1. Safety and Health Program Assessment Worksheet OSHA Form 33 Jim Barkley OSHCON Consultant Manager

2. Purpose
The intent of this presentation is to explain how OSHCON uses the Form 33, and show how employers might use it to measure and evaluate the strength and completeness of their safety and health programs.
Form 33 Revised -- August 2007

3. WHAT IS THE FORM 33?
The Form 33 is an evaluation tool used by OSHA Consultation to assess an employer’s total safety and health management system when we perform Full Service -Comprehensive consultation visits.
Form 33 Revised -- August 2007

4. Relation To SHARP & VPP
The Form 33, though completed for all consultations performed by OSHCON, has a critical scoring requirement for those companies vying for SHARP status.
The S&H Program attributes that the Form 33 contains are the same attributes that VPP applicants must also successfully develop.
Form 33 Revised -- August 2007

5. History First assessment worksheet was developed in 1984
Evolved with the inception of OSHA’s 1989 Safety and Health Program Management Guidelines - Originally four Categories with 22, then 25 elements.
Current 58 attribute form launched in 2001.
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6. Attribute Types
Basic Items - 50 Attributes - Fundamental Building Blocks
Stretch Items (*) - 8 Attributes - Attributes of Excellence - Operate Best When Basic Attributes are fully in Place
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7. Rating Values Defined
0: No discernible or meaningful indication that the item is even partially in place
1: Some portion or aspect is present although major improvement is needed
2: Item is largely in place with only minor improvements needed
3: Item is completely in place
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8. Rating Values Defined
NE: Not Evaluated - Recognizes that comprehensive evaluations are often incremental processes.
NA: Not Applicable – Recognizes that there are organizational differences between larger and very small workplaces.
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9. Concept of an Organizational Safety and Health System
Operational Component
Managerial Component
Cultural Component
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10. Operational Component
Nineteen (19) Assessment Items
Concerns system output regarding workplace hazards and violations (unsafe and unhealthful conditions and activities)
Two (2) Sub-Components
Hazard Anticipation & Detection (Items 1-10)
Hazard Prevention & Control (Items 11-19)
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11. Managerial Component Twenty (20) Assessment Items
Concerns effect of traditional managerial functions:
Planning
Controlling
Communicating
Three (3) Sub-Components
Planning & Evaluation (Items 20-25)
Administration & Supervision (Items 26-33)
Safety & Health Training (Items 34-39)
Organizing
Staffing
Coordinating
Directing
Staff Development
Motivating
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12. Cultural Component Nineteen (19) Assessment Items
Concerns values and principles mutually held by members of an organization
Two (2) Sub-Components
Management Leadership (Items 40-49)
Employee Participation (Items 50-58)
(Management leadership is needed to initiate change toward an improved safety and health culture, and employee participation is necessary to nurture and grow that culture.)
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13. All Three Components Are Interrelated
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14. A Systematic Method for Rating Attributes
Incorporates the Concept of “Rating Cues” which are specific facts or perceptions that prompt and support the rating of a relevant attribute.
Each attribute is worded as a positive statement.
Each rating cue will operate either to CONFIRM or to NEGATE an attribute statement.
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15. Sources of Rating Cues Observations and Measurements
Interviews of employees and management at all levels
Review of Documents and Record keeping
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16. Cue Content Indication of the existence (or absence) of the Attribute
Indication of the extent of the Attribute
Indication of the actual effect of the Attribute
1) Workplace accidents are investigated by the safety representative
2) Accidents are investigated by a team and multiple statements and forms are filled out. Latest JHA/JSA is re-evaluated for anything missing or possibly contributing to accident.
3) Workplace injuries dropped 60% from last year when 2 was implemented.
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17. Multiple Cues Are Considered And Weighed Together
Initial Cue
Supporting Cues
Conflicting or Contradictory Cues
Example: #2 Effective safety and health self-inspections are performed regularly.
Manager says monthly inspections are conducted. (initial)
Safety coordinator pulls out completed inspection forms for 17 different types of inspections performed at the facility. (Supporting)
Inspection forms are missing for some of the last 12 months, and others appear to be filled out incompletely or incorrectly. (conflicting) or….
Despite all the inspections, there were numerous hazards and violations identified.
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18. “Effective” and “Effectively”
No two words carry more weight in our Safety and Health Program evaluations.
It is not enough to just have something in place, it must be EFFECTIVE.
Attributes that are only partially in place, or partially complete, or in place most of the time, are not 100% effective, and generate negative cues.
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19. Using Cues to Score Attributes
Rating Value
Eliminated by a Single Confirming (Positive) Cue 1
Requires a single Confirming cue and multiple Negating (Negative) cues 2
Requires multiple Confirming cues and only a few Negating cues 3
Eliminated by a single Negating cue
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20. Examples Of Negative Cues
Obviously, hazards and violations are negative cues. We would also include:
Latest date on Safety Manual is 2002.
“Safety Man” is keeping the place really safe, but it’s all up to him.
NEO very thorough, but occurs 1 month after hire.
Safety meetings not held when too busy.
Listed HAZCOM coordinator died 1 year ago.
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21. Examples of Positive Cues
Employees know what an MSDS is.
Has all the MSDS’s organized in a binder.
Facility exhibits good housekeeping.
Has stack of sign-in sheets for past safety meetings.
Has a safety committee.
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22. Examples of Better Positive Cues
Safety responsibilities built into every job description.
Formal annual review of all JHA/JSA’s.
Created a matrix chart to show who’s first aid card, certification, hearing test, etc., is due when.
Meeting minimum OSHA requirements gets you 2’s.
Exceeding minimum OSHA requirements gets you 3’s.
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23. Analysis Of S&H Program
OSHCON is taught two ways to evaluate the Safety Program: Top-Down, and Bottom-Up Analysis.
Most Consultants prefer Bottom-Up Analysis because it starts with determination of hazard/no hazard, document/no document, positive response/negative response.
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24. Bottom-Up Assessment
Cultural Component: Management Leadership & Employee Participation ^
Managerial Component: Planning and Evaluation; Administration and Supervision; and Safety & Health Training ^
Operational Component: Hazard Anticipation and Detection; and Hazard Prevention and Control
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25. Bottom-Up Assessment
This generally occurs during the physical walkthrough of the workplace. Employs primarily Observations, Measurements, and Employee Interviews
Focuses on Hazards, Violations, and Program voids which are then linked to Operational Attribute(s) as negative cues.
Positive cues are similarly linked to one or more Attributes.
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26. Bottom-Up Assessment
Requires Analytical thinking to link Operational cues to Managerial and Cultural Attributes. You must identify the ROOT CAUSE, or you will be missing “The Gorilla” again.
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27. Hazard to System Linkage
Tier I Analysis
1. Link the Hazard to an Operational Component Failure
Tier II Analysis
2. Link the Operational Failure to a Managerial Component Failure
Tier III Analysis
3. Link the Managerial Failure to a Cultural Component Failure
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28. Linking A Hazard to the Operational Component
Hazard Found: Damaged ladder in use. Could be due to breakdown in one of the following:
Att #2
Effective Inspections
Att #3
Effective Surveillance of Hazard Controls
Att #4
Effective Hazard Reporting
Att #12
Effective S&H Rules
#2 – No inspection, incomplete inspections, too infrequest inspections
#3 – Workers and supervisors don’t observe hazards outside of inspection activities. Non-inspection employees don’t know what to look for.
#4 – Employees don’t know how to report hazards; don’t recognize to report; or don’t care to report.
#12 – No rules about using damaged ladders; have rules but too lazy to get another;
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29. Linking an Operational Failure to the Managerial Component
ADMINISTRATIVE & SUPERVISORY SUBCOMPONENTS
Assignment of Responsibility
Attributes 26,27,28
Training of Responsible Person
Attribute 29
Authority of Responsible Person
Attribute 30
Resources of Responsible Person
Attribute 31
Motivation of Responsible Person
Attributes 32,33
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30. What Is The Source of the Problem (Hazard) ?
(2) Inspection program exists but ladder is defective;
(26) An employee is designated to inspect ladders;
(27) Employee knows he is responsible for inspections;
(28) Employee has been told he’s accountable for the job;
(29) Employee has knowledge and skills to do effective inspections;
(30) Employee has the authority to get the job done;
(31) Employee has the resources available to correct;
(32) Organizational policies promote the performance of his S&H responsibilities.
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31. OPERATIONAL COMPONENT WEAKNESS….
Attribute #33 – Organizational policies do not result in correction of non-performance of safety and health responsibilities.
The company says it is tough on safety accountability but overlooks non-performance. No one has ever been disciplined.
Now we look for a link to the Cultural Component.
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32. Linking a Managerial Failure to the Cultural Component
During interviews of employees and supervisors we find that:
#41, “Top Management considers S&H to be a line rather than a staff function.” and
#50, “There is an effective process to involve employees in safety and health issues” both score low because…
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33. Linking a Managerial Failure to the Cultural Component
The Owner has difficulty truly relinquishing primary safety responsibilities to others. He likes to be in control. His running the company, and busy schedule are resulting in his overlooking of accountability issues.
What looked so good initially in the written Policies & Procedures Manual, is only in print – not fact.
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34. Linking a Managerial Failure to the Cultural Component
Bottom-Up analysis of an individual hazard may not reveal a clear link to the Cultural Component
Bottom-Up analysis of multiple hazards with common Managerial failures should provide much easier linkage to the Cultural Component.
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35. Realistically, back on Slide #28, we may have found that in addition to the Inspections, we had issues with other Operational Component Attributes.
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36. Effective Inspections Att #3 Effective Surveillance of Hazard Controls
Hazard Found: Damaged ladder in use. Could be due to breakdown in one of the following:
Att #2
Effective Inspections
Att #3
Effective Surveillance of Hazard Controls
Att #4
Effective Hazard Reporting
Att #12
Effective S&H Rules
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37. Likewise, any of the other Managerial Component Attributes from Slide 30 could have been found to be inadequate or ineffective.
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38. What Is The Source of the Problem (Hazard)? Slide 31
(2) Inspection program exists;
(26) An employee is designated to inspect ladders;
(27) Employee knows he is responsible for inspections;
(28) Employee has been told he’s accountable for the job;
(29) Employee has knowledge and skills to do effective inspections;
(30) Employee has the authority to get the job done;
(31) Employee has the resources available to correct;
(32) Organizational policies promote the performance of his S&H responsibilities.
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39. Finished Product
With multiple negative and positive cues for multiple Attributes, the finished analysis, if drawn on paper, might create so many Bottom-Up tracks crossing over each other that the analysis looks like one of John Madden’s confusing play diagrams, or an air traffic controller’s screen. It can get that complicated.
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40. Finished Product
The 58 Attributes are so interrelated, that I equate them to 58 marbles in a small bowl: You can’t move one, without causing several others around it to also move.
In this same manner, I have found that successful implementation of an action plan to enhance one Attribute, can indirectly result in various degrees of improvement for 2-5 other attributes.
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41. The Pitch!
Try the Form 33 at your workplace and see if it doesn’t help your safety program look better. If it doesn’t, you haven’t lost anything.
But I think it will make a difference in the way you identify program problems, and solve them more effectively.
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42. QUESTIONS? Jim Barkley, OSHCON Consultant Manager 210-593-0070 ext 700
Fax
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43. I. Operational Component A. Hazard Anticipation & Detection
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44. Item 1. A comprehensive, baseline hazard survey has been conducted within the past five (5) years.
Purpose: To determine if the organization, through site inspection and analysis, has developed a reasonably complete inventory of the S & H hazards existing at a certain time, to serve as the basis for subsequent action planning and priority setting.
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45. Item 2. Effective safety and health self-inspections are performed regularly.
Purpose: To determine if personnel in the organization are performing effective S & H inspections on a regular basis.
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46. Item 3. Effective surveillance of established hazard controls
Item 3. Effective surveillance of established hazard controls is conducted.
Purpose: To determine if the organization exercises ongoing diligence to detect situations in which previously established safety and health controls have become missing, defective, deficient, improperly applied or otherwise inadequate.
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47. Item 4. An effective hazard reporting system exists.
Purpose: To determine if the organization has policies and procedures that operate to effectively confirm employee knowledge of hazard existence in order to facilitate planning and prompt hazard correction.
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48. Item 5. Change analysis is performed whenever a change in facilities, equipment, materials, or processes occurs.
Purpose: To determine if the organization has effective policies and procedures that result in advance detection of potential hazards associated with planned or anticipated changes in the workplace.
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49. Item 6. Accidents are investigated for root causes.
Purpose: To determine if the organization investigates accidents to identify underlying causes so that corrective action can be taken to prevent recurrence.
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50. Item 7. Material Safety Data Sheets are used to reveal potential hazards associated with chemical products in the workplace.
Purpose: To determine if the organization is effectively utilizing the information contained in Material Safety Data Sheets to detect existing or potential hazards.
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51. Item 8. Effective job hazard analysis is performed.
Purpose: To determine if the organization conducts systematic, job specific analyses to detect conditions and work practices that may lead to worker injury or illness.
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52. Item 9. Expert hazard analysis is performed.
Purpose: To determine if the organization seeks competent advice and assistance when the expertise needed to perform effective surveys, review, and analyses for workplace hazard detection is lacking internally.
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53. Item 10. Incidents are investigated for root causes.
Purpose: To determine if the organization investigates S & H incidents to identify underlying causes so that corrective action can be taken to prevent accidents that have the same underlying causes.
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54. I. Operational Component A. Hazard Anticipation & Detection B
I. Operational Component A. Hazard Anticipation & Detection B. Hazard Prevention and Control
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55. Item 11. Feasible engineering controls are in place.
Purpose: To determine if the organization identifies and employs engineering methods to eliminate or control workplace hazards.
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56. Item 12. Effective safety and health rules and work practices are in place.
Purpose: To determine if the organization has established general workplace rules and specific work practices that prescribe safe and healthful behaviors and task performance methods.
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57. Item 13. Applicable OSHA-mandated programs are effectively in place.
Purpose: To determine if the organization has effectively implemented program management requirements in applicable OSHA standards.
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58. Item 14. Personal protective equipment is effectively used.
Purpose: To determine if the organization ensures effective use of personal protective equipment.
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59. Item 15. Housekeeping is properly maintained.
Purpose: To determine if the organization maintains housekeeping at a level that avoids the creation of workplace hazards.
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60. Item 16. The organization is prepared for emergency situations.
Purpose: To determine if the organization is prepared for those foreseeable emergency events that could result in injuries or illnesses in the workplace and/or adjacent community.
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61. Item 17. The organization has an effective plan for providing competent emergency medical care to employees and others present at the site.
Purpose: To determine if the organization has established procedures that ensure timely access to emergency medical care.
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62. Item 18. Effective preventive maintenance is performed.
Purpose: To determine if the organization maintains facilities and equipment in a manner that precludes the creation of physical hazards and avoids the hazardous working conditions often associated with emergency repairs.
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63. Item 19. An effective procedure for tracking hazard corrections is in place.
Purpose: To determine if the organization monitors timely correction of identified hazards.
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64. II. Managerial Component A. Planning & Evaluation
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65. Item 20. Workplace injury/illness data are effectively analyzed.
Purpose: To determine if the organization uses injury and illness data to aid hazard detection activities and to set safety and health priorities.
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66. Item 21. Hazard incidence data are effectively analyzed.
Purpose: To determine if the organization uses hazard incidence data to set safety and health priorities.
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67. Item 22. A safety and health goal and supporting objectives exist.
Purpose: To determine if the organization has established a clear purpose and direction for its safety and health management function.
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68. Item 23. An action plan designed to accomplish the organization’s safety and health objectives is in place.
Purpose: To determine if the organization has established specific actions with performance time frames to achieve its safety and health objectives.
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69. Item 24. A review of in-place OSHA-mandated programs is conducted at least annually.
Purpose: To determine if the organization periodically assesses the management aspects of its OSHA-mandated programs.
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70. Item 25. A review of the overall safety and health management system is conducted at least annually.
Purpose: To determine if the organization periodically audits the management aspects of its overall safety and health system, determining progress achieved toward its safety and health objectives, and identifying needed changes or improvements.
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71. II. Managerial Component A. Planning & Evaluation B
II. Managerial Component A. Planning & Evaluation B. Administration & Supervision
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72. Item 26. Safety and health program tasks are each specifically assigned to a person or position for performance or coordination.
Purpose: To determine if the essential safety and health responsibilities are identified and assigned to appropriate personnel.
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73. Item 27. Each assignment of safety and health responsibility is clearly communicated.
Purpose: To determine if individuals in the organization are aware of and understand their assigned safety and health responsibilities.
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74. Item 28. An accountability mechanism is included with each assignment of safety and health responsibility.
Purpose: To determine if persons making assignments of safety and health responsibilities and personnel receiving such assignments have a mutual understanding of how and when performance will be evaluated.
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75. Item 29. Individuals with assigned safety and health responsibilities have the necessary knowledge, skills, and timely information to perform their duties.
Purpose: To determine if the organization’s personnel have the understanding, skill and current information needed to effectively perform their safety and health responsibilities.
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76. Item 30. Individuals with assigned safety and health responsibilities have the authority to perform their duties.
Purpose: To determine if the organization's personnel have adequate authority to perform their safety and health responsibilities effectively.
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77. Item 31. Individuals with assigned safety and health responsibilities have the resources to perform their duties.
Purpose: To determine if the organization’s personnel have the necessary resources to perform their safety and health responsibilities effectively.
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78. Item 32. Organizational policies promote the performance of safety and health responsibilities.
Purpose: To determine if the organization’s personnel are provided positive incentive for performance of their safety and health responsibilities.
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79. Item 33. Organizational policies result in correction of non-performance of safety and health responsibilities.
Purpose: To determine if the organization’s personnel are provided disincentives for failure to perform their assigned safety and health responsibilities.
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80. II. Managerial Component A. Planning & Evaluation B
II. Managerial Component A. Planning & Evaluation B. Administration & Supervision C. Safety & Health Training
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81. Item 34. Employees receive appropriate safety and health training.
Purpose: To determine if the organization’s personnel are provided appropriate training to ensure that they have the necessary knowledge and skill to perform their assigned safety and health responsibilities.
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82. Item 35. New employee orientation includes applicable safety and health information.
Purpose: To determine if the organization provides appropriate education and training in safety and health protection for new employees who are assuming new duties.
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83. Item 36. Supervisors receive appropriate safety and health training.
Purpose: To determine if the organization trains supervisors to understand, recognize, and prevent or control safety and health hazards affecting their operations and personnel, and to take prompt and appropriate action in response to emergencies.
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84. Item 37. Supervisors receive training that covers the supervisory aspects of their safety and health responsibilities.
Purpose: To determine if the organization provides supervisory training that addresses the supervisor’s safety and health management responsibilities as well as information on hazards.
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85. Item 38. Safety and health training is provided to managers.
Purpose: To determine if the organization provides an appropriate level of safety and health education and training for its managers.
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86. Item 39. Relevant safety and health aspects are integrated into management training.
Purpose: To determine if the organization educates its managers to understand the way and the extent to which effective safety and health protection impacts overall business effectiveness, so that managers will be more likely to ensure that the necessary safety and health management systems operate as needed.
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87. III. Cultural Component A. Management Leadership
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88. Item 40. Top management policy establishes clear priority for safety and health.
Purpose: To determine if the organization has an established policy, emanating from top management, that sets worker safety and health as an organizational priority.
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89. Item 41. Top management considers safety and health to be a “line” function rather than a “staff” function.
Purpose: To determine if the organization has established safety and health performance as an operational responsibility.
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90. Item 42. Top management provides competent safety and health staff assistance to line managers and supervisors, as appropriate.
Purpose: To determine if the organization provides appropriate staff guidance and assistance to managers and supervisors relative to their safety and health responsibilities.
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91. Item 43. Managers personally follow safety and health rules.
Purpose: To determine if the organization’s managers set a visible leadership example by strict adherence to established safety and health rules.
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92. Item 44. Managers delegate the authority necessary for personnel to carry out their assigned safety and health responsibilities effectively.
Purpose: To determine if the organization’s managers demonstrate safety and health leadership, promote a culture of safety and health in the organization, and support effective operation of the safety and health management system by delegating adequate authority for personnel to perform their safety and health responsibilities.
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93. Item 45. Managers allocate the resources needed to properly support the organization’s safety and health system.
Purpose: To determine if the organization’s managers demonstrate safety and health leadership, promote a culture of safety and health in the organization, and support effective operation of the safety and health management system by allocating needed resources.
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94. Item 46. Managers ensure that appropriate safety and health training is provided.
Purpose: To determine if the organization’s managers demonstrate safety and health leadership, promote a culture of safety and health in the organization, and support effective operation of the safety and health management system by ensuring that appropriate safety and health education and training is provided to workers, supervisors, and managers.
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95. Item 47. Managers support fair and effective policies that promote safety and health performance.
Purpose: To determine if the organization’s managers demonstrate safety and health leadership, promote a culture of safety and health in the organization, and support effective operation of the safety and health management system by establishing and adhering to reward and disciplinary policies for safety and health performance.
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96. Item 48. Top management is involved in the planning and evaluation of safety and health performance.
Purpose: To determine if the organization’s top managers personally track performance in safety and health protection to demonstrate visible management leadership.
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97. Item 49. Top management values employee involvement and participation in safety and health issues.
Purpose: To determine if the organization’s top managers solicit and respect employee input regarding workplace safety and health issues, and encourage voluntary participation in the organization’s safety and health system.
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98. III. Cultural Component A. Management Leadership B
III. Cultural Component A. Management Leadership B. Employee Participation
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99. Item 50. There is an effective process to involve employees in safety and health issues.
Purpose: To determine if there is an established organizational process that is known, trusted, and used by employees to provide input regarding safety and health issues.
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100. Item 51. Employees are involved in organizational decision-making in regard to safety and health policy.
Purpose: To determine if employees of the organization influence policy decisions affecting their safety and health.
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101. Item 52. Employees are involved in organizational decision-making in regard to the allocation of safety and health resources.
Purpose: To determine if employees of the organization influence the allocation of resources affecting their safety and health.
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102. Item 53. Employees are involved in organizational decision-making in regard to safety and health training.
Purpose: To determine if employees of the organization influence training decisions affecting their safety and health.
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103. Item 54. Employees participate in hazard detection activities.
Purpose: To determine if employees of the organization are actively engaged in hazard detection activities.
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104. Item 55. Employees participate in hazard prevention and control activities.
Purpose: To determine if employees of the organization are actively engaged in hazard prevention and control activities.
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105. Item 56. Employees participate in the safety and health training of co-workers.
Purpose: To determine if employees of the organization are actively engaged in the delivery of safety and health training.
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106. Item 57. Employees participate in safety and health planning activities.
Purpose: To determine if employees of the organization are actively engaged in setting the safety and health goal and objectives of the workplace.
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107. Item 58. Employees participate in the evaluation of safety and health performance.
Purpose: To determine if employees of the organization are actively engaged in reviews and audits of safety and health performance.
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