Safety Program Development

Program Development OSHA and JCAHO Policy Development Program Implementation Training Programs Standard Reviews Applicability Analysis Construction Safety Pennsylvania AIPP

1Source professionals draw on their many years of technical and management responsibility for the development of policies and programs, to help you comply with regulations. Knowledge of the changing regulatory and business management environments not only helps in the development of programs, but also in their implementation. Projects have ranged from single procedure revisions done in a day to multiple procedure development and implementation requiring placing personnel at a client's facility for months. Need more information, or a proposal?  Please click on Information Request, or contact Colin J. Brigham, CIH, CSP, CPE, CPEA, Vice President Safety Management and Ergonomics at 888.873.9983, Ext. 24 or cbrigham@1ssh.com.

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Reduce Your Workers’ Compensation Insurance Cost

For most companies, the cost of workers’ compensation insurance is a major expense. However, there is a way to reduce that expense. Forming a safety committee can provide real savings for your company. A well-designed and administered safety committee can help to reduce the burden of running a safety program and increase the return on the investment.

The benefits to forming an effective safety committee include

1. Increased employee involvement
2. Increased productivity
3. Increased morale
4. Decreased injuries and illnesses
   
5. Decreased waste of materials
   
6. Decreased cost of insurance coverage

In reviewing the benefits, let’s begin at the bottom and work our way up. Pennsylvania provides a 5 percent reduction in your workers’ compensation premium if you have an effective safety committee that meets the state’s criteria. Pennsylvania offers this savings in recognition that having an effective safety committee typically reduces workers’ compensation costs by much more than the 5 percent. If an employer has an effective committee, both the employer and the state win. It’s a good return on investment for both parties.

Both material waste and injury and illness rates are reduced. Morale is increased through the improvement in both the ability to be involved in decision-making and improvement in workplace conditions. Productivity is improved as people are working smarter and safer. The burden of running the safety program is reduced as the responsibility for safety is switched from a selected few to all employees served by the safety committee.

The safety committee can serve as the H.E.A.R.T. (Hazard Evaluation Accident Review Team) of your safety and health program. It can help to strengthen the body of the program by detecting conditions that could or have caused harm, and then pumping information into the program to protect it from that harm or to repair the harm that has occurred. Using the heart and body analogy, if one hazard that you have is chemical use and your program to address hazardous chemicals is weak, you need to strengthen that “muscle” by having the H.E.A.R.T. remove the weak parts of the program, and then rebuild it.

How do you establish an effective safety committee?
Why is a committee needed?
Who should be involved?
What should their responsibilities be?
When should they meet?
Where should they meet?
 
For answers to these and other questions, or for assistance in establishing or revitalizing a safety committee, please contact Colin J. Brigham, CIH, CSP, CPE, CPEA, Vice President, at 888-873-9983, ext. 24, or cbrigham@1ssh.com.

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Accident and Illness Prevention Programs – A Formula for Success

The Commonwealth of Pennsylvania requires insurers, individuals who are self-insured, and group self-insurance funds to develop and maintain accident and illness prevention programs (AIPP) in order to provide workers’ compensation coverage. Failure to do so may mean the removal of the right to provide such coverage.

Why are these programs required?

Prior to implementing this requirement and other workers’ compensation reforms in the mid-1990s, Pennsylvania employers were experiencing very high injury and illness rates, losses, and increased premiums. They were losing money and jobs to other states! Something had to be done, and AIPP was part of the solution.

What is required, and how can you make AIPP compliance a formula for success?

There are two sets of requirements: those for required accident and illness program elements (A-O elements) and those for work environment procedures (P elements).

The A-O elements must be present within the AIPP that was developed, implemented, and monitored by the self-insured employer. These elements are required by the Pennsylvania Bureau of Workers’ Compensation. Each element has descriptive language stating the requirements. For example, the following is the description for the Safety Program Policy Statement:

“A written statement regarding the Accident and Illness Prevention Program that contains the employer’s philosophy regarding accident and illness prevention. The Safety Program Policy Statement is the foundation for all program activities. The statement is signed by a Chief Executive Officer and is communicated to all employees in the organization.”

The P elements are written work environment procedures that must be developed, implemented, and maintained if you have those exposures. Each of those elements also has descriptive language stating the requirements.

Implementing an effective AIPP-compliant program can have significant positive impacts. Examples of the success achieved by some winners of the 2003/2004 Governor’s Award for Safety Excellence are:

• Centocor: A biopharmaceutical company located in Malvern, Pennsylvania, their OSHA recordable rate dropped from 1.65 in 1996 to 0.59 in 2001.
• Grove Worldwide: A manufacturer of mobile hydraulic cranes and aerial platforms located in Shady Grove, Pennsylvania, their OSHA lost workday incident rate dropped from 3.7 in 1998 to 1.0 in 2002, a 72.9 percent reduction.
  
• EME Homer City Generation L.P.: One of the largest coal-fired power plants in the mid-Atlantic region, it is located in Homer City, Pennsylvania. They exceeded over 2 million hours without a lost-time injury.

On a final note, the Pennsylvania Bureau of Workers’ Compensation conducts random and planned audits of ALL businesses, schools, hospitals, etc., that are required to have an AIPP program. Depending on the outcome of the audit, they have the authority to suspend the self-insured status of an organization.

To learn more about AIPP compliance, how to achieve it, the benefits it provides, and auditing procedures, please contact Colin J. Brigham, CIH, CSP, CPE at 610.524.5525 ext 24 or cbrigham@1ssh.com

GRAPHIC CONTENT

A-O Elements
a. Safety Program Policy Statement
b. Safety Coordinator Designation
c. Safety Program Responsibility Assignment
d. Hazard Identification Methods
e. Industrial/Occupational Health Services
f. Industrial Hygiene Services
g. AIPP Training
h. Emergency Action Plan
i. Employee Safety Suggestion Program
j. Employee Involvement Methods
k. Safety Rule Enforcement Procedure
l. Accident Reporting and Investigation
m. Availability of First Aid and CPR
n. Program Evaluation Methods
o. Program Goals and Objectives

Workplace
Accident
Reduction
&
Performance
Enhancement
Achieving
Compliant
Environments

p. Elements

1. Electrical and Machine Guarding
2. Personal Protective Equipment
3. Hearing Conservation Program
4. Vision Conservation Program
5. Lockout/Tag Out Program
6. Hazardous Materials and Waste Program
7. Confined Space Entry Program
8. Fire Prevention & Protection Program
9. Bloodborne Pathogens Exposure Control
10. Pre-Operational Process Review
11. Substance Abuse Awareness & Prevention

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Hazardous Energy Lockout/Tagout: Fried and Died

The consequences of failing to effectively lock out/tagout equipment can be catastrophic. An extreme example of this occurred at a Wyman-Gordon Forgings, Inc., facility in Houston, Texas, on December 22, 1996, when eight workers were killed. A crew of ten maintenance workers was performing work on a 40-foot-high pressurized nitrogen tank for a 35-ton forging press. They believed that the pressure had been bled from the tank prior to beginning work. When two-inch bolts were removed from a three-foot-square lid, it blew off, ripping a 40-by-50-foot hole in the factory roof. Five of the workers were blown off of the top of the tank. How could this have been prevented?

The OSHA-proposed penalty was $1,803,500. The citation that OSHA issued had 34 items listed, including:

• There was a failure to provide appropriate hardware for isolating, securing, or blocking machines or equipment from energy sources.
  
  
• The hazardous energy control procedures (HECP) did not clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be used for the control of hazardous energy.
  
  
• The employer failed to effectively train each authorized employee.
  
  
• The employer did not conduct a periodic inspection of the energy control procedure at least annually.

Another example that illustrates the need to use of HECPs and effective communication between host employers and contractors occurred at RR Donnelley & Sons Company in Lancaster, Pennsylvania, on December 22, 2002. The contractor, who was with Herr and Sacco, Inc., was severely burned by a release of steam from a line that he believed had been de-energized. He died from the burns. Both employers were cited, with RR Donnelley & Sons paying $55,000 as the host employer and Herr and Sacco incorporated paying $3,325. OSHA items common to both
citations included:

• Lack of a compliant energy control program
  
  
• Absence of a suitable hazardous energy control procedure
  
  
• Failure to provide appropriate hardware for isolating, securing or blocking machines or equipment from energy sources
  
  
• Failure of the on-site and outside employers to inform each other of their respective lockout or tagout procedures

Failing to protect your employees from an unexpected release of energy can obviously have significant adverse consequences. 1Source Safety and Health, Inc. can help you to properly address this exposure by working with you to develop and implement compliant hazardous energy control programs, develop equipment-specific HECP, and provide training. For additional information or support contact Colin J. Brigham, CIH, CSP, CPE, CPEA, at cbrigham@1ssh.com or 610-524-5525, xt. 24.

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NFPA 70E: It’s Now Effective. Is Your Program?

On August 13, 2007, the revisions for the OSHA Electrical Installation Standard, Subpart S, 29CFR 1910.302-308, which were issued on February 14, 2007, became effective. This standard was last updated in 1981. What are the major changes and how might they affect you?

While there was no change to these OSHA standards from 1981 to 2007, there were substantial changes in the National Fire Protection Association (NFPA) standards. The NFPA is the organization that generates the National Electrical Code (NEC). Primary among the changes was the issuance of NFPA 70E: Standard for Electrical Safety in the Workplace, 2004. This standard includes requirements for employers to develop programs, procedures and work practices, and to supply appropriate personal protective equipment (PPE) to protect employees against electrical shock and arc flash hazards.

Key concepts in this standard include:

Why did the NFPA feel the need to generate this standard? Between five and 10 serious arc flash/blast hazards occur each day in the United States. The NFPA felt that selecting and using appropriate arc flash clothing and equipment could prevent the injuries and fatalities associated with arc flash/blast. It also believed that selecting and using the appropriate insulating equipment could prevent the injuries and fatalities associated with electrical shock.

The standard requires that a flash hazard and a shock hazard analysis be done before a person approaches any exposed electrical conductor or circuit part that has not been placed in an electrically safe work condition. The shock hazard analysis determines the voltage to which personnel will be exposed, boundary requirements, and the PPE necessary to minimize the possibility of electrical shock. The shock protection boundaries identified as Limited, Restricted, and Prohibited Approach Boundaries are applicable to situations in which approaching personnel are exposed to live parts. Where it has been determined that work will be performed within the flash protection boundary, the employer shall document the incident energy exposure of the worker. This incident energy exposure level shall be based on the working distance of the employee’s face and chest area from a prospective arc source for the specific task to be performed. Flame-resistant (FR) clothing and PPE shall be used by the employee based upon the exposure associated with the specific task. As an alternative, the PPE requirements can be determined based upon the task to be performed, as shown in Table 3.3.9.1, Hazard Risk Category Classification, of the standard.

No qualified person shall approach or take any conductive object closer to live parts than the restricted approach boundary unless:

• The qualified person is insulated or guarded from the live parts (insulating gloves or insulating gloves and sleeves are considered insulation only with regard to the energized parts that are being worked on) and no un-insulated part of the person’s body enters the prohibited space, or
• The live part is insulated from the qualified person and from any other conductive object at a different potential, or
• The qualified person is insulated from any other conductive object during bare-hand live-line work.

Unqualified persons shall not be permitted to enter spaces that are accessible to qualified employees only, unless the electrical conductors and equipment involved are in an electrically safe work condition. Where any unqualified person is working at or close to the limited approach boundary, the designated person in charge of the work space where the electrical hazard exists shall cooperate with the designated person in charge of the unqualified persons to ensure that all work can be done safely. This shall include advising the unqualified persons of the electrical hazard and warning them to stay outside of the limited approach boundary.

There are numerous other requirements and details in this standard, including the need to develop and use Electrical Energized Work Permits. OSHA has not formally compared each provision of the NFPA 70E-2004 standard with the parallel provision in Subpart S but generally believes the NFPA standard offers useful guidance for employers and employees attempting to control electrical hazards. 

For additional detail, see the standard or contact Colin J. Brigham, CIH, CSP, CPE, CPEA, at 888-873-9983, ext. 24, or cbrigham@1ssh.com.

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