Compliance and Regulatory Health and Safety Management Spring 2010 Professional Certificate in Human Resources Tom Brandon, CPP, CUSA O (619) 749- 179 F (619) 749-0182 fortressec@cox.net

Compliance and Regulatory General definitions and requirements “Titles” are different for written plans (depending on State) Examples: CA – Injury and Illness Prevention Program (IIPP) http://www.dir.ca.gov/dosh/dosh_publications/iipp.html WA – Accident Prevention Program (APP) http://www.lni.wa.gov/Safety/basics/programs/accident/default.htm Language must be understood Review annually Document As we discussed, the first step in building your safety program is to conduct a Needs Assessment (Taking Stock Checklist and others in the book) Set goals Chapter 3 (page 49), and lead the charge that employee safety and health is an intrinsic company value – that working safety is not just a “program” but a way of doing things. (page 50) Value like honesty… Make safety part of the performance appraisal process, practice actively caring steps, engage employees at all levels, and have leaders, managers and employees commit to being safe. Expectation that safety is a value (not a priority).

Compliance and Regulatory Core regulatory requirements Management commitment and responsibility Employee involvement Work-site analysis Hazard recognition and resolution Training and education Recordkeeping

Compliance and Regulatory Management commitment and responsibility Establish the importance of safety program Enforcement/coaching Continuous improvement Annual audit/review of program Assign responsibilities Managers/Supervisors Employees Chapter 3 (pages 50-54)

Compliance and Regulatory Employee involvement Interview and orientation process New hires (buddy system) Regular meetings Inspections Job safety analysis Incident investigations Safety Committee Policy and plan development/modifications

Compliance and Regulatory Work-site analysis Frequency Internal and External resources

Compliance and Regulatory Hazard recognition and resolution Recognition Inspections Job safety analysis Incident investigation External support (Consultation services, carriers, and…) Documentation Resolution (Correction) Engineering controls Work practices Personal protective equipment (PPE) Care and treatment of injured workers Chapter 3 (pages 57-63)

Compliance and Regulatory Training and education Timing and frequency requirements New employee New job Changes in conditions Deficiencies Communication Delivery Content Comprehension Chapter 3 (pages 64-67)

Compliance and Regulatory Recordkeeping Injury and illness records Exposure records and others

Compliance and Regulatory Best practices Establish and communication policies Provide resources Identify safety as a value Involve employees Perform work-site analysis Implement hazards recognition and resolution procedures Institute training and education Institute recordkeeping

Compliance and Regulatory Key programs required Injury and Illness Prevention Program (IIPP) (California) Workplace Safety Plan (outside California) Emergency Action Plan (response and preparedness) Fire Prevention Plan Hazard Communication Plan Specialty programs Fall protection Vehicle Electrical Lockout-tagout Workplace violence

Compliance and Regulatory Key programs required Injury and Illness Prevention Program (IIPP) (CA) Workplace Safety Plan (outside CA)

Fed OSHA versus Cal OSHA 29 CFR 1910 - General Industry 29 CFR 1926 - Construction Cal OSHA CCR Title 8 General Industry Construction State Plans must be ALAE (at least as effective) 26 States have self-administered programs http://www.osha.gov/dcsp/osp/index.html

Compliance and Regulatory Creating the IIPP Injury and Illness Prevention Program (IIPP) (CA) http://www.dir.ca.gov/dosh/dosh_publications/iipp.html http://www.dir.ca.gov/dosh/puborder.asp Postings http://www.dir.ca.gov/wpnodb.html Workplace Safety Plan (outside CA) http://www.consultationconnection.com/

Injury and Illness Prevention Program (IIPP) 8 Points Responsibility: Mission Statement, Day-to Day Compliance: Disciplinary Action Policy Communication: Method / System Hazard Assessment: JSA, Facility Inspections, Audits, Investigations, Code of Safe Work Practices Accident / Incident Investigation: Prevent Recurrence Hazard Correction: Tracking System, Timely, Effective Training & Instruction: Managers/ Supervisors, Specific to Job Duties Recordkeeping: If it isn’t written down…

Compliance and Regulatory Emergency Action Plan (response and preparedness) Elements… How do you know there is an emergency? How do you notify your employees of the emergency? Chemical Leak Earthquake Fire What do your employees do in the emergency? First Responders Floor Coordinators Shelter in Place Evacuate How do you account for your employees? Contact / Emergency Numbers, facility map, emergency number? List of Hazards and controls measures

Compliance and Regulatory Fire Prevention Plan Fire Detection Systems Types, maintenance Control of Fires Smoking controls Chemical Controls Fire Extinguishers Monthly tags Tie into EAP

Compliance and Regulatory Hazard Communication Plan System to identify and control chemical hazards in the workplace Chemical Inventory Compile Material Safety Data Sheets (MSDS) http://www.ilpi.com/msds/FAQ/parta.html Identify Controls, PPE, Training Routine and Non-Routine Conditions

Compliance and Regulatory Hazard Communication Plan What employees should know about chemical hazards in the workplace Product Identification  Handling and Storage Composition  Exposure Controls/Personal Protection  Hazards Identification  Physical and Chemical Properties  First Aid Measures  Stability and Reactivity  Fire Fighting Measures  Toxicological Information  Accidental Release Measures  Ecological Information  Disposal Considerations Other Information

Compliance and Regulatory Specialty programs Respiratory Protection Engineering, Administrative, PPE Pulmonary Testing, Fit Testing, Training Note: Can voluntarily wear dust masks without falling under the standard Lock Out/ Block Out Machine repair/Maintenance Confined Space Working space that is not entered through a normal door May have a hazardous atmosphere, engulfment, toxic Note: Consider transferring risk

Compliance and Regulatory Specialty programs Hearing Conservation TWA 85dba Blood borne Pathogens Healthcare workers and reasonably anticipated exposure Janitors Housekeepers First Aid Responders (watch “job duties”) Specific Hazards of Job Machine Guarding Fork Lift Drivers Ladders Hand Tools Fall Protection Scaffolds Lasers Vehicle Workplace violence Ergonomics

Compliance and Regulatory Tools and resources Cal OSHA (training requirements) http://www.dir.ca.gov/dosh/dosh_publications/trainingreq.htm Cal OSHA (IIPP) http://www.dir.ca.gov/dosh/dosh_publications/iipp.html Ready.gov (business continuity http://www.ready.gov/business/index.html ILO (workplace stress) http://www.ilo.org/public/english/protection/safework/stress/whatis.htm

Compliance and Regulatory Homework Read Chapter 3 (pages 45-67) of Workplace Safety: A Guide for Small and Midsized Companies Be prepared to discuss in class an OSHA topic from public media (from the previous week) Go to: http://www.dir.ca.gov/dosh/dosh_publications/trainingreq.htm http://www.dir.ca.gov/dosh/dosh_publications/iipp.html http://www.ready.gov/business/index.html http://www.ilo.org/public/english/protection/safework/stress/whatis.htm