procedures for employees who remain behind to operate critical plant operations and shut downs.
   
4. Procedures to account for all employees after emergency evacuation.
   
5. Identification of employee rescue and medical duties.
   
6. Types of evacuation to be used in emergency circumstances (i.e. Code yellow, all except for emergency responders; Code red, total evacuation including responders).
   
7. Names and job titles of persons who can be contacted for further information about the emergency action plan.
   
8. Type of emergency alarm system.
   
9. Emergency reporting system (i.e. emergency phone extension, 911, public address system or radios).
   
10. Posting of emergency telephone numbers.

Hazard Assessment Program
The eighth written plan is the Hazard Assessment Program for the use of personal protective equipment. OSHA requires employers to assess their workplace to determine if personal protective equipment should be used.

When a plating rack fell out of Dick's hands and landed on his foot, he went to the hospital with a serious injury. Dick tried to sue his employer. Further inquiry into the accident, however, revealed that Dick had not been wearing the steel metatarsal and toe shoes required by the company's hazard assessment plan. Having a plan in place saved the employer thousands of dollars.

The standard requires that the hazards be identified and the assessment recorded. The program must indicate the following:

1. Hazard assessment for eye and face protection (i.e. flying particles, molten metals, liquid chemicals, acids or caustic liquids, chemical gases or vapors, potentially injurious light radiation, etc.)
   
2. Head protection where assessment indicates there is a potential for head injuries from falling objects.
   
3. Foot protection where assessment indicates potential for injuries from falling or rolling objects, objects piercing the sole, electrical ground hazards, etc.
   
4. Hand protection required where the hazard assessment indicates the potential of skin absorption of harmful substances, severe cuts, lacerations, abrasions, punctures, chemical burns, thermal burns and harmful temperature extremes.
   
5. Employee training including when and what personal protective equipment is required; how to use personal protective equipment; the limitations of personal protective equipment; proper care, maintenance, useful life and disposal of personal protective equipment.

Forklift Safety Program
The ninth and final written program required by OSHA is the Forklift Safety Program for companies using forklift trucks. The programs should include:

1. Individuals responsible for administrating, training and assessment of the forklift truck safety program.
   
2. Maintenance and repair.
   
3. Operator safety and training.
   
4. General rules of equipment operation.
   
5. Verification of authorized forklift truck drivers.
   
6. Before-use equipment checklist.

Conclusion
A successful safety program is an attitude which employees apply to the tasks of their jobs. Interpersonal skills should be developed so that good attitudes are recognized and encouraged. Poor attitudes must be identified, corrected and eliminated. Safety programs help promote professionalism, integrity, trust and respect. Employee accessible written safety programs are the foundation for this type of safety plan. They communicate that safety in the work place is a part of management's ethic by providing communication, leadership, example and training. They also help make employees responsible for learning and following safe practices. Having these safety and health programs also reduce costs and risks, that could result in workplace injuries and illnesses. Having effective safety programs is a good business practice because healthy, safe employees are a company's most valuable asset.