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Baseline Hazard Analysis
Development, Validation, Implementation and Enhancement for a Voluntary Protection Programs Center of Excellence (VPP CX) Capability for the Department of Defense Baseline Hazard Analysis
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Objectives After this training you will be able to:
Identify the need, requirement and purpose for conducting a baseline hazardous analysis Understand the similarities and differences of the safety vs. health baseline hazard analysis Recognize who should perform the baseline hazard analysis Compare and contrast various methods for performing a baseline hazard analysis.
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Safety & Health Management System
S&HMS First lets cover a view basics about what a safety and health management system is. OSHA’s Voluntary Protection Program is simply a model to put into practice all the necessary components of an effective safety and health management system. The word “system” is used to describe this safety and health structure rather than calling it a program as is sometimes used because this “system” includes many components. Many of these components are actually stand alone “programs” that lots of facilities have had in place for numerous years, such as LO/TO, safety inspections, and accident investigations to mention a few. So lets take a look at some of the things that make for an effective safety and health management system. Next slide.
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Safety & Health Management System
Effective S&HMS includes: Multiple provisions for systematic identification, evaluation, prevention, or control of workplace hazards Goes beyond compliance requirements to address all hazards, even without a rule, order or law. S&HMS Several of the key points in an effective safety and health management system are: They have multiple provisions that systematically and fully identify all hazards in the workplace. The key here is MULTIPLE provisions or techniques are used to identify all hazards, not just the common or obvious, and not just by the expert or assigned personnel, but by everyone. Once identified these hazards are evaluated; this is where the use of an established risk management or assessment process like Operational Risk Management (ORM) can be very useful to evaluate a hazard and determine how to protect employees from the hazard. That is, can the hazard be eliminated, controlled, avoided or prevention or control measures applied or other actions taken to prevent the hazard from harming anyone.
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Safety & Health Management System
Effective S&HMS includes: Multiple provisions for systematic identification, evaluation, prevention, or control of workplace hazards Goes beyond compliance requirements to address all hazards, even without a rule, order or law. S&HMS There are four major elements or pillars to an effective safety and health management system. They are: Management Commitment and Employee involvement Obviously if management is not committed to implementing a system to eliminate, prevent and control the safety and health of its work force little can be accomplished. In addition, unlike simply placing a rule or operation in place, if employees are not involved, including unions if the work site is organized, the current status quo of safety is not likely to improve. Implementation of safety and health by insistence, compliance with rules or regulations, or compulsion through stepped up enforcement can only go so far. When all personnel, both management and employees actively contribute, the safety and health system prosper and no one gets hurt at work. Hazard Analysis * stop Hazard Prevention and Control Safety and Health Training
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Safety & Health Management System
Effective S&HMS includes: Multiple provisions for systematic identification, evaluation, prevention, or control of workplace hazards Goes beyond compliance requirements to address all hazards, even without a rule, order or law. S&HMS The other key characteristic of a successful safety and health management system is that it “goes beyond compliance.” It does not stop with only those hazards, risk or workplace dangers that are required to be abated or protected. ALL hazards should be dealt with to protect personnel and equipment from injury, harm or loss. Next slide
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Safety & Health Management System
Effective S&HMS includes: Multiple provisions for systematic identification, evaluation, prevention, or control of workplace hazards Goes beyond compliance requirements of the law to address all hazards, even without a rule, order or law requiring it Four Major Elements: Management Commitment & Employee Involvement Hazard Analysis Hazard Prevention & Control Safety & Health Training. S&HMS There are four major elements or pillars to an effective safety and health management system. They are: Management Commitment and Employee involvement Hazard Analysis Hazard Prevention and Control and Safety and Health Training Next slide
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Four Major Elements of S&HMS
So these are the four pillars or major elements of our safety and health structure or system. But a structure or system needs a foundation or base on which to be built. If it not a stable and substantial underpinning, then the building or in our case the safety and health system may fail. This failure could then permit for the conditions or actions in the workplace to allow an accident to occur with possible human loss, injury or illness. Next Slide
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Safety & Health Management System
So here is our stable, secure, and sturdy foundation holding up the four pillars of the Safety and Health Management System. Please notice that I have purposely colored the building blocks or sub-elements to match one of the major elements or pillars of the Safety and Health Management System. Remember I said earlier that one of the keys or important components of an EFFECTIVE safety and health system is that it has MULTIPLE provisions for systematic identification, evaluation, prevention, or control of workplace hazards. Well this is so that if one of the safety and health system building blocks should fail the other blocks or sub-elements remaining will stop the accident, injury or illness from happening! To look at it another way, it will break the chain of events and the safe environment will continue with no work interruption or loss. Next slide
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Safety & Health Management System
Now after that review of effective safety and health systems, lets focus on just one of those building blocks that is necessary to put into practice a world class safety and health management system that creates a safe, healthy, efficient, high performing place of work. Next slide
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Safety & Health Management System
That sub-element of the safety and health system is Base Line Hazard Analysis.
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Safety & Health Management System
Hidden Slide . This is the complete slide I built to make the other partial slides that is why it’s hidden.
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Baseline Hazard Analysis
First attempt to identify common hazards Inventory & document hazards Effort to understand the hazards and potential hazards Examination, Study, or Review of the work & working conditions. Baseline Hazard Analysis IS: 1. First attempt to identify all those safety and health hazards which are easily recognized or are specific to the industry or operation being surveyed is a critical foundation for an effective safety and health protection program. 2. A comprehensive baseline hazard analysis or sometimes called a comprehensive survey is the most basic of all the tools used to establish the inventory of hazards and potential hazards in the worksite. This then permits a systematic inventory and recording of the hazards and potential hazards. This baseline record may also make it easy to develop customized site specific checklists for use conducting routine employee monthly safety and health inspections. It is an opportunity to assess and understand the hazards found and anticipate potential hazards that could be created. It is more akin to an EXAMINATION, STUDY, or REVIEW of the work and working conditions at a particular site or location.
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Types of Work Place Hazards
This is a partial list of some of the work place hazards that the Baseline may identify at your work site. Many of these may already have programs in place to prevent of control the hazard, that’s good! But it can and should still be list it in the Baseline Hazard Analysis for reference and to ensure that any auditor knows that you know and have addressed the hazard.
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Baseline Hazard Analysis
Baseline Hazard Analysis IS NOT: An INSPECTION In general NOT conducted by line employees Is not the only method of Hazard Analysis Is not conducted ONLY ONCE. IS NOT: Simply and INSPECTION of the workplace – Inspections may only monitor one or two areas of the facility at a specific time of day. Inspections may not devote adequate time to a full and thorough examination of all work areas and work operations. The Baseline Comprehensive surveys should be performed by individuals who can bring to the facility a fresh look or vision. They should possess extensive knowledge and experience in safety and industrial hygiene and in a number of different industries if possible. Likely candidates to conduct the Baseline Hazard Analysis are: safety professionals, industrial hygienists, environmental professionals, or ergonomists. A Baseline Hazard Analysis is also not meant to analyze in detail each and every operation or more complex operations. However, it should take note and record those for additional Hazard Analysis by the use of other methods such as Job Hazard Analysis, Change Analysis, Fault Tree Analysis, Failure Mode & Effects Analysis, Process Hazard Analysis, and Phase Hazard Analysis. With the baseline established, subsequent or update comprehensive surveys provide an opportunity to step back from the routine check on control of previously recognized hazards and look for others. These subsequent reviews are one occasion for focusing more intensive analysis in areas with the highest potential for new or less obvious hazards. The frequency with which additional comprehensive surveys and examinations are needed depends on the complexity, hazardousness, and changeability of the worksite. Many successful worksites conduct such reviews on an annual or biannual basis possibly in combination with the annual self evaluation.
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Baseline Hazard Analysis
How to conduct a Baseline Hazard Analysis: Ensure both Safety and Health are included Should include review of the following: OSHA 300 Log OSHA 301 or equivalent First Aid Log or Reports Accident Reports Prior Inspection Reports Past IH Surveys Maintenance (Safety) Work Orders Safety Committee Minutes Safety Suggestions. How to conduct the Baseline Hazard Analysis: The comprehensive Baseline Hazard Analysis must include a survey of both safety and health (Industrial Hygiene) hazards. Should include an administrative review of the following documents for identification of reported and/or identified hazards: OSHA 300 Log OSHA Form 301, Injury and Illness Incident Report First Aid Log or Reports Accident reports Prior Inspection Reports Past Industrial Hygiene Surveys Maintenance work orders, specifically those for safety issues Safety committee minutes Safety suggestions
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Baseline Hazard Analysis
How to continued: Industrial Hygiene Survey specifics: Inventory all chemicals & hazardous materials Review HAZCOM Program Review available air sample results Review noise surveys if they exist Recommended sampling strategy To assess exposure, including duration, route, frequency of exposure, and number of exposed employees Performed by qualified and experienced personnel Document of ALL findings and hazards Both unsafe conditions and unsafe acts. How to conduct the Baseline Hazard Analysis continued: For an industrial hygiene survey you should, at a minimum, inventory all chemicals and hazardous materials in the plant, review your hazard communication program, and analyze air samples. For many industries, a survey of noise levels and a review of the respirator program also will be vital. Personnel who perform the comprehensive baseline and update surveys and analysis of facilities, processes, procedures, and equipment, may require greater expertise than those who conduct routine inspections. Although a review of past IH sampling will normally occur as part of the Baseline, IH sampling at the time of the baseline survey may or may not be necessary to accomplish the comprehensive survey. It is more likely that the health segment of the baseline survey may recommend additional IH sampling or special sampling for new or potential health hazards identified by the health professional conducting the baseline survey. Comprehensive surveys ideally should be performed by personnel who can bring to the worksite a fresh vision and possess extensive knowledge of safety & health. Because there are few professionals equipped to do comprehensive surveys in both areas, the best approach is to use a team consisting of outside specialists such as a safety professional and an industrial hygienist. Documents all findings and identified hazards. This is key to the reason for the baseline. Both unsafe conditions such as physical hazards of equipment and also actual or potential unsafe acts observed or determined by review of a process. The use of a narrative format is acceptable for the documentation of the Baseline. And this is IMPORTANT, document ALL hazards identified, even if there is no standard or rule covering it. It could still cause or contribute to causing an accident or injury.
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For Management Management must:
Identify hazards in the workplace that could result in injury or illness Evaluate the level of risk to help determine what controls to implement Select an appropriate solution to control the hazard and/or protect the employee. Here are several specific points for managers to understand. Management ultimately has the obligation and duty to provide a safe and healthful work place for all employees under what is called the “General Duty Clause” of the OSH Act. “Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.“ Federal employers have a similar mandate contained in 29 CFR (a) which federal agencies. “The head of each agency shall furnish to each employee employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm.” Management should also participate in both the evaluation of the hazard to determine the level of risk to assist with determining what prevention and/or control measures to implement and the selection of the solution to prevent accidents and protect employees from injury or illness.
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OSHA VPP Baseline Hazard Analysis
VPP Policies & Procedures Manual CSP
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OSHA VPP Baseline Hazard Analysis
What it says: ID common safety hazards ID common health hazards ID those needing further study Cover entire worksite & tell who conducted. Excerpt from CSP Chapter III What the OSHA VPP manual says is just what we’ve been discussing. Here are the four key items it covers. ID common safety hazards ID common health hazards ID those needing further study Cover entire worksite & tell who conducted.
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OSHA VPP Baseline Hazard Analysis
Questions: Minimally effective? Methods used to ID health hazard? Documented sampling strategy for health hazards? Sampling follow national recognized procedures? Results compared to PEL, TLV, etc.? ID issues for further study? Sample records maintained? VPP Onsite Report There are seven questions on the VPP evaluation dealing with the Baseline Hazard Analysis that the OSHA VPP review team must answer. The are: Is the Baseline Minimally Effective? MR What methods are used to ID health hazard? They want to know how you did the sampling and what method was used. Documented sampling strategy for health hazards? Here they will determine if the site has some type of strategy to conduct sampling, such as one based on the identified hazards or a time frame to conduct the sampling. Sampling follow national recognized procedures? Did you follow recognized protocols, not simply make up your own. Results compared to PEL, TLV, etc.? What did you do with the result to determine if there where any overexposures or close to over exposure where more study needed. ID need for further study? Sample records maintained? Where records kept and available in some order that could be retrieved.
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Review of Baseline Hazard Analysis
A comprehensive baseline hazard analysis identifies and documents common S&H hazards found in: OSHA regulations Building codes Other recognized industry standards. A baseline analysis is a first attempt at understanding the hazards at a worksite to: Establish initial levels of exposure (baselines) for comparison to future levels, Allow changes to be recognized for additional evaluation. 1st Bullet – Remember, even if there is no regulation, code, or standard the hazard if recognized should still be documented for future evaluation of risk and possible measures to protect employees. 2nd Bullet – At some facilities that have been in existence for many years, but have never documented a baseline hazard analysis, past inspection and industrial hygiene reports can and should be used by personnel to develop the baseline hazard analysis.
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VPP Application This training addresses the following VPP actions:
Worksite Analysis Baseline Hazard Analysis Hazard Analysis of Routine Jobs Industrial Hygiene Hazard Prevention & Control Hazard Control Programs Hazard Elimination & Control / Reporting Safety & Health Training Training for S&H Staff on How to Conduct a Baseline Assessment.
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Summary In this presentation you learned about:
The reasons for conducting a Baseline Hazard Analysis The difference between a baseline hazard analysis and other types of hazard analysis What a Baseline Hazard Analysis is and is not Who should conduct the Baseline Hazard Analysis How to conduct a Baseline Hazard Analysis The role of Leadership in Baseline Hazard Analysis The specific OSHA VPP requirements and audit protocols for the Baseline Hazard Analysis.
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Questions?
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