Association of County Commissions of Alabama Self ...Meadowbrook Insurance Group – May 2011 1 The purpose of this document is to assist you with your risk management practices. Keep

Association of County Commissions of Alabama

Self- Insurance Funds

Safety Manual

Safety Manual

Table of Contents

Introduction .................................................................................................................. 1 Safety Management ......................................................................................................... 2

The Importance of Written Policies and Procedures ................................................................ 2 Purposes of a Policy Manual ............................................................................................. 4 Basic Elements of a Loss Control Program ............................................................................ 6 Employees’ Roles in the Safety Program ............................................................................. 10 The Purpose of Safety Committees ................................................................................... 13 Developing a Safety and Health Program ............................................................................ 15 Organizing a County Safety Committee .............................................................................. 19 Duties and Responsibilities of Safety Committee Members ....................................................... 21 Effective Safety Committee Meetings ................................................................................ 22 Safety Incentive Programs .............................................................................................. 23

Employment .................................................................................................................31 Hiring Safe Employees................................................................................................... 31 Guidance for Adoption of Drug Test Policy .......................................................................... 32 Implementing a Return-to Work Program ............................................................................ 55 Sample Return to Work Program....................................................................................... 58 Memo to the RTW Coordinator......................................................................................... 59 Sample RTW Policy Memo to Employees ............................................................................. 62 Sample RTW Letter to Care Provider / Doctor ...................................................................... 63 Sample RTW Letter to Injured Workers............................................................................... 64

Accident Investigation ....................................................................................................65 Accident Prevention ..................................................................................................... 65 Investigation Procedures................................................................................................ 66 Problem Solving Techniques............................................................................................ 69

Safety Programs and Procedures........................................................................................71 The Hazard Communication (Right-To-Know) Standard............................................................ 71 The Hazard Communication Standard - Self-Assessment .......................................................... 74 Sample Hazard Communication Program Introduction ............................................................. 75 Material Safety Data Sheet (MSDS ..................................................................................... 80 Sample Letter for Requesting an MSDS ............................................................................... 87 Personal Protective Equipment (PPE.................................................................................. 88 Personal Protective Equipment Guide to Hazard Sources ......................................................... 96 Types of Personal Protective Equipment............................................................................. 97 Personal Protective Equipment Policy and Program................................................................ 98 Sample Hearing Conservation Program ..............................................................................101 Audiometric Testing Procedures......................................................................................103 Machine Guarding - Sample Policy and Procedure .................................................................105 Machine Safeguarding: Using the Quarter-Inch Rule ..............................................................107 Implementing Energy Control Procedures...........................................................................110 Lockout/Tagout Procedures Self-Assessment.......................................................................113 OSHA’S Lockout/Tagout................................................................................................114 Sample Lockout/Tagout Procedure ..................................................................................116 Ground-Fault Circuit Interrupter .....................................................................................122 Compressed Gas Cylinder Safety......................................................................................124 Sample Compressed Gas Cylinder Safety Policy....................................................................126 Housekeeping Practices ................................................................................................129

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Housekeeping & Material Storage ....................................................................................132 Ladder Safety Program.................................................................................................136 Ladder Inspection and Repair Guide .................................................................................139 Fall Prevention ..........................................................................................................140 Fall Prevention and Control ...........................................................................................142 Reducing Employee Slips, Trips, and Falls ..........................................................................146 Guidance on Developing a Basic Plan for Preventing Back Injuries .............................................148 Back Injury Prevention Program ......................................................................................150 Safety Talks – Lifting Tips to Help in Preventing Back Injuries ..................................................155

Powered Industrial Trucks ............................................................................................. 157 Operator Training .......................................................................................................157 Safe Operating Procedures ............................................................................................160 Operator Qualification .................................................................................................163 Operational Safety Checklist ..........................................................................................164

Motor Vehicle Operations .............................................................................................. 165 Managing Motor Vehicle Operations..................................................................................165 Motor Vehicle Operations Self-Assessment..........................................................................167 Developing a Motor Vehicle Operations Policy .....................................................................168 Hiring and Training to Reduce Losses................................................................................170 Motor Vehicle Inspection and Maintenance .........................................................................173 Vehicle Inspection Procedure .........................................................................................175 Sample Motor Vehicle Safety Policy and Program .................................................................176 Sample Motor Vehicle Policy and Program..........................................................................177 Driver Road Testing Program..........................................................................................182 Preventable Motor Vehicle Accidents................................................................................183 Sample Seat Belt Policy ................................................................................................189 Sample Usage of Wireless Communication Devices While Driving Policy.......................................190

Ergonomics Program..................................................................................................... 192 Fitting the Job to the Employee......................................................................................193 Effects on Workers......................................................................................................194 Hazard Prevention and Control .......................................................................................198 Medical Management ...................................................................................................201 Training and Education.................................................................................................202 Ten Steps to Repetitive Motion Injury Reduction ..................................................................203

Appendix...................................................................................................................... 1 Accident Cause Analysis Worksheet.................................................................................... 1 Personal Protective Equipment for Worker Protection Against HIV and HBV Transmission ................... 3 Self-Evaluation: Safety Program Effectiveness....................................................................... 4 Employee Training - Sample Checklist................................................................................. 7 Important Contact Information ........................................................................................ 8 List of Hazardous Chemicals ............................................................................................ 9 Material Safety Data Sheet Checklist ................................................................................. 10 Hazard Communication -Training Checklist.......................................................................... 11 Employee Acknowledgement of PPE Training ....................................................................... 13 Personal Protective Equipment -- Hazard Assessment ............................................................. 14 Personal Protective Equipment Worksheet .......................................................................... 15 Personal Protective Equipment Training Log ........................................................................ 17 Certification of Safety-Related Personal Protective Equipment ................................................. 18 Employee Notification of Noise Level................................................................................. 19 Audiological Examination ............................................................................................... 20 Employee Notification of Audiometric Test Results ................................................................ 21

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Respirator Use - Identification & Location of Exposures Worksheet ............................................. 22 Respirator Selection Information Worksheet ........................................................................ 23 Respirator Selection Summary ......................................................................................... 24 Respirator Training Record ............................................................................................. 25 Employee Training Record.............................................................................................. 26 Respirator Use & Maintenance Record................................................................................ 28 Machine Guarding Check List........................................................................................... 29 Vehicle Inspection Form ................................................................................................ 31 Vehicle Check -- Repair Request....................................................................................... 32 Driver's Road Test ........................................................................................................ 33 Compressed Gas Cylinders - Quick Quiz .............................................................................. 34 Ladder Inspection Checklist ............................................................................................ 35 Back Injury Prevention Program - Essential Functions Analysis................................................... 37 Back Injury Prevention Program - Job Assessment ................................................................. 38 Back Injury Prevention Program - Job Analysis...................................................................... 39 Back Injury Prevention Program - Self-Inspection Checklist ...................................................... 40 General Ergonomic Checklist........................................................................................... 41 Ergonomic Manual Material Handling Checklist ..................................................................... 42 Ergonomic Task Design Checklist ...................................................................................... 43 Ergonomic Work Space Checklist ...................................................................................... 44

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© Meadowbrook Insurance Group – May 2011 1

The purpose of this document is to assist you with your risk management practices. Keep in mind that other exposures may exist in your operation that present varying degrees of risk. Although this information may assist you in your risk management efforts, it does not address every loss producing condition that exists currently or that may develop in the future.

Introduction

Meadowbrook/ASI Inc. (MIG) and the Association of County Commissions of Alabama (ACCA) are pleased with our combined effort in developing this manual. MIG hopes that it will be a useful tool to assist you and your organization in the area of safety.

It is the intent of Meadowbrook/ASI Inc. to fulfill its responsibility and live up to our motto, “Service and Integrity”, to the best of our ability and in a professional manner. Your goals and objectives are our goals and objectives, and we pledge to assist you in any way possible to achieve success.

This safety manual is one expression of our willingness to promote every effort to support the ACCA and its Insurance Programs. In addition to developing it, we are ready, willing, and prepared to continue our support and to respond to any requests from participants in the ACCA program.

This safety manual is a starting point in the promotion of safety on behalf of you and the Association of County Commissions of Alabama (ACCA). It does not cover every acceptable safety practice. It also does not address every circumstance you might experience that may require additional policies and procedures.

Please feel free to contact your Loss Control Representative if you have any questions concerning your safety program.

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2 © Meadowbrook Insurance Group – May 2011


Safety Management The Importance of Written Policies and Procedures

If your county is small or if it operates under a relatively close-knit management group, policies may be "understood.” This means that even though you may not have written policies, managers and supervisors have a good idea of the county’s expectations regarding certain basic issues pertaining to employees.

Relying on "understood" policies, however, may lead to misunderstandings. For example, the manager of a construction company arranges a safety meeting during which he launches into a tirade about the number of employees he has observed not wearing appropriate personal protective equipment (PPE). One supervisor at the meeting interprets the manager’s tirade as a shift in the organization's policy toward the use of PPE. He immediately begins a crackdown on employees that fail to follow PPE requirements in his area, disciplining employees who do not wear PPE when required. Another supervisor hears the same tirade, but does not take it as seriously. He decides to wait before he does anything drastic.

These kinds of situations can lead to frustration and resentment. For example, two employees from the same department eat lunch together and begin to talk about how their supervisors reacted to the manager’s tirade. One worker’s supervisor immediately disciplined him for not wearing hand protection; the other worker’s supervisor did nothing. This kind of situation can result in lower morale and productivity, more grievances, and understandably poor relations between supervisors and employees. Furthermore, both supervisors have failed to do anything that will improve employee compliance with the requirement to wear PPE.

Often managers and supervisors who have worked for the same County for a number of years believe they understand its policies. However, all they really have is a sense of how the other members of the management team and their predecessors have handled similar situations in the past. Other managers rely on their own judgment with each situation involving safety as it arises to make the right decisions. Either approach may result in inconsistencies that can in turn lead to misunderstandings, grievances, and even lawsuits. It is common for managers and supervisors to take a single manager's decision -- with no written documentation to back it -- as policy setting. The original decision then influences many similar decisions by other managers and supervisors throughout the County. If the original decision was sound, there may not be any consequences. However, if that manager made a decision that was illogical, irrational, or even illegal, there will be repercussions, and managers and supervisors who think they are complying with policy may repeat the original error in judgment many times.

This is why a policy manual is essential in today's complex, competitive, litigious, and regulation-ridden workplace. Employers should never assume that their managers or supervisors are keeping up with the numerous forces that constantly shape a County’s policy, among them changes in the law, changes in the character of the work force and its expectations, and changes in operations. Every organization should have a single, current, and authoritative source of information and guidance that managers and supervisors can use when making decisions or enforcing policy. This will minimize the tendency to act instinctively or on memory. With a policy manual, managers and supervisors are able to act decisively, consistently, fairly, and legally. An added benefit is that employees will also know that their managers or supervisors are acting in accordance with County policy as well as applicable federal and state regulations.

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A policy manual may not address all your problems. For example, your supervisors must know your policies about employee safety and health and understand the reasons behind them. Without this, you cannot expect them to carry the policies out with the commitment that is so vital to their effectiveness. For example, a supervisor needs to hire a large number of summer workers and get them in the field quickly. The supervisor knows the County’s policy is train all new hires in that department with right-to-know training as the Occupational Safety and Health Act requires. However, the supervisor has projects that need immediate attention, and he would like to ignore the requirement, especially since the employees are short term. Unless supervisors understand how failing to comply with OSHA might result in injury to employees and/or fines to the County, they may not cooperate with your efforts to provide employees with a safe and healthful workplace.

Good written policies do more than help supervisors and managers make difficult decisions and enforce rules. They provide the framework and background for such decisions, so that supervisors can explain to their subordinates (and to themselves) why a certain action or decision is the right one under the circumstances. Some policy manuals have a brief introduction to each policy, stating the reason a policy is necessary in this area, and what the organization hopes to achieve through implementation of the policy. Such information is invaluable when it comes to explaining an unpopular decision to employees, or when a supervisor must decide a course of action that runs contrary to his or her instincts.

Developing Policies

Most policies arise from the decision-making process. Managers who face a situation or problem for the first time evaluate it and make a decision or issue an order that they feel is appropriate. While this decision may not create a problem immediately, it may later. Another manager faces a similar situation under different circumstances. The manager who must make the decision this time has to revise the original to fit the changed circumstances. Over time, you have many supervisors and managers making different decisions in the same area while believing that they are adhering to the County’s policy.

Most policies develop from past practices no matter how good or fair they are. Even in companies where there is a policy manual, past practices may continue to influence managerial decisions. Therefore, the best policy is one that arises from the best decisions of the past. It should reflect the careful thought, good judgment, and valuable experience of all managers who have faced problems or decisions in a particular policy area. Most important of all, a good policy is a natural outgrowth of the organization's management philosophy and overall objectives. It helps management direct the organization according to its established goals and mission.

More specifically, policy development occurs when a group of people -- a policy committee -- meets and reaches consensus on specific policy statements. Committee members review past practices and the traditional approaches to certain situations as well as the latest legal requirements and management techniques. They try to pool their ideas and experiences, iron out differences of opinion, and come up with policies that are both fair and workable. Ideally, representatives come from the employee, supervisory and management ranks. This helps to assure that the committee considers the interests of all three groups during policy formulation.

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Purposes of a Policy Manual

A well-written, current policy manual guides managers and supervisors when they make decisions, train, or handle employment issues that relate to safety and health. A policy manual also offers other less obvious benefits.

• A policy manual is basic tool for communication tool. In the process of developing a policy manual, managers, supervisors, and employees contribute their ideas about each subject or policy area. This process enables top management to find out where their staff stands and how they feel about certain issues. Top management also learns what steps their management staff would like to see them take to improve and maintain safety, what areas are giving them problems, and where confusion and misunderstandings lie. In other words, the policy formulation process is perhaps the best opportunity that an organization's top managers will have to communicate with its management team on subjects of mutual interest. At the same time, supervisors and managers find out exactly where top management stands on safety issues.

• Remember, though, that communication should continue after the committee completes the manual. This is the time when real communication -- between supervisors and employees as well as between supervisors and their superiors – should begin. Every single time a question concerning a policy arises, the supervisor or manager in charge has an opportunity to improve communication and understanding with the employee(s) involved.

• A policy manual is a training resource. You can use the manual for training employees and new or recently promoted supervisors and in conducting refresher courses for experienced supervisors. Many companies use the manual’s table of contents to structure their supervisory training programs. You can develop and use case studies to illustrate problems. This is especially useful when discussing employment related safety issues. The manual can serve as a guide in deciding the right way to handle these hypothetical situations.

• A policy manual provides written documentation of the organization's commitment to its employees’ safety and health. Although a policy on right-to-know or confined space does not guarantee that you are in complete compliance with the law, having policies can be helpful if an employee files a complaint and someone from OSHA comes to inspect your operations. If you can show the OSHA inspector that you have clear, easily accessible, and widely publicized policies to ensure a safe and healthful workplace, it will make you look that much better. It may also help to reduce any fines you might receive if the OSHA inspector finds violations.

• A policy manual saves times. Your managers and supervisors will no longer spend time arriving at decisions that others have made before. They will not have to struggle with how to handle a ‘delicate’ situation. They will not have to wonder if management would approve of their actions. If your policy committee researches and writes the policies well, supervisors and managers will have all the information and support they need to carry out top management's objectives.

These and other reasons make it desirable to have a safety policy and procedure manual. In addition, there are other reasons that make such a manual mandatory if you are to fulfill your obligations to serve the public and to preserve all its resources -- human, material, and monetary. The regulatory requirements that OSHA imposes frequently change. Without current, documented policies and procedures, managers and supervisors are likely to make some mistakes in the area of safety and health that can lead to costly losses.

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Another reason for developing a policy manual is the increasing difficulty of managing and controlling complex operations. For example, in some organizations, managers of relatively small departments often make decisions that can affect the entire organization. It may not be possible or even desirable to control all management decisions under circumstances like these. It is, however, desirable to provide managers with a framework within which they can make their own decisions on important or sensitive issues in a fair and consistent manner.

In addition, some OSHA standards mandate that companies have a policy and procedure manual in place as a means of providing information to their employees. Employees in particular are becoming more outspoken about their desire to know what regulatory agencies require of their employers. They are most likely to bring their concerns to their immediate supervisors or department heads. It is, therefore, essential that these individuals have a resource to which they can turn to provide the requested information.

A policy manual is more than an item you might want to have. It is something you must have to preserve your ability to serve your customers, to attract and retain satisfied employees, and to reach your objectives through logical and consistent management decision-making.

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Basic Elements of a Loss Control Program

Accident Prevention

Accident prevention is essential to an efficient operation. Faced with today’s spiraling operational costs, managers and supervisors must control accident costs if they are to meet budgetary requirements. They realize that conserving human resources is a necessity not a nuisance. In addition, managers must coordinate activities that relate to safeguarding the organization’s investment and continuity of operations with their safety efforts.

To be effective, a loss control program should share and assign responsibilities for accident prevention and provide a means of ascertaining that those who have responsibility for it perform adequately. The program should not simply impose safety measures on the organization but build safety into every process and job, thus making the program an integral part of operations.

An organization can prevent accidents and injuries by controlling the work environment and its employees’ actions. For this reason, only management can implement such a program. Although this may add to management’s obligations, organizations that have effective loss control programs have a working environment in which employees can operate economically, efficiently and safely.

Basic Considerations for a Loss Control Program

Basic to any effective loss control program the method by which management assigns and assures responsibility for the program. Equally important to any successful program are these basic elements:

• Declaration of management policy and leadership

• Assignment of responsibility, authority, and accountability

• Maintenance of safe working conditions

• Establishment of loss control training

• Establishment of a system for accident reporting and investigation

• Creation of medical and first aid programs

• Acceptance of personal accountability for their own and others’ safety by workers

Management should include these basic elements into a formal written loss control program that addresses both general and department specific issues and is broad enough to include worker safety as well as other important areas, such as:

• Completed operations (the services you provide or functions you fulfill)

• Vehicles

• Equipment

• Property

• The general public

Management can implement the program by taking the following steps:

• Developing and communicating to employees the organization’s safety and loss prevention policy.

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• Conducting regular inspections to identify potential hazards on all physical properties, vehicles, and operations

• Developing and applying safety standards and procedures for all departments and facilities

• Educating and training employees on general loss control and safe work procedures

• Reviewing accidents to determine causes and to formulate measures to prevent recurrences

• Establishing effective means to measure employee performance in the area of safety and to correct deficiencies

Safety Policy and Program: The Important First Step

The first step to controlling losses should be management’s sincere communication of its interest in as well as its concern and requirement for the safety of its employees and the public. The communication should remind both supervisors and employees of their responsibilities.

All employees should receive a copy of the policy and acknowledge in writing that they have received, read, and understood it. In addition, management should post the policy in all locations -- such as lunchrooms or by time clocks -- where employees congregate.

Four sample policy statements follow. You may use one as is, combine parts of the four, or develop a policy statement of your own.

Sample Safety Policy Statements

Sample A

Our purpose is to deliver products and services to our customers effectively, safely, and on time. Our customers and our employees are our most important assets. The safety of our employees and our client while we deliver these services is one of our most important responsibilities.

A good accident prevention and loss control program demonstrates good management. Every managerial decision must consider the safety of our employees as well as the preservation of equipment and other resources. Accidents or operational errors that result in injury, death, or property loss are preventable.

The goal of our accident prevention and loss control efforts is to prevent injury to employees and damage to property. The program also exists to protect the public and our employees from the results of accidents and improper procedures.

Sample B

[Name of County] acknowledges that a sound safety program is an important function of its operational and administrative systems. It also acknowledges that the goals of the safety program apply to all employees of the organization.

The health and safety of our customers as well as our employees are of primary importance. Each department will strive to maintain a safety conscious attitude.

To support this policy, [Name of County] expects all its employees, present and future, to accept the idea that the safe way to accomplish a task is also the most efficient way to perform it.

Following safe work practices will be an integral part of appraisals for supervisors and employees.

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Sample C

Dear employee:

[Name of County] recognizes that accident prevention is essential in our efforts to provide service to our citizens.

Management is committed to providing the active leadership and support necessary to develop and maintain a successful accident prevention program. To this end, management strives to:

Provide a safe and healthful work environment for our employees.

Minimize the risk of human and financial loss that results from unnecessary personal injury and property damage.

Assure the security, well being, and protection of our employees, property, and vehicles.

Comply with all safety and health laws and regulations that apply to the workplace.

The success of our accident prevention program requires the full cooperation of all our employees.

All employees must consider accident prevention a vital part of their jobs.

Sample D

Purpose

The purpose of [Name of County]’s safety policy is to effectively address our commitment to employee, public and contractor safety and health, property protection or any other condition that may produce loss.

Scope

This policy encompasses all operations, physical buildings and property, or any other conditions, that fall within [Name of County]’s control.

Policy

[Name of County] believes that employee safety and the prevention of loss are of utmost importance. Our concern for safety exceeds our concern for quality, cost, and productivity.

[Name of County] has established procedures to manage safety on an ongoing basis. These procedures will carry out our philosophy that:

• All types of injury and loss are preventable

• Every supervisor and manager at any level is responsible for preventing injury and loss

• All employees will receive training and be responsible for working safely

• All operating exposures that possess potential for injury or loss are identifiable and controllable.

• In addition to concerns for our clients’ and employees’, injuries cost money and reduce productivity

• Working safely is a condition of employment. We will hold them accountable for safety in operations in which they are involved. When employees identify a hazard, they should report it promptly. There will be no reprisal for reporting of hazards.

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It is our policy to provide the resources necessary to obtain a loss-free work environment.

Our policy is to comply with the intent and spirit of applicable laws and regulations at both state and federal levels.

The safety coordinator will conduct and document periodic safety inspections. Department supervisors are responsible for assuring that they abate deficiencies promptly. If an injury or loss occurs, it is our policy to conduct a thorough investigation using competent employees.

Management will monitor the frequency and severity of losses regularly. If management notes a shift in loss experience, management will review the policies and procedures in this manual for their effectiveness.

This safety policy and procedure manual becomes effective on [Date].

_______________________________________________

County Administrator or Commission Chairman

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Employees’ Roles in the Safety Program

Management

Management has primary responsibility for the accident prevention program at every facility. Management will continually emphasize the importance of accident prevention -- both as a means of protecting employees and of operating efficiently.

Management will convey its interest in accident prevention to supervisors and employees through example, leadership, and participation in all of [Name of County]’s safety and accident prevention programs.

Management will:

• Delegate responsibility and duties to supervisors

• Provide supervisors with the training that they need to effectively encourage and manage safety in the workplace

• Make accident prevention efforts a part of the total operation

• Keep themselves and supervisors informed of accident problems and of the newest approaches to accident prevention

• Be alert to potential hazards by frequent monitoring of the workplace

• Review reports of accidents as well as documentation of safety inspections

• Consult with [Name of County]’s Safety Director, loss control representatives of its insurance company, and other outside authorities having jurisdiction

• Stress the importance that management attaches to positive results when discussing accident prevention.

• Stress that a successful accident prevention program requires everyone’s cooperation.

The Safety Director reports directly to [Title] and is accountable for all aspects of the accident prevention program that the President has approved.

Department Heads

Department Heads will:

• Actively support [Name of County]’s and the department’s safety program.

• Develop practical safety and accident prevention rules that relate to the activities of the department.

• Establish and maintain a system of monthly inspections of the facilities, vehicles, and systems for which they are responsible.

• Arrange for adequate job training and ongoing training in safety and accident prevention for departmental employees.

• Take prompt corrective action for any unsafe condition they observe or that employees report to them that might adversely affect the safety of an employee or the public.

• Coordinate departmental compliance with fire codes as well as safety laws and regulations.

• Assure that employees follow departmental safety rules.

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• Establish an adequate budget for safety equipment.

• Monitor the condition of all safety equipment and replenish it as necessary.

Supervisors

Supervisors should realize that employees see them as representatives of management. Therefore, supervisors’ conduct and attitudes are critical to the success of any accident prevention program.

The management of [Name of County] holds supervisors responsible for any accidents that occur. Supervisors should have a thorough knowledge of the hazards of any operations within their departments. They must run their operations with a firm commitment to the principles that every accident is preventable and that operating safely means operating efficiently.

Supervisors will:

• Provide or arrange for adequate basic job training and safety instruction for all employees that they supervise. They will also maintain adequate documentation of all training activities.

• Be fully accountable for any preventable losses and liabilities that their employees cause.

• Implement all of management’s accident prevention policies and make certain that the employees they supervise understand and comply with them.

• Provide ongoing safety instruction to focus attention upon potential hazards, changes in equipment or work assignments, as well as new conditions that may adversely affect employees or the public.

• Continually monitor and evaluate work conditions and procedures to uncover and correct any conditions or practices that might result in an accident.

• Make certain that the department has the necessary safety equipment and other protective devices for each job

• Make sure employees are using safety equipment and other protective devices properly.

Employees

Employees are also responsible for safety and accident prevention. [Name of County] requires employees, as a condition of their employment, to develop and use safe work practices that will prevent injuries to themselves, their coworkers, and the public. In addition, we require that all employees demonstrate by their actions that they share the County’s commitment to a safe and healthful workplace and to preserving the County’s resources.

Employees will:

• Promptly report to their supervisors all accidents and injuries -- no matter how slight -- that occur during their employment

• Cooperate fully and assist in the investigation of accidents to identify correctable causes and prevent recurrences

• Report to their supervisors any unsafe actions, practices, or conditions that they observe in the workplace

• Learn about and follow approved safe work practices as they perform their assigned duties

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• Always keep work areas clean and orderly

• Avoid horseplay and behavior that can distract coworkers from the safe performance of their jobs

• Obey all County and departmental safety rules and procedures and follow all work instructions

• Wear all required personal protective equipment and follow all instructions for maintaining such equipment in good condition.

• Wear seat belts when operating or riding in any County vehicle.

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The Purpose of Safety Committees

The County should appoint a formal safety committee to assist management on matters relating to the control of accidents, injuries, and incidents. To maintain continuity and control, the County should assign the safety coordinator as a permanent staff consultant to the safety committee.

Basic functions that all safety committees perform • Creating and maintaining an active interest in safety

• Reducing accidents (committees do not dictate policy nor relieve those in the line of authority of their direct responsibility)

• Gaining the involvement of fellow employees in furthering the cause of accident prevention

Membership

The size of the County determines the type and number of safety committees that will function most effectively. However, the membership of each committee should create prestige for the group. For example, a main or governing committee should include important executives and workers respected by fellow employees.

The committee membership should encompass the maximum knowledge of methods, practices, and conditions in the County. The committee should be as small as is consistent with these requirements. The types of committees found are as follows:

Safety Council

This is usually a central safety committee composed of department heads; it quite frequently includes such persons as department managers, and should include an hourly employee from each department.

• Department Safety Committees;

• Foreman's Safety Committee;

• Labor-Management Safety Committee;

• Housekeeping Committee

A large County may use more than one of these committees. A central safety committee should deal with policies and other general issues; department safety committees should focus on specific departmental issues. The department meetings should take place approximately one week before the central safety committee. Delegates, management, and hourly employees from each department or operating facility should attend the central safety committee meeting. The task of the central safety committee is to provide overall guidance and direction for safety, industrial hygiene, and loss control, while the task of the specific department safety committee is to solve specific problems and develop department policy.

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Activities

When the County establishes a committee, it should develop and communicate certain policies and procedures in writing. These should cover:

• The committee’s scope of responsibility

• The extent of the committee’s authority

• The committee’s reporting responsibility

• Procedures such as:

• Time and place of meetings (committees should not be required to meet after working hours)

• Frequency of meetings

• Order of business

• Records the committee should keep

• Attendance requirements

The safety committee has the following basic functions:

• Discuss and formulate safety policies and recommend their adoption by management

• Work through supervisors by having management-approved recommendations put into practice

• Conduct safety inspections, discover unsafe conditions and practices, and determine their remedies

• Stimulate and maintain the interest of supervisors and heads of departments to help them understand that safety is the responsibility of everyone

• Stimulate and maintain the interest of workers and convince them they should obey safety rules and instructions

• Provide an opportunity for free discussion of both accident problems and preventive measures

• Maintain a cooperative spirit between management and employees

• Establish procedures for handling safety recommendations and suggestions

• Review accident investigations and make suggestions and recommendations

Committee meetings should take place periodically and on schedule. Regular attendance of each member should be mandatory. All recommendations and suggestions from these committees (recorded in the minutes) should receive careful and prompt consideration.

There are two ways of selecting members of the workers' safety committee. Their supervisors may appoint them or their fellow employees may elect them. However, members of the committee should select their own chairperson. The success of a safety committee depends on:

• The support that management is willing to give to the group

• The belief each member has in his usefulness in the overall safety program

• The willingness of each committee member to accept responsibility

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Developing a Safety and Health Program

The following provides an outline of the essential components of an effective occupational safety and health program.

Section I -- Employer Information

In this section you need to enter basic information about the County and the types of activities you conduct. Items of information necessary include the following:

• Name of County

• Primary business address, city, state, and zip

• Telephone numbers of the administrative office

• Type of operation(s) and brief description of primary types of occupations employed or processes used

• List all locations where you conduct operations. For example, storage buildings, maintenance and so on

• List by name and job position all persons you have assigned authority and responsibility to implement and maintain your safety program

Section II -- Safety Coordinator

List the name and other pertinent information about each person responsible for carrying out your safety program:

• Designate only one primary Safety Coordinator; however, you may assign responsibilities for parts of your safety program to as many people as necessary

• For each person describe the authority and responsibility assigned to him or her

• Include telephone numbers and business mail addresses for each person

Section III -- Methods to Establish a Safe Workplace

Discuss the methods you will use to identify safety and health hazards. Some methods you may want to consider are:

• Review of applicable OSHA General Industry or Construction Safety Standards

• Industry best practices

• Review of industry and general information on potential occupational safety and health problems specific to your operation.

• Evaluate all previous accidents, injuries, illnesses, and unusual events that have occurred at each of your locations

• Study of Material Safety Data Sheets (MSDS) to identify health and safety hazards associated with chemicals used in your workplaces

• Scheduled inspections of general work areas and specific work locations

• Evaluation of information provided by employees

List and describe each safety-training program that you provide for your employees. You should also include a short description of each one.

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If you used a task safety analysis to develop information about safe procedures and to identify safety problems, describe the process and the location where you keep these records.

If you have developed a set of general safety rules or a policy and procedures manual, mention it here and list where copies are available in the workplace.

Section IV -- Procedures for Safety Inspections and Correction of Hazards

Discuss your procedure for scheduling and making safety inspections. Discuss each of the following items:

• The frequency for each type of safety inspection you plan to conduct

• The individuals, by title responsible for the safety procedures and the correction of hazards

• The procedures the person making the inspection will use

• How you will document safety inspections and corrective action taken on problems you identify

• How you will assure that the responsible person has taken corrective action on problems found during inspections.

• The methods you will use to alert employees to uncorrected problems.

List:

• Each checklist or inspection form you use to document inspections and state where these forms are available.

• The method or form you use to document inspection activities and the where you keep these records

List the procedures for follow-up. This assures that the person responsible has corrected the problem. Monitor so that problem does not recur.

Section V -- Safety and Health Training Programs

List when you plan to provide safety training. The following are minimum requirements:

• For all employees when your program is first established

• For all new employees prior to starting work

• For employees who receive a new job assignment

• When you introduce new substances, processes procedures, or equipment

• When you introduce new protective equipment or different work practices

• When you find new or previously unrecognized hazards

• For all supervisors to assure they know workplace hazards

Discuss your program for documenting training you provide your employees. Include complete information about the forms that you use and about where you retain them.

Review when refresher training is given and the documentation you maintain.

List each type of refresher training provided and the frequency.

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State the name of the person responsible for the various types of refresher training.

List and discuss all other types of safety and health training you provide and the methods used; i.e., video, discussion, lecture, hands-on, or computer-based.

Section VI -- Employee Safety Communications Program • Describe your procedures for communication of safe working conditions, work practices and required

personal protective equipment to be included in all initial and refresher training.

• Discuss all methods of communications about safety and health matters with employees. Specify what methods you use: meetings, posters, payroll stuffers, and so on.

• Describe how you solicit safety-related information from employees -- for example, a safety suggestion program. Discuss your provisions for the anonymous submission of ideas for or concerns about safety and health matters.

• State how you inform employees that they may express any concern, comment, suggestion, or complaint about a safety-related matter without fear of reprisals or other job discrimination.

Section VII -- Procedures to Assure Employee Compliance with Safety Rules • Describe your procedures to ensure employees follow safe work rules.

• Describe how you inform employees that policies and procedures for safe work conditions and practices as well as required personal protective equipment are mandatory.

• Describe specifically how you will enforce mandatory policies and procedures; for example:

• Recognition programs for compliance or good safety records

• Discipline for non-compliance and the method of applying discipline

Section VIII -- Accident and Illness Investigation Procedures • Discuss your accident and injury/illness investigation program and procedures:

• State that the persons responsible should conduct the investigation as soon as possible after the accident, injury, or illness.

• Include a procedure to investigate "near-miss" or unusual occurrences.

• List any forms you use and where they are available.

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Section IX -- Recordkeeping Procedures

List the forms you use to document accident and injury investigation and where these forms are maintained

• Describe your record-keeping program for occupational injury and illness

• List the period of retention of all written records

• Discuss maintenance of OSHA 300 log and associated documents

Section X -- Review and Approval

At a minimum, senior management official should approve and sign the plan. You may have as many levels of approval and signatures as are necessary.

You may want to consider having the responsible persons (safety coordinators) sign the plan.

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Organizing a County Safety Committee

The purpose of this guide is to give County employers basic guidelines on setting up safety and health committees. Properly organized, such committees can prove invaluable in detecting safety and health hazards and in recommending and supporting measures to reducing or eliminating the hazards.

A good safety and health program is the key to control of economic losses. An active, effective safety and health committee that includes representatives of management and employees is an essential part of that control.

General Guidelines for County Safety Programs

Management safety policy

Management should issue and post a safety policy statement containing a clear and concise view of management's determination that accident prevention should be equal to production and that all employment and places of employment shall be free of recognizable hazards. The safety policy shall delegate responsibilities with respect to implementing the safety program.

County accident investigation program

Management should implement an accident investigation program, which will investigate and record all accidents involving personnel, including medical only injuries, and accidents in which there was damage to material, equipment and/or machines. The investigation should determine all obtainable facts of each accident and cite corrective measures for implementation.

Accident/injury loss analysis

Management should develop an accident/injury loss analysis system. This analysis should show comparisons, locations occurring, and predominant type of injuries (responsible conditions).

County safety rules

Management should develop and implement a set of safety rules that are equal to or exceed applicable national standards. Such rules should be consistent with the size of County.

County safety-training program

County management should implement a program of safety training that provides:

• Training, by supervisor and/or trained instructor, of new employees and/or employees transferring to new jobs, on safety policies, right-to-know, and on operating procedures of County vehicles and equipment that the employee(s) will use.

• Supervisory training

• Specialized training as required

• Employee safety motivation; i.e., safety meetings, contests/awards, and recognition

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County Safety Inspection Program

Management should implement a safety inspection program that County employees conduct. The inspection program should include the following components:

• Daily inspections of the physical environment to which employees and the public have access - Examples: Housekeeping, defective premises, portable electrical equipment, handling/storage of toxic or explosive chemicals.

• Regular and periodic inspections - Examples: Machine guarding, handrails, guardrails, stairs, catwalks, elevators, lighting, noise exposure, fire prevention systems

• Special occupational hazards - Examples: Paint spray booths, confined space, entry controls, air contamination, and asbestos exposures.

• Preventive maintenance programs - Examples: Vehicles, floor-loading capacities, forklifts, elevators, respiratory protection equipment, building structure, etc.

County First Aid Program

Management should adopt a first aid program that should provide for:

• Qualified first-aid person available

• Adequate first aid supplies of sufficient quantity in well-sealed containers and restocked as needed

Selection and Hiring Procedures

Establish a uniform selection and hiring program for all new employees. Use a standardized application with due consideration for job requirements, physical examinations, prior employment checks, and previous injury records. Comply with all state and federal laws, including the Americans with Disabilities Act.

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Duties and Responsibilities of Safety Committee Members

Chair • Arrange for meeting place

• Notify members of meeting

• Make time schedule for meeting

• Review and approve minutes of meeting

• Select and appoint committee members

• Report to top management

Secretary • Prepare minutes of meeting and distribute

• Report status of recommendations

Members • Report unsafe conditions

• Attend all safety meetings

• Report all accidents or near accidents

• Investigate all serious accidents

• Contribute ideas and suggestions for improvement of safety

• Work safely and influence others

• Make inspections

The most important duty for each member of the safety committee is that of carrying out the responsibilities of a total safety program. He or she should know the general safety rules, pass on safety instructions to new employees, and make suggestions regarding unsafe conditions and practices.

The minutes are of great importance since other individuals besides safety committee members often receive them. These other recipients include top management. The minutes must record accurately all decisions made and action taken since they serve as a means of keeping management informed of the group's work.

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Effective Safety Committee Meetings 1. Send a notice of the meeting with an agenda to each member of the committee a few days before the

scheduled day.

2. Arrange a comfortable meeting room with adequate seating capacity.

3. Limit the meeting to a definite amount of time. Start promptly and adjourn at the appointed time.

4. To maintain interest, have a sufficient number of items of business on the agenda. Meeting should not be more than one hour long, preferably shorter.

5. Allow no distractions except for emergencies.

6. Conduct the meeting according to the generally accepted rules of order, with order respected and maintained. Do not allow formality to overwhelm the meeting or inhibit free and frank discussions. Maintain an atmosphere of free speech from the beginning of all such meetings.

Suggested Order Of Business 1. Call to Order Start the meeting promptly at the appointed time.

2. Roll Call Record the names of the members and guests present. Members who cannot attend should notify the secretary in advance. Note the reasons for their absence in the minutes.

3. Introduction of Visitors

4. Minutes Read the minutes of the previous meeting and correct them as necessary. (You can sometimes waive this item.)

5. Review of Accidents and Statistics

Determine and approve the classification of accidents by cause. The committee should establish responsibility for every accident and discuss preventive measures discussed.

6. Unfinished Business Reconsider all matters on which the committee has not made definite decisions.

7. Safety Education Select and review a definite subject for training. The subject should be pertinent to your operation. Training can be a film, slides, or literature. Record the subject in the minutes.

8. Committee Reports Poll committee members for any unsafe conditions noted in their departments. Review the results of previous inspections, conditions of safety posters, fire extinguishers, etc.

9. New Business The chairman should appoint sub-committees to arrange for inspections, investigations into safety rules and practices; obtaining safety educational material for future meetings and, in general, any idea or suggestion that may improve safety.

10. Speakers from outside the county or comments from visitors

11. Adjournment

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Safety Incentive Programs

Overview

A safety incentive program can enhance and maintain interest in an established safety program and help build cooperation among employees when management wants to launch a safety campaign that focuses on a specific area of concern. Safety incentives, however, cannot substitute for a safety program itself and sometimes incentive programs create problems such as employees working safely only until they have received the prize they want or failing to report hazards and incidents.

Before implementing an incentive program, ensure that you have all the components of an effective safety program in place. These may include:

• A safety policy that clearly states the County’s commitment to providing a safe environment for employees as well as customers and visitors

• Ongoing management support for activities that promote safety -- These may range from safety meetings and training sessions in which management participates to written “at-boys” and other less formal means of recognizing employees who are working safely

• Policies that communicate management’s expectations about all employees’ responsibilities and accountabilities for safety in the work place

• Work rules that make clear management’s expectations about job performance and other areas of conduct that may affect workplace safety

• Effective procedures for applying appropriate corrective action – ranging from training to disciplinary actions -- when employees fail to comply with expectations

• A performance appraisal system that includes the evaluation of each employee’s safety performance

• A safety committee that evaluates incidents and accidents and seeks ways to prevent them in the future

• The designation of individuals who have responsibility for monitoring workplace safety through form inspections and/or audit activities at regular intervals

It is essential to have a firm foundation upon which to build the incentive program. Otherwise, the objective of the incentive program -- increasing worker safety while reducing the direct and indirect costs of accidents and injuries -- will be lost. The goal of the incentive program is to increase worker awareness of safety issues and procedures, not to win prizes.

Creating the Program

There are many approaches to building an effective safety incentive program. Your approach will depend on:

• the nature of your operations

• the size of your operations

• the number of employees you have

• the number of work locations

• whether or not you wish to include all employees (line and clerical)

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• your budget

However, there are some general guidelines you may find useful.

Decide Your Objective

Management needs to determine why it wants to establish a safety incentive program. For example, your objective may be to decrease workers’ compensation premiums by reducing the number of worker injuries. Alternatively, you may want to increase productivity by decreasing the number of lost workdays. If your County is just beginning to implement a formal safety program, the objective may simply be to reinforce general safety principles.

Target Your Participants

Management should ask itself: "Which employees need to participate in the program -- or a particular phase of a long-term program -- to achieve the objective?” If there has been an increase in the number of claims resulting from respiratory disorders, a program that includes clerical workers is not necessary. You would probably want to target workers whose job responsibilities require them to use respirators.

Find a Focus

Having a central theme helps to remind participants of the goal that management wants its employees to achieve.

Select Appropriate Prizes with Increasing Value

Prizes need not be expensive, but they do need to be meaningful. Many companies decide to use various items imprinted with the County’s logo (and sometimes with the slogan of the specific contest). If a County runs an ongoing program, as distinct, for example, from a monthly contest, these types of promotional items come in a wide range of prices. This allows management to set up a point system in which winners in one phase can bank points to earn prizes of higher value. Prizes that reinforce the contest theme can be very effective; for example, safety glasses, work shoes, hard hats, etc.

Establish Duration

The incentive program should be intermittent and should last for a specified period. If carrying out a contest idea will require a prolonged period, it is best to have several shorter duration contests under the main contest heading. This will maintain employee interest and allow managers to stress various safety issues.

Communicate the Goal

The program should convey the enthusiasm of its designers (management, safety director, and safety committee) to the people (supervisors, employees) for whom they have designed it. The program should be fun, relevant to the work experience of all employees, and make recognition for being “safety smart” more significant than the value of the prize.

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Common Elements

While each safety incentive contest or program is different, all successful programs share the following basic elements.

1. A specific objective

2. A method for recording performance toward reaching the objective

3. A budget

4. Determination of participants and judges

5. Specific rules and time limits

6. A specific theme

7. The acceptance of top management

8. Promotion among all employees

9. A special kickoff

10. Design to keep continued interest

11. Method of keeping employees informed on performance and/ or standings

12. The announcement of winners

13. The posting of final standings

14. Management gives recognition for the effort employees have expended

If the County gives prizes or awards, the awards or prizes should never be so large that the goal becomes winning them rather than improving safety.

The following are samples safety incentive programs that employers have successfully used.

Safety Slogans

Programs that focus on creating safety slogans are extremely popular. They usually do not require employees to have special knowledge about safety. Before implementing the program, management should establish selection criteria to guide the judging process. Will the criteria be originality, applicability to operations at the work location, most dramatic, most appealing? Management should also decide who would serve as judges.

Most Original

This contest runs for a period of two months. Management encourages all employees to submit original safety slogans. A panel of judges selects four winners each month. First prize is the choice of item from an incentive catalog (moderate prices). Prizes for runners-up are items from an incentive catalog (lower prices).

Management posts the slogan throughout the plant and prints them in the County’s newsletter.

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Quarterly Slogan

Hold a slogan contest during the months of August, September, and October of each year, and invite all employees to submit slogans. The management committee selects a winning slogan. The employee who submits the winning slogan any of the three months receives a check for $25. The best safety slogan for the entire three-month period earns an additional reward of $50.

Each month, the winner's name and his/her slogan appear on the County’s paychecks.

“Do You Know?”

Management sets a budget of $## for each month during which this campaign will take place. At the beginning of each month, management posts a safety slogan pertaining to workplace conditions or practices on bulletin boards throughout the work location. At the end of the month, management puts the names of all employees in a box and draws six out.

The safety supervisor (or other individual) approaches each of these six in turn and asks them what the safety slogan is. If the employee is able to repeat the slogan, he or she receives a silver dollar. If an individual does not know the slogan, management draws another name. The process repeats until the entire $6 is used.

Variation of “Do You Know?”

Management posts the slogan of the week on bulletin boards throughout the facility. The Safety Director then picks 15 names at random from the employee list, numbering them in order. Armed with five silver dollars, he looks for the first person on the list. No prior publicity is given, and the safety Director simply asks the employee what the slogan of the week is. If the individual can repeat it, he/she receives one of the dollars. If not, the Safety Director goes on to the second person on the list. The Safety Director continues until he or she has given the five silver dollars away or has asked all the employees on the list. Usually, a period of a few weeks is sufficient to get the employees to read the safety bulletin boards, after which time, discontinue this contest and start another.

Best Slogan

Management encourages all employees to submit safety slogans. A group of judges selects the best one each week.

The prize for the best slogan each week varies. It might be a baseball cap with the County’s logo, certificates for dinner and a movie, a coffee mug, etc.

After the period designated for the contest ends, the judges decide which should receive the grand prize. The winner receives an award of greater monetary value.

Each weekly winning slogan and the person submitting receive wide publicity throughout the plant. In addition to his or her monetary award, the grand prizewinner wins pizza and pop or donuts and coffee for his or her department.

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Children's Safety Slogans

For a period of six weeks, management encourages employees' children up to age 13 to submit safety slogans. The safety committee (or other panel of judges) picks winners weekly with a prize of $20 for first place, $10 for second place, and five dollars for third place (or other equivalent reward). At the end of the contest, there is a grand prizewinner for the best overall slogan with a $25 award.

Photographs of the winning children and their slogans appear in a County calendar or in the County’s newsletter.

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One Thousand Safe Days

In this contest, the winner is any department that is able to operate 1,000 days free of any lost-time injury. Every employee in the department receives a quality gift suitably inscribed with the achievement of the department. The gift can be a ballpoint pen, a coffee mug, a baseball cap, or a tee shirt. Management makes the presentation with appropriate ceremony, pictures, and publicity.

Hours Worked

For every 50,000 hours that the entire County operates without a lost-time accident, management purchases and displays a prize with a value of approximately $10. After six such prizes have been set aside, management calls a general meeting of all employees, at which time they have a chance to participate in a general drawing for the prize.

If a lost-time accident interrupts the contest before the six prizes have been set aside, the department in which the accident occurs is ineligible, and all other departments are eligible to draw for the prize.

Safe Employee

The contest starts at the beginning of each month and is for employees who have had no accidents during the preceding month. Management writes the name of each accident-free employee on a piece of paper and places it in a hat. At the same time, management posts different safety slogan monthly. At the end of the month, a member of management draws a name from the hat. A member of management makes a phone call to the selected employee's residence. If the person answering the phone is able to quote the plant slogan, he or she wins a prize.

No Accident - No Absenteeism

Once a month, management places stubs with the time card numbers or names of all employees in a box. The contest winner from the previous month draws one stub from the box before the monthly safety meeting.

Management checks the selected employee’s record for:

• No accidents during past month

• No absenteeism during past month

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This process continues until one meets the two above requirements, at which time he/she receives a special prize.

Management announces the name of the winner at the Safety Committee Meeting and posts it on the facility’s bulletin boards. This contest can be County-wide or limited to a specific department.

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Safety Quizzes

Safety Know How

This county publishes a bulletin dealing entirely with the subject of safety. The schedule can be monthly, bi-monthly, or quarterly. To make sure that employees read the bulletin, management sets up a quiz contest.

The names of all employees go into a box and each month (every other month, quarter) the safety director draws a name. He or she approaches this person and asks him or her several questions concerning the most recent issue of the bulletin. If he or she is able to answer the questions, he or she receives a prize.

There are two important considerations: (1) the material should not be too technical since it must appeal to a wide range of employees. Suitable topics might be good housekeeping or fire prevention. (2) The contest should take place within one week of distribution of the newsletter.

Lottery Winner

Management posts a safety slogan on all bulletin boards daily. Sometime during the day, the Safety Supervisor approaches an employee whose name he or she has drawn at random. The Safety Supervisor asks the employee to quote the safety slogan of the day. If the employee can do this, he or she receives a lottery ticket. If the employee cannot, the Safety Supervisor adds the ticket to the following day’s award, increasing its value. When someone is able to quote the safety slogan accurately, that person receives the entire award. The next day the contest starts again with a new lottery ticket.

Telephone Tag, You’re it

Interested employees submit their names and home telephone numbers for a special drawing.

A member of the Safety Committee draws one name out of the box each month and calls the employee's home. If the person who answers the telephone is able to quote the safety slogan for the month, he/she receives a gift certificate. If the person is unable to recite the slogan, the Safety Committee increases the gift certificate for the next month.

Miscellaneous and Combination Contests

Cash and Grocery

Only employees in departments without a lost-time accident during the preceding month are eligible for this contest.

In this contest, management awards a combination of cash and groceries to one employee each month based on a safety slogan displayed throughout the facility.

Management writes the names of eligible employees on slips of paper and places them in a box. Management draws the winning name at the designated time each month. The winner gets $10.

Management then makes a telephone call to the winner's home. If anyone there is able to repeat the current safety slogan, he or she receives a $25 certificate towards a grocery order from a local store.

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Safety Suggestion

Management places suggestion boxes throughout the work location. Employees write out safety suggestions. The suggestions can be about unsafe acts, unsafe conditions, and health hazards. The Safety Committee reviews the suggestions at each monthly meeting. The committee selects the best suggestion each month by vote. Recognition takes the form of posting the winner’s name and his or her suggestion on bulletin boards along with the action management or the Safety Committee will take because of the suggestion.

Good Housekeeping

Monthly a manager and one member of the Safety Committee inspect various work locations within the facility. The Safety Committee person changes monthly.

The manager and the Safety Committee member make the inspections and score them individually. Each inspector then turns his or her scoring into a designated individual such as an Administrative Assistant. This person averages the scoring for each work location and, by comparing it with the previous month’s score, decides which work location has made the most improvement and thereby becomes the winner of the good housekeeping award for the month.

The Safety Committee posts the monthly total scores in the order of rating on bulletin boards throughout the facility.

Inspectors perform the scoring on a sheet that lists the ten items that they will check with the department numbers across the top of the sheet. Each department can rate up to ten points on each of the ten items.

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Employment Hiring Safe Employees

Every county should make safety a part of the hiring process. Federal and state laws require employers to provide a safe and healthful workplace for their employees. Beyond that, you can increase productivity by hiring safe employees. Employees who are aware of safety issues and have a commitment to following safe work practices can reduce accidents that result in lost time. A reduction in accidents improves employee morale. When a coworker receives an injury on the job, employees can become less motivated to perform their responsibilities. However, if employees have a commitment to safety and understand that you, as their county, want them to have a safe workplace, they feel better about their jobs. Finally, hiring for safety can also reduce a county’s exposure to liability from employees whose unsafe acts result in harm to others.

Every county wants productive employees. What does this mean? Certainly it means that counties want to hire and retain individuals who can perform their job responsibilities efficiently and by established deadlines. However, it also means – or should mean – that they want to hire and retain individuals who are qualified for the work they will perform, are motivated to perform well, and have a concern for safety.

For example, when hiring a driver, counties need to determine, among other things, if:

• The candidates have the appropriate license(s),

• They have the knowledge, skills, and abilities to drive the type(s) of vehicle for which they will be responsible,

• Their past employment and (or driving record) supports the hiring decision. In particular, do reference checks and motor vehicle record checks reveal safe driving habits?

If a county wants to hire a person to perform maintenance on electrical equipment, the county would want to determine if candidates are licensed and if they are familiar with regulations such as those for the Lockout and/or Tagout of Hazardous Energy Sources.

Making wrong hiring decisions can be costly. Injuries to employees cost employers millions of dollars every year in direct medical costs and wage benefits. In addition, there are the hidden costs that result from reduced motivation and productivity in the workplace as well administrative costs that a county incurs when a worker receives an injury. Sometimes the same unsafe work habits that injure employees also hurt members of the public. The county may then face the additional burden of financial loss as well as diminished public trust.

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Guidance for Adoption of Drug Test Policy Federal law requires entities, including local governmental entities that employ certain categories of workers to implement a Drug and Alcohol policy. This law is administered by the United States Department of Transportation (“USDOT”). Employees who must be tested pursuant to USDOT regulations include all CDL drivers who operate commercial motor vehicles on public highways and all transit employees. In addition, the Association of County Commissions of Alabama recommends that all members adopt a comprehensive Drug and Alcohol policy applicable to all employees. Such a policy ensures the safety of all County residents and employees and can lower your liability risk.

Therefore, the Association is providing a sample Drug and Alcohol policy, which may be customized and adopted for your county. This policy satisfies current USDOT requirements and is the policy recommended under the Association’s Workers’ Compensation Self-Insurers’ Fund and Liability Self-Insurance Fund. While you should read the entirety of the policy very carefully, there are a few areas to which you should pay special attention, including as follows:

Safety Sensitive Employees: Please carefully review the definition of “safety sensitive employees” contained in the sample policy. When determining whether an employee is safety sensitive, ask yourself whether the employee could seriously injure or kill himself or others if he makes a mistake while intoxicated. If the answer is “probably not,” then the employee is not safety-sensitive. It is very important that you have current, accurate job descriptions that clearly state whether the position is safety-sensitive.

Random Testing: Public employers cannot randomly drug test all employees. Only those employees who hold positions that have been designated to be safety sensitive can be randomly drug tested! Randomly drug testing public employees who do not qualify as safety sensitive is a violation of the Fourth Amendment of the United States Constitution.

Pre-Employment Testing: There is a debate about whether non-safety sensitive employees may be subjected to pre-employment testing. The issue has not been definitively decided in Alabama. Some courts across the country have held that pre-employment testing is acceptable because it is different from random drug testing in that an applicant’s interest in obtaining a job is lower than a current employee’s interest in maintaining a job, while the employer’s interest in finding out whether the applicant has used drugs is higher than their interest in randomly testing employees with satisfactory job performance. However, many other courts have rejected that test. Importantly, in Chandler v. Miller, 520 U.S. 305 (1997), the United States Supreme Court has held candidates for public office, who are essentially applicants for public employment, may not be subjected to drug-testing as a precondition to getting on the ballot, finding that there was no justification for doing so that outweighed the candidates’ Fourth Amendment rights because the positions at issue could not be considered safety sensitive. After carefully considering the relevant law, the ACCA recommends that counties only conduct both random and pre-employment testing for safety-sensitive positions.

Appendix C

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Reasonable Suspicion/Post-Accident Testing: The restrictions on pre-employment and random testing do not mean that you must tolerate non-safety-sensitive employees being intoxicated at work. All employees can and should be subjected to reasonable suspicion and post-accident testing.

Employee Assistance Program: As stated in the sample policy, employers are required to provide information to employees regarding Substance Abuse Professionals (“SAPs”) who can assist them in fighting a drug or alcohol addiction. In addition, employers may, but are not required to, institute an Employee Assistance Program (“EAP”) to assist employees who are fighting such an addiction while remaining employed. A brief sample EAP policy is included in the larger sample policy. If you do not wish to adopt an EAP, then you should delete it. If you currently have an EAP or wish to institute such a program, then you should customize this policy to your needs.

USDOT Requirements: USDOT has very specific requirements for drug and alcohol policies. The Association recommends that most of these requirements, such as the provision of annual training for employees and supervisors and the use of certified testing labs, be adopted across the board. However, even if a comprehensive policy is adopted, there are still a few special requirements for employees subject to USDOT regulations. For example, USDOT has very specific yearly requirements for how many employees must be randomly tested and requires that these employees be placed in a separate random-testing pool from other safety-sensitive employees. You should check USDOT’s website each year to ensure compliance (www.dot.gov/adapc). USDOT may also require you to submit a report to ensure compliance; therefore, it is important that you keep appropriate records of all testing.

Drug Program Coordinator: Each county should designate a Drug Program Coordinator who will be responsible for ensuring compliance with your drug and alcohol policy, including ensuring that the testing laboratories and Medical Review Officer are properly certified.

http://www.dot.gov/adapc�

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Sample Drug and Alcohol Abuse Policies and Procedures

(Effective date: _______________)

General Statement Of Policy

Employer is committed to providing a safe working environment for all employees while serving the citizens of ____ County. Employer recognizes that any employee who improperly uses intoxicating substances, including drugs and alcohol, poses a serious threat to his or her self, his or her coworkers, and to the public in general. Even small quantities of narcotics, abused prescription or over-the-counter drugs or alcohol can impair judgment and reflexes. This impairment can have dire results, particularly for employees operating vehicles or potentially dangerous equipment.

It is therefore the policy of the EMPLOYER that all employees or any person performing any kind of work for EMPLOYER must report to work completely free from alcohol, illegal or unauthorized drugs, or any other substances that may have a mind-altering or intoxicating effect or otherwise impair the employee’s judgment, reaction times, or functioning.

Employer also prohibits all employees from using, possessing, manufacturing, distributing or making arrangements to distribute alcohol, illegal or unauthorized drugs, or any other intoxicating substances while at work or on or about any county property.

In order to avoid creating safety problems and violating this Policy, employees must inform their supervisor when they are legitimately taking any medication, including prescription drugs or over-the-counter medications, which may affect their ability to work. Employees whose job performance may be affected by such medications may be required to provide a fitness-for-duty certification before being allowed to resume their job duties.

Any employee who violates this Policy in any way shall be immediately removed from his or her job duties and shall be subject to discipline, up to and including immediate termination.

No part of this Policy shall be construed to create a contract of continued employment or to confer upon any employee or applicant a property interest in his or her employment. Employer maintains the right to change this policy at any time without notice. To the extent that any portion or provision of this Policy and Procedure conflicts with any applicable federal or state laws or regulation, such federal or state laws or regulations will be controlling.

Employer has designated {Drug Program Coordinator} as the Drug Program Coordinator. If you have any questions or concerns regarding this Policy or its application, please contact him/her at: {Contact Information}.

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Definitions

• “Accident” means any on the job accident. “Accident” includes vehicular accidents as well as any acts or omission causing an accident or injury to any person, or damage to any equipment or property belonging to the county.

• “Administrator” means the person or entity that implements drug testing on employees and applicants.

• “Alcohol” means distilled or fermented beverage containing ethyl alcohol, including, but not limited to, beer and wine.

• “Chain of Custody” means procedures implemented by the Employer for the identification and integrity of each urine specimen. Employer requires [person responsible for policy implementation] to track the handling and storage of each urine specimen from the point of specimen collection to final disposition of the specimen. These procedures include an appropriate drug testing chain of custody form to be used from time of collection to receipt by the testing laboratory. Chain of custody forms shall document the date and purpose of each time a specimen is handled or transferred and shall identify every individual in the chain of custody.

• “Collector” means a person who instructs and assists tested employees and applicants for eligible positions at a collection site and who receives and makes an initial examination of the urine specimens. The collector shall have successfully completed training to carry out this function or shall be a licensed medical professional or technician who shall be provided instructions for collection under this procedure and certifies completion as required herein. In any case, where a collection is observed or monitored by non-medical personnel, the collector shall be a person of the same gender as the employee or applicant.

• “Collection Site” means a place designated by Employer where employees present themselves for the purpose of providing a specimen of their urine to be analyzed for the presence of specified controlled substance and alcohol. The site will possess necessary personnel, materials, equipment facilities, and supervision to provide for the collection, security, temporary storage, and the transportation or shipment of the samples to a laboratory.

• “Controlled Substance” means any substance defined or classified as a controlled substance according to Federal or State law. Title II of the Comprehensive Drug Abuse Prevention Act of 1970 (Controlled Substance Act), as it is amended from time to time, provides the basic standard. Controlled substances include, but are not limited to, any and all forms of marijuana, stimulants or hallucinogens the sale, and purchase, transfer, use or possession of which are prohibited or restricted by law.

• “County” means ___County.

• “DOT Employee” is an employee who is subject to the rules and regulations of the United States Department of Transportation regarding drug and alcohol testing because of the job duties that he or she performs.

• “Drug Program Coordinator” is the person designated by Employer to ensure compliance with this Policy, including, but not limiting, ensuring that proper testing procedures are followed, ensuring that the lab(s) used by Employer are properly certified, and ensuring that the Medical Review Officer is

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properly credentialed. The name and contact information of the Drug Program Coordinator will be distributed to all employees.

• “Employer Premises” includes all property owned, leased, used or under the control of Employer, including, but not limited to, the job site of any employee, structures, building offices, facilities, vehicles and equipment, or transportation to and from those locations while in the course and scope of County employment.

• “Employee” means any and all employees of Employer.

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• “Illegal/Unauthorized Drug” means any drug (A) which is legally obtainable but has not been legally obtained or, even if legally obtained, is not being used in accordance with instructions given either by a physician or, if over-the counter, on the drug’s label; or (B) all illegal drugs, including, but not limited to, methamphetamine, marijuana, cocaine, etc.

• “Intoxicating Substance” means any substance, whether legal or illegal, that may have an intoxicating or mind-altering effect when ingested, snorted, smoked, or otherwise introduced into the body. Intoxicating substances include, but are not limited to, “bath salts,” nitrous oxide, glues, solvents, or herbs or other plants such as salvia.

• “Legal Drug” means prescribed drugs and over-the-counter drugs which have been legally obtained and are being used appropriately for their intended purpose in accordance with directions given either on the label or by employee’s treating physician.

• “Possession” means actual or constructive care, custody, control or immediate access.

• ”Under the Influence” means being unable to perform work in a safe and productive manner; being in a physical or mental condition which creates a risk to the safety and well-being of the individual, other employees, the public and/or having any laboratory evidence of the presence of drugs, alcohol, prohibited or controlled substance in the employee’s body.

• “Medical Review Officer” (MRO) means a licensed physician (medical doctor) responsible for receiving laboratory results generated by the county’s drug testing program. The MRO shall have knowledge of substance abuse disorders and have appropriate medical training to interpret and evaluate an individual’s confirmed positive test result, together with his/her medical history and any other relevant biomedical information.

• “Random Selection Process” is the process used to ensure that each employee holding a safety-sensitive position has an equal chance of being drug-tested every time that random drug tests are conducted. This process means that some employees may be tested multiple times in any given year.

• “Reasonable Cause” means that the County believes the actions or appearance or conduct of an employee on duty are indicative of the use of a controlled substance or alcohol.

• “Safety-Sensitive Employees” are those persons who are subject to random drug and alcohol testing. These employees include, but are not limited to, persons who inspect, service, repair or maintain a vehicle or other heavy equipment, operate or load a vehicle or heavy equipment, use tools, including both power and hand tools, that have the capacity to injure any person, and those who are authorized to carry weapons of any kind. An employee is engaged in a safety-sensitive function at all times from the time that an employer begins to work or is required to be in readiness to work until the time he or she is relieved from work and all responsibility for performing work.

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Persons Subject to Testing

The following employees have been designated by Employer to submit at any time to be tested for illegal drug abuse and alcohol abuse:

• All employees who hold positions or regularly perform duties that have been designated to be “safety sensitive” by Employer.

• Any employee who, during the course of said employee’s employment, is involved in an accident causing physical injury to any person or damage to any property.

• Any employee, regardless of whether he or she holds a safety sensitive position, whose conduct, behavior, or physical symptoms establishes reasonable cause to believe that said employee is under the influence of any, drug and/or alcohol while performing his or her job duties, or while being physically present on the premises of the Employer’s property during any activity sponsored, supervised, or in which the Employer participates.

Types of Testing

Pursuant to Employer’s policy and procedures, employees will undergo testing as follows:

1) Pre-Employment Testing: All employees applying for a position that has been designated as safety-sensitive will be required to submit to a pre-employment drug and alcohol test before a final offer of employment is extended. All pre-testing offers of employment to such persons are explicitly conditioned on the employee successfully taking and passing the drug and alcohol test. Pre-employment testing will also be done when an employee transfers from a non-safety-sensitive position to a safety sensitive position.

2) Random Testing: All employees holding safety-sensitive positions will be subject to testing on a random basis without advance notice to them.

3) Reasonable Cause Testing: Employer may schedule a drug/alcohol test when behavioral observations indicate to the employee’s supervisor that any employee may be involved in illegal use of a controlled substance, use of alcohol, or abuse of legal drugs. Before testing, the employee’s supervisor shall either (a) contact another supervisor to observe the employee’s behavior and to concur with the decision to test the employee, or (b) review the employee’s behavior with another supervisor to obtain concurrence with the decision to test the employee. The employee shall be promptly escorted to the collection site for testing by the employee’s supervisor or designee.

• Employees arrested or convicted for the off-the-job use or possession of illegal or controlled substances shall undergo testing to assist Employer in determining fitness for duty. If the employee tests positive, Employer shall discharge the employee.

4) Post Accident Testing: All employees are required to report all injury or damage related accidents and submit to a post accident drug/alcohol test as set out in this policy. Each employee whose performance either contributed to the accident or cannot be completely discounted as a

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contributing factor to the accident shall be subject to testing. The employee’s supervisor or his designee shall schedule the drug screening test immediately following an incident reportable or a reportable accident.

5) Return-To-Duty Testing: If you have violated the prohibited drug and alcohol rules, you must take and pass a drug and alcohol test before being returned to work. Further, any person who has violated the prohibited drug and alcohol rules is required to take a drug and/or alcohol test before returning to safety-sensitive functions for any DOT regulated employer and is also subject to unannounced follow-up testing at least six (6) times in the first twelve (12) months following a return to active safety-sensitive service.

Any and all drug testing conducted by Employer will not be used to identify the existence of any disability.

In the event there is reasonable suspicion of a violation of this policy, Employer also reserves the right to search all property, cabinets, tool boxes, vehicles, including personal vehicles brought onto Employer’s property, or any other property on Employer’s property, under control of any employee or in the personal vehicle of any employee, and located on Employer’s property and used by said employee in commuting to work or in that employee’s duty as an employee.

Safety-Sensitive Employees

Employees are considered to be “safety-sensitive” when their job duties regularly require them to engage in activities that have the potential to cause physical injury to themselves or others or to cause serious property damage. Such activities include, but are not limited to,

• Maintaining or repairing motor vehicles or heavy equipment, including, but not limited to, bulldozers, tractors, and riding mowers

• Maintaining or repairing tools that have the capacity to seriously injure the user or another person, including, but not limiting to, chainsaws or weed-eaters

• Regularly operate motor vehicles or heavy equipment as part of his or her job duties, including equipment such as tractors or riding mowers for which licensure is not required by the State of Alabama

• Regularly operate tools that have the capacity to seriously injure the user or another person

• Loading and unloading vehicles or heavy equipment.

• Any activity related to the safe operation of a mass transit system, including dispatching vehicles.

• Carrying any weapon or object that could reasonably be used as a weapon, including, but not limited to, firearms, knives, machetes, blades, tasers, or batons.

• Answering emergency calls and/or directing the provision of emergency services.

• Providing emergency medical services.

A list of positions that have been designated as safety sensitive by Employer is attached hereto as Attachment A. Some safety-sensitive positions are specifically subject to regulation by the Department of Transportation (DOT). These positions are indicated by an asterisk. An accredited testing laboratory will

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maintain two different random testing pools, including one pool for persons specifically subject to regulation by DOT and one pool for all other safety-sensitive employees.

All employees are subject to drug and alcohol testing when there is reasonable cause to believe that they have violated this policy and after any accident involving physical injury or serious property damage. However, employees who have been designated as safety-sensitive are also subject to pre-employment testing and random testing. Random drug tests can be performed any time a safety-sensitive employee is on duty. An alcohol test can be performed when the safety-sensitive employee is performing a safety sensitive duty, just before, or just after the performance of a safety sensitive duty.

In addition, employees occupying positions deemed to be “safety-sensitive” must promptly report any arrests, charges, or convictions for drug or alcohol related criminal offenses, including both misdemeanors and felonies, to his or her supervisor. FAILURE TO REPORT SUCH ARRESTS, CHARGES, OR CONVICTIONS MAY BE GROUNDS FOR DISCIPLINE, UP TO AND INCLUDING IMMEDIATE DISMISSAL.

Necessity of Compliance with Testing Requirements

All employees are subject to reasonable suspicion and post-accident testing as a condition of their employment. In addition, all safety-sensitive employees will be subject to pre-employment and random urine drug test and breath alcohol testing as a condition of their employment.

Any employee who refuses to take a drug and/or alcohol test to which he or she is properly subject shall be considered to have a verified positive test result. An employee who has a verified positive test result, including by refusal, shall be immediately removed from their duties and may be subject to immediate termination. In addition, any employee subject to DOT regulations will receive educational and rehabilitative information and a referral to a Substance Abuse Professional.

Refusals can include a variety of behaviors, including as follows:

• Failure to appear for any test (except for pre-employment) within a reasonable time, as determined by the employer;

• Failure to remain at the testing site until the testing process is complete;

• Failure to provide a urine specimen for any required drug test;

• Failure to permit the observation or monitoring of the specimen collection when required to do so;

• Failure to provide a sufficient amount of urine when directed without an adequate medical explanation for this failure;

• Failure to take a second test when directed to do so by the employer or collector;

• Failure to undergo a medical examination when directed to do so by the MRO or employer;

• Failure to cooperate with any part of the testing process (e.g., refuse to empty pockets when directed by the collector, behave in a confrontational way that disrupts the collection process, fail to wash hands after being directed to do so by the collector);

• Failure to follow the observer’s instructions during an observed collection, including instructions to raise your clothing above the waist, lower clothing and underpants, and to turn around to permit the

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observer to determine if you have any type of prosthetic or other device that could be used to interfere with the collection process;

• Possess or wear a prosthetic or other device that could be used to interfere with the collection process; and

• Admit to the collector or MRO that you adulterated or substituted the specimen

• Failure to sign step 2 of the alcohol test form

• Leaving the scene of an accident without a valid reason before post accident tests have been completed. Failure to remain "readily available."

Off-Duty Conduct

Off-the-job use of drugs, alcohol, or any other prohibited substance which results in impaired work performance, including, but not limited to, absenteeism, tardiness, poor work product, or harm to the County’s image, tasks, or government is prohibited. Employees should realize that these regulations prohibit all illicit drug use, on and off duty.

Prescription Drugs

The proper use of medication prescribed by a physician is not prohibited; however, Employer prohibits the misuse of prescribed and/or over-the-counter medications or other intoxicating substances and requires all employees using drugs at the direction of a physician to notify the Employer’s Medical Review Officer (MRO), or their Drug Program Coordinator where these drugs may affect their job performance, such as by causing drowsiness. Employees may not perform safety-sensitive functions while using any controlled substances unless the employee’s physician certifies that the substances will not adversely affect the employee’s ability to perform his or her job.

Pre-Employment

All safety-sensitive applicants shall undergo urine drug testing prior to performing safety sensitive duties. This requirement also affects employees not in safety-sensitive positions who seek reclassification into a safety-sensitive position. Receipt by Employer of a negative test result is required prior to performing safety sensitive duties in a covered position. A cancelled test result is not acceptable and must be retaken. If the applicant has a positive pre-employment drug test, he/she cannot be hired for a safety sensitive position.

A negative result on a pre-employment test by a job applicant is valid for thirty days. If a current covered employee has not performed a safety sensitive duty for 90 days or longer, and has been removed from the random pool, the employee must submit to a new pre-employment test and receive a negative result before resuming safety-sensitive duties.

A MRO may report negative pre-employment rest results for individuals who are unable to provide sufficient volume due to permanent disability, but has a medical evaluation that indicates no chemical evidence of illegal drug use.

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All applicants for safety-sensitive positions will be notified in writing that they will be required to undergo pre-employment/reclassification drug testing prior to their employment and that they will be subject to drug and alcohol testing throughout the period of their employment. Applicants will acknowledge in writing their understanding of these provisions for their application and employment. Employer will retain on file the negative drug test results of all new hires.

In addition to undergoing pre-employment testing, applicants for a safety-sensitive position will be asked to sign forms for release of information from any previous employer for whom the applicant performed safety sensitive functions. Failure to sign this form will result in not being hired. When a covered applicant has previously failed a pre-employment drug test with a prior employer, the employee must present proof of successfully having completed a referral, evaluation and treatment plan.

Reasonable Cause

All employees (whether or not safety-sensitive) will be required to submit to screening whenever a supervisor observes circumstances which provide reasonable cause to believe an employee has used a controlled substance or has otherwise violated the substance abuse rules. Examples of circumstances that may establish reasonable cause to warrant testing include supervisor observation, co-worker complaints, performance decline, attendance or behavior changes, involvement in workplace or vehicular accident, or other actions which indicate a possible error in judgment or negligence, or other violations of the drug or other Commission policy. Before testing the employee, another supervisor shall be contacted to observe the employee’s behavior and to concur with the decision to test the employee, or the observing supervisor will review the employee’s behavior with another supervisor either face to face or via telephone, to obtain concurrence with the decision to test the employee. The documentation of the employee’s conduct shall be prepared and signed by the witnesses within twenty-four (24) hours of the observed behavior or before the results of the test are released, whichever is earlier.

Upon the reasonable suspicion determination being made, Employer shall ensure that the employee is transported immediately to a collection site for the collection of a urine sample. The employee shall be counseled not to drive a vehicle and a supervisor shall provide transportation for the employee to the collection site.

All persons designated to make a determination that reasonable suspicion exists to require an employee to undergo testing under this provision shall receive at least sixty (60) minutes of training on both alcohol and controlled substance use. The training shall cover the physical, behavioral, speech and performance indicators of probable alcohol misuse and use of controlled substances.

Any employee refusing to submit to reasonable suspicion testing or any employee having a positive drug and/or alcohol test will be terminated.

Random Testing

Employer will conduct random unannounced screening of all designated employees at unannounced times throughout the year. An accredited laboratory will maintain two computerized random testing pools including one DOT pool and one non-DOT pool. There will be no maximum number of samples that any one individual will be required to provide during the testing schedule in either pool.

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Employees will be required to report to the designated collection site for testing as soon as possible but in no case later than two (2) hours following notification. Failure to report for drug/alcohol screening within two (2) hours of notification will be treated as a positive test result.

Post Accident Testing

Employees are required to immediately notify the Drug Program Coordinator or his designee of any accident resulting in injury or damage to any county property or personnel.

Each employee whose performance either contributed to the accident or cannot be completely discounted as a contributing factor to an accident shall provide a urine specimen to be tested for the use of controlled substances and/or alcohol as soon as possible after the accident, but in no case later than eight (8) hours for alcohol testing and thirty-two (32) hours for drug testing.

Employees will be required to undergo urine drug and breath alcohol testing if they are involved in an accident that results in a fatality. A post-accident test will also be conducted in situations where there is no fatality but the following occurs: (1) an individual requires immediate transport to a medical treatment facility as a result of collision or non-collision; (2) any time one or more vehicles incurs disabling damage that prevents any of the vehicles involved from leaving the scene of the occurrence in their usual manner in daylight after simple repairs; or (3) with respect to any occurrence in which a vehicle including a mass transit vehicle (rail car, trolley car, trolley bus or vessel) is removed from operation. In a non-fatal accident as previously described, post-accident testing will be conducted unless the operator’s performance (and any other covered employees whose performance could have contributed to the accident) can be completely discounted as a contributing factor to the accident as determined by employer suing the best information at the time of the decision. In addition, drug screening and alcohol screening will be required for any driver receiving a citation for any moving violation resulting from an accident.

After notification of any accident, County will arrange for the employee to be taken as soon as practicable to collection site designated by County. The supervisor or designee will schedule the employee and assure that he/she is tested the same day as the reportable accident, if possible.

If an employee is injured, unconscious, or otherwise unable to evidence consent to the drug test, all reasonable steps must be taken to obtain a urine sample. A supervisor may elect not to test under these circumstances, but such a decision must be made based upon information received as a result of an investigation of the accident. Nothing in this document should be construed to require the delay of necessary medical attention for injured people following an accident, or prohibiting a driver from leaving the scene of an accident for the period necessary to obtain assistance in responding to the accident, or to obtain necessary emergency medical care.

Any employee subject to post-accident testing must refrain from consuming alcohol or taking any controlled substance for eight hours following an accident, or until he/she submits to an alcohol test, whichever comes first. As stated above, the employee will be tested not to exceed eight (8) hours following an accident for alcohol and not to exceed thirty-two (32) hours post-accident for drug testing. If there is a delay of greater than 2 (two) hours for an alcohol test, a reason must be given in writing, retained in a file for possible later referral, and the employer must still attempt to administer an alcohol test for up to 8 (eight) hours following the accident or until the employee undergoes a post-accident alcohol test.

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An employee who is subject to post-accident testing must remain available and follow these guidelines, or the County may consider the employee to have refused to submit to testing.

The Commission will discipline or terminate any employee who fails to report an accident or submit to substance screening where required by law or this policy. The Drug Program Coordinator shall insure that an Accident Report is filed in compliance with Commission Policy and applicable laws and regulations.

General Testing Procedures

Employer will contract with a properly certified testing laboratory that will ensure that all proper testing procedures are followed in accordance with this Policy and all applicable laws. The following is a list of the general procedures that will be followed for all drug and alcohol testing, regardless of the reason why the test is being performed:

• All testing procedures, including collections, will be performed by certified technicians and/or laboratories.

• Upon arrival at the collection site, the employee must provide proof of identification. The employee will be required to read and sign the controlled substance testing consent form provided by County. The signature shall be witnessed by the collector. Acceptable proof of identification shall be a current driver’s license, with photo, other form of picture identification, or identification by a County representative.

• The Employee shall complete a drug testing custody and control form.

• The Drug Program Coordinator shall notify the employee directly of the results of any positive drug test in order to give the employee an opportunity to challenge the findings. The County may, but shall not be required to, reanalyze the employee’s original sample to clarify the findings. Controlled substance testing must follow split sample procedures. Under this provision, an employee whose urine sample has tested positive for a controlled substance has the option of having the other portion of the split sample tested at another laboratory. The employee must notify the County within 72 hours after notification of a positive sample that he/she desires a retest under this provision.

• If a split sample test produces a negative result or if they second portion is not available, the test is considered negative and no sanctions will be imposed.

• All persons who receive information by County regarding drug tests shall maintain this information on a confidential basis.

Both Employer and the laboratory shall rely, when practical, on the guidance of the Federal Department of Transportation, Procedures for Transportation Workplace Drug Testing Programs.

Substances Tested For

DOT employees will regularly be tested for:

1) Marijuana (THC Metabolite)

2) Cocaine

3) Amphetamines

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4) Opiates (including heroin)

5) Pheneyefidine (PCP)

6) Alcohol

Non DOT-employees may be tested for other substances without advance notice. DOT employees may also be separately tested for other substances without advance notice by the Employer for safety purposes. Such tests will be coordinated with the Drug Program Coordinator.

Collection Sites

Employer will designate a collection site in a reasonably accessible location.

Collection Procedures

Drug testing is conducted by analyzing an employee’s urine specimen. The analysis is performed at laboratories certified and monitored by the Department of Health and Human Services (DHHS). The employee provides a urine specimen in a location that affords privacy. The collector seals and labels the specimen, completes a chain of custody document and prepares the specimen and accompanying paper work for shipment to a drug-testing laboratory. The specimen collection procedures and chain of custody ensures the specimen’s security, proper identification, and integrity is not compromised.

Split specimen procedures:

1) Each urine specimen is subdivided into two bottles labeled as a “primary” and a “split” specimen.

2) Both bottles are sent to a laboratory.

3) Only “primary” specimen is opened and used for analysis.

4) “Split” specimen remains sealed and stored at the laboratory.

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5) If the “primary” specimen confirms the presence of illegal, controlled substances, the employee has 72 hours to request in writing the “split” specimen be sent to another DHHS certified laboratory for analysis.

6) If it is positive for one or more of the drugs then a continuation test is performed for each drug using state-of-the-art gas chromatography/mass spectrometry (“GC/MS”) analysis.

7) GC/MS confirmation insures that over-the-counter medications or prescriptions are not reported as positive results.

Direct Observation

Observed collections are required in a number of situations for DOT employees. Any employee subject to a drug test may also be required to undergo observed collection. The purpose of direct observation is to guard against employee attempts to mask the testing process. Observed collections are required in the following circumstances:

1) All return-to-duty tests

2) All follow-up tests

3) Anytime the employee is directed to provide another specimen because the temperature on the original specimen was out of the accepted temperature range of 90 – 100 degrees Farenheit

4) Anytime the employee is directed to provide another specimen because the original specimen appears to have been tampered with;

5) Anytime a collector observes materials brought to the collection site or the employee’s conduct clearly indicates an attempt to tamper with a specimen;

6) Anytime the employee is directed to provide another specimen because the laboratory reported to the MRO that the original specimen was invalid and the MRO determines that there is not an adequate medical explanation for the result’

7) Anytime the employee is directed to provide another specimen because the MRO determined that the original specimen was positive, adulterated or substituted, but had to be cancelled because the test of the split specimen could not be performed.

The employee who is being observed will be required to raise his or her shirt, blouse, or dress/skirt as appropriate, above the waist, lower clothing and underpants, and turn around completely at the direction of the observer in order to show that he or she is not wearing any prosthetic device.

Where necessary, an Employer representative or medical personnel may obtain a specimen outside of a designated collection site (such as the emergency room following an accident investigation, etc.).

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Alcohol Testing Procedures

All employees are prohibited from possessing, drinking, or being impaired or intoxicated by alcohol while at work or on duty. In addition, safety-sensitive employees are prohibited from consuming any alcohol four hours prior to going on duty. A BAC of 0.04 will be accepted as presumptive evidence of intoxication.

Any employee may be subject to alcohol testing either for reasonable suspicion or post-accident. Safety sensitive employees are also subject to random alcohol testing. Random testing will be conducted just before, during, or just after the employee has performed a safety-sensitive function. Safety sensitive employees with a BAC of 0.02 will be immediately removed from the safety sensitive duties for a period of at least twenty-four (24) hours.

All alcohol tests will be conducted using evidentiary breath testing devices approved by the National Highway Traffic Safety Administration by a properly trained person. Any result showing greater than a 0.02 BAC will be repeated.

Evaluations and Return Of Results

The MRO will be responsible for reviewing the quantified test results of employees and confirming that the individuals testing positive have used drugs in violation of policy. Prior to making a final decision, the MRO shall give the individuals testing positive an opportunity to discuss the result either face to face or over the telephone. If the test result is negative dilute, the MRO may decide that the employee must take another test. If this second test results in a negative dilute result, the test will ordinarily be considered to be a negative and no additional testing will be required unless the MRO so directs.

The MRO shall then promptly tell the Drug Program Coordinator which employees or applicants test positive.

Request for Retest

An employee may submit a written request for a retest of the original specimen within 72 hours of receipt of the final test results. Requests must be submitted in writing to the Drug Program Coordinator. The employee may be required to pay the associated costs of retest in advance but will be reimbursed if the result of the retest is negative.

Release Of Test Results

Except where otherwise specifically required by law, employee drug testing results and records are maintained under strict confidentiality by the employer, the drug testing laboratory, and the medical review officer. They cannot be released to others without the written consent of the employee. Exceptions to this confidentiality are limited to DOT agencies when license or certification actions are required or to the decision-maker in arbitration, litigation, or administrative proceedings arising from a positive drug test.

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However, all employees will be required to execute a consent/release form permitting the Employer to release test results and related information to the Department of Industrial Relations or other relevant government agency. Applicants for safety-sensitive positions will also be required to execute a consent/release form permitting Employer to review records of previous drug and alcohol testing information.

Retention of Records

All records will be maintained so as to preserve confidentiality and prevent unauthorized persons from accessing, releasing, or tampering with records. The following records will be maintained:

1) Records related to the collection process, including:

i) Collection logbooks, if used.

ii) Documents relating to the random selection process.

iii) Documents generated in connection with decisions to administer reasonable suspicion drug or alcohol tests.

iv) Documents generated in connection with decisions on post-accident drug and alcohol testing.

v) MRO documents verifying existence of a medical explanation of the inability an employee to provide adequate urine or breathe sample.

2) Records related to test results:

i) The employer's copy of the custody and control form.

ii) Documents related to the refusal of any employee to submit to a test

iii) Documents presented by an employee to dispute the result of a test

3) Records related to referral and return to duty and follow-up testing, including records of any DOT employee’s entry into and completion of the treatment program recommended by the substance abuse professional.

4) Records related to employee training:

i) Training materials on drug use awareness and alcohol misuse, including a copy of the employer's policy on prohibited drug use and alcohol misuse.

ii) Names of employees attending training on prohibited drug use and alcohol misuse and the dates and times of such training.

iii) Documentation of training provided to supervisors for the purpose of qualifying the supervisors to make a determination concerning the need for drug and alcohol testing based on reasonable suspicion.

iv) Certification that any training conducted under this part complies with the requirements for such training.

5) Copies of any annual MIS reports submitted to FTA.

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The following records will be maintained for no less than five years: Records of verified positive drug or alcohol test results, documentation of refusals to take required drug or alcohol tests, referrals to the substance abuse professional, and copies of annual MIS reports submitted to FTA.

The following records will be maintained for no less than two years: records related to the collection process and employee training.

The following records will be maintained for no less than one year: records of negative drug or alcohol test results, with the exception that all post-accident testing records will be maintained for at least three (3) years after an accident.

Employee Education and Training

Employer will provide written information in drug/alcohol use and treatment resources to safety-sensitive employees. Employer will provide one hour of training for employees on the dangers of controlled substance use annually. All supervisors of safety-sensitive employees must also attend one hour of training on the signs and symptoms of drug abuse. The training is necessary to assist supervisors in making appropriate determinations for reasonable suspicion testing.

Employment Assessment

Any safety-sensitive employee or applicant who tests positive for the presence of illegal drugs and/or alcohol above the minimum thresholds set forth in 49 CFR Part 40, as amended, or has refused to submit to a drug or alcohol test (except in the case of an applicant) will be referred to a Substance Abuse Professional (SAP). A SAP can be a licensed physician (Medical Doctor or Doctor of Osteopathy), or a licensed or certified psychologist, social worker, or employee assistance professional with knowledge of and clinical experience in the diagnosis and treatment of drug and alcohol related disorders or an addiction counselor certified by the National Association of Alcoholism and Drug Abuse Counselors Certification Commission. The SAP will follow the protocols and meet the requirements defined in 49CFR part 40. All employees and applicants will be given contact information for a USDOT qualified SAP if they test positive.

Employee Assistance Programs (EAP)

The County’s EAP shall include:

1) Education and training for employees regarding drugs and alcohol.

2) Education and training for Supervisors regarding drugs and alcohol, including:

i) Effects and consequences of substance use on personal health, safety, and work.

ii) Manifestations and behavioral causes that may indicate substance use.

iii) Documentation of training provided.

3) A written statement on file and available at the Commission office outlining the EAP.

The Drug Program Coordinator or his designee should be contacted for further guidance. [CONTACT INFORMATION HERE]

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Investigation/Searches

Where a supervisor has reasonable cause to suspect that an employee has violated the substance abuse policy, he/she may inspect vehicles which an employee brings on the Commission’s property, lockers, work areas, desks, purses, briefcases, tool boxes, or other belongings, and at locations where County related activities are being conducted without prior notice in order to ensure a work environment free of prohibited substances. An employee may be asked to be present and remove a personal lock. Where the employee is not present or refuses to remove a personal lock, the Drug Program Coordinator will do so for him/her. The Commission may release any illegal, or controlled drugs, or paraphernalia to appropriate law enforcement authorities.

All searches should be coordinated with the Drug Program Coordinator or his designee.

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System Contacts

Any questions regarding this policy or any other aspect of the drug free and alcohol-free transit program should contact the following transit system representative:

Designated Employer Representative/Program Manager:

Name:

Title:

Address:

Telephone Number:

SAMHSA Certified Laboratory

Name:

Medical Review Officer:

Name:

Address:

Substance Abuse Professionals

Primary SAP:

Agency:

Address:

Telephone Number:

Backup SAP:

Agency:

Address:

Telephone Number:

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Attachment A

Safety-Sensitive Functions

Safety-Sensitive Positions

All positions were reviewed for safety-sensitive duties, as defined in 49 CFR part 655, to determine the safety-sensitive positions. Additionally, any new positions created in the future will be reviewed for safety-sensitive duties. The following positions were determined to be safety-sensitive:

(Examples)

Dispatchers

Operations Manager

Full-time Bus Drivers

Part-time Bus Drivers

Leadman/Mechanic

Mechanic

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Attachment B

(Proof of Policy Adoption by Governing Board or Highest Authority.)

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Employee Receipt of Drug and Alcohol Testing Policy

Return this completed form to your immediate supervisor

Employee Name :___________________________________________

(print)

I hereby certify that I have received and will read this Drug and Alcohol Abuse Testing Policy. I understand that I will be held responsible for the content of the policy and I agree to abide by drug and alcohol testing policy. If I need any clarification or if I have any questions regarding the substance of the policy, I will address them with the company’s program administrator.

I understand that violation of this Policy may be grounds for immediate termination of my employment

This policy adheres to the Federal Transit Administration’s mandated regulations for drug and alcohol testing.

Employee Signature: _____________________________________________

Date Signed:

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Implementing a Return-to Work Program

As a County Administrator or Manager, you know the importance of controlling costs. You develop a budget carefully, hold the line on expenses, and encourage your employees to work efficiently and productively. You also probably have an active safety program because you know that preventing injuries is the surest way to reduce your insurance costs.

However, you can do more. To reduce these costs, you should establish a Return to Work (RTW) program. If one of your employees receives an injury on the job, the best way to control the cost associated with the claim is to return the injured employee to work as quickly as possible. To reach this goal, you will probably need to reevaluate the employee's job, considering the following approaches to return to work:

Modified Work

In modified work, you allow the employee to return to his original job even though the treating physician has placed some restrictions on the worker’s activities. Restrictions may include shortening the workday and/or restricting certain activities such as bending or lifting. Modified Work is also referred to as Light Duty.

Alternate Work

In alternate work, it is not possible to modify the employee’s job to confirm to the treating physician’s restrictions. Instead, you provide the employee with another temporary job that accommodates the injured employee's abilities.

A RTW program is a carefully considered procedure for returning injured workers to work as quickly as medically possible by allowing the injured employee to work within the limitations the treating physician establishes. The success of a Return to Work program depends on the cooperation between all the affected individuals: the employer, the injured employee, treating physician, case manager, if applicable, and the claims adjuster.

Developing a Successful RTW Program

Management Commitment

If you want your RTW program to succeed, it is very important to communicate to your employees why you are implementing such a program and how it will benefit the County and all of them. After you have developed your program, take the time to explain it to your employees and communicate your enthusiasm about it. By communicating with your employees and training them as necessary, you are demonstrating that you are committed to and will continue to support the Return to Work program fully.

Job Descriptions

Before you can develop your RTW program, you must have a written description for each present job as well as for potential alternate jobs. Descriptions should include a listing of the job's essential functions, the location where an employee will perform it, length of shift, etc. It should also classify job functions such as lifting, carrying, bending, walking, standing, and other repetitive motions according to severity and

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recurrence. Do not forget to get information from employees who actually perform the job. They are your subject matter experts.

The injured employee’s treating physician needs copies of the employee’s actual job description and of the proposed alternate to determine if work modification or temporary assignment to an alternate job is necessary.

Policies and Procedures

Your next step is to develop policies and procedures for the program. During this stage, you will need to make decisions about a variety of issues, among them:

• Who will run the program and how will you select that individual? When should the program be used and by whom?

• What sort of forms (job demands, doctor's release to work, and standard letters) need developing?

• How long should Temporary Alternate Work last?

• How long should Modified Work last?

You will also need to address everyday concerns such as communicating with employees who are out because of injuries and methods of documenting employee progress in the Return to Work program.

Communication and Training

After you have developed your RTW program, it is a good idea to communicate with employees about the importance of the program and their roles in it. Train your managers and supervisors and hold meetings with employees during which employees may ask questions or raise concerns. You may also find it useful to meet with treating physicians or other medical personnel to get their feedback and involvement.

Follow Up and Evaluation

Remember, your business may change over time. Therefore, it is important for you to review your RTW program periodically. During the evaluation, review how well the program is working and identify any problem areas; then modify your existing program to make it more effective.

The Benefits of a RTW Program

RTW involves the use of short-term job assignments or modified work for an employee who is released to “light duty” with one or more job restrictions (i.e. one handed work, 10 pound lifting, standing less than 4 hours per 8 hour shift).

“Light duty” positions should always be safe, meaningful and productive and enable the employee to perform the job task while staying within the treating physician’s restrictions. Injured employees and their managers or supervisors are both responsible for ensuring that employees do not perform work that exceeds physicians’ restrictions.

A RTW program benefits both management and employees because it:

• Reinforces the County's interest and concern for an injured employee

• Allows an injured employee to continue to be productive and to contribute to the County

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• Maintains communications between injured employees and management

• Improves communications between County, the employee and the treating physician

• Discourages malingering

• Reduces the disability associated with an injury and its related costs

Another benefit of developing a RTW program is that it helps a County comply with the Americans with Disabilities Act. By following the steps listed below, specifically those in Job Descriptions, you will identify and classify the essential components of each job. This will help management identify jobs which potential employees with disabilities may be able to perform.

Other benefits of a RTW program

• Increase control of medical cost

• Increase control of indemnity cost (lost time TTD payments)

• Reduce OSHA recordable – lost time injuries and potential for OSHA inspection

• Improve employee/employer relationships

• Increases overall employee morale and job security

• Decreased workers’ compensation cost

• Decreased litigation rate (lawyer involvement)

• Decreases lost production costs

• Decreases hiring/turnover costs

Typical RTW positions

• Distribute mail, file paperwork, and answer phones

• Help the maintenance department, housekeeping staff, and the shipping/receiving department perform light tasks

• Assist supervisor with daily tasks

• Assist office personnel with filing or phone duties

• Conduct safety checks (ex: emergency lights, fire extinguishers, etc.) and follow up on previous safety recommendations

• Assist a safety committee with developing job-specific safety training or descriptions

• Quality control and inspection tasks

• Assist with inventory checks

Every department has small tasks, which you and your workers never to get around to; these tasks are excellent RTW jobs. How many potential tasks are located within your facility? With the ever-increasing costs of workers’ compensation, making sound business decisions can greatly affect your organization’s bottom line. You can control or contain employee injury costs largely through an effective RTW program.

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Sample Return to Work Program

An employee who is on leave as a result of a work-related injury or illness may be released to work on modified or light duty subject to conditions specified by his or her physician. [EMPLOYER] will make reasonable efforts to provide the employee with a position meeting the requirements imposed by the physician for the duration of a reasonable recovery period. Such a position is temporary and does not constitute a contract of employment or property interest in the modified or light duty position. An employee working in such a position is still subject to the same policies and procedures applicable to all employees, including the Drug and Alcohol Policy. Any employee who is offered a physician-approved, modified duty job will be required to accept the offer; otherwise, such a refusal will be considered job abandonment.

When the injured employee reaches Maximum Medical Improvement, [EMPLOYER] will make reasonable efforts to place the employee in a permanent position with as similar terms and conditions of employment as possible as the employee’s original position.

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Memo to the RTW Coordinator About Early Return-To-Work Program Policy and Procedures:

Building a Return-To-Work Plan:

The Return-To-Work Coordinator is the keystone of a successful Return-To-Work Program. Through your coordination of a few people working together, you will bring the non-productive (injured) employee back to gainful employment on time. Through your efforts, you will restore self-confidence, self-worth, and self-reliance to the non-productive employee. You will be working with the injured worker, the manager, the attending physician, health care provider, an insurance claims representative, and our safety committee in assisting the injured worker to return to full productivity.

Key People You Will Be Working With:

It is [Name of County]'s goal to have “Zero” lost time accidents. Neither management nor one single person alone can achieve this goal. It requires a team effort. [Name of County]’s written safety policies and procedures, when carefully followed, provide a safe work place for our employees. However, under the best of safety conditions it is possible that an accident could happen, causing a worker to be off work for an unspecified time. Should an employee receive an injury, we will use a team effort approach to return the injured employee to gainful employment as soon as possible.

You, as the Return-To-Work Coordinator, will lead the team in returning the injured worker to full productivity. The team could comprise only a few people, or several people. The size of the team depends on the seriousness of the injury. Team members might include:

Manager

The manager’s role is to assist in establishing modified work assignments that are productive and worthwhile to both the worker and the County. A returning worker should be made to feel his assignment is important and not an assignment of punishment for being injured. In some cases, a worker may need return to work gradually. Part time work might be appropriate. The manager will assign a RTW Coordinator to each case. Often the manager assigns him or her self.

Medical Provider or Rehabilitation Specialist

If there is a serious injury, our insurance provider’s claim representative may refer a worker’s case to a Rehabilitation Specialist for medical management. This professional, usually a registered nurse, will coordinate the medical treatment plan with you and the physician. In some cases, physical therapy can continue after the worker has returned to work. The specialist will work with you in obtaining information needed to complete a job analysis. With this information, the physician will determine the job modifications necessary to fit the injured employee’s needs.

Attending Physicians

[Name of County] has retained a physician as its attending doctor. If an employee receives an injury on the job, unless otherwise requested by the injured worker, use the County doctor. Based on the job analysis furnished to the doctor, the doctor will assess the physical capacity or limitations of the

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worker and authorize a release to return to work, identifying the specific job restrictions placed on the worker.

Claims Representative

Our Third Party Administrator is Meadowbrook / ASI. Their claims representative will monitor and investigate a worker’s recovery process. It is important to keep the claims representative advised of changes or plans for the returning worker.

The Worker

Returning to work after being on disability is emotionally and physically difficult. Good communication with the injured worker is essential. It is extremely important to have routine visits with the worker. Before returning to work, remind the employee of his or her physical limitation in a meeting between the manager and direct co-workers. Provide the employee with an orientation to his or her new job or modified position that covers the job function along with safety procedures and equipment safety.

Safety Committee

As part of the team effort in returning an injured worker to work, the safety committee may be a part of the returning process. The committee members can give support and ideas as to type of work available.

The Coordinator’s Guidelines for a Return-To-Work Program: 1. If the manager is not the RTW Coordinator, he or she will assign a coordinator as needed to each case.

2. The manager will complete all claims reporting documents. These include first accident report, OSHA forms, insurance accident reports, and investigation reports.

3. Report all accidents within 12 hours, but if the injury is serious, call the insurance claim representative immediately.

4. Direct all injured (cuts and bruises not included) employees to [Name of County]’s doctor or to the hospital by a supervisor or a responsible person. Take a severely injured worker to the hospital in an ambulance.

5. Advise the doctor of the Workers’ Compensation insurance carrier, providing the name and address of the claims representative. Other than for immediate first aid, refer all requests for authorization for medical service (including medications, etc.) to this claims representative.

6. Show concern for the injured worker. Advise the claim representative and the doctor that you can provide a modified job for the employee when he or she is medically able to do such work. (See letter) Continue to maintain regular contact with the injured worker.

7. Once the claim representative and the doctor confirms “restricted” or “modified” duties, be sure you find a position which falls within the parameters of the physical limitations, as we do not want to cause any re-injuries.

8. Inform the injured worker’s supervisor of the specific restrictions and that the worker must not deviate from the modified job duties until released to normal duties.

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9. Keep in touch with the claim representative regarding target date to return to normal duties. This should help both you and the injured worker prepare for the return to his or her regular job function.

10. Communication and follow-up are essential. These are the keys to the Return-To-Work Program. Communication must remain open between all the parties -- the employee, the physician, the manager, and the insurance carrier and its claims representative -- in order to develop a successful program.

Coordinator’s Checklist:

Initial contact with the injured worker within 12 hours.

Contact with the injured worker within three days.

Contact with the injured worker at least every two weeks.

Employee reminded of the County’s Return-To Work Program. (See Letter)

Employee satisfied with medical care the County Doctor is providing.

Modified job available, if yes, what job? _______________________________.

Employee notified in writing that modified work is available. (See Letter)

Insurance carrier and claims representative notified of injury.

Insurance carrier and claims representative notified of modified position.

Physician notified of modified work available.

Rehabilitation Specialist notified of modified work available.

RTW job analysis correlated with manager.

NOTE:

Decisions about “modified” or “restricted “duties must be in accordance with the requirements of the Americans with Disabilities Act.

A County should have a clearly stated and communicated Family Medical and Leave Act policy. The County should notify employees any time they are on leave if the County’s policy is to count disability leave toward FMLA leave.

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Sample RTW Policy Memo to Employees

What You Should Know About Our Return-To-Work Program and How It May Affect You:

[Name of County] values you as an individual and as an employee. Therefore, our commitment is to provide you with a safe and healthy workplace in which you can earn your livelihood and provide for your family. Your skills are essential to providing our citizens the essential services they expect. The County knows that each employee plays a vital role in preserving our resources. Protecting these resources assures continuous job security and income for you and your family. Your daily presence on the job is essential. Job related lost-time accidents are costly both to you and to the County]. Revenue and employee morale decline each time there is an employee injured.

It is our goal to have “Zero” lost time accidents. We cannot achieve this goal alone. It requires a team effort. [Name of County] has developed and implemented a written safety program, and when employees carefully follow it, it will provide a safe place for you and other co-workers.

If you are involved in an accident and receive an injury while you are on the job, we have developed a Return-To-Work Program to help you return to gainful employment as soon as possible. If necessary, the County will identify a job that will be suitable for a modified work position. We will appoint a Return-To-Work Coordinator for you to help you return to work as soon as possible. If you are injured [Name of County]’s goal is to assure your rehabilitation and restore you to full gainful employment promptly.

If you are injured, your Return-To-Work Coordinator will help you in coordinating your return to work with your physician (appointed by County), Workers' Compensation claims representative, manager and others important to your recovery. When you are medically stable, your Coordinator will recommend return-to-work activities. If physical therapy is necessary to your recovery, your Coordinator will arrange accommodations in your work schedule. Your Coordinator will work with our physician, manager and others in determining the job modifications necessary to fit your momentary limitations.

Your Return-to-Work Coordinator and physician(s) will assess your physical capacity and limitations. Under certain conditions, it may be necessary to bring you back to work in the middle of the workweek or on a part-time basis. The important issue is that you understand your worth to [Name of County]. The objective of your returning to work is twofold--first and, most importantly, is your physical and mental well being, and second, is the return of your productive contribution to [Name of County].

Employee signature Date

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Sample RTW Letter to Care Provider / Doctor

County Letterhead

[Date]

Dear Care Provider/Doctor:

[Name of County] considers the safety of our employees as one our principal responsibilities. It is our desire and intention to provide our employees with a safe workplace, safe equipment, and to establish safe work methods. If accident occurs, our concern is that our employees receive appropriate and timely care to assure a speedy recovery and the employees’ return to work.

Only through the cooperation of [Name of County], our employees, and you can we expect to achieve our goal.

[Name of County] has established a drug free workplace policy and program, as well as an early Return-to-Work Program. We have attached copies of each program your review.

To gain a better understanding of [Name of County]’s operations, we invite you to visit us at a time that is mutually acceptable. I will give you a telephone call to make the necessary arrangements.

If you have any questions, please call me at (telephone number). Sincerely, Return-To-Work Coordinator Enclosures:

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Sample RTW Letter to Injured Workers

Dear (Name of Employee):

Regrettably, you have experienced a work-related injury or illness. Please read the following important information regarding your rights under the Workers’ Compensation system. You are a valued employee and we want you to have complete information.

Our first concern is that you receive appropriate and timely care to speed your recovery and return you to work. As you recover, it is important to keep your Return to Work (RTW) Coordinator informed of your progress and any subsequent problems arising from a work injury. [Name of County] is responsible for directing your care. If you feel additional treatment is necessary, contact your Return-to-Work Coordinator or manager immediately.

[Name of County] will treat you and all other employees who experience work injuries with dignity and respect. We expect every employee to return to work immediately following most work related injuries. Our goal is to return you to your original job rapidly and efficiently. [Name of County] has an early Return-to-Work Program for employees who initially cannot perform their regular jobs. In almost every case, productive work will be available for employees while they are recuperating. Your Return to Work Coordinator has information on jobs that accommodate most restrictions. If your doctor has concerns about you returning to work, please have him/her call your Return to Work Coordinator for an explanation of our early Return-to-Work Program. You Coordinator can provide your doctor with the descriptions of jobs he/she may recommend you do upon returning. Returning to work is important to you financially.

[Name of County]’s Early Return-to-Work Program is a benefit to you. It allows you to do productive work and get paid wages even with most restrictions.

What are your benefits from Workers’ Compensation? The Workers’ Compensation plan will pay for all the medical care necessary to treat your injury and return you to work. Our insurance company pays you what the law specifies. You will always get what we legally owe you based on your specific situation.

Where can you go if you want more information about the Workers’ Compensation law and your rights? Ask for information from your RTW Coordinator first. He or she is has received training on the law and how it affects you. The Coordinator can answer most routine questions very quickly to your satisfaction. If you would like to find out more about the law and your benefits under it, you can call the insurance company who handles our Workers' Compensation insurance plan. You can contact your State Insurance Commissioner if you want a third party expert opinion. The experts in this office are often attorneys working for the state. They would represent your interest if there were a dispute over benefit payments.

Remember: everyone involved -- [Name of County], your medical care provider, the Workers' Compensation provider, and state Insurance Commissioner all have the same goal -- to speed your recovery and return you to productive work while providing you with all your legal rights and benefits allowed under the law.

We hope this answers your questions and helps you understand the Workers' Compensation system. We are sorry you had a work injury. We are here to serve you -- let us know how we can help.

Sincerely,

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Accident Investigation

Many accidents occur every day. The failure of people, equipment, supplies, or surroundings to behave or react as expected causes most of the accidents. Accident investigations determine how and why these failures occur. By using the information you gain through an investigation, you may be able to prevent a similar or perhaps more disastrous accident. Always conduct accident investigations with accident prevention in mind. An accident is any unplanned event that results in personal injury or in property damage. When the personal injury requires little or no treatment, it is minor. If it results in a fatality or in a permanent total, permanent partial, or temporary total (lost-time) disability, it is serious. Similarly, property damage may be minor or serious. Investigate all accidents regardless of the extent of injury or damage. Accidents are part of a broad group of events that adversely affect the completion of a task. These events are incidents. For simplicity, the procedures discussed in later sections refer only to accidents. They are, however, also applicable to incidents. This discussion introduces the reader to basic accident investigation procedures and describes accident analysis techniques. See Accident Cause Analysis Worksheet in appendix.

Accident Prevention

Accidents are usually complex. An accident may have 10 or more events that can be causes. A detailed analysis of an accident will normally reveal three cause levels: basic, indirect, and direct. At the lowest level, an accident results only when a person or object receives an amount of energy or hazardous material that they cannot absorb safely. This energy or hazardous material is the DIRECT CAUSE of the accident. The direct cause is usually the result of one or more unsafe acts or unsafe conditions, or both. Unsafe acts and conditions are the INDIRECT CAUSES or symptoms. In turn, indirect causes are usually traceable to poor management policies and decisions, or to personal or environmental factors. These are the BASIC CAUSES.

In spite of their complexity, most accidents are preventable by eliminating one or more causes. Accident investigations determine not only what happened, but also how and why. The information gained from these investigations can prevent recurrence of similar or perhaps more disastrous accidents. Accident investigators are interested in each event as well as in the sequence of events that led to an accident. The accident type is also important to the investigator. The recurrence of accidents of a particular type or those with common causes shows areas needing special accident prevention emphasis.

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Investigation Procedures

The actual procedures used in a particular investigation depend on the nature and results of the accident. The agency having jurisdiction over the location determines the administrative procedures. In general, responsible officials will appoint an individual to be in charge of the investigation. The investigator uses most of the following steps:

1. Define the scope of the investigation.

2. Select the investigators. Assign specific tasks to each (preferably in writing).

3. Present a preliminary briefing to the investigating team, including:

• Description of the accident, with damage estimates

• Normal operating procedures

• Maps if needed (local and general)

• Location of the accident site

• List of witnesses

• Events that preceded the accident

4. Visit the accident site to get updated information.

5. Inspect the accident site.

• Secure the area. Do not disturb the scene unless a hazard exists.

• Prepare the necessary sketches and photographs.

• Label each carefully and keep accurate records.

6. Interview each victim and witness. Include any individuals who were present before the accident and those who arrived at the site shortly after the accident. Keep accurate records of each interview. Use a tape recorder if desired and if approved.

7. Find out

• What was not normal before the accident

• The nature of the abnormality

• Where or when the abnormality occurred

• When it was first noted

• How it occurred

8. Analyze the data obtained in step 7. Repeat any of the prior steps, if necessary. Determine

• Why the accident occurred

• Alternative sequences

• A likely sequence of events and probable causes (direct, indirect, basic)

9. Check each sequence against the data from step 7. Determine the most likely sequence of events and the most probable causes. Conduct a post-investigation briefing.

10. Prepare a summary report, including the recommended actions to prevent a recurrence.

11. Distribute the report according to applicable instructions.

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An investigation is not complete until you analyze all data and complete a final report. In practice, the investigative work, data analysis, and report preparation proceed simultaneously over much of the time spent on the investigation.

Fact-Finding 1. Gather evidence from many sources during an investigation.

2. Get information from witnesses and reports as well as by observation.

3. Interview witnesses as soon as possible after an accident and inspect the accident site before any changes occur.

4. Take photographs and make sketches of the accident scene.

5. Record all pertinent data on maps.

6. Get copies of all reports. Documents containing normal operating procedures, flow diagrams, maintenance charts, or reports of difficulties or abnormalities are particularly useful.

7. Keep complete and accurate notes in a bound notebook.

8. Write down pre-accident conditions, the sequence of the accident, and post-accident conditions.

9. Document the location of victims, witnesses, machinery, energy sources, and hazardous materials.

In some investigations, a particular physical or chemical law, principle, or property may explain a sequence of events. Include laws in the notes taken during the investigation or in the later analysis of data. In addition, gather data during the investigation that may lend itself to analysis by these laws, principles, or properties. An appendix in the final report can include an extended discussion.

Interviews

In general, experienced personnel should conduct interviews. If possible, the team responsible for this task should include an individual with a legal background. In conducting interviews, the team should:

1. Appoint a speaker for the group.

2. Get preliminary statements as soon as possible from all witnesses.

3. Locate the position of each witness on a master chart (including the direction of view).

4. Arrange for a convenient time and place to talk to each witness.

5. Explain the purpose of the investigation (accident prevention) and put each witness at ease.

6. Listen, let each witness speak freely, and be courteous and considerate.

7. Take notes without distracting the witness. Use a tape recorder only with consent of the witness. Use sketches and diagrams to help the witness.

8. Emphasize areas of direct observation. Label hearsay accordingly.

9. Be sincere and do not argue with the witness.

10. Record the exact words used by the witness to describe each observation. Do not "put words into a witness' mouth."

11. Word each question carefully and be sure the witness understands.

12. Identify the qualifications of each witness (name, address, occupation, years of experience, etc.).

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13. Supply each witness with a copy of his or her statements. Signed statements are desirable.

After the interviews, team members should analyze each witness's statement. They may wish to re-interview one or more witnesses to confirm or clarify key points. While there may be inconsistencies in witnesses' statements, investigators should assemble the available testimony into a logical order. Analyze this information along with data from the accident site.

Not everyone reacts in the same way to a particular stimulus. For example, a witness close to the accident may have an entirely different story from one who saw it at a distance. Some witnesses may also change their stories after they have discussed it with others. Determining the reason for the change may give the team additional clues.

A witness who has had a traumatic experience may not be able to recall the details of the accident. A witness who has a stake in the results of the investigation may offer biased testimony. Finally, eyesight, hearing, reaction time, and the general condition of the witnesses may affect their powers of observation. A witness may omit entire sequences because of a failure to observe them or because the witness did not recognize their importance.

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Problem Solving Techniques

Accidents represent problems that investigators must solve through specific procedures. This section discusses two of the most common: Change Analysis and Job Safety Analysis.

Change Analysis

As its name implies, this technique emphasizes change. To solve a problem, you must look for deviations from the norm and consider that problems result from some unanticipated change. You then need to analyze the change to determine its causes. Use the following steps in this method:

1. Define the problem (What happened?)

2. Establish the norm (What should have happened?)

3. Identify, locate, and describe the change (What, where, when, to what extent?)

4. Specify what was and what was left unaffected

5. Identify the distinctive features of the change

6. List the possible causes

7. Select the most likely causes

Job Safety Analysis

Job safety analysis (JSA) is part of many existing accident prevention processes. In general, JSA breaks a job into basic steps and identifies the hazards associated with each step. The JSA also prescribes controls for each hazard. A JSA uses a chart listing these steps, hazards, and controls. Review the JSA during the investigation if management has conducted a JSA for the job involved in an accident. Perform a JSA if one is not available. Perform a JSA as a part of the investigation to determine the events and conditions that led to the accident.

Report of Investigation

As noted earlier, an accident investigation is not complete until you prepare a report and submit it to proper authorities. Special report forms are available in many cases. Other instances may require a more extended report. Such reports are often very elaborate and may include a cover page, a title page, an abstract, a table of contents, a commentary or narrative portion, a discussion of probable causes, and a section on conclusions and recommendations.

The following outline has proved to be especially useful in developing the information that the formal report will contain:

1. Background Information:

• Where and when the accident took place

• Who and what were involved

• Operating personnel and other witnesses

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2. Account of the Accident (What happened?):

• Sequence of events

• Extent of damage

• Accident type

• Agency or source (of energy or hazardous material)

3. Discussion of Accident Causes (How and Why?)

• Direct causes (energy sources; hazardous materials)

• Indirect causes (unsafe acts and conditions)

• Basic causes (management policies; personal or environmental factors)

4. Recommendations (to prevent a recurrence) for immediate and long-range action to remedy:

• Basic causes

• Indirect causes

• Direct causes (such as reduced quantities or protective equipment or structures)

Summary

Thousands of accidents occur daily throughout the United States. These result from a failure of people, equipment, supplies, or surroundings to behave as expected. A successful accident investigation determines not only what happened, but also finds how and why the accident occurred. Investigations are an effort to prevent a similar or perhaps more disastrous sequence of events.

Most accident investigations follow formal procedures. This discussion covered two of the most common procedures: Change Analysis and Job Safety Analysis. An investigation is not complete however, until completion of a final report. Responsible officials can then use the resulting information and recommendations to prevent future accidents.

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Safety Programs and Procedures

The Hazard Communication (Right-To-Know) Standard An Overview

Introduction

Employees frequently have exposure to chemicals that pose a threat to their safety and health. To protect them, the Occupational Safety and Health Administration’s (OSHA) Hazard Communication standard, Title 29, Code of Federal Regulations (CFR) 1910.1200. OSHA first enacted the Hazard Communication Standard, also known as the Right-to-Know Law, on November 25, 1983. A modified version, containing minor changes and technical amendments, took effect in March 1994.

The purpose of the standard is to provide information to employers and employees exposed to hazardous chemicals in the workplace. Under the standard, employers must identify and evaluate chemical hazards in the workplace and then communicate information concerning those hazards to employees. The standard also requires employers to make sure that employees receive this information by implementing a comprehensive hazard communication program. The program includes container labeling and other forms of warning as well as Material Safety Data Sheets (MSDS) and employee training.

The Right-to-Know Law

The standard covers six major areas:

1. Evaluation of hazardous chemicals

2. A written communication program

3. Labeling of hazardous chemicals

4. Material Safety Data Sheets (MSDS)

5. Posting requirements to inform employees of information regarding MSDS

6. Employee training

Evaluation of Hazardous Chemicals

Unless they manufacture or import chemicals, employers usually do not have to evaluate chemicals. An exception is an employer who mixes chemicals to produce a new hazardous chemical. However, the standard requires employers to identify all the hazardous chemicals they use in the workplace.

OSHA classifies the following as physical or health hazards: combustible liquids, oxidizers, corrosives, reproductive toxins, and non-toxins.

The following are exempt from the standard:

• wood and wood products (except wood dust)

• regulated hazardous waste

• tobacco products

• food, drugs, and cosmetics

• alcoholic beverages

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• various types of pesticide

• nuisance particulate and articles

• agricultural items or vegetable seed treated with pesticides

These items are exempt because separate government standards regulate them.

Written Program

This section requires employers to explain fully how they will comply with the provisions of the standard and to list the responsible person(s) for each area of the program. The written program must also:

• Include a list of the hazardous chemicals present in the workplace

• Describe how the employer will inform employees of the hazards of non-routine tasks such as cleaning a tank, pit, or a spill.

Employers must make a copy of the written program available, upon request, to all employees and OSHA officials.

Labeling of Hazardous Chemicals

The standard requires labels on all chemicals in the workplace. Each label should identify the material by name and the name must match the one on the MSDS. The label must also contain appropriate hazard warnings. If chemicals remain in their original containers, the containers must have labels that show the name and address of the manufacturer, importer, or other responsible party. Employers may use other means of providing appropriate warning information (such as pictures and symbols) in conjunction with the hazard information. Labels must be legible and in English. Employers may add labels in a second language as long as the English label is present.

Besides appropriate labels, employers must also implement a system for pipes and piping that contain hazardous chemicals. In place of labels, employers may use placards, operating instructions, process sheets, or other written materials for pipes, piping, vats, mixing tanks, and other stationary process containers.

The standard does not require labels on portable containers if both of the following conditions exist:

1. An employee dispenses a small quantity of a chemical from a large container into a small one

2. The same employee will use the chemical during a single work shift.

Otherwise, portable containers must have appropriate labeling.

The Material Safety Data Sheet (MSDS)

Once an employer identifies all the hazardous chemicals in the workplace, he or she must document them and obtain an MSDS for each item. MSDS are available from the chemical supplier or manufacturer. The chemical manufacturer or importer prepares the MSDS after conducting an evaluation of the chemical. These sheets contain specific chemical hazard information such as:

• Physical hazards

• Health hazards

• Routes of entry

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• Exposure limits (if any)

• Precautions for safe handling and use (if known)

• Known or suspected cancer causing agents

• Spill clean-up and procedures

• Emergency and first aid procedures

• The name, address, and telephone number of the chemical manufacturer

All the information on the MSDS must be in English and be available to employees working with or near the hazardous chemical. Employers may also provide the MSDS in a second language if necessary. The Hazard Communication Standard contains a provision allowing manufacturers to protect trade secrets. A chemical manufacturer may withhold the chemical identity, including the chemical name and other specific information, from the MSDS. However, under special conditions, health care professionals, treating an individual exposed to such a chemical, may obtain the necessary information from the manufacturer.

Posting Requirements

As part of the requirement to communicate clearly the presence of hazardous chemicals to employees, employers must post where employees can find the MSDS for the chemicals in their work area. The employer must also post whenever he or she introduces a new chemical into the workplace.

Employee Training

The standard requires employers to provide employees with effective information and training on hazardous chemicals in their work areas. Training must take place at the time of initial assignment, whenever the employer introduces a new physical or health hazard into the area, and when an employee transfers to a new job. The training should include information about:

• The requirements and purpose of Michigan’s Right to Know law

• The employer’s written hazardous communication program

• The employer’s list of hazardous chemicals

• The methods that employees can use to detect the presence or release of a chemical

• The organization's procedures

• Physical and health hazards of chemicals

• Protective measures employees can take when handling hazardous chemicals

• Labeling and the MSDS.

Sources for More Information

29 CFR 1910.1200, Hazard Communication

Federal Register, February 9, 1994

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The Hazard Communication Standard - Self-Assessment

Management is responsible for providing its employees with a safe and healthful work place. Compliance with the Hazard Communication Standard assures that employees’ exposure to hazardous chemicals is minimal and that all employees are aware of the chemical hazard they may face while performing their normal duties. It also assures that employees know what to do in non-routine and/or emergency situations involving hazardous chemicals.

HAS YOUR ORGANIZATION: 1. Reviewed the standard and provided managers and supervisors with appropriate training?

Yes No 2. Conducted an evaluation of the workplace?

Yes No 3. Developed a written communication program?

Yes No

Have You

Identified all chemicals in the workplace? Identified those chemicals that the standard considers

hazardous? Identified the location of the chemicals by department? Prepared a list of all chemicals used in the workplace? Made the list available to employees upon request? Established, at a minimum, annual review for the list?

Do You

Know the purpose and requirements of the standard? Ensure that managers and supervisors understand their

responsibilities?

Does the Program

Explain the steps you take to protect employees from hazardous chemicals?

Establish accountability and responsibility for implementing the program?

Describe the employee training component of the program?

Receive, at a minimum, an annual review? Include the master list of hazardous chemicals in use in

the workplace?

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4. Made sure all chemicals have labels that comply with the standard?

Yes No

5. Made sure that manufacturers, importers, or distributors provide you with Material Safety Data Sheets as the standard requires?

Yes No 6. Meet the posting requirements of

the standard?

Yes No 7. Provide employee training that meets the requirements of the standard?

Yes No

Sample Hazard Communication Program Introduction

Do You

Ensure that all original containers have appropriate labels?

Replace labels on original containers when worn or illegible?

Check that labels are in English? Provide supplementary labels in a second language if

necessary? Ensure that employees label temporary containers

properly?

Do You Post the location of the Written Program? Post the location of MSDS? Post when you receive new MSDS? Keep the postings where employees can readily see

them? Put up postings in all departments where hazardous

chemicals are in use? Review postings, at a minimum, annually?

Do You

Have a written training program? Include department specific information as the standard

requires? Make certain that employees receive training before

their initial assignment? Train employees whenever you introduce a new

hazardous chemical into the workplace? Provide retraining for employees who transfer to a new

job assignment? Document all training properly?

Do You

Check each incoming shipment for the MSDS? Make sure that each department using a specific

chemical has the correct MSDS? Request additional information from the manufacturer,

importer, or distributor if necessary? Understand the “Trade Secret” provision of the

standard? Review the MSDS, at a minimum, annually? Notify OSHA when a manufacturer, distributor or

importer fails to provide an MSDS even after a written request?

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The Hazard Communication (HazCom) Standard requires employers to develop a written hazard communication program. You can adapt the following sample HazCom program to the requirements and conditions of your workplace.

Our Hazard Communication Program

General Policy

The purpose of this notice is to inform you that [Name of County] complies with OSHA Hazard Communication Standard, Title 29 Code of Federal Regulations 1910.1200.

We do this by

• Compiling a hazardous chemicals list

• Using Material Safety Data Sheets (MSDS)

• Ensuring that containers are labeled

• Providing you with training

This program applies to all of our work operations where there may be exposure to hazardous substances under normal working conditions or during an emergency. This County relies on Material Safety Data Sheets (MSDS) from suppliers to meet determination requirements.

[Name of Individual] is the program coordinator. He/she reports to the safety director who has overall responsibility for the program. The program coordinator will review and update the program as necessary. You may obtain a copy of the written program from the program coordinator.

Under this program, the County will inform you of

• The contents of the Hazard Communication Standard

• The hazardous properties of chemicals with which you work

• Safe handling procedures

• The measures you can take to protect yourselves from these chemicals

You will also learn about the hazards associated with non-routine tasks, such as the cleaning pits, tanks, or spills as well as the hazards associated with chemicals in unlabeled pipes.

List of Hazardous Chemicals

The program coordinator, working with department heads, will make a list of hazardous chemicals and their related work practices used in the facility, and will update the list as necessary. Our list of chemicals identifies all of the chemicals used in our work process areas.

Each work area maintains and posts its own list of the hazardous chemicals to which employees in the area may be exposed. Each list identifies the corresponding MSDS for each chemical. The program coordinator will maintain a master list of these chemicals and will make this list available to you upon request.

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Material Safety Data Sheets (MSDS)

MSDS provide the specific information on the chemicals that you use. The program coordinator will maintain a binder with an MSDS on every substance on the list of hazardous chemicals. The MSDS will comply with OSHA requirements for information.

Management will make certain that each work site maintains an MSDS for hazardous materials in that area. These MSDS are readily available to you at your workstations during your shifts. The location of the MSDS in your department is:

The program coordinator is responsible for acquiring and updating MSDS. He/she will contact the chemical manufacturer or vendor if additional research is necessary or if the manufacture or vendor has not supplied an MSDS with an initial shipment. Department heads must clear all new procurements of chemicals with the program coordinator.

A master list of MSDS is available from the program coordinator. The location(s) of the master list are:

Labels and Other Forms of Warning

The program coordinator will ensure that all hazardous chemicals have proper, current labeling as necessary. At a minimum, labels will provide the substance’s chemical identity, appropriate hazard warnings, and the name and address of the manufacturer, importer, or other responsible party.

Your department head will refer to the corresponding MSDS if you need help in verifying label information. The supervisor of shipping and receiving will check all containers that come from the plant to make sure they have the proper labels.

If there are a number of stationary containers within a work area that have similar contents and hazards, we will post signs that provide the hazard information. On our stationary process equipment, we will substitute regular process sheets, batch tickets, blend tickets, and similar written materials for container labels when they contain the same information as labels. These written materials are readily available to you during your work shift.

If you transfer chemicals from a labeled container to a portable container only for your immediate use, you do not have to label the portable container. We will instruct you on pipes or piping systems and their contents during training.

We will ensure that all containers of hazardous materials we receive have labeling in compliance with OSHA’s Hazard Communication Standard.

In addition, we will make certain that all our trucks that carry hazardous chemicals have appropriate warning placards in accordance with US Department of Transportation’s Hazardous Materials Regulations.

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Non-Routine Tasks

When your job requires you to perform hazardous non-routine tasks (e.g., cleaning tanks, entering confined spaces, etc.), you will receive special training to inform you about the hazardous chemicals to which you might be exposed, and the proper precautions you should take to reduce or avoid exposure.

Training

[Name of County] will make certain that everyone who works with or has potential exposure to hazardous chemicals receives training on the Hazard Communication Standard and the safe use of those hazardous chemicals before they report to work.

[Name of County] has developed a program for this purpose. Whenever we introduce a new hazard, you will receive additional training. Your department head will use regular safety meetings to review the information presented in the initial training. Department heads and supervisors will receive extensive training regarding hazards and appropriate protective measures so they will be available to answer your questions and provide daily monitoring of safe work practices.

Training will emphasize the following:

• OSHA’s Hazard Communication Standard and this written program

• Chemical and physical properties of hazardous materials (e.g., flash point, reactivity) and methods you can use to detect the presence or release of chemicals (including chemicals in unlabeled pipes)

• Physical hazards of chemicals; e.g., the potential for fire, explosion, and so on

• Health hazards, including signs and symptoms of exposure associated with exposure to chemicals and any chemical with properties that may affect a medical condition

• Procedures to protect against hazards

• Required personal protective equipment (PPE)

• Proper use and maintenance of PPE

• Work practices or methods to assure proper use and handling of chemicals and procedures for emergency response)

• Procedures you should use to protect yourself and others when cleaning hazardous chemical spills and leaks

• Where we keep MSDS, how to read and interpret the information on both labels and MSDS, and how employees may obtain additional hazard information.

The safety director or designee will review our training program for employees and advise department heads and supervisors on training or retraining needs. The Hazard Communication Standard requires retraining when the hazard changes or when a new hazard is introduced into the workplace. However, it is County policy to provide training regularly in safety meetings to ensure the effectiveness of the program. As part of the assessment of the training program, the safety director will obtain input from employees regarding the training they have received and their suggestions for improving it.

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Contractor Employers

The safety director, upon notification by the responsible supervisor, will personally advise outside contractors of

• Chemical hazards to which they may have exposure in the normal course of their work on the premises

• Labeling system in use

• Protective measures they should take

• Mandatory safe handling procedures

In addition, the safety director will notify these individuals of the location and availability of MSDS.

Each contractor bringing chemicals on-site must provide us with the appropriate hazard information on these substances, including the labels used and the precautionary measures workers will take when using these chemicals.

Additional Information

All employees, or their designated representatives, can obtain further information on this written program, the hazard communication standard, applicable MSDS, and chemical information lists at ______________________________________.

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Material Safety Data Sheet (MSDS

Overview

The Material Safety Data Sheet (MSDS) is a detailed information bulletin that the manufacturer or importer of a chemical prepares. It describes the following:

• Physical and chemical properties

• Physical and health hazards

• Routes of exposure

• Precautions for safe handling and use

• Emergency and first-aid procedures

• Control measures

The information on an MSDS aids in the selection of safe products. It also helps prepare employers and employees to respond effectively to daily exposure situations as well as to emergencies.

Because MSDS are a comprehensive source of information for all types of employers, they may contain information that is not useful to you or not important to the safety and health in your particular operation. Concentrate on the information that applies to your situation. Generally, hazard information and protective measures should be your major concern.

OSHA Requirements

Employers must maintain a complete and accurate MSDS for each hazardous chemical that they use. If there are multiple suppliers of the same chemical, there is no need to retain multiple MSDS for that chemical.

The manufacturer or distributor must automatically provide this information when shipping hazardous chemicals to employers. When new and significant information becomes available about a product's hazards or ways to protect against them, chemical manufacturers, importers, or distributors must add it to their MSDS within three months and provide it to their customers with the next shipment of the chemical.

Although standard does not require the manufacturer or distributor to attach an MSDS physically to a shipment, they must accompany or precede the shipment. When the manufacturer or supplier does not send an MSDS with a shipment of a hazardous chemical, the employer must obtain one from the chemical manufacturer, importer, or distributor as soon as possible. Similarly, if the MSDS is incomplete or unclear, the employer should contact the manufacturer or importer to get clarification or obtain missing information.

When an employer is unable to obtain an MSDS from a supplier or manufacturer, he/she should submit a written complaint, with complete background information, to the nearest OSHA office. OSHA will contact the supplier or manufacturer to obtain the needed information. If the supplier or manufacturer still fails to respond within a reasonable time, OSHA will inspect the supplier or manufacturer and take appropriate enforcement action.

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Sections of an MSDS & Their Importance

OSHA specifies the information that the manufacturer must include on an MSDS. However, OSHA does not prescribe the precise format for a MSDS. OSHA has issued a non-mandatory MSDS form that meets the Hazard Communication Standard requirements. Manufacturers can use this form as is or expand it as necessary. The MSDS must be in English and must include at least the following information.

Section 1 Chemical Identity

• The sheet must provide the chemical and common name(s) for single chemical substances.

• The sheet must cross-reference the identity on the MSDS to the identity found on the label.

Section 2 Hazardous Ingredients

The MSDS must list:

• The chemical and common names of the ingredients that are associated with the hazards and the common name of the mixture for a hazardous chemical mixture that has been tested as a whole to determine its hazards

• The chemical and common names of all ingredients determined to be health hazards and comprising 1 percent or more of the composition if the chemical is a mixture that has not undergone testing as a whole

• Chemical and common names of carcinogens listed if they are present in the mixture at levels of 0.1 percent or greater.

• All components of a mixture that have been determined to present a physical hazard

• Chemical and common names of all ingredients determined to be health hazards and comprising less than 1 percent (0.1 percent for carcinogens) of the mixture if they can still exceed an established Permissible Exposure Limit (PEL) or Threshold Limit Value (TLV) or present a health risk to exposed employees in these concentrations.

Section 3 Physical and Chemical Characteristics

The MSDS must list the physical and chemical characteristics of the hazardous substance. These include items such as boiling and freezing points, density, vapor pressure, specific gravity, solubility, volatility, and the product's general appearance and odor. These characteristics provide important information for designing safe and healthful work practices.

Section 4 Fire and Explosion Hazard Data

The MSDS must:

• Describe the compound's potential for fire and explosion.

• Identify the fire hazards of the chemical and the conditions under which it could ignite or explode.

• Describe recommended extinguishing agents and fire-fighting methods.

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Section 5 Reactivity Data

This section gives information about other chemicals and substances with which the chemical is incompatible, or with which it reacts.

The section must include information on any hazardous decomposition products, such as carbon monoxide.

Section 6 Health Hazards

Section VI must list the acute and chronic health hazards of the chemical, together with signs and symptoms of exposure. In addition, it must list any medical conditions that exposure to the compound can aggravate.

The standard specifies the following types of chemical health hazards:

• carcinogens

• corrosives

• toxins

• irritants

• sensitizers

• mutagens

• teratogens

The MSDS must detail:

• Effects on target organs; i.e., liver, kidney, nervous system, blood, lungs, mucous membranes, reproductive system, skin, eyes, and so on.

• The route of entry, that is, the primary pathway by which the chemical enters the body (inhalation, skin, and ingestion)

• The OSHA PEL, the ACGIH TLV, and other exposure levels that the chemical manufacturer uses or recommends

• Whether the compound is listed as a carcinogen (cancer-causing agent) by OSHA, the National Toxicology Program (NTP), or the International Agency for Research on Cancer (IARC), the MSDS must provide this information

Section 7 Precautions for Safe Handling and Use

The standard requires the preparer to describe the precautions for safe handling and use. These include recommended industrial hygiene practices, precautions employees should take during repair and maintenance of equipment, and procedures for cleaning up spills and leaks. Some manufacturers also use this section to include useful information not specifically required by the standard, such as EPA waste disposal methods and state and local requirements.

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Section 8 Control Measures

The standard requires the preparer of the MSDS to list any generally applicable control measures. These include engineering controls, safe handling procedures, and personal protective equipment. Information is often included on the use of goggles, gloves, body suits, respirators, and face shields.

Employer Responsibilities • Employers must assure that each employee has a basic knowledge of how to find information on an

MSDS and how to make use of that information properly.

• Make complete and accurate MSDS available during each work shift to employees when they are in their work areas.

• Provide information for each hazardous chemical.

A Sample MSDS follows on the next page.

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AGA GAS -- CARBON MONOXIDE

MATERIAL SAFETY DATA SHEET

NSN: 6830011038438

Manufacturer's CAGE: 09785

Part No. Indicator: A

Part Number/Trade Name: CARBON MONOXIDE

===========================================================================

General Information

===========================================================================

Company's Name: AGA GAS INC

Company's Street: 6225 OAKTREE BLVD Company's City: CLEVELAND

Company's State: OH Company's Country: US

Company's Zip Code: 44131-5000

Company's Emerg Ph #: 216642-6600

Company's Info Ph #: 216-642-6600

Distributor/Vendor # 1: IWECO Distributor/Vendor # 1 Cage: 03XZ9

Record No. For Safety Entry: 001

Tot Safety Entries This Stk#: 003 Status: SE

Date MSDS Prepared: 01APR92 Safety Data Review Date: 17APR96

Preparer's Company: AGA GAS INC

Preparer's St Or P. O. Box: 6225 OAKTREE BLVD

Preparer's City: CLEVELAND Preparer's State: OH Preparer's Zip Code: 44131-5000

MSDS Serial Number: BZFYK

===========================================================================

Ingredients/Identity Information

===========================================================================

Proprietary: NO

Ingredient: CARBON MONOXIDE

Ingredient Sequence Number: 01

NIOSH (RTECS) Number: FG3500000

CAS Number: 630-08-0

OSHA PEL: 55 MG/CUM

ACGIH TLV: 57 MG/CUM

Other Recommended Limit: 50 PPM

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===========================================================================

Physical/Chemical Characteristics

===========================================================================

Appearance And Odor: COLORLESS, ODORLESS GAS.

Boiling Point: -312.7F

Vapor Pressure (MM Hg/70 F): -337.1F

Specific Gravity: 0.96

Solubility In Water: SLIGHT

===========================================================================

Fire and Explosion Hazard Data

===========================================================================

Lower Explosive Limit: 12.5

Upper Explosive Limit: 74

Extinguishing Media: WATER, DRY CHEMICAL, CO2.

Special Fire Fighting Proc: STOP THE FLOW OF CO. USE WATER SPRAY TO COOL

SURROUNDING CONTAINERS.

Unusual Fire And Expl. Hazards: CO HAS ALMOST THE SAME DENSITY AS AIR. IT

WON'T DIFFUSE BY RISING AS W/SOME LIGHTER FLAMMABLES SUCH AS HYDROGEN/

NATURAL GAS (METHANE). AUTOIGNITION TEMP=1166F.

===========================================================================

Reactivity Data

===========================================================================

Stability: YES

Cond To Avoid (Stability): CONDITIONS >125F, SOURCES OR IGNITION.

Materials To Avoid: OXIDIZERS

Hazardous Decomp Products: NONE

Hazardous Poly Occur: NO

===========================================================================

Health Hazard Data

===========================================================================

Route Of Entry - Inhalation: YES

Route Of Entry - Skin: NO

Route Of Entry - Ingestion: NO

Health Haz Acute And Chronic: INHALATION: OXYGEN TRANSPORT FUNCTION OF THE

HEMOGLOBIN OF THE BLOOD IS REDUCED SINCE IT REACTS W/INHALED CO TO FORM

CARBOXY HEMOGLOBIN INSTEAD OF ITS NORMAL REACTION W/THE OXYGEN IN THE LUNGS

FORMING OXYHEMOGLOBIN. THE AFFINITY OF HEMOGLOBIN FOR CO IS 200-300 TIMES

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GREATER THAN ITS AFFINITY FOR OXYGEN. (SEE SUPP)

Carcinogenicity - NTP: NO

Carcinogenicity - IARC: NO

Carcinogenicity - OSHA: NO

Explanation Carcinogenicity: NONE

Signs/Symptoms Of Over exp: HEADACHE, DIZZINESS, HEART PALPITATIONS,

WEAKNESS, CONFUSION, NAUSEA, CONVULSIONS, UNCONSCIOSNESS.

Med Cond Aggravated By Exp: PERSONS IN ILL HEALTH WHERE SUCH ILLNESS WOULD

BE AGGRAVATED BY EXPOSURE TO CO SHOULDN'T BE ALLOWED TO WORK W/HANDLE

PRODUCT.

Emergency/First Aid Proc: INHALATION: IF CONSCIOUS ASSIST TO AN

UNCONTAMINATED AREA & TREAT W/SUPPLEMENTAL OXYGEN. IF UNCONSCIOUS REMOVE TO

UNCONTAMINATED AREA & GIVE ASSISTED RESPIRATION & OXYGEN AT THE SAME TIME.

OBTAIN MEDICAL ATTENTION IN ALL CASES. PHYSICIAN SHOULD BE INFORMED THAT

PATIENT HAS INHALED TOXIC QUANTITIES OF CO.

===========================================================================

Precautions for Safe Handling and Use

===========================================================================

Steps If Material Released/Spill: EVACUATE ALL PERSONNEL FROM AREA. USE

APPROPRIATE PROTECTIVE EQUIPMENT. IF LEAK IS IN USER'S EQUIPMENT, BE

CERTAIN TO PURGE PIPING W/INERT GAS PRIOR TO ATTEMPTING REPAIRS. IF LEAK IS

IN CONTAINER/CONTAINER VALVE CONTACT CLOSEST SUPPLIER.

Waste Disposal Method: DON'T ATTEMPT TO DISPOSE OF WASTE/UNUSED

QUANTITIES. RETURN IN THE SHIPPING CONTAINING PROPERLY LABELED, W/ANY VALVE

OUTLET PLUGS/CAPS SECURED & VALVE PROTECTION CAP IN PLACE TO SUPPLIER.

DISPOSE OF IAW/FEDERAL, STATE & LOCAL REGULATIONS. UN 1016

Precautions-Handling/Storing: USE ONLY IN WELL-VENTILATED AREAS. VALVE

PROTECTION CAPS MUST REMAIN IN PLACE UNLESS CONTAINER IS SECURED W/VALVE

OUTLET PIPED TO USE POINT.

Other Precautions: DON'T DRAG, SLIDE/ROLL CYLINDERS. USE SUITABLE HAND

TRUCK FOR CYLINDER MOVEMENT. USE PRESSURE REDUCING REGULATOR WHEN

CONNECTING CYLINDER TO LOWER PRESSURE

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Sample Letter for Requesting an MSDS

[Date]

{Company Name]

[Street Address]

[City, State Zip]

Dear Sir:

The Occupational Safety and Health Act Hazard Communication Standard (1910.1200)

requires employers be provided Material Safety Data Sheets (MSDS) for all hazardous substances used in their facility, and to make these MSDS available to employees potentially exposed to these hazardous substances.

We, therefore, request a copy of the MSDS for your product listed as Stock # __________. We did not receive an MSDS with the initial shipment of the [product name] we received from you on [date].

We also request any additional information, supplemental MSDS, or any other relevant data that your company or supplier has concerning the safety and health aspects of this product.

Please consider this letter as a standing request to your company for any information concerning the safety and health aspects of using this product that future use or testing may uncover.

Please send us the MSDS and any other relevant information within 10, 20, and 30 days (appropriate time). Delays in receiving the MSDS information may prevent use of your product. Please send the requested information to [individual’s Name], Safety Director, (name of Company, address, city, state, zip code).

Please be advised that if we do not receive the MSDS on the above chemical by [Date], we may have to notify OSHA of our inability to obtain this information. It is our intent to comply with all provisions of the Hazard Communication Standard and the MSDS are essential to this effort.

We greatly appreciate your cooperation and your timely response to this request. If you have any questions concerning this matter, please contact [individual’s Name] at [area code + telephone number].

Sincerely,

________________________________, (Title)

Name of County

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Personal Protective Equipment (PPE

The following summarizes some of the key points of OSHA’s requirements for personal protective equipment. You should refer to the standard for more detailed information.

Management Responsibilities

Your first step when implementing effective personal protective equipment (PPE) program should be a comprehensive evaluation of the equipment your employees might need to protect themselves against hazards in the workplace. Your assessment should:

• Help you understand your employees’ job responsibilities and the hazards they face

• Help you decide if administrative or engineering controls are feasible

• Help you determine what types of PPE to provide and to understand their limitations in protecting employees

• Result in the development of a standard operating procedure (SOP). Your training program on personal protective equipment should include instruction on the SOP

Ideally, engineering controls and procedural safeguards will be the first step in protecting your employees. PPE should be the last step. PPE does not eliminate hazards. It only provides a barrier between the worker and hazard. If the employee removes the equipment or the equipment fails, the employee is at risk. You must make sure that:

• Equipment fits properly.

• Your employees know how to inspect PPE for defects and how to maintain it in a clean and serviceable condition.

• Provide and document training so employees understand the equipment’s purpose and limitations.

The PPE standards, 29 CFR 1910.132 through 29 CFR 1910.138, establish the employer’s obligation to provide PPE to employees. Detailed information about the employer’s obligation to pay for personal protective equipment may be found in Section XII of 29 CFR Part 1910, Subpart I, Enforcement Guidance for Personal Protective Equipment in General Industry.

http://www.osha.gov/OshDoc/Directive_pdf/CPL_02-01-050.pdf (Issued February 10, 2011)

Hazard Assessment

OSHA requires you to assess the workplace to determine if hazards that would require the use of PPE are present or are likely to be present. The assessment should record:

• The workstation and/or job classification

• The potential hazards

• The body part affected

• A determination of whether PPE is necessary, and, if so, what type.

http://www.osha.gov/OshDoc/Directive_pdf/CPL_02-01-050.pdf�

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Hazard Assessment Certification

You must maintain records that certify that you or a designated employee has completed the assessment. “Certification” means that you have a form on which you record the following information:

• Name and address of the workplace where the evaluation took place

• The name of the person certifying that the assessment is complete

• The date on which the employer or his designate completed the assessment

Training

The OSHA standard requires you to train your employees before requiring them to use PPE. Training should cover:

• When to use PPE

• What type of PPE is necessary

• How to wear required PPE properly

• The limits of PPE

• Proper care, useful life, and disposal of PPE

Always maintain accurate records of the training you provide and have some means of documenting how well employees have understood the training. You training records should contain:

• The name of the employees trained

• The date of the training

• The subject(s) covered (that is, safety glasses, safety boots, hard hats)

You must retrain employees if:

• There are changes in the workplace or an employee changes job assignments

• There are changes in personal protective equipment

• When employees fail to use PPE or use it improperly

The following summarizes the key points of OSHA’s requirements for PPE in General Industry.

Head Protection

Hazards

A survey by the US Bureau of Labor Statistics (BLS) in 1994 revealed that most workers who suffered impact injuries to the head were not wearing head protection. Most were performing their normal job when the injury occurred.

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You should look for the following hazards as you conduct their workplace assessment:

• Bump contact

• Overhead falling objects

• Side flying projectiles

• Electrical contact

• Hair entanglement -- This may occur if employees whose hair is loose work around or near rotating machinery such as drill presses. To limit the potential for this type of injury, you should require employees to contain their hair by a hat, cap, or net.

Providing Head Protection

If you identify the existence of or potential for head hazards, you must provide your employees with head protection. The protective hats must:

• Resist penetration

• Absorb the shock of blow

Protective hats protect the wearer from electrical shock. Refer to the current American National Standards Institute (ANSI) Standard to make sure your protective hats meet with current requirements.

Protective headwear that meets MIOSHA standards is made of water-resistant and slow burning material. Each helmet consists essentially of a shell and suspension. A space between the headband and the shell provides ventilation. Instructions should come with each helmet that explains the proper method of adjusting and replacing the suspension and headband.

Fit

You should provide training so that your employees know how to adjust their head protection properly. Headbands are adjustable in 1/8-size increments. When the user adjusts the headband to the right size, there should be sufficient clearance between the shell and the headband.

Inspection and Maintenance

If your employees will wear hats or helmets while using paint or cleaning agents, consult with the manufacturer. Some paints and thinners may damage the shell and reduce protection by physically weakening or negating electrical resistance.

Users should keep their head protection clean. The most common method of cleaning shells is dipping them in hot water (approximately 140 degrees Fahrenheit) containing a good detergent for at least one minute. Users may then scrub the shells and rinse them in clean hot water.

Users should inspect their helmets daily after cleaning them. They should check all components, shells, suspensions, headbands, sweatbands, and any accessories daily for signs of dents, cracks, penetration, or any other damage that might reduce the degree of safety originally provided.

Users should not store or carry protective headwear on the rear-window shelf of an automobile for two reasons. First sunlight and extreme heat may adversely affect the degree of protection. Second, the helmets could become flying projectiles.

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Eye and Face Protection

Hazards

The US Bureau of Labor Statistics (BLS) Study found that about 60 percent of workers who suffered eye injuries were not wearing face protection. Employers must provide suitable eye protection when an eye or face injury is possible because of the following:

• Flying particles

• Molten metal

• Liquid chemicals, acids or caustic liquids

• Chemical gases or vapors

• Potentially injurious light or heat radiation, or a combination of these

Look for the existence of the following conditions when you assess your workplaces for possible eye hazards:

• Frontal and side impact

• Electrical arc

• Molten metal

• Chemical splash

• Injurious light radiation

• Suspended particles

• Extreme hot/cold splash

Providing Eye Protection

The design of type of each eye, face, or face-and-eye protection targets a particular hazard. Therefore, you should consider the kind and degree of hazard and select the protection accordingly.

Protection must meet the following minimum requirements. It must:

• Adequately protect against the specific hazards for which the manufacturer designed it.

• Be reasonably comfortable when worn under the designated conditions. It must fit snugly and not interfere with the wearer’s vision or movements. It must be durable.

• Be capable of being disinfected and be easily cleaned.

• Be clean and in good repair.

OSHA requires that every face and eye protector have the manufacturer’s name and ANSI rating clearly marked on it.

Persons using corrective spectacles and those whom OSHA requires to wear eye protection must wear face shields, goggles, or spectacles of one of the following types:

• Spectacles with protective lenses providing optical correction;

• Goggles worn over corrective spectacles without disturbing the adjustment of the spectacles; or

• Goggles that incorporate corrective lenses mounted behind the protective lenses.

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If you need to coat eye protection with an anti-fogging or other agent so that water beads and runs off quickly, check with the manufacturer to assure that the agent will not damage it or reduce protection.

Employers must inform employees who use eye, face, or face-and-eye protectors about any limitations or precautions that the manufacturer indicates. It is very important that the user observe any limitations.

Eye protection is available in many types and styles in order to meet the wide range of demands for protection in the workplace. Goggles also come in a number of different styles for specific uses such as protecting against dusts and splashes. They also come in models for chippers, welders, and cutters.

Safety spectacles require special frames. Combinations of normal street wear frames with safety lenses are not acceptable.

Fit

You should assure that an individual skilled in fitting goggles and safety spectacles helps employees to achieve a proper fit. Only a qualified optical person should fit spectacles.


Users must keep eye protection clean because dirty lenses can cause eyestrain. Your employees should inspect and clean their eye protection with soap and hot water or with a cleaning solution and tissue daily. They should look for deep scratches or excessive pitting. These can cause lenses to break more easily. They should also check the headband to make sure it has enough elasticity to hold the eyewear in the proper position.

Employees should keep goggles in a case when not in use. Since rough usage of prescription spectacles can damage the frame, nose pads, and temples, employees who wear them should care for them as they would for their own glasses.

Management should:

Make certain that replacement lenses are available when old ones develop pits

Disinfect previously used eye and/or face protection before issuing it to another employee

Store the dry parts or items in a clean, dust-proof container, such as a box, bag, or plastic envelope for protection until you reissue them.

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Arm and Hand Protection

Hazards

Examples of common injuries to arms and hands are burns, cuts, electric shock, amputation, and absorption of chemicals.

A recent BLS study found that seven of ten workers were not wearing hand protection at the time of the injury. About 60 percent worked in manufacturing processes. More than two out of every five workers received injuries while operating, maintaining, or repairing fixed machinery or equipment.

The study also revealed that the most common condition(s) leading to the injury were:

• Working at too quickly

• Lack of awareness that hands were in a hazardous area

• Misjudgment about time and/or distance needed to avoid injury.

When you assess the workplace for arm and hand hazards, look for the following potential hazards:

• Skin absorption

• Severe abrasions

• Severe lacerations

• Thermal burns

• Extreme cold

• Puncture

• Chemical burns

Providing Skin, Arm, and Hand Protection

A wide assortment of gloves, hand pads, and wristlets is available for protection against various hazardous situations.

You must determine what hand protection employees will need after evaluating their activities. Other considerations are:

• The degree of dexterity employees need to perform job responsibilities

• The duration, frequency, and degree of exposure to hazards

• The physical stresses of the job.

You need to select gloves to fit the job. Criteria for selection should be performance requirements, conditions, duration, and hazards. For example, employees may need to use gloves--such as wire mesh, leather, and canvas--that tests have shown provide insulation from burns or cuts.

Certain occupations require special protection. For example, electricians and people working around electricity need special protection from shocks and burns.


Employees should use and maintain gloves following the manufacturer's recommendations.

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Employers must be aware of the "degradation" and "permeation" of the gloves they select. Degradation means the material is physically breaking down. Permeation refers to the ability of the chemical to penetrate the material without necessarily affecting the materials. Prompt decontamination of gloves after exposure to chemicals is necessary to reduce the effects of degradation and permeation. When decontamination of protective clothing is not possible, the organization should discard it.

Foot and Leg Protection

Hazards

The BLS found that most of the workers in selected occupations who suffered foot injuries were not wearing protective footwear. Furthermore, their employers did not require the use of foot protection.

Workers need foot and/or leg protection when there is a danger of failing or rolling objects, sharp objects, molten metal, hot surfaces, and wet slippery surfaces.

In assessing the workplace for foot hazards, look for the following potential hazards:

• Falling objects

• Rolling objects

• Electrical contact

• Sole puncture

• Wet slippery surfaces

• Molten metal

• Hot surfaces

Providing Foot and Leg Protection

Safety shoes should be sturdy and have an impact-resistant toe. Some shoes have metal insoles to protect against puncture wounds. Some types of footwear provide additional protection such as metatarsal guards. Safety shoes come in a variety of styles and materials, such as leather and rubber boots and oxfords.

Leggings protect the lower leg and feet from molten metal or welding sparks. Safety snaps permit their rapid removal.

Aluminum alloy, fiberglass, or galvanized steel foot guards are available for wear over work shoes. However the guard may catch on something, causing a worker to trip.

Heat-resistant soled shoes protect against hot surfaces such as those found in the roofing, paving, and hot metal industries.

Refer to the ANSI Standard for Men’s Safety-Toe Footwear to determine if the protective footwear your employees use meets current requirements.

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Employees should receive training on inspecting foot and leg protection in accordance with manufacturer's recommendations to assure that they provide continued protection.

Body Protection

Hazards

Many hazards can threaten the body and torso including heat, splashes from hot metals and liquids, impacts, cuts, acids, and radiation. A variety of protective clothing is available including vests, jackets, aprons, coveralls, and full body suits.

When assessing the workplace for torso hazards, look for these potential hazards:

• Chemical contact

• Splashes from dipping, plating, and other operations

• Thermal burns

• Extreme cold

• Severe lacerations

Providing Body (Torso) Protection

To guard against heat and flame, look for clothing of wool and specially treated cotton. These natural fibers are fire-resistant and comfortable since they adapt well to changing workplace temperatures. You should also consider heat-resistant material, such as leather, in protective clothing to guard against heat and flame.

Duck, a closely woven cotton fabric, is good for light-duty protective clothing. It can protect against cuts and bruises on jobs where employees handle heavy, sharp, or rough material.

To guard against chemical hazards, you should request information from the manufacturers of protective clothing to determine if the protection is appropriate for the hazard(s) that you anticipate. You must determine the properties of the chemical(s) by consulting the Material Safety Data Sheet during the selection process.

Rubber and rubberized fabrics, neoprene, and plastics give protection against some acids and chemicals.

Disposable suits of plastic-like or other similar synthetic material are particularly important for protection from dusty materials or materials that can splash. If the substance is extremely toxic, a completely enclosed chemical suit may be necessary.

It is important for employers to refer to the manufacturer's selection guides for the effectiveness of specific materials against specific chemicals.


Users should inspect clothing regularly to make sure of proper fit and function and for continued protection in accordance with manufacturer's recommendations.

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Personal Protective Equipment Guide to Hazard Sources

Source Type of Hazard Protection Impact Chipping, grinding,

machining, wood working, sawing, masonry work, drilling, turning, chiseling, sanding, etc.

Flying fragments, objects, chips, turnings, and particles, grinding fines

Safety glasses, side shields, face shields.

Light or Radiation

Welding, cutting, brazing, and torch soldering

Optical Radiation

Welding goggles or shields with shades

Heat Furnace operations

High temperature, hot sparks, molten metal

Face shields (reflective), arm sleeves, gloves, coat, leggings

Chemicals Acid and chemical handling, fumes, degreasing, dipping, plating

Splash, irritating mists, direct contact

Gloves, chemical goggles, face shields, aprons, special shoes or boots

Falling Objects Working in areas where potential for failing objects exists or bumping hazards

Steel receiving, heavy parts transfer, overhead conveyors for parts movement, or low ceilings or mechanisms

Hard hat, bump caps, safety shoes

Sharp Objects Handling sharp edged parts, clearing turnings, objects which may pierce a foot or hand

deburring, removing turnings, assembling sharp parts

Special cut resistant gloves, penetration resistant shoes

Electrical

Direct or indirect contact with electricity

Electricity

Non-conductive safety shoes, hard hats, safety glasses, and gloves designed to reduce electrical shock and protect from sparks.

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Types of Personal Protective Equipment Face and Eye Welding Helmets

Spectacles with No side shield Half side shield Full side shield Detachable side shield Non-removable lens Lift front Headband temple Cover goggles with No ventilation Indirect ventilation Face shield

Burning goggles Welding helmets with Stationary window Lift front window Hand held

Helmets by Type Type 1: Full brim 1.25” wide Type 2: No brim, forward peak Helmets by Class: A General service with limited

voltage protection B Utility service with high

voltage protection C Special service with no

voltage protection D Firefighters full brim with

ear flaps and chin strap Hair enclosures

Foot and Leg Electrical* Fall Safety shoes or boots with Impact resistant toe Metal insoles Metatarsal guards Chemical resistance Electrical protection Cold weather protection Slip resistant soles Leggings Molten metal and welding

Insulating blankets Matting Covers Line hose Sleeves Gloves Hot stick * Must be capable of withstanding imposed voltage

Safety belts* Safety harness Lifelines Lanyards * No safety belts for fall protection after 1/1/98

Arm and Hand Body Protection Types Gloves Hand pads Sleeves Wristlets

Types Vests Jackets Aprons Coveralls Full body suits

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Personal Protective Equipment Policy and Program

___________________________________________

[Name of County]

Purpose

The purpose of the PPE Program is to protect visitors and the employees of [Name of County] from the occupational hazards within the workplace by providing protective equipment (PPE). It is our goal to use engineering controls as the primary method for protecting employees. However, when additional protection is necessary, employees will wear PPE. The scope of this program includes PPE for eye, face, head, foot, and leg and hand protection. If respirators and/or hearing protection are necessary, the organization’s Respiratory Program and Hearing Conservation program, respectively, will cover their use.

Responsibility

The person responsible for coordinating the program is [Job Title]. This person will ensure that hazard assessments take place, that affected employees receive appropriate PPE and training. The responsible person will also be in charge of maintaining the documentation for this program.

Department managers should advise the responsible person of changes in the requirements for PPE (for example, new procedures, processes that require PPE, omission of a job or task). Additionally, managers should consult with the responsible person before purchasing any new PPE.

Hazard Assessments

Each task and/or job will be assesses to determine foot, head, eye, face, and hand hazards present and the proper PPE that should be worn. The assessments will include observation of the following sources of hazards:

Impact: Flying chips, objects, dirt, particles, collision, and motion hazards

Penetration: Falling/dropping objects, sharp objects that cut or pierce

Compression: Rollover or pinching

Chemical: Splashing, burns, fumes

Temperature Extremes: Sparks, splashes from molten materials, burns from high/low temperatures

Harmful Dust: Dirt, particles, asbestos, lead

Light Radiation: Welding, cutting, brazing, lasers, furnaces, lights

We will complete a Hazard Assessment form for each job and/or task and will serve as certification that a hazard assessment has taken place. The person conducting the hazard assessment will also survey jobs that are non-routine or periodic. In some cases, we cannot complete these assessments until the jobs are scheduled. Hazard assessments will be update/evaluated whenever conditions or procedures change.

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Selection of PPE

The responsible person will make certain that the personal protective equipment in use is appropriate for the identified tasks, provides a level of protection that meets or exceeds the minimum required to protect employees from the hazards, and meets all OSHA/ANSI requirements as specified in OSHA’s PPE standard.

Training and Fit Testing

The responsible person will make certain that all affected employees receive training on

• What PPE is necessary and why

• How to wear PPE properly

• PPE limitations and capabilities

• PPE care and maintenance

Each employee will demonstrate that he or she understands the training and will sign the PPE Assignment, Training, and Fit-Test Form. The information on the form will include the name of the employee, the date(s) of training, and the type of PPE the person responsible has certified the employee to wear.

Employees will receive repeat training under the following conditions:

• Changes in the workplace that make previous training obsolete

• New assignment for employee or change in job assignment/equipment

• Incorrect use of failure to use equipment

• Introduction of new PPE

PPE Inspection, Cleaning and Maintenance

Employees will conduct inspection, cleaning, and maintenance of PPE at intervals according to the manufacturer’s instructions. They will not use damaged or defective equipment.

Individuals with questions about the PPE Program and Policy should address them to the responsible person named above.

Assignment, Training and Fit-Test Form

All affected employees receive training on Personal Protective Equipment. Training covers:

• When PPE is necessary

• What PPE is necessary and why

• How to wear PPE properly

• PPE limitations and capabilities

• PPE care and maintenance

Each employee will receive properly fitting PPE.

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Training

Both supervisors and workers shall receive instruction from a qualified person.

This training shall include:

• Proper fitting instructions including hands on demonstration and practice in a normal atmosphere and finally in a test atmosphere

• Discussion of the contaminant involved, including basic description, route of transmission, and its potential effects on the human body

• Discussion of engineering and administrative controls

• Discussion of the respirator selected, its function and limitations

• Discussion regarding how to recognize and handle emergencies

• Demonstrations and instructions in the proper care, maintenance, repair, and storage of the respirator

Management shall conduct periodic checks to verify worker diligence in observing proper respirator procedures. Supervisors and managers shall reinforce training periodically at least annually or whenever a process or respirator change occurs.

___________________________ will maintain appropriate documentation on all training procedures.

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Sample Hearing Conservation Program

Purpose

The purpose of this program is to protect personnel from possible noise-induced hearing impairment by establishing a comprehensive Hearing Conservation Program, and to comply with OSHA requirements.

Policy

[Name of County] will take the actions outlined in this policy to assure that employees work in an environment that will not adversely affect their hearing.

[Name of County] will consider noise control devices when purchasing equipment, so that new equipment that will operate at less than 80 dBA

When maintaining or repairing existing equipment, [Name of County] will determine if engineering solutions can reduce excessive noise levels prior to implementing mandatory hearing protection.

Responsibility and Procedure

Health, Safety, and Training -- Program Administrator:

• Will conduct noise surveys to identify employees whose noise exposure may equal or exceed an 8-hour time weighted average (TWA) of 85 dBA.

• Will determine and provide plug and muff hearing protectors that will offer acceptable attenuation characteristics for the environment to which the employee is subject

• Will perform monitoring whenever a change in production, process equipment, or controls increases noise exposure to the extent that additional employees may have exposure at or above the action level of 85 dBA.

• Employees will receive written notification when they undergo personal dosimeter monitoring.

• Will determine areas in which noise levels are at a TWA of 85 dBA or greater, and assist departments in posting the periphery of the defined areas with warning signs.

• Establish a training program and conduct training annually for all employees identified by paragraph #1 of this guideline. Training program shall include:

• The effects of noise on hearing

• Purpose of hearing protection devices offered, advantages, disadvantages, and attenuation characteristics

• Proper use and maintenance of hearing protectors

• Purpose of audiometric testing and explanation of test procedures

• Will notify the Program Administrator of all individuals whom the annual audiometric testing program will include

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Health Center

• Will schedule and conduct audiograms for all employees identified by paragraph A.1. Tests will take place annually thereafter.

• Maintain records of all audiometric test results for employees.

• Calibrate audiometric booths and instruments according to ANSI 53.6-1969. Maintain all calibration records.

• Notify employees in writing within 21 days when a standard threshold shift is determined. We will retest these employees in six months.

• Notify employees in writing of annual audiometric test results in comparison to their baseline audiogram.

• Log on Form 300 any threshold shift greater than 10 db according to protocols.

Department Manager

• Assist safety staff to reduce noise levels to lowest level possible.

• Assure compliance with this guideline in all affected areas within department.

• Cooperate in freeing employees to come to Program Administrator for testing.

Supervisors and Managers

• Adhere to the testing schedules that the medical provider establishes.

• Enforce the use of personal protective equipment (hearing protection).

Employees

• Will wear hearing protection if they are working in areas with noise levels at a TWA of 85 DBA or greater.

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Audiometric Testing Procedures Health, Safety and Training

Purpose

The purpose of this program is to prevent and control hearing impairment in the workplace and to meet the requirements of the Occupational Safety and Health Act 29 CFR 1910.95

Certification • Occupational Hearing Conservationists (OHC)

• Responsibilities of Health Center Staff

• Calibration of audiometric equipment

• Recording of calibrations

• Recording the diagrams

• Employee education program

• Correct techniques in obtaining audiometric testing

• Referrals to audiologists and physicians as indicated

Requirements

Occupational Hearing Conservation begins when measurements are 85 DBA over 8-hours.

• Calibrations

• Biological calibrations of audiometric machine on individuals with known threshold daily

• Acoustic calibrations annually

• (Name of testing facility) will conduct exhaustive calibrations

• Equipment certifications shall be posted in Health Center

• Audiometric Testing

o Baseline testing at beginning of employment

o Pre-placement situations demand testing

o Monitoring on yearly basis

o Exit audiometric testing on individuals leaving or retiring

• Referrals

To audiologist or physician:

o When STS of 10 decibels or more is averaged at 2,000, 3,000 and 4,000 Hz in both or either ear

o When there is significant hearing loss at 500, 1,000, 2,000, or 3,000 Hz

o When there is pain or drainage from either ear

• Techniques

o Hughson-Westlake ascending technique for threshold determination at 1,000, 2,000, 3,000, 4,000, 6,000, 8,000 (reliability test) and 500 Hz in that order for both ears Reliability test need only be done for the first ear at 1,000 Hz

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o O-right ear in red ink -- X-left ear in black ink

o Employees must be free of loud noise for 14 hours before test and instructed so

• Personal Hearing Protection Devices

o Use is mandatory when working in 85 DBA or higher for 8 hours

o Program to educate employee in the need for hearing protection is mandatory

• Daily Calibration

o Check fuse and power cord.

o Check all switches and dials.

o Turn dial to 40 db and with headset on, sweep through all frequencies in each ear.

o Check at one frequency in each ear for any intermittent noise by wiggling cords.

• Patient Instructions

o Ask patient if he or she has a “better ear.”

o Have individual remove glasses, earrings, and/or hearing aid.

o Have patient face away from tester.

o Instruct patient to push button when he or she hears sound.

o Tell patient that some sounds will be softer.

o Use thumbs to place earphones over each ear with diaphragm over the ear canal.

• Tighten headband as indicated.

• Abbreviations

CAOHC Council for Accreditation of Occupational Hearing Conservation

EEP Employee Education Program

db Decibels—Intensity of Sound

HZ Hertz—Frequency of Sound

NRR Noise Reduction Rating

OHC Occupational Hearing Conservationist (Certification required)

OHL Occupational Hearing Loss

PHPD Personal Hearing Protection Devices

STS Standard Threshold Shift

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Machine Guarding - Sample Policy and Procedure

Introduction

To protect the safety or our employees, managers, supervisors and department heads are responsible for assuring, where applicable, that all machines have appropriate guarding.

Mechanical guarding must encompass both the power transmission parts of all mechanical equipment and the points of operation on production machines.

Guards must be in place where rotational motion, nip points, and cutting, shearing, punching, and forming mechanisms can cause injury to personnel or damage to tools and equipment.

Mechanical Guards

Guarding, whether designed by the personnel of [Name of County], or procured form the machine’s manufacturer or another source, must meet the following specifications:

The guard:

• Must provide positive protection equal to that specified in ANSI B15.1

• Must be considered a permanent part of the machine or equipment, not capable of being easily or quickly removed or replaced

• Must not interfere with efficient operation or maintenance of the machine or give discomfort to the operator

• Must not weaken the machine structure

• Must be of a design specific to the job and the specific machine

• Must be durable, resistant to fire and corrosion, and easily repaired

• Must not present hazards, such as rough edges, splinters, pinch points, shear points, or sharp corners

Responsible members of management must consider the following methods of guarding:

• Enclosing the operation (preferred)

• Interlocking devices

• Moving barriers

• Removal devices

• Remote control

• Two-handed tripping devices

• Electronic safety devices

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General • Machines designed for fixed locations must be securely anchored to the floor or bench to prevent

walking or tipping.

• Employees may operate machinery only when they have received proper training and authorization to do so.

• Employees must wear proper clothing and protective devices if the supervisor, the department head, or MIOSHA specifies this.

Maintenance

Employees who must perform maintenance work on a machine must follow all safety precautions, including [Name of County]’s lockout/tagout program. Following the safety precautions will protect both employees who perform maintenance as well as other workers in the area from injury.

Important points:

1. De-energize the machine.

2. Lock out all "disconnect "switches.

3. Tag all "disconnect” switches.

4. Test the equipment to ensure it is de-energized before working on it.

NOTE: You may use a tagout only procedure if you cannot lockout the machine

1. If the machine is supplied power from a single source and is under the control of a trained and qualified person at all times and

2. Only if there are no other persons in the area who might suffer harm by accidental re-energizing.

Re-Energizing

Many accidents occur during re-energizing. Once you are ready to reenergize machinery, alert everyone in the aware and keep these individuals at a safe distance from the machinery. Only one person may perform the re-energization. This person should be either the individual who performed the lockout/Tagout or a person acting under the immediate and direct commands of the original lockout/tagout person. In the event of a shift change, or other unavailability of the original person, then the original person shall, before leaving, appoint a surrogate original person and show him or her all steps taken to lockout/tagout the equipment.

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Machine Safeguarding: Using the Quarter-Inch Rule Protecting Employees from Point Of Operation & Mechanical Hazards

Where Hazards Occur

Any machine part, function, or process that might injure the operator or other workers must have a safeguard. When the operation of a machine or accidental contact with it can injure the operator or others in the vicinity, you must either control or eliminate the hazards.

There are three areas where mechanical hazards occur:

• Point of Operation: The area on a machine where the employee performs work on the material, such as cutting, boring, or forming of stock

• Power Transmission Apparatus: All mechanical systems that transmit energy to the part of the machine performing the work. These components include flywheels, pulleys, belts, connecting rods, couplings, cams, spindles, chains, and gears.

• Other Moving Parts: All parts of the machine that move while the machine is working. These can include reciprocating, rotating, and transverse moving parts, as well as feed mechanisms and auxiliary parts of the machine.

Machinery hazards are as varied and complex as the types of equipment that you can find in your operations. However, there is one rule you can apply to determine if the hazard has adequate guarding. Mechanical hazards must have guarding unless you can reduce the opening or access to the hazard to one-quarter inch or less.

The Quarter-Inch Rule

Under OSHA, one-quarter inch or less is the allowable opening that an inspector will accept when evaluating machinery hazards. By definition, OSHA does not consider an opening of a quarter inch or less to be a hazard. Simply put, if the exposure to the operator at the point of operation is one-quarter inch or less, you do not have to safeguard the exposure. Any opening greater than one-fourth inch requires a safeguard.

Table 1 provides guidance that applies to most machine safeguarding exposures for the point of operation. Whether the hazard is at the point of operation or at a power transmission point, you can usually use the one-fourth inch rule as the standard to determine if the hazard has proper guarding.

Distance of opening from point of operation hazard (inches)

Maximum width of opening (inches)

1/2 to 1-1/2 1/4 1-1/2 to 2-1/2 3/8 2-1/2 to 3-1/2 1/2 3-1/2 to 5-1/2 5/8 5-1/2 to 6-1/2 3/4 6-1/2 to 7-1/2 7/8 7-1/2 to 12-1/2 1-1/4 12-1/2 to 15-1/2 1-1/2 15-1/2 to 17-1/2 1-7/8 17-1/2 to 31-1/2 2-1/8

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Requirements for Safeguards

Safeguards must meet the following general requirements:

• The safeguard must prevent hands, arms, and any other part of a worker's body from making contact with dangerous moving parts. A good safeguarding system eliminates the possibility of the operator or another worker from placing parts of their bodies near hazardous moving parts by reaching over, under, around or through the safeguarding system.

• Workers should not be able to easily remove or tamper with the safeguard. A safeguard that a worker can easily make ineffective is no safeguard at all. Guards and safety devices should be made of durable material that will withstand the conditions of normal use. To ensure guards secure on the machine, the machine should come with a device that requires a “tool” to remove.

• The safeguard should ensure that no objects could fall into moving parts. A small tool that a worker drops or knocks into a cycling machine could easily become a projectile that could strike and injure someone.

• A safeguard defeats its own purpose if it creates a hazard of its own such as a shear point, a jagged edge, or an unfinished surface that can cause a laceration. The edges of guards, for instance, should have rolled edges or be bolted in such a way that they eliminate sharp edges.

• Any safeguard that impedes a worker from performing the job quickly and comfortably might result in the worker overriding or disregarding it. Proper safeguarding can actually enhance efficiency since it can relieve the worker's apprehensions about injury.

• Safeguarding should allow for minor equipment adjustments and lubrication when possible. Locating adjustment controls, control devices, and lubrication lines outside the area requiring guarding will reduce the need for the operator or maintenance worker to enter the hazardous area. It will also reduce the need to remove the guard. If workers remove guards, they may not replace them.

OSHA requires that tongue guards for abrasive wheels be one-quarter inch from the grinding wheel. A rigid guard for the in-running nip of a printing press should be set one-quarter inch from the surface of the rotating cylinder. The stroke for equipment cutting sheet metal or chopping light gauge scrap is frequently set to a maximum opening of one-quarter inch.

Press break safeguarding applies a variation of the quarter inch rule by using the "two hand down and step through" technique. The operator places his or her hands on the two hand control buttons which bring the knife (sized for the operation) of the press brake down to within one quarter inch of the work piece. The operator then steps on the foot control to bring the knife into contact with the work piece, keeping the hands free to support other steps of the operation.

Consider Engineering to Reduce Exposure

You can avoid the need to use safeguards by engineering the system to keep exposures to an opening one-quarter inch or less. This can have several advantages:

• You do not have to fabricate or purchase guards; you are not investing time or money.

• If guards are unnecessary, maintenance staff does not have to worry about replacing guards following maintenance work.

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• You minimize potentially serious injury to operators from machinery hazards because of substantial engineering controls.

Summary

You should take time to inspect your machinery for compliance with OSHA’s guarding requirements. In addition you should ask the following questions:

1. Do you use standardized guidance (Table 1) to determine if all hard guards are properly fabricated, set, or adjusted for the point of operation?

2. Do your written procedures for maintaining or servicing equipment include the removal and replacement of safeguards?

3. Do you train your operators before they start work with you and thereafter on a scheduled basis in what constitutes good safeguarding practices? Does the training familiarize them with their equipment safeguards, and enable them to recognize if the equipment is in good condition before operating it. Do you appropriate procedures for operation and for reporting deficiencies? Do you document all training?

4. Do you perform and document self-audits of your safeguard practices for both operator and maintenance groups on a periodic basis? Quarterly self-audits are typical.

Even if you cannot adjust your production methods to apply the one-quarter inch rule, a supportable "yes" for each of the four questions indicates an operations management system that will enhance loss control.

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Implementing Energy Control Procedures Lockout/Tagout

Machinery that starts up unexpectedly during maintenance or repairs can result in employee injury or death. Because of the grave risk, management must provide proper training on lockout/tagout procedures for employees who work on or with energized systems. Management also must develop and enforce a written lockout/tagout plan that documents

• Appropriate procedures

• Disciplinary action that may result if employees fail to follow the procedures

What Employers Should Do

Employers should:

1. Develop a written lockout/tagout program that includes both procedures for energy control and training for employees. The document should discuss the scope, purpose, authorization, rules, techniques, and enforcement of the program.

2. Maintain a current copy of the lockout/tagout program, and make it available for inspection by employees and by the Director of the Michigan Department of Labor and his/her authorized representatives.

3. Buy adequate locks and tags for each type of energy source at each location. Use effective tagout methods when lockout is not possible. Tagouts should provide at least as much protection for employees as lockouts.

4. Provide training for employees. The training should cover the purpose of the program, methods of energy control, and the proper use of lockout/tagout procedures. Employers should document all training. Videos are available by calling the League’s Loss Control Services.

5. Monitor the program for effectiveness.

6. Designate employees “authorized” to perform lockout/tagout.

7. Notify affected employees before and after lockout/tagout.

Lockout Procedures

Employers select “authorized” employees. Only these employees may perform lockout/tagout procedures.

“Authorized” employees should:

1. Establish a safe and orderly procedure before de-energizing circuits or equipment.

2. Disconnect circuits and equipment requiring service from all electric energy sources. They should not use control circuit devices -- for example, push buttons, selector switches, or interlocks -- as the only means of de-energizing circuits or equipment. Interlocks are not acceptable substitutes for lockout.

3. Release stored electric energy that might endanger employees. They should discharge capacitors, and short circuit and ground high-capacitance elements if stored electric energy might endanger personnel. Employees should treat the capacitors and associated equipment as energized if they must handle them in meeting this requirement.

4. Block or relieve stored non-electrical energy in devices that could re-energize electric circuit parts.

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5. Place a lock on each disconnecting means used to de-energize circuits and equipment on which employees will work. The “authorized” employee should attach the lock so that another employee cannot operate the disconnecting means without exerting undue force or using tools to remove the lock.

Under OSHA standards, circuits or equipment are unsafe until employers meet the above requirements. Only then can employees work on the equipment.


1. Test equipment-operating controls or otherwise determine that the equipment will not restart

2. Use test equipment on the circuit elements and electrical parts of equipment to which employees may have exposure to verify that they are de-energized. The test should also determine if any energized condition exists because of inadvertently induced voltage or unrelated voltage back-feed, even though the “Authorized” employee has de-energized specific parts of the circuit and workers assume they are safe. If the circuit that requires testing is more than 600 volts, nominal, the “authorized” employee should check that the test equipment is operating properly immediately before and immediately after the test.

Removing Lockouts/Tagouts

As with lockout/tagout, only “authorized” employees should remove energy controls. They should meet all of the following requirements in the order listed before re-energizing circuits or equipment, even temporarily:


1. Conduct tests and visual inspections, as necessary, to check that employees have removed all tools, electrical jumpers, shorts, grounds, and similar devices so that the circuits and equipment can be safely energized.

2. Warn employees who have exposure to the hazards associated with re-energizing the circuit or equipment to stay clear of circuits and equipment.

3. Supervise the removal of energy controls.

4. The employee who applied each lock should remove it or direct an employee who is under his/her direct supervision to remove it.

5. If the employee who applied the lock is absent from the workplace, an “authorized” employee may remove it if he or she complies with both of the following provisions:

o The employer verifies that the individual who applied the lock is unavailable.

o The employer assures that the employee who applied the lock knows -- before resuming work -- that the “authorized” employee has removed it.

6. Determine by visual inspection that all employees are clear of the circuits and equipment.

Other Requirements

If using a lock is not practicable or if the employer can demonstrate that tagging procedures will provide safety equivalent to a lock, a worker may use a tag without a lock. The tag should comply with all the following requirements.

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The tag should:

• Be of a distinctive employer design and clearly prohibit unauthorized energizing of circuits and removal of the tag.

• Not be used without an additional safety measure such as the removal of an isolating circuit element, the blocking of a controlling switch, or the opening of an extra disconnecting device.

The employer should also train all persons who have access to controlling devices so they are familiar with the employer's tagging procedures.

Under the law, employers should comply with each of the above requirements. More important, compliance will help employers make certain that employees will be safe and thorough when they should use lockout/tagout procedures.

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Lockout/Tagout Procedures Self-Assessment

Many serious injuries -- even deaths -- occur each year because of employees working on or performing maintenance on equipment. Because of the grave risk to employees who work on or near machinery and other devices with stored energy, employers should take a proactive approach to Lockout/Tagout safety. In order to determine if your practices concerning the control of energy sources are adequate, you should review the following questions.

Does your organization:

1. Have a written Lockout/Tagout Policy?

Yes No

2. Train your employees?

Yes No 3. Enforce the use of the Lockout/Tagout policy?

Yes No 4. Have adequate locks and tags available?

Yes No

The policy should:

Identify the location of equipment with store energy. Identify energy control procedures; Identify training requirements for employees, Discuss the scope, rules, authorization, and

enforcement of the policy; and Be accessible for inspection.

The training program should:

Cover the purpose of the program; Cover the methods to control typical energy sources; Be documented; and Include a refresher course when conditions change.

Enforcement must include

Monitoring the effectiveness of the program by conducting periodic checks of work areas

Designating employees who a Have the authority to perform lockout/tagout. Disciplinary steps for employees who violate the policy

The locks and tags must:

Fit the energy source. Not be centrally keyed or duplicated. Be controlled to ensure that extra keys are not available.

Note: Tags should provide at least as much protection as locks.

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OSHA’S Lockout/Tagout Key Elements of OSHA’s Lockout/Tagout Standard

General Requirements 1. Establish a program consisting of energy control and employee training procedures.

2. Use effective tagout methods if it is not possible to lockout equipment. Provisions for lockout/tagout devices are a requirement for new machines or equipment or following major repairs or modifications.

3. Make certain that tagouts, when employees use them in place of lockouts, offer protection that is at least as effective as lockouts.

4. Develop, document, and use an energy control procedure to control hazardous energy. Procedures must clearly outline the scope, purpose, authorization, rules, techniques, and enforcement. The standard offers some exemptions to the requirement for documentation.

5. Provide the necessary hardware and materials.

6. Conduct and certify inspections of the procedure to assure compliance.

7. Train employees on the purpose and function of the energy control program. The employer must certify the training.

8. Allow only "authorized employees" to perform lockout/tagout.

9. Notify affected employees before and after lockout/tagout.

Procedure for Applying Controls 1. Inform authorized employees about energy and hazards before shutdown.

2. Make sure that the shutdown is orderly to prevent increased hazard(s) to employees.

3. Assure that equipment isolation devices are located and operated for isolation.

4. Affix lockout/tagout devices after isolation.

5. Relieve, disconnect, restrain, or otherwise safeguard stored or residual energy.

6. Verify isolation before the "authorized employee" works on equipment.

Procedure for Removing the Lockout/Tagout

1. Inspect for and remove nonessential items, and make sure that equipment is operationally ready.

2. Remove employees from equipment areas.

3. Remove lockout/tagout device.

4. Energize equipment and proceed with testing or positioning.

5. De-energize equipment and reapply lockout/tagout device according to the procedures for applying controls.

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In addition:

Require contractors or outside servicing persons and employers to inform one another of lockout procedures. Develop rules for department lockout and for shift and/or personnel changes.

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Sample Lockout/Tagout Procedure

Purpose

To prevent injury from the unexpected energizing, startup or release of stored energy that could cause injury.

Examples of Stored Energy Where Lockout/Tagout Applies • Electrical

• Mechanical

• Thermal, Steam

• Chemical, Acids, and Caustics

• Explosives, Natural Gas

• Hydraulic

• Pneumatic

• Gravity

Scope

Lockout/tagout is mandatory whenever employees perform maintenance or service work on machines or equipment.

Required Lockout/Tagout

1. Maintenance or service work means constructing, installing, setting up, adjusting, inspecting, modifying, maintaining, and/or servicing machines or equipment. These activities may also include lubrication, cleaning or releasing jams in machines or equipment and making adjustments or tool changes if the employee may have exposure to the unexpected energizing or startup of the equipment or release of hazardous energy.

2. Before removal or bypassing any guard or other safety device

3. When an employee must place any part of his or her body into a "point of operation" or other danger zone that exists during a machine operation cycle

Exceptions to Lockout/Tagout

1. Normal production activities in which lockout cannot take place because of the nature of the operation or if the operation is routine, repetitive, and integral to the use of the equipment for production, but only if the employer provides alternative measures that provide effective protection.

2. Cord and plug type of equipment (operator has "control" of cord).

3. Hot Tap operations.

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Responsibilities

Safety Manager

• Procedure development and maintenance

• Authorization of lockout/tagout devices

• Employee training

• Annual inspections for compliance of procedures

Supervisors

• Knowledge of lockout/tagout procedures

• Enforcement of lockout/tagout procedures

• Recognition when retraining is needed

• Participates in development of specific job procedures

Employees Authorized to Perform Lockout

• Understanding of purpose of lockout/tagout

• Understanding hazards of unexpected energizing of equipment

• Can perform lockout/tagout

Affected Employees—Employees in Area of Lockout/Tagout

• Understanding the importance of lockout/tagout and the importance of not attempting to remove a lockout/tagout device

Approved Lockout/Tagout Devices

All authorized employees will receive specific lockout locks.

• The Safety Manager will issue approved locks. The County uses standardized locks.

• The lock owner will receive only one key with the lock. The lock owner must maintain the key. The Safety Manager may maintain a master key but cannot use it without following lock removal procedures.

• The employer will engrave each lock with its owner’s name.

• The employer will maintain a record of all assigned locks in the maintenance office and the Safety Manager’s office.

• Employees must not make duplicate keys.

• Employees must not use locks for any purpose other than lockout.

• Multiple lock adapters will be available for all jobs requiring more than one safety lock.

• Tags will not replace locks unless it is impossible to install locks physically to isolation devices. Employees will inform the Safety Manager when lockout is impossible so the Safety Manager can arrange for engineering changes that allow the use of locks.

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Training

Frequency

• During facility or job orientation

• Before new job assignment

Affected Employee

• Purpose and function of energy control (lockout/tagout) program

Authorized Employee

• Purpose and function of energy control (lockout/tagout) program

• Recognition of type and magnitude of applicable hazardous energy sources

• Methods and means for isolation and control of energy (lockout/tagout)

Record Keeping

• Maintained in the Safety Manager’s office

Retraining

• When procedure inspection reveals non-compliance

• Accidents due to non-compliance of procedures

• Changes in lockout/tagout program

• Changes in equipment or machines

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General Lockout Procedure 1. Employee Notification

Notify all affected employees that a lockout or tagout system is will be in use and inform them of the reason for lockout.

2. Preparation

Locate all energy sources needing isolation.

3. Equipment Shutdown

Shut equipment down by the normal stopping procedure (depress stop button, open toggle switch, etc.), if it is operating. Contact operator for shutdown procedures. Note: Do not use the electrical disconnect switch to stop equipment.

4. Equipment Isolation

Operate the switch, valve, or other energy isolating device(s) to cut the equipment off from its energy source(s).

• For electrical energy - Locate correct electrical disconnect switch and pull down the disconnect switch.

• For mechanical energy - Allow mechanical energy, such as that in springs, elevated machine members or rotating flywheels to dissipate or restrain it by methods, such as repositioning or blocking.

• For thermal, chemical, flammable, pneumatic, hydraulic where such energy is contained in lines or pipes - Close valves, disconnect lines, or install isolating "blanks".

5. Application of Lockout/Tagout Device

Place assigned lock on disconnect switch, valve or other locking device.

• Each person shall place his/her lock on the locking device. The use of a single lock is not permissible to represent more than one employee unless management has established procedures for such a situation and the procedure will provide "at least as effective" protection to all employees working on that particular equipment.

• If maintenance "crew" is conducting extensive equipment service or repair that will continue into the next shift, the crew will follow group lockout procedures.

o Supervisor will assume responsibility or assign responsibility for group lockout.

o The "responsible" individual will follow equipment lockout procedure and install group lockout device.

o Each employee performing equipment servicing will install personal lockout device and remove personal lock when completing work. (This includes "responsible" individual installing group lock.)

o The group lock will remain on equipment throughout repair and the “responsible” individual is the only person who can remove it.

• Employees may not use tags unless a specific job procedure that demonstrates their necessity and correct use is in place and the tags are "at least as effective" as a lock. (The Safety Manager must approve the procedure.)

6. Release of Stored Energy

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It is mandatory to release, disconnect, restrain, or otherwise make safe all potentially hazardous stored or residual energy. If servicing of hazardous chemical transfer lines occurs, you shall flush the lines, according to County (or manufacturer’s) procedures.

7. "Test Start"

After you ensure that personnel have no exposure, and as a check on having disconnected the energy sources, operate the push button or other normal operating controls to make certain the equipment will not operate.

Specific Lockout Procedures

If equipment meets one of the following criteria, follow the specific lockout procedures for that type of equipment:

• Has more than one energy source

• Requires more than one lockout device

• Requires multiple lockout boxes

• Has had a previous unexpected energizing accident

• Requires tags rather than locks

Restoring Locked Equipment 1. Notify personnel in startup area

2. Clear all tools and repair equipment

3. Remove locking devices

4. Restore all isolating devices

5. Notify operating personnel of operation status

Emergency Removal of Lock Other than By Installer 1. Attempt to reach person who installed lock to determine equipment status.

2. Notify security.

3. Security supervisor and maintenance supervisor will inspect equipment that requires starting.

o Review work order

o Repair completed

o Guards installed

o Tools cleared from machinery

4. Notify personnel in area of startup and follow unlocking procedures.

Inspections/Enforcement 1. Inspections will take place annually and records maintained. Safety Manager will be responsible to

complete and record inspection.

2. If inspections reveal improper or lack of lockout/tagout procedures, affected employees will attend retraining.

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3. Supervisors will conduct daily inspections for compliance of lockout procedures and employees will receive discipline if they fail to lockout properly.

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Ground-Fault Circuit Interrupter

The ground-fault circuit interrupter (GFCI) is a fast-acting circuit breaker. It senses small imbalances in the circuit caused that current leakage to the ground creates and, in a fraction of a second, shuts off the electricity. The GFCI continually matches the amount of current going to an electrical device against the amount of current returning from the device along the electrical path. Whenever the amount “going” differs from the amount “returning” by approximately 5 milliamps, the GFCI interrupts the electric power within as little as 1/40 of a second.

Employer’s Responsibility

OSHA has developed ground-fault protection rules and regulations that are necessary and appropriate for employee safety and health. According to OSHA, an employer is responsible for providing either:

1. Ground-fault circuit interrupters on construction sites for receptacle outlets in use and not part of the permanent wiring of the building or structure; or

2. A scheduled and documented program for equipment grounding conductor at construction sites. The program should cover all cord sets and all receptacles that are not part of the structure’s permanent wiring. It should also cover any equipment connected by cord and plug that are available for use or in use by employees.

Insulation and Grounding

Insulation and grounding are two recognized means of preventing injury during electrical equipment operation. Conductor insulation usually takes the form of non-conductive material such as plastic around the conductor. Grounding is attainable by a direct connection to a known ground such as a metal cold water pipe.

The enclosure around a motor or the metal box that contains electrical switches, circuit breakers, and controls should protect the equipment from dirt and moisture. In addition, such housings also prevent

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accidental contact with exposed wiring. However, there is a hazard associated with housings and enclosures. An internal equipment malfunction, such as deteriorated insulation, may create an electrical shock hazard.

To eliminate the hazard, many metal enclosures are connected to a ground. If a “hot” wire contacts a grounded enclosure, the resulting ground fault will normally trip a circuit breaker or blow a fuse. The usual method of grounding metal enclosures and containers is to connect them with an equipment grounding conductor, to a ground. The same method is in use for most portable electric tools and appliances. There is one disadvantage to grounding. A break in the grounding system may occur without the user’s knowledge.

Hard use on the job or age may damage insulation. If the damage exposes the conductors, hazards of shocks, burns and fire will exist. Double insulation may afford additional protection on the live parts of a tool. However, it does not protect against defective cords and plugs or against heavy moisture conditions.

The use of a ground-fault circuit interrupter (GFCI) is one method to overcome grounding and insulation deficiencies.

There are two classes of GFCIs - Class A and Class B.

The Class A GFCI trips at not more than 5 mA. The Class A GFCI is used where personal protection against ground fault is required or desired.

The Class B GFCI trips when the current exceeds 20 mA. The latter is only used with swimming pool underwater lighting fixtures that were installed prior to local adoption of the 1965 edition of the NEC.

Portable Tool Hazards

The common use of portable tools frequently increases the need for flexible cords. Improperly using and maintaining the following can create hazards: cords, cord connectors, receptacles as well as cord and plug connected equipment.

Generally, flexible cords are more vulnerable to damage than fixed wiring because they are exposed, flexible, and unsecured. In addition, flexible cord conductors have fine strands for flexibility. As a result, the strands of one conductor may loosen from under terminal screws and touch another conductor, especially if the cord is subject to stress or strain. It is very important to connect flexible cords to devices and fittings in a manner that prevents tension at joints and terminal screws.

Normal use, door or window edges, staples, or fastenings, abrasion from adjacent material or aging may damage a flexible cord. Exposed electrical conductors pose a danger of shocks, burns, or fire.

A wet cord connector can cause hazardous leakage to the equipment-grounding conductor. The leakage can also harm individuals who pick up that connector if they also provide a path to ground. Such leakage is not limited to the face of the connector but also develops at any wet portion of it.

If the leakage current of tools is below 1 ampere and the ground conductor has a low resistance, a person should feel no shock. However, an increase in the resistance of the equipment-grounding conductor also causes an increase in the current through the body. If the resistance of the equipment ground conductor is significantly greater than 1 ohm, tools with even a small leakage become hazardous.

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Compressed Gas Cylinder Safety

General Description

According to OSHA’s Hazard Communication Standard, Compressed Gas" means:

(i) A gas or mixture of gases having, in a container, an absolute pressure exceeding 40 psi at 70 deg. F (21.1 deg. C); or

(ii) A gas or mixture of gases having, in a container, an absolute pressure exceeding 104 psi at 130 deg. F (54.4 deg. C) regardless of the pressure at 70 deg. F (21.1 deg. C); or

(iii) A liquid having a vapor pressure exceeding 40 psi at 100 deg. F (37.8 deg. C) as determined by ASTM D-323-72.

Compressed gases can be toxic, flammable, oxidizing, corrosive, or inert. In the event of a leak, inert gases can quickly displace air in a large area creating an oxygen-deficient atmosphere, toxic gases can create poison atmospheres, and flammable or reactive gases can result in fire and exploding cylinders. In addition, there are hazards from the pressure of the gas and the physical weight of the cylinder. A gas cylinder falling over can break containers and crush feet. The cylinder can itself become a missile if the cylinder valve is broken off.

General Cylinder Safety • Accept only properly identified cylinders; do not rely on color codes.

• Wear safety equipment appropriate for the hazard potential of the gas before beginning work.

• If a cylinder or valve has noticeable corrosion, contact the vendor for instructions.

• Remove and isolate a leaking cylinder in a well-ventilated safe area. It may be necessary to call in trained emergency response personnel.

• If the leak is at the junction of the cylinder valve and cylinder do try to repair it! Instead, contact the supplier.

Cylinder Use and Storage

Leave cap on and valve closed when cylinder is not in use. Store cylinders upright Use regulators only for the type of gas for which the manufacturer designed them. Never interchange them or force regulator connection fittings. Never drag, slide, or roll the cylinder; never transport with the regulator in place; and secure the cylinder to a suitable hand truck or cart during transport. Properly secure cylinders in a well-ventilated and protected area away from heat, flames, and the sun. Segregate cylinders by hazard classes while in storage. Discontinue use of the cylinder when it has at least 25 psi remaining; close valve to prevent air and moisture from entering. Return unused and empty cylinders to the vendor for reuse or refill. Mark or tag empty cylinders "EMPTY" or "MT." Separate empty and full cylinders during storage.

Never – • Purchase more or larger cylinders than necessary;

• Store flammable gases next to an exit or near oxygen cylinders;

• Use copper fittings or tubing on acetylene tanks;

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• Use Teflon® tape on cylinder or tube fitting connections that have metal-to-metal face seals or gasket seals;

• Permit oil or grease to contact cylinders or their valves, especially cylinders that contain oxidizing gases.

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Sample Compressed Gas Cylinder Safety Policy

This is an example of a compressed gas safety policy for clients whose operations include welding.

Purpose

To establish the requirements for the safe handling and storage of compressed gas cylinders.

Reference

OHSA 29 CFR 1910.253 Compressed Gas Safety: General Safety Guidelines

Scope

This policy covers all (County’s name) employees, contractors, vendors, and visitors that handle and store compressed gas cylinders.

Responsibilities

(Names or titles of individuals) are responsible for administering this policy.

• Safety Coordinators

o Prepare and maintain the County’s compressed program for gas cylinder safety.

• Department Heads:

o Coordinate the development and implementation of training programs for initial and refresher training.

• Supervisors:

o Know the County’s requirements of the program for compressed gas cylinder safety.

o Ensure that employees in their area(s) of concern participate in training programs related to the compressed gas cylinder safety.

o Ensure that employees follow appropriate compressed gas cylinder-related work practices.

• Contractors:

o While working on County property, contractors shall comply with all Federal OSHA standards, as they pertain to compressed gas safety.

o The Project Engineer or other County representative bringing the contractor onto County property is primarily responsible for assuring that contractors are meeting these criteria.

General

Compressed gases present unique hazards. Depending on the particular gas, there is a potential for simultaneous exposure to both mechanical and chemical hazards. Gases may be:

• Flammable or combustible

• Explosive

• Corrosive

• Poisonous

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• A combination of hazards

The pressure in a compressed gas cylinder can cause the cylinder to become airborne if the valve stem sustains damage.

Identification

You must clearly identify the contents of any compressed gas cylinder. Stamp or stencil the identification on the cylinder itself. Report any compressed gas cylinders without labels and whose contents you cannot identify to (Name or person or position title) immediately.

• Never use the color of the cylinder to identify its contents because the cylinder colors may vary from supplier to supplier.

• Post “NO SMOKING” signs shall in areas where you store flammable compressed gases.”

Inspection

Each employee shall perform a visual inspection of the cylinder before use. Work areas shall perform periodic inspections to ensure that compressed gas cylinders under their control are in a safe condition.

Handling & Use

Comply with the following rules for using and handling compressed gas cylinders all times:

• Secure gas cylinders at all times to prevent tipping.

• You may attach cylinders to bench top, individually to a wall, or in a holding cage.

• Use chains or sturdy straps to secure the cylinder.

• If you discover a leaking cylinder, report it to (Name or position title) immediately.

• Never attempt to repair a cylinder or valve.

• Place cylinders so that the valve accessible at all times.

• Close cylinder valves whenever you are using or when you leave them unattended.

• Make sure the valve handles remain on the valve stem at all times when you are using a cylinder.

• Open cylinder valves slowly. You should open oxygen cylinders completely as they have a back-seating valve.

• When you open the valve on a cylinder, you should position the cylinder with valve pointing away from yourself and others nearby

• Remove the regulator and cap the cylinder when it is empty.

• Always use PPE for the task or material you are working with when handling compressed gas cylinders.

Storage

Always comply with the following rules for storing compressed gas cylinders:

• Empty and full cylinders should be stored in separate areas.

• Never store cylinders containing flammable gases such as hydrogen or near to open flames, areas where tasks produce electrical sparks, or where other sources of ignition might be present.

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• Never store compressed gas cylinders next to elevators, stairwells, or in aisles/walkways.

• Never store oxygen cylinders, full or empty, near flammable gases (including acetylene). To store oxygen cylinders properly, you need a minimum of 20 feet between flammable gas cylinders or you need to separate the areas -- at a minimum -- by a firewall 5 feet high with a fire rating of 0.5 hours.

• Never keep greasy and oily materials around oxygen cylinders and never oil or grease cylinder fittings.

• Never store acetylene cylinders on their side

Transporting

Always obey the following rules for transporting compressed gas cylinder:

• Handle only one cylinder at a time.

• Never subject cylinders to rough handling or abuse.

• Make sure the cylinder caps are in place to protect the valve assembly

• Never roll or drag cylinders.

• Always strap or chain cylinders properly to designed carts or trucks.

Training

The County shall provide training to all employees whose job responsibility requires them to handle compressed gas cylinders initially upon assignment and refresher training annually thereafter. The training shall include:

• Cylinder Identification

• Cylinder Inspection

• Cylinder Handling and Use

• Cylinder Storage

• Cylinder Transportation

Revisions

(Name or position title) has accountability for reviewing and revising the program annually.

See Compressed Gas Cylinders Quick Quiz in appendix

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Housekeeping Practices

Overview

Good housekeeping is essential to fire safety for each type of occupancy from the simplest dwelling to the most sophisticated municipal complex. Housekeeping is the maintenance of an orderly, clean, and neat work place. Good housekeeping practices, both indoors and outdoors, reduce the danger of fire. They can control the presence of unwanted fuels, obstructions, and sources of ignition that can create extremely hazardous exposures to both life and property.

It is not practical or possible to discuss every aspect of good housekeeping. Some aspects of housekeeping are common to practically all occupancies; others are peculiar to a particular occupancy and require special procedures. Although a cliché, the statement “a place for everything and everything in its place” captures the best approach to assuring good housekeeping practices.

Principles of Good Housekeeping

Housekeeping consists of the simpler aspects of building care and maintenance:

1. Maintaining operational tidiness and order,

2. Properly controlling waste, and

3. Regulating activities, such as smoking that can lead to hazardous conditions.

To be successful, housekeeping requires organization and continuous monitoring.

Responsibility for Housekeeping

No matter what the area of operation, work activity creates waste materials and obstructions to orderly movement throughout the premises. It is essential that every organization have a system for removing them. It is not enough to be aware that waste accumulates and obstructions to movement can occur and then remove them when they become unwieldy or a nuisance. Developing a systematic approach is the only way to make sure that housekeeping activities achieve their goal: an orderly work place that contributes to fire safety.

A disciplined approach to prescribed housekeeping practice is essential so that workers remove debris as well as trash regularly and store materials and equipment neatly. The same is true for routine building maintenance chores. Without a systematic approach, workers may neglect the chores and property can suffer. This may also indicate that the organization is neglecting the routines for maintaining fire defenses.

In a large organization, management usually assigns housekeeping to a maintenance staff charged with the routines involved in housekeeping and maintenance. Direction for the overall effort, however, remains with management. Management communicates how important and urgent good housekeeping routines are if efforts are to be effective. Without direct and vigorous management support, housekeeping goals and objectives can become a low priority.

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In a smaller organization without a maintenance staff, good housekeeping is more an individual effort. Yet the principles are the same: Management must lead workers and convey to them how important vigorous and systematic attention to the tenets of orderliness and cleanliness is.

Basics of Good Housekeeping

Except for the somewhat specialized activities of basic building maintenance, there are three factors required for good housekeeping:

1. Adequate space, proper layout, and equipment

2. Correct materials handling and storage

3. Cleanliness and orderliness

Good housekeeping is certain to result when the organization pays proper attention to establishing routines for these three factors.

Layout and Equipment

An adequately designed work area has adequate working space, adequate and proper storage facilities, and the right equipment for moving material. Otherwise good housekeeping falters as the work area becomes clogged, materials back up waiting for processing, and the messy surroundings result in a decline of overall cleanliness. A careful review of space requirements for the actual operations being carried on may suggest ways to rearrange the space. A better-arranged space can improve the levels of housekeeping considerably.

Materials Handling and Storage

The lack of adequate equipment to move and to arrange materials in convenient storage areas results in haphazard storage. This compounds the housekeeping problem. It can easily result in blocked exit paths and obstruct access to fire extinguishers, small hose stations, and automatic extinguishing system control valves. Other fire protection equipment, such as fire doors, can become inoperable. Poorly organized storage may result in the collection of debris and trash in neglected corners and cul-de-sacs.

Cleanliness and Orderliness

No matter what the occupancy, an organization can immeasurably improve the level of fire safety by paying attention to the fundamental need to keep all areas as clean and neat as possible. The most important defense against unsightly and dangerous accumulations of unwanted materials and trash is each individual’s personal sense of responsibility and desire to keep the surroundings neat and clean. Management must support workers by providing efficient and timely waste removal programs.

Housekeeping Hazards

Many occupancies pose special housekeeping problems because of their operations. Specific planning and arrangements are necessary to address these.

Drip pans are essential for many operations. In particular, workers must place pans under some motors, under machines that use cutting oils, or bearings, and under work that involves borings and turnings that may contain oil. Pans should be of non-combustible material. Workers can best handle spills and drips by using oil-absorbing compounds that consist primarily of diatomaceous earth. These compounds are

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commercially available and are preferable to sawdust or sand. Regular removal of oil soaked material is essential.

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Housekeeping & Material Storage

Purpose

This document is general in nature and we do not intend it to cover all specific housekeeping requirements.

Attention to general cleanliness, storage and housekeeping can prevent numerous accidents. In addition, good housekeeping efforts are a part of the County fire prevention and accident prevention program.

Management and Employee Responsibility

All Employees share the responsibility for maintaining good housekeeping practice and following the established housekeeping procedures. The Manager, Supervisors, Safety Coordinator and Safety Committee will be responsible to monitor housekeeping as part of their facility safety inspection procedures, note any hazards or areas of non-compliance, initiate clean-up procedures and provide follow-up. Management has the additional responsibility to provide disciplinary action when necessary to reinforce compliance with this program.

Smoking Policy

We do not permit smoking inside buildings and/or within 50 feet of the building and/or material storage. This includes all offices, hallways, rest rooms, locker rooms, production floor, storage areas, coolers, etc.

Hazards

Improper housekeeping and material storage can create or hide numerous hazards such as:

• Slip & trip hazards

• Chemical exposure

• Contact with sharp objects

• Fire & Explosion hazards

• Over loading of storage shelves and bins

Hazard Control

Offices

Keep office areas neat and orderly. The following general rules apply to prevent injuries and maintain a professional appearance.

1. Keep all aisles, emergency exits, fire extinguishers, etc., clear (a minimum of three feet of either side) of material storage (temporary and permanent) at all times.

2. Maintain storage areas in an orderly manner at all times. When you receive supplies, store them properly.

3. Clean up spills immediately and dispose of wastes of properly.

4. Line all waste receptacles with a plastic trash bag to avoid direct contact while handling. Custodial Employees will use rubber gloves and compaction bar when handling wastes.

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5. Keep file and desk drawers closed when not attended to avoid injuries. Open only one drawer at a time to prevent tipping of file cabinets.

6. At the end of the business day, turn off all office equipment (area heaters, lamps, coffeemaker, PCs, etc.) and lights to save energy and prevent fires. Unplug all space heaters at the end of the day to assure they have been turned-off.

Production Areas –

Keep production areas neat and orderly during operations and as follows:

1. Keep all aisles, emergency exits, fire extinguishers, eye wash stations, etc., clear (a minimum of three feet in front of and to either side) of product storage, material storage, fork trucks and pallet jacks at all times.

2. Clean up spills immediately.

3. Report all process leaks to supervision and maintenance for immediate repair and clean up.

4. Utility Employees will be responsible to keep aisles and work floors clear of excessive debris and waste materials during shift operation, between breaks and at shift change when necessary or directed by supervision. However, all employees are responsible to communicate slippery floors to supervision for immediate clean up.

5. Place all refuse and waste materials in the waste containers for disposal.

Rest Rooms, Locker Rooms and Cafeteria

We provide rest rooms, locker rooms and the lunchroom as a convenience for all Employees. The following rules will apply:

1. Employees shall clean up after themselves as a common courtesy to fellow employees.

2. Employees may not store flammable materials (fire works, explosives, gasoline, etc.) or bring them on County property.

3. Personal food item will not be stored in lockers or the lunchroom overnight.

4. Line all waste receptacles with a plastic trash bag to avoid direct contact while handling and Custodial Employees will use rubber gloves and compaction bar when handling wastes.

5. Place all refuse and waste materials in waste containers for disposal.

Maintenance Areas

1. All aisles, emergency exits, fire extinguishers, etc., will be kept clear (a minimum of three feet of either side) of material storage (temporary and permanent) at all times.

2. Maintain storage areas in an orderly manner at all times:

• Store pipe stock horizontally on racks and sorted by size

• Store metal stock on racks and sort them by size

• Store sheet metal stock vertically in racks and sorted the sheets type

• Store all fittings, etc. in bins on shelves and sort them by type and use

• Store all flammables in OSHA-approved fire cabinets and self-closing cans when necessary.

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• Clean up spills immediately if you have made the spill and dispose of wastes properly.

• Place all refuse and waste materials the waste containers for disposal.

Grounds

The grounds surrounding the plant are an extension of the work place. Grounds that are kept neat and orderly show pride by the County for Employees, customers and neighbors to enjoy.

The following general rules will apply:

1. Discard all trash in the waste containers provided.

2. Park in the designated assigned area only

3. The Maintenance Department will be responsible for grounds keeping (mowing, trimming, etc.) as needed. Maintenance will also establish procedures for ice/snow removal, when necessary, prior to operations each day.

Materials Storage

Proper storage procedures are necessary for dry, raw materials, finished product flammables and compressed gases storage to prevent fires, keep exits and aisles clear and avoid injuries and illnesses.

General rules for material storage are as follows:

Materials and Finished Products Storage

1. Do not store materials any closer than 18 inches to walls or sprinkler heads. Maintain a minimum of three feet side clearance around doorways and emergency exits. Properly mark passageways and aisles and maintain a minimum of six feet in width. Do not store materials, forklifts, pallet jacks, etc., in aisles or passageways.

2. Keep aisles and passageways clear of debris. The person responsible will clean up all spills of materials immediately.

3. Ensure that all platforms and racks have maximum load capacity displayed. The weight of stored material will not exceed the rated load capacity.

Flammable Storage

1. Store all flammables in OSHA-approved flammable storage cabinets or stored outside (at least 50 feet from any structure)

2. Fuels, solvents and other flammables (not stored in original shipping containers) will be stored in OSHA-approved self-closing containers with flame arresters. Flammables may not be stored in open containers (open parts baths, etc.).

3. Keep flammable storage areas dry and well ventilated. Never store combustible materials or have open flames or exposed electrical components in the flammable storage area.

4. Never store flammable or combustible materials in electrical rooms. Keep any electrical rooms clean and dry at all times.

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Compressed Gas Safety

Gas Cylinder Shipment Receiving

• Inspect bottle for defects & proper marking/labels

• Ensure stamped date on bottle has not expired

• Inspect valve assembly and adapter thread area

• Ensure MSDS is on file or with shipment

• Follow MSDS requirements for storage

Gas Cylinder Storage

• Secure cylinder cap in place when not in use.

• Marked with contents and if empty/full.

• Store cylinders upright and secured to a stationary structure in a shaded and well ventilated area.

• Do not store cylinders within 50 feet of exposed electrical components or combustible materials.

• Protect cylinders from accidental rupture.

• Do not store chemically reactive gases within 50 feet of each other.

Gas Cylinder Movement

• Must be secured to a cart or cylinder trolley

• Cap securely fastened

Gas Cylinder Usage

• Inspect valve adapter threads.

• Inspect all fasteners, hoses & regulators prior to hooking up to cylinder.

• Use only for approved purposes.

• Use in up-right position.

• Fasten cylinder to structure or cart.

• Regulators must be of same rated pressure as cylinder

• Keep cylinder valve shut when not in use; don't depend on regulators

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Ladder Safety Program

Purpose

The purpose of this safety policy and procedure is to establish guidelines for the safe use of ladders throughout (County Name)by employees, contractors and visitors. Ladders are used when employees need to move up or down between two different levels. Slips, trips, and falls are significant contributors to (County Name)’s accidents. Slips, trips, and falls can occur when employees select the wrong ladder, use improper climbing techniques, or use defective ladders are used.

At (County Name), we expect employees to use the appropriate ladder for the task they are performing and to inspect ladders so they do not use a defective one. When hazards exist that we cannot eliminate, we will implemented engineering practices, administrative practices, safe work practices, Personal Protective Equipment (PPE), and proper training regarding ladders. These measures should help to minimize those hazards to ensure the safety of employees and the public.

Reference

This safety policy and procedure is established in accordance with Occupational Safety and Health Standards for General Industry (29 CFR 1910.25-27) and Occupational Safety and Health Standards for the Construction Industry (29 CFR 1926.1053).

Responsibilities

Managers: Managers are responsible for ensuring that adequate funds are available and budgeted for the purchase of ladders in their areas. Managers will obtain and coordinate the required training for the affected employees. Managers will also ensure compliance with this safety policy and procedure through their auditing process.

Supervisors: Supervisors are responsible for ensuring that their department regularly inspects and properly maintains all ladders (fixed and portable). They are also be responsible for tagging ladders in need of repair and removing defected ladders from service for repair or destruction. Supervisors will audit for compliance with this safety policy and procedure during their facility and jobsite audits.

Employees: Employees shall comply with all applicable guidelines contained in this safety policy and procedure. Employees are also responsible for reporting immediately suspected unsafe conditions or ladders to their supervisor. Employees shall inspect ladders before using them and keep ladders clean and in good condition.

Safety: Safety will provide prompt assistance to managers, supervisors or others as applicable on any matter concerning this safety policy and procedure. Additionally, Safety will assist in developing or securing required training. Safety will provide consultative and audit assistance to ensure effective implementation of this safety policy and procedure. Safety will also work with Purchasing Department to ensure that all newly purchased ladders comply with this safety policy and procedure and current safety regulations.

Training: Ladder safety training shall take place upon initial employment and/or job assignment. Supervisors shall provide refresher training to employees whenever an accident occurs that involves ladders and at their discretion. Employees using the ladders shall receiving training in:

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• The proper use of the ladders

• The types of ladders and their purposes

• How to set up ladders

• Ladder inspection

• Proper maintenance

Ladder Hazards

There are inherent hazards associated with ladder use. Typical ladder hazards include:

• Insufficient surface resistance on ladder rungs and steps

• Ladder structural failure

• Ladders tipping sideways, backwards, or slipping out at the bottom

• Ladder spreaders not fully opened and locked, causing the ladder to “walk”, twist or close up when a load is applied to the ladder

• Using metal ladders around electricity

• Using deteriorated ladders

• Using fixed ladders without cages or fall protection

Safe Ladder Use

Employees should follow certain rules when placing, ascending, and descending ladders. These include:

• Inspect ladder for defects before using.

• Never use a defective ladder. Report the defective ladder to your supervisor who will tag it and arrange for its repair.

• Hold on with both hands when going up or down the ladder. If you must handle material, raise or lower it with a rope before going down or after climbing to the desired level.

• Always face the ladder when ascending or descending.

• Never slide down a ladder.

• Be sure shoes are not greasy, muddy, or slippery before climbing.

• Do not climb higher than the third rung from the top on straight or extension ladders, or the second tread from the top on stepladders.

• Carry tools on a tool belt not in the hand.

• Never lean too far to the sides. Keep your belt buckle within the side rails.

• Use a 4 to 1 ratio when leaning a single or extension ladder. (i.e., place a 12-foot ladder so that the bottom is 3 feet away from the object the ladder is leaning against.)

• Never splice or lash a short ladder together.

• Never use makeshift ladders, such as cleats fastened across a single rail.

• Be sure that a stepladder is fully open and the metal spreader locked before starting to climb.

• Keep ladders clean and free from dirt and grease.

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• Never use ladders during a strong wind except in an emergency. Make sure you fasten the ladder securely to a stable structure.

• Never leave ladders that you placed unattended.

• Never use ladders as guys, braces, or skids, or for any other purpose other than their intended purposes.

• Never attempt to adjust a ladder while a user is standing on the ladder.

• Never jump from a ladder. Always dismount from the bottom rung.

Ladder Safety Devices

Safety devices are available for both portable and fixed ladders to prevent a climber from falling. Safety devices for portable ladders include slip-resistant bases, safety tops, and any other device to increase the ladder stability. Employees shall securely fasten ladders at the bottom and the top if it is at a location where work activities may result in its being tipped over. Safety devices for fixed ladders include cages, which enclose the stairwell, or a restraint belt attached to a sliding fixture anchored to the ladder.

Ladder Inspection

Supervisors should establish an inspection program in which inspections take place every three months. The supervisor shall arrange for the removal of ladders that are weak, improperly repaired, damaged, have missing rungs, or appear unsafe from the job or site for repair or disposal. Before discarding a wood ladder, cut it up so no one can use it again. Additionally, maintain and frequently inspect portable ladder. Tag any ladders that have developed defects with DANGEROUS--DO NOT USE, and remove from service for repair or disposal.

For portable wood ladders, all wood parts shall be free from sharp edges and splinters, sound and free of decay, shaking, compression failures, or other irregularities. For portable metal ladders, the design shall be without structural defects or accident hazards such as sharp edges, burrs, etc. The selected metal shall be of sufficient strength to meet the test requirements and shall be protected against corrosion. For fixed ladders, all wood parts shall meet the criteria of wood ladders. All metal parts shall meet the criteria of metal ladders.

Maintenance

Paint a coating of water-repellent preservative on portable wood ladders to provide a suitable protective material. Metal ladders and metal parts on wood ladders should be corrosion-resistant and kept free from nicks. If nicks occur, always treat them promptly to prevent possible metal fatigue due to rust.

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Ladder Inspection and Repair Guide

An unsafe ladder is a hazard to the user and can be the cause of a serious or even deadly accident. Ladder users frequently take ladder safety for granted. Unless users take specific steps to ensure the safety of the equipment, a damaged, misused, or worn-out ladder could be the cause of serious accidents.

Worker Morale - Employees who have with safe and functional equipment available to them have a better attitude toward their work than those who are required to work with damaged or otherwise unsafe equipment.

Worker Efficiency - A damaged or worn-out ladder left in service will frequently be the cause of lost working time. (Work time is lost because the worker will need to work slower and more cautiously with the damaged ladder, the worker will be unable to complete the job due to an unusable ladder, or the worker will simply need to take time to acquire another ladder.)

Factors That Make Ladders Unsafe: • Missing components, such as the treads, shoes, truss-blocks under steps, braces, and especially labels

can make a ladder unsafe.

• Damaged parts weaken the ladder structure.

• Showing signs of wear and tear (Like all mechanical devices, ladders wear out with use.)

• Ladders with alterations or ladders that users have modified may weaken the ladder structure and cause failure.

• Improper storage can cause ladders to bow, weather check, rot, melt, char, corrode, and otherwise deteriorate causing them to be unsafe.

• Improper handling can damage ladders and ladder parts -- for example, dropped ladders, ladders that have tipped over, that have been “walked”, thrown, skidded, shoved

• Horseplay, trickery, sabotage, and malicious destruction can damage ladders.

• The leading cause of unsafe ladders is NORMAL WEAR. (Ladders that have never been abused or misused will still wear out.)

See Ladder Inspection Checklist in appendix.

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Fall Prevention

The Problem

Work place falls injure or kill thousands of people annually. For every serious injury, employees lose an average of 31 workdays. These injuries result in costly claims, lost work time, lower productivity, and hidden costs (including increased administrative costs that result from addressing the problem).

A number of variables can contribute to the frequency and severity of slips, trips and falls. These include slippery or deteriorated walking surfaces, improper construction and poor design of walking surfaces, and human factors. Some variables are more controllable than other variables.

Solutions

It is unlikely that you can eliminate slips, trips, and falls entirely. However, there are steps you can take to reduce the number of incidents as well as the severity of the injuries that do occur.

Consider walking surfaces when remodeling or during new construction. Avoid terrazzo, glazed ceramic tile, marble, and granite. These building materials can be especially slippery when wet. Consult with an architect who is familiar with the coefficient of friction of walking surfaces.

Review the walking surfaces of buildings. Replace slippery surfaces when possible and take steps to reduce slipperiness if replacement is not feasible. You can measure the coefficient of friction on any walking surface to determine its potential for hazards.

If replacement is not possible, maintain the area in a manner that will reduce the hazard. A good source of information is a reputable building maintenance supplier. With the proper equipment, materials, maintenance, and employee training, you can significantly reduce the potential for slips, trips, and falls.

Identify and correct significant differentials in surface continuity. Falls frequently occur when two significantly different walking surfaces require people to change their gait and stride abruptly. Examples are (1) the change in surface from a ramp onto a regular walking surface, (2) the change from a parking lot to bumper stops, (3) the change from a street to a curb, and (4) broken pavement. Eliminate or reduce differentials as much as possible or post signs to warn people of the potential hazard.

Identify and correct significant differences in height. As little as 1/4’’ differential can cause a trip and fall. Carpet to tile, tile to carpet, different levels of carpet, defects in construction or deterioration all contribute to this variable. Eliminate or reduce differentials when possible.

Reduce fall hazards by installing the proper protective equipment to protect your employees’ safety. Ladders that exceed 4’ in length must have fall protection. Stairways should have adequate railings, proper riser and tread depth, and proper tread friction to eliminate or reduce slips and falls. Some organizations install aluminum tread edges on their stairways.

Implement regular inspections to identify and correct defects, deterioration and other slip, trip, and fall hazards. Practice good housekeeping. Conduct regular, documented self-inspections. Instruct employees to clean their work area and not to leave tools, cords and other hazards lying on the floor. Once you identify a hazard, either correct it immediately or post warning signs and a barricade to reduce the possibility of injuries.

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Conduct a thorough investigation of all reported slips, trips, and falls. Investigations are usually the responsibility of the supervisor. The purpose of the investigation is to determine the cause of the accident and to develop possible solutions. Once the cause is determined, you should remedy it immediately to prevent another incident.

Develop a planned maintenance program. Determine your maintenance needs for cleaning and providing safe walking surfaces. Make sure that you inspect and clear outdoor surfaces frequently, especially during colder months. You should monitor areas where water frequently collects, such as entryways in inclement weather and drinking fountains.

Provide other means to reduce the potential for loss. Review the need for mats or runners, install adequate lighting, and install gutters to deflect water run-off.

Review causes of slips, trips, and falls with employees. Make employees aware of what contributes to the problem. Identify any special procedures or areas that need special attention. Focus on mutual goals rather than assigning blame. Review techniques to reduce slips, trips, and falls with employees whose positions do not allow for discretion in walking surfaces. For example, police officers frequently slip and fall during the capture of an assailant. A meter reader who must enter a structure to read a meter may not be able to avoid the typical hazards that are normally controllable in a publicly owned building.

Do not forget to reduce the hazards in vehicles and equipment. Install anti-slip coatings or tape on the steps of vehicles and equipment. Make sure dump trucks have securely attached steps and handles welded to the dump box body.

Review the type of footwear that employees are wearing. Some communities buy or contribute to the cost of footwear for their employees. Make the right choice for the employee based on indoor or outdoor weather, the type of work or activities, the type and conditions of walking surfaces, and comfort. Discuss the possibility of reducing the hazard with a footwear specialist. Include the employees in this decision process. Consider this item’s impact on the potential for reducing back injuries.

Conclusion

The above recommendations may appear to have little or no effect on your ability to control slips, trips, and falls. However, acting on even a few of them can contribute significantly to a reduction of your exposure to slip, trip, and fall accidents. The reduction can benefit you in decreased claims and associated costs, a reduced number of lost workdays, and increased productivity.

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Fall Prevention and Control

Architectural and human factors play an important role when people fall. It is important to understand these factors in order to develop and implement an effective risk reduction program.

Problem Overview

Customers and employees alike fall down and sustain injuries. Some injuries are disabling and very costly in claims dollars, public relations, lost work or productivity, etc. As is the case with the majority of accidents, most slip, trip and fall accidents are preventable. Although it is obvious that accidents due to falls are a problem, few people recognize its magnitude.

Definitions

A "fall" is the interruption of the human locomotion process. A fall occurs when a person is unable to regain his or her balance and erect posture after slipping or tripping. The terms "slip and fall" and "trip and fall” refer to this process or occurrence. Generally, a "slip and fall" occurs when a person loses his or balance because there is insufficient friction between the forward moving heel and the surface on which the person is walking. A "trip and fall" occurs when a person loses his or her balance because the forward motion of the non-weight supporting foot hits an obstacle in the walkway. Usually, people slip and trip without falling. Only a small percentage of slips and/or trips result in falls.

There are three categories of falls:

1. Falls on level areas

2. Falls on ramps and stairs

3. Falls from elevations

This discussion only covers falls on level areas and falls on ramps and stairs that occur in buildings or on sidewalks.

Architectural Elements

Slippery walking surfaces (inadequate friction) and defects, such as raised edges, cracks, gaps and holes (surface continuity) are the two most common contributing factors in fall accidents.

When people walk, the friction between the shoes they wear and the walking surface allows for forward motion. The National Bureau of Standards refers to this as "anti-slip coefficient friction." The lower the “anti-slip coefficient friction” is, the more slippery the surface is. The accurate measurement of the coefficient friction is extremely difficult. In addition, the friction measurement is dependent on the material of the heel and sole of the shoe when it is on the walking surface.

Research has shown that some friction is necessary to prevent a shoe from slipping. If the friction in the area between the shoe and walking surface is too low, a slip can occur. The slip may or may not result in a fall.

The occurrence of a fall is dependent upon the following factors: a person's age and physical condition and the level of the friction. For example, when people slip on ice, or other extremely slippery surfaces, they quickly scramble to regain their footing. However, they usually fall because the very low coefficient friction of the ice does not allow them to keep or regain their balance.

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Walking Surface Construction

The makeup of a walking surface construction material is an important element that determines walking surface friction and its hazard level. The following is a summary of the hazard levels of common construction materials:

High Hazard Level

High hazard materials include floor materials, such as terrazzo, glazed ceramic tile, marble and granite. These have a have a very low anti-slip coefficient of friction. When wet, these surfaces become extremely slippery. Unfortunately, these are common materials in high traffic areas, such as entryways and stairs.

Medium Hazard Level

These include wet or weathered wood, unglazed ceramic tile and vinyl tile. These usually have an adequate anti-slip coefficient of friction. However, they require precautions during maintenance. An excessively buffed surface becomes a high hazard and is unsuitable for pedestrian traffic areas. Although smooth, finished concrete is adequate when dry, it becomes very slippery when wet and is, therefore, a high hazard.

Slight Hazard Level

Many materials provide an adequate level of surface friction, even when wet. Such materials include rough-finished concrete, carpet, and dry, well-maintained wood.

When evaluating surface friction conditions, it is important to consider potential environmental changes. Snow, ice and rain significantly reduce the "anti-slip coefficient of friction" of walking surfaces. Low areas subjected to developing puddles will freeze and result in ice patches. Downspouts that discharge water across areas meant for walking may also create reduced surface friction and may result in icy walks during winter months.

Newly installed surfaces may provide adequate levels of surface friction, but they can deteriorate over time, depending upon usage. This is common with stairways where many people use the path of travel closest to the handrail.

Surface Continuity

Uneven surface continuity is the second most common contributing factor to fall accidents. A person unconsciously adjusts his or her stride to the "anticipated walking surface continuity." This adjustment normally occurs during the first few steps. Even the slightest change in surface continuity increases the chance of a fall. Cracks, holes, raised edges, gaps, debris, spalling, scaling or pitted surfaces, exceeding one-half inch in height, depth or width, are conditions that contribute to a lack of surface continuity. Other conditions are torn carpeting, doormats, raised door thresholds, loose boards and nails on boardwalks and docks, loose stair nosings, missing manhole covers, missing caps on utility valves, and other similar defects.

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Other Architectural Elements

Illumination

Inadequate illumination can contribute significantly to slips, trips, and falls. Sufficient natural or artificial illumination can reduce or eliminate this problem. Illumination should be at a level that allows pedestrians to see the walkway and any changes in it easily. Changes include stairs, ramps, turns, or other conditions. The normal recommended minimum level of illumination is at least one foot-candle measured at the walking surface. One foot-candle is enough illumination for a person with normal vision to be able to discern the contours of the walkway.

Stairways

Improper Construction and Design: Stairways are also a common source of falls. Research has shown that the vast majority of accidents on stairways result from improper construction, poor design and hazardous conditions. The most common accident on stairways is a fall while descending. The usual cause is a slip or misstep due to a defective design, or the existence of hazardous conditions on the stairway. The most common substandard defect is a stairway with low risers and long tread surfaces, or high risers and short tread surfaces. Hazardous conditions include slippery conditions, foreign objects on walkways, loose carpeting, and worn or polished metal nosings. These conditions are responsible for a large percentage of the accidents on stairways.

Steep Stairways: The rise angle of the stairway is important. There is a significant correlation between stairways that rise at angles of 39° to 40° or greater and falls resulting in serious injuries. Accidents occur for several reasons. First, a person may be unable to evaluate the angle or height properly and may misjudge the step. This causes him or her to stumble and fall. In part, the misjudgment may occur because of a "learned pattern.” The person has become accustomed to using properly designed stairs with a somewhat lower angle of rise.

Handrails: Another problem related to steep stairways is that the handrails are usually at the same slope as the stairs. The handrail, therefore, is not within the "lunge range" of a falling person. As the person falls, his or her outstretched hand is at a much higher plane than the handrails. Installing handrails that meet code requirements corrects this problem. Handrails can sometimes prevent stumbles, slips and trips from turning into falls and can reduce injury potential and severity by breaking some falls.

Riser Height: Probably the most important aspect of stair geometry is riser height (height of each step) and the tread depth. If a riser is too high, the foot tends to land too far out on the tread of the next lower step. Consequently, the ball of the foot to has little or no support from the tread surface. If the riser is too low, the foot lands so far back on the next lower tread that the heel of the opposite foot catches as the person lowers it to the next step. Both of these conditions can cause missteps resulting in falls. Correcting riser heights can contribute to a reduction in slips, trips, and falls. In addition, risers should be uniform in height and depth within a given stairway.

Tread depth is the actual depth from each step or riser. Adequate depth is necessary to provide safe support for the feet when climbing and descending stairs. Inadequate depth causes the ball of the foot to land in an open space or slip on the edge of the step. An overly deep tread may cause the heel of the foot

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in motion to catch the edge of the step. Steps that are either too narrow or too deep can also lead to falls.

Generally, riser heights should be between 6-1/2 inches to 7-3/4 inches. Tread depths should be between 9-1/2 inches to 10-1/2 inches, exclusive of any nosing or overhang. Various building codes and the Life Safety Code mandate step dimensions within this approximate range, depending upon the building's occupancy. Stairways with risers that are above and below these ranges pose a significant potential for a fall.

Human Factors

Walking is virtually an automatic series of body movements linking together a continuous series of steps. There is little, if any, conscious thought to the process. The brain processes information so quickly that most people can easily accommodate changes in surface continuity or obstacles in the way if they see or anticipate them. It is the unseen and the unanticipated change or obstacle that causes trips and/or loss of balance in falls. However, the type of surface a person is walking on as well as the individual’s age and physical condition can determine his or her gait and the likelihood of an accident.

When a person begins walking, the brain adjusts the gait and stride to accommodate "anticipated walking surface conditions." Sensory feedback from the feet, eyes, and so on defines the anticipated conditions. During the first few steps, the brain, after processing the sensory feedback, measures the friction of the walking surface relative to the person's shoes and any anticipated obstacles. The brain then sets the stride and gait to accommodate the anticipated walking conditions. When anticipated conditions change significantly, the potential for a fall greatly increases.

When walking from an area of adequate surface friction to one having less surface friction, such as from a clear sidewalk to an icy one, the foot will loses traction and rapidly slips from its intended position. The result is normally a fall. This type of incident occurs because of an unanticipated encounter with a very low friction-walking surface. If an individual begins walking on a continuous icy surface, the brain modifies a person’s gait and stride to accommodate this condition. The person is much more conscious of his or her walking in an attempt to deal with the unusual conditions. He or she takes deliberate, slower and shorter steps to reduce the necessary friction needed to walk forward.

The same situation occurs in a trip and fall incident. As a person begins to walk on a smooth surface, such as a public sidewalk, the brain sets his or her gait and stride for the surface conditions. If the person encounters an obstruction or changes in elevation in the walkway, an accident can occur. Changes in elevation of as little as a quarter-inch in height on a walkway can cause a trip or stumble. This is important to remember when evaluating the condition of sidewalks or other walking surfaces.

People can easily accommodate changes and obstacles on walkways if they see or anticipate them. The unseen and unanticipated changes cause trips and/or loss of balance resulting in falls.

The age and physical condition of individuals using walkways can also affect the probability of falls. Small children tend to shuffle their feet making them more apt to fall. However, the probability of a severe injury is small. Senior citizens, by contrast, tend to be more cautious when walking to compensate for the changes in the physical conditions that accompany aging. These changes include reduced eyesight, slower reflexes, a declining ability to regain balance, less muscle pliability, and more brittle bone. As a result, older adults are more likely to sustain severe injuries than children and young adults.

Safety Manual



Reducing Employee Slips, Trips, and Falls

Public agency employees often slip, trip, and fall and, as a result, sustain injuries. These injuries result in costly claims, lost work time, lower productivity, and hidden costs (including increased administrative costs that result from addressing the problem).

A number of variables can contribute to the frequency and severity of slips, trips, and falls. These include slippery or deteriorated walking surfaces, improper construction, and poor design of walking surfaces, and human factors. Some variables are more controllable than other variables.

Solutions

It is unlikely that you can eliminate slips, trips, and falls. However, there a number of steps you can take to reduce the number of incidents as well as the severity of the injuries that do occur.

Consider walking surfaces when remodeling or during new construction. Avoid terrazzo, glazed ceramic tile, marble, and granite. These building materials can be especially slippery when wet. Consult with an architect who is familiar with the coefficient of friction of walking surfaces.

Review the walking surfaces of municipal buildings. Replace slippery surfaces when possible and take steps to reduce slipperiness if replacement is not feasible. You can measure the coefficient of friction on any walking surface to determine its potential for hazards.

If replacement is not possible, maintain the area in a manner that will reduce the hazard. A good source of information is a reputable building maintenance supplier. With the proper equipment, materials, maintenance, and employee training, you can significantly reduce the potential for slips, trips, and falls.

Identify and correct significant differentials in surface continuity. Falls frequently occur when two significantly different walking surfaces require a person to abruptly change their gait and stride. Examples are (1) the change in surface from a ramp onto a regular walking surface, (2) the change from a parking lot to bumper stops, (3) the change from a street to a curb, and (4) broken pavement. Eliminate or reduce differentials as much as possible or post signs to warn people of the potential hazard.

Identify and correct significant height differentials. As little as 1/4’’ differential can cause a trip and fall. Carpet to tile, tile to carpet, different levels of carpet, defects in construction or deterioration all contribute to this variable. Eliminate or reduce differentials when possible.

Reduce fall hazards by installing the proper protective equipment to protect your employees’ safety. Roof ladders, meter pits and lift stations, as well as other ladders that exceed 20’ in length must have fall protection. Stairways should have adequate railings, proper riser and tread depth, and proper tread friction to eliminate or reduce slips and falls. Some agencies install aluminum tread edges on their stairways.

Implement regular inspections to identify and correct defects, deterioration, and other slip, trip, and fall hazards. Practice good housekeeping. Conduct regular, documented self-inspections. Instruct employees to clean their work area and not to leave tools, cords and other hazards lying on the floor. Once you identify a hazard, either correct it immediately or post warning signs and a barricade to reduce the possibility of injuries.

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Conduct a thorough investigation of all reported slips, trips, and falls. Investigations are usually the responsibility of the supervisor, but your County’s Safety Committee may assume this responsibility. The purpose of the investigation is to determine the cause of the accident and to develop possible solutions. Once the cause is determined, you should remedy it immediately to prevent another incident.

Develop a planned maintenance program. Determine your maintenance needs for cleaning and providing safe walking surfaces. Make sure that you inspect and clear outdoor surfaces frequently, especially during colder months. Monitor areas where water frequently collects, such as around drinking fountains and slop sinks.

Provide other means to reduce the potential for loss. Review the need for mats or runners, install adequate lighting, and install gutters to deflect water run-off.

Review causes of slips, trips, and falls with employees. Make employees aware of what contributes to the problem. Identify any special procedures or areas that need special attention. Focus on mutual goals rather than assigning blame. Review techniques to reduce slips, trips, and falls with employees whose positions do not allow for discretion in walking surfaces. For example, police officers frequently slip and fall during the capture of an assailant. A meter reader who must enter a structure to read a meter may not be able to avoid the typical hazards that are normally controllable in a publicly owned building.

Do not forget to reduce the hazards in vehicles and equipment. Install anti-slip coatings or tape on the steps of vehicles and equipment. Make sure dump trucks have securely attached steps and handles welded to the dump box body.

Review the type of footwear that employees are wearing. Some communities buy or contribute to the cost of footwear for their employees. Make the right choice for the employee based on indoor or outdoor weather, the type of work or activities, the type and conditions of walking surfaces, and comfort. Discuss the possibility of reducing the hazard with a footwear specialist. Include the employees in this decision process. Consider this item’s impact on the potential for reducing back injuries.

Involve your employees in the process of reducing injuries. Committees, incentive programs, and recognition for safety accomplishments may result in a stronger and more community-wide interest in the problem and its solution

Conclusion

The above recommendations may appear to have little or no effect on your ability to control slips, trips, and falls. However, acting on even a few of them can contribute significantly to a reduction of your exposure to slip, trip, and fall accidents. The reduction can benefit you in decreased claims and associated costs, a reduced number of lost workdays, and increased productivity.

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Guidance on Developing a Basic Plan for Preventing Back Injuries

Overview

Back injuries continue to be one of the most prevalent types of workplace injury. Over 2 million injuries occur annually and experts estimate that eight out of 10 Americans will suffer a back injury sometime during their lives. In addition, slowed production as well as the increased turnover and medical bills that result from low back pain claims make these type injuries as the most expensive medical problem for industry. Each year employers experience approximately 10 million dollars in losses due to back injuries.

Occupational & Non-Occupational Causes for Back Pain and Injury

Numerous factors can contribute to or aggravate low back injuries and pain. The major occupational causes are:

• Physical work – Blue-collar workers suffer significantly higher rates of low back pain, absenteeism, and symptoms of sciatica (pain radiating down the leg) than white-collar workers. The higher injury rate results from the greater frequency with which such workers lift objects.

• Bio-mechanically stressful postures -- These postures, which include twisting at the waist, prolonged static postures, such as forward bending and prolonged sitting, result in a five-fold increase in low back pain.

• Whole body vibration of low frequency (4 to 10 hertz) -- Operators of autos, trucks and heavy construction equipment frequently experience this type of vibration. There is substantial data that shows that workers in these categories have significantly higher rates of serious back pain.

• Direct trauma to the spine, generally because of falls, accounts for 8 to 15% of all serious low back pain and spinal fractures.

In addition, age and lack of fitness are non-occupational causes that contribute to the development and severity of low back pain.

Employers can protect themselves and their employees from back injuries. Prevention and education are the keys. Making changes in the workplace, educating employees about using proper lifting and material handling techniques and encouraging employee wellness all help assure many hours of work and play without pain.

Prevention

Is low back pain preventable? The answer is “yes and no." Research indicates that a substantial amount of low back pain will occur even if the level of physical stress is low. At the same time, research in ergonomics and biomechanics strongly suggests that improved workplace design and appropriate engineering controls can prevent one third of occupational low back pain. Measures employers can take include:

• Reducing mechanical spinal loading to within or near National Institute for Occupational Safety and Health (NIOSH) criteria

• Minimizing high stress postures, low-level lifts, axial trunk rotation, static postures, and asymmetrical movements under load

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• Matching worker abilities to job performance requirement

• Implementing administrative controls such as job rotation

Taking these steps can dramatically reduce the frequency and severity of back injury related workers’ compensation claims. In addition, improved workplace design can allow many more workers to perform their normal -- or alternative tasks -- even when they are experiencing low back pain.

Wellness

Real prevention begins with education. Employees need to know that low back pain is a "disease" common to most people. They need to understand that it is only partially preventable through improved work methods and workplace design. Most of all, they need to learn the things they can do to protect themselves.

An education program that stresses proper lifting and material handling techniques as well as the importance of proper diet and exercise to back health is essential to reducing the number and severity of back injuries. Instituting a wellness plan can encourage employees to take responsibility for their health. Wellness plans give employees information about health and fitness. They may also provide employees with the facilities they need to achieve fitness.

A complete fitness program, including stretching, strengthening and aerobics exercises, is important to a healthy back. It is essential to condition all the muscles that help support the spine. Strengthening the large muscles in the arms, hips and legs helps to compensate for muscular weakness in the back.

Because fitness is so important, we recommend that management:

• Seriously consider enrolling employees in an accredited wellness program.

• Encourage employees who want to participate in a wellness program. Encouragement can take the form of recognition, incentives, facilities or equipment.

Back Injury Prevention Self-Assessment

One of the most common employee injury complaints is back pain. Back pain often results in high medical expenses, lost work time and productivity as well as permanent disabilities. It is important, therefore, to identify back pain as a problem and seek measures to reduce the cause of injuries as much as possible.

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Back Injury Prevention Program

Hiring

To be successful, a complete program for preventing back injuries begins with the hiring process. Employers who address the issue of back safety during the hiring process send a clear message to

candidates and new employees that back health and safety are important to the organization. They also have greater assurance that they have correctly matched the employee to the job.

Employers can reduce the risk of on-the-job back injuries by assuring that the employees they hire can physically perform the job. Employers can successfully achieve this by properly analyzing positions in their job descriptions, considering the use of post job-offer physicals, and Using pre-employment physicals for all employees who are at substantial risk of back injury from the essential functions their jobs require.

As with all aspects of employment, hiring employees requires that employers do not discriminate against candidates who may have pre-existing back conditions. Employers must comply with the requirements of the Americans with Disabilities Act during hiring. They should also

implement reasonable accommodations for employees who are "otherwise qualified" to perform essential functions but may be at risk for back injury.

What Employers Should Do

Employers should develop accurate, detailed descriptions that provide the physical requirements of each position. These job descriptions are important to an effective hiring process and important for candidates who need precise information about the tasks a position for which they are applying may involve. The job description should reflect how employees actually perform the work and, therefore, employers should obtain information from employees who currently fill the position. The job description can then be useful for determining whether an employee has the physical capability to perform the essential functions of the job. A properly developed description also provides guidance on the type of training a newly hired employee needs to be successful in the position.

The first step in developing an accurate and effective job description is to identify and define the essential functions of the job. Most positions have functions that are essential and essentials that are marginal. To identify the essential functions, the employer should ask the following questions:

• Does the position exist to perform that function?

• How many other employees are available to perform the function?

• To how many other employees can the employer assign the function?

• What degree of knowledge, skill, or expertise is necessary to perform the function?

• How much time is necessary to perform the function?

• What are the consequences of not requiring an employee to perform the function?

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The job description should breakdown the responsibilities of the position into its individual tasks and responsibilities. Where appropriate, the employer should describe the physical demands of each task or responsibility. The description should specify:

• Any amounts of weight an employee would have to lift,

• Any amounts of time the employee would have to stand or sit for long periods of time, and

• Any requirements for physical flexibility (Does the employee have to crawl, kneel, bend, reach?).

Employers should obtain information from existing employees who perform the work to develop the most accurate and objective description possible.

Pre-Employment Physicals

Once employers have job descriptions in place, they should analyze the physical requirements of each position and identify those positions that pose a high risk for back injury.

If an employer uses pre-employment physicals properly, these exams can be very useful in assuring the success of our program for back injury prevention. Done incorrectly, the physical can result in costly litigation.

The examination should take place after the job offer and be job-related and consistent with the employers' business needs. Employers should not require pre-employment physicals for low risk positions because such examinations are not consistent with business requirements and increase the organization’s exposure to lawsuits. Employers may make a job offer conditional on the results of the medical examination but only if all entering employees in similar jobs must take the physical.

Selecting a Physician

Employers should use the same physician or physicians from the same medical facility to conduct pre-employment physicals. This should help to assure consistency in the opinions related to job suitability.

Employers should communicate the importance of thorough physicals and of giving opinions that are consistent with the specific position for which an employee has applied. To assure accurate opinions, employers should provide the physician with the job description and, where appropriate, photographs of an employee actually performing essential functions.

Employment Inquiries

Employers must take care when asking questions of candidates for employment. Under the Americans with Disabilities Act, it is illegal for employers to ask applicants about the existence, nature, or extent of a disability. However, the employer may and should review the physical requirements of positions with applicants and ask them about their ability to perform specific job functions.

Employers should limit their inquiries to physicians to questions about the candidate’s ability to perform all of the functions as described in the job description without posing a significant threat to the health and safety of themselves or others. Employers should not ask physicians about candidates’ disabilities. However, they can ask the physician to indicate

• Any physical restrictions that might limit a candidate’s ability to perform essential job functions, and

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• The accommodations that the employer could implement that would allow the candidate to perform successfully in the position

Reasonable Accommodations

If the physical identifies certain functions or tasks that the employee is physically unable to perform, the employer should first determine if these functions or tasks are “essential” according to the job description. If the function is not essential, the employer should remove it from the employee’s job description.

If the task or function, however, is essential, the employer should consider making a reasonable accommodation that would allow the employee to perform the essential functions of the job within their physical restrictions. Reasonable accommodations may include:

• Adaptive devices or the modification of existing equipment,

• Job restructuring,

• Modified or part-time work schedules,

• Adjusting or modifying examinations, training materials and approaches, or policies,

• Reassigning the employee to a vacant position which he or she can perform,

• Providing readers or interpreters, and

• Making the workplace accessible to and useful by people with disabilities

Employers should review their responsibilities under the Americans with Disabilities Act when developing their pre-employment physical program.

Training Content

Employers should provide all their employees with training on all aspects of the back and back injury prevention. Training should cover the two broad areas of physiology and mechanics and include sessions on the following topics:

• Anatomy of the back

• Physiology of injuries

• Back maintenance, exercise, wellness

• Proper lifting techniques

• Ergonomics

• Equipment usage

• Hazard identification

Scheduling of Training

Employers should begin training their employees before putting them on the job. Pre-placement training on back injury prevention should be mandatory and, at a minimum, should cover proper techniques for lifting and safe procedures for equipment usage. Current employees who change positions -- lateral move, promotion, or injury -- should receive “pre-placement” type training in areas specific to their new positions. The training sessions do not have to be long or formal. Even a ten-minute toolbox talk can be effective in communicating information and reinforcing safe habits.

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After initial training, training should take place at regular intervals (monthly is preferable) until all employees have received training in all recommended areas. Thereafter, annual refresher training is necessary to keep skills and awareness high.

Employees who receive back injuries because of improper mechanics or equipment usage should attend training in those areas immediately upon their return to work from the back injury. If injured employees cannot identify why the injury occurred, they should attend additional training in hazard identification.

Training: A Supervisory Responsibility

Training can take many forms:

• Lectures

• Handouts

• Videos

• Hands-on training

• Slide presentations

Supervisors should document all training provided, including topic covered, date of the sessions, name of the person conducting the training, and names of attendees.

Evaluating the Need for Equipment

As employers analyze job procedures, they should also consider the use of equipment that employees use to help them perform the work. For lifting or material handling tasks, for example, such equipment includes hand trucks, lift trucks, conveyors, and pallet jacks.

Investigating Near Misses and Accidents

When a “near miss” or an accident occurs, it is evidence that a hazard exists. Conducting a thorough investigation can help the employer to identify the hazards that contributed to the accident so that the employer can deal with them.

Reducing Hazards

To reduce the causes of hazards or injuries, employers should consider the three traditional risk management alternatives:

1. Engineer the risk out of the procedure. Employers should determine if there is safer way to perform the task or equipment that employees could use to perform the hazardous procedure.

2. Reduce the risk. Employers can reduce either the frequency or the severity of the risk. To reduce the frequency, employers should decide if it is necessary for employees to perform the task as often as they currently do, or if a large number of employees could share the task. Reducing the severity can be as simple as instituting rules to control behavior. For example, employers can mandate that employees make two trips to carry 25 pounds rather than one trip to carry a 50-pound load.

3. Transfer the risk. Sometime the most effective choice for reducing the risk is contract the work out to a company that specializes in the area. If the employer has a job requiring heavy lifting but does not

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have the resources to purchase the necessary equipment, the employer should consider contracting the work.

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Safety Talks – Lifting Tips to Help in Preventing Back Injuries

Have you checked the object before you try to lift it? 1. Test every load before you lift it. How? Push the object lightly with your hands or feet to see how easy

it moves - this will tell you about how heavy it is.

2. Remember, a small size does not always mean a light load. Is the load you are about to lift packed correctly?

3. Make sure the weight is balanced and packed so it will not move around.

4. Are there loose pieces inside a box that can cause accidents if the box becomes unbalanced?

Is it easy to grip this load?

Be sure you have a tight grip on the object before you lift it. Handles applied to the object may help you lift it safety.

Is it easy to reach this load? 1. You can receive an injury if you arch your back when lifting a load over your head.

2. To avoid hurting your back, use a ladder when you're lifting something over your head

What is the best way to pick up an object? 1. Use slow and smooth movements. Hurried movements can strain the muscles in your back.

2. Always face the object while you lift. Twisting while lifting can hurt your back.

3. Keep the load close to your body. Having to reach out to lift and carry may hurt your back.

4. You should "lift with your legs" only when you straddle the load. To lift with your legs, bend your knees not your back, as you pick up the load, not your back. Keep your back straight.

5. Try to carry the load in the space between your shoulder and your waist -- this puts less strain on your back muscles

How can you avoid back injuries? 1. Pace yourself. Take small breaks between lifting operations.

2. Do not overdo it- do not try to lift something too heavy. If you have to strain to carry the load, it is too heavy for you.

3. Make sure you have enough room to lift safely. Observe your surroundings.

4. Look around before you lift and as you carry the load. Make sure you can see where you are walking and know where you are going to put the load down.

5. Avoid walking on slippery and uneven surfaces while carrying something.

6. Do not rely on a back belt to protect you. To date, no one has proven that back belts can protect you from back injury.

7. Get help before you try to lift a heavy load. Use a dolly or forklift if you can. Remember, your Back is one of your greatest assets. Please, take care of it!

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Ten Components of a

Back Injury Prevention Program

Job descriptions include physical requirements Policy for pre-employment physicals in place Mandatory pre-job placement training Mandatory regularly scheduled training Working disciplinary policy for violations Completed and document job analyses of all “at risk” positions Mandatory regularly scheduled inspection Management actively and appropriately addresses hazards Mandatory investigations of all “near-miss” and actual accidents Audit system for the program for back injury prevention in place

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Powered Industrial Trucks Operator Training

Program Implementation Requirements

• Employers shall evaluate operators on their knowledge and performance as part of initial and refresher training, and at least once every three years.

• New employees and employees reassigned to different departments and/or trucks shall receive training before their assignment. Training will consider the following:

• The operator’s prior knowledge and skill,

• The types of powered industrial trucks the employee will operate in the workplace,

• The hazards present in the workplace, and

• The operator’s demonstrated ability to operate a powered industrial truck safely.

If necessary, employees should receive refresher training. Conditions that require refresher training are:

• The operator has an accident or near miss incident.

• The operator has been observed operating the vehicle in an unsafe manner.

• The operator has been determined during an evaluation to need additional training.

• Changes in the workplace have occurred that could affect the safe operation of the vehicle.

• The operator is assigned to operate a different type of truck.

Classroom Instruction • Engineering principles of a forklift

• Nomenclature of parts

• Procedures for safe operation

• Proper refueling, battery charge, etc., procedures

• Methods to conduct daily inspections

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[Name of County] will use a written test to determine each operator’s retention level. This test will be the same for all employees. Employees must successfully complete this test before they receive hand-on training and take the supervised training test.

Hands-On Training

In addition to classroom instruction, all new powered industrial truck operators will receive supervised training in operating the vehicle correctly. After completion of the training, operators must pass a supervised driving test.

The duration of the test will vary based on the operator’s ability to operate the vehicle in a safe manner. Operators must demonstrate the following basic skills: vehicle inspection, turning, backing, loading, stopping, and working with a raised load. Scoring procedures will be used to rate the operator’s performance. Additional supervised hands-on training will be provided, if necessary, for the operator to develop the skills to operate the forklift safely.

Required Training Program Content

The employer must provide powered industrial truck operators with initial training in the following topics. This requirement applies unless the employer can demonstrate that the topics do not apply to the safe operation of the truck in the employer’s workplace.

Truck related topics:

• Operating instructions and precautions for the types of truck the operator will receive authorization to operate.

• Differences between the truck and the automobile

• Truck controls and instrumentation: where they are located, what they do, and how they work;

• Engine or motor operation

• Steering and maneuvering

• Visibility (including restrictions to loading)

• Fork and attachment adaptation, operation, and use limitations;

• Vehicle capacity;

• Vehicle stability;

• Any vehicle inspection and maintenance the operator will be required to perform;

• Refueling and/or charging and recharging of batteries;

• Operating limitations;

• Any other operating instructions, warnings, or precautions listed in the operator’s manual for the types of vehicle that the employee is bring trained to operate

Workplace-related topics: • Surface conditions where the employee will operate the vehicle;

• Composition of loads to be carried and load stability;

• Load manipulation, stacking, and removing from a stack;

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• Pedestrian traffic areas where the vehicle will be operated;

• Hazardous (classified) locations where the vehicle will be operated;

• Ramps and other sloped surfaces that could affect the vehicle’s stability;

• Closed environments and other areas where insufficient ventilation or poor vehicle maintenance could cause a buildup of carbon monoxide or diesel exhaust;

• Other unique or potentially hazardous environmental conditions in the workplace that could affect safe operation

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Powered Industrial Trucks Safe Operating Procedures

Equipment Check 1. Before operating any type of Powered Industrial Truck, perform a pre-operational safety check,

including truck lights and horn.

2. Report faulty performance or signs of defect tom your supervisor immediately. Defects involving steering, braking, or anything else of a serious nature should take a Powered Industrial Truck out of service immediately. Do not operate a defective Powered Industrial Truck. Do not attempt repairs yourself.

3. Do not place any kind of objects in battery compartment.

4. Do not add water to the battery because it has acid in it and this can be dangerous. Let the mechanics do it. If you should get battery acid on you, wash it off immediately.

5. Do not smoke in the battery room because batteries on charge emit hydrogen gas, which is extremely explosive.

6. Whether a truck is loaded or empty, always be aware of the position of its fork tips. Lower them to not more than six inches (6”) from the floor before traveling.

7. If you must leave a lift truck unattended or when parking it at the end of a shift or job, lower the forks, put the controls in neutral, set the brakes, block the wheels if on an incline, shut off the power and remove the key or connector plug. You should always park in designated areas.

8. Keep truck clean—especially control levers, foot pedals, forks, and platforms—to prevent slipping, which could make you lose control of truck or load.

9. You should report any controls and units that are not working properly to your supervisor. This can greatly reduce overall truck maintenance costs by allowing us to make minor repairs before strains affect on other parts, causing whole assemblies to fail. Report such conditions as decreases in normal speed, lack of power, worn or damaged tires, poor brakes, worn tires or short-circuit flashes in controller, and missing guards, covers, and fire extinguishers.

Driving Guidelines 1. Always be alert for pedestrians, other trucks, or obstructions in your path of travel. As in city traffic,

keep to the right. Pedestrians have the right of way.

2. Do not drive a Powered Industrial Truck up to anyone standing in front of a fixed object, i.e., wall, tank, door, machinery, etc.

3. Do not engage in stunt driving and horseplay.

4. Slow down and sound the horn at cross aisles and other locations where vision is obstructed.

5. Ride only those pieces of equipment specifically provided with seats or platforms for the operator. In no case shall anyone ride the forks or hitch a ride in any manner.

6. Keep the truck under control at all times and maintain a safe distance from other vehicles. Avoid sudden stops and starts, especially when carrying liquids.

7. Be alert to floor conditions—go slow, but maintain control over drains, wet and slippery surfaces and around corners. Avoid running over debris and other loose objects—pick it up and dispose of it properly.

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8. Do not pass other Powered Industrial Trucks traveling in the same direction at intersections, blind spots or other dangerous locations.

9. Take care when operating on a grade. Always operate a loaded Powered Industrial Truck with the load upgrade.

10. Always operate so that you have a clear view of where you are going. Under normal operating conditions, operate Powered Industrial Truck with the load “pulled behind you”, i.e., forward.

11. ONLY OPERATORS WITH TRAINING AND AUTHORIZATION MAY OPERATE POWERED INDUSTRIAL TRUCKS.

12. Never back up against a wall or other fixed objects.

13. Drive at a speed that is safe for all conditions in a given situation. This includes the conditions of the truck (see Operator’s Daily Report), road surface, load, and in-plant traffic.

14. Always slow down when making a turn, even with an empty truck.

15. Wear personal protective equipment as instructed.

16. Avoid sudden stops and starts when carrying liquids.

17. Do not drive in the dark. Report all poorly lighted aisles or passageways.

18. Do not drive with wet or greasy hands. Your hands may slip from controls, causing serious injury.

19. Tell your supervisor about all rubbish, grease, oil, and water on the travel routes. When possible, don’t run over such wastes.

20. Before starting truck, look to front and rear, making sure there is no one in your path. Always look behind you before backing out from under load.

21. Keep arms and feet inside the truck and away from the hoist mechanism.

22. Do not stop suddenly except in absolute emergencies. Momentum of load may tip over truck, especially when load is elevated.

23. When reversing direction, stop electric truck completely with brakes before you throw reversing switch.

Load Handling Guidelines 1. Never exceed the load capacity of your Powered Industrial Truck.

2. Always lift with two forks. Insert both forks under the load as far as possible before rising. Lifting with one fork over-balances truck and may damage truck and/or injure you.

3. Before loading trailers, make sure you bring the truck to a complete stop in its bay, that you engage the dock lock or place wheel chocks. Check floor condition for defects and debris before entering.

4. Avoid the edges of loading dock and dock plates.

5. Enter confined spaces (i.e., elevators, trailers) with load end first (i.e., reverse) being pushed by the operator. Approach all elevators slowly and squarely.

6. Do not block emergency exits, doorways, stairways, or emergency equipment.

7. Do not overload elevators. Observe posted elevator weight limits. All power equipment operators who use elevators are responsible for knowing the weight of the elevator they are loading and for making sure an elevator is never overloaded. This also requires the operator to know the weight of the truck and weight of the load on the truck.

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8. Watch low-clearance signs and signals. Know the overall height of your truck and load before entering restricted overhead areas.

9. Keep the load as low as possible. This lessens the danger of tipping and lets you see over the load when moving it.

10. Before you pick up the load, inspect it. Refuse to haul loads not safely piled. Report all loads exceeding your truck’s rated capacity. Remember that you are responsible for a load once it’s on your truck.

11. Never handle flammable liquids or acids except in approved containers.

12. Never permit anyone to walk or stand under the forks or elevated loads.

13. Pick up every load squarely. This lessens the load’s chance of slipping while traveling. Spread forks according to width of load.

14. Move control levers firmly from one speed to another. This prevents arcing, which pits contact surfaces of switches. Pitted switches may fail to give expected control in an emergency.

15. Use tilting control when carrying loads. This brings balance of load directly over drive wheel, prevents spilling load when rounding corners.

16. Make a full stop six feet in front of elevator gates. Slow down for bridges, inclines, tunnels, and tracks. Cross the tracks diagonally, not at a right angle.

Electric Walking Truck 1. For normal movement, you are to "pull" not "push" electric walking trucks, especially when going

through doorways and into halls.

2. Never attempt to operate two electrical walking trucks at the same time by pushing one and pulling another. When traveling down a ramp with an electric walking truck, either empty or loaded, reduce speed and use the brake intermittently to maintain full control of the vehicle at all times.

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Powered Industrial Trucks Operator Qualification

Only qualified, licensed drivers may operate vehicles. Employees will receive licenses only after they successfully complete the supervised driving test and written test.

Equipment Inspection

The operator shall conduct a daily visual check of the vehicle and complete the checklist. Special attention should be given to safety devices—the horn, lights, brakes and backup alarm. Do not use the vehicle if any feature does not work.

Formal inspections/repairs will be the responsibility of qualified maintenance personnel. They shall document inspections, documenting the deficiency found and corrective action taken.

Fork Truck Inspection 1. Check the tires for excessive wear, deep cuts, and proper inflation.

2. Check the horn and any other visual warning devices, such as lights or blinkers.

3. Check all lift, lower, tilt and attachment controls for proper operation, and any visual signs of hydraulic leakage.

4. Check the brakes and familiarize yourself with their proper operation.

5. Check the steering for excessive play or binding. Also, remember some vehicles steer opposite than normal. This is especially true on narrow aisle equipment.

6. Check the forks and fork retaining pins for damage.

7. In an internal-combustion truck, check the oil level, fuel level. (If the truck is equipped with LPG, check for secure mounting and condition of tank, battery, and radiator coolant each day.)

8. Check a battery-operated vehicle to ensure that the battery is securely mounted and fully charged, and that there is no excessive corrosion.

9. Report any malfunction of the equipment immediately.

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Operational Safety Checklist

You must inspect the lift truck before operating it and report defective equipment to your supervisor. You should tag or label the equipment and take it out of service if it is defective. Only a qualified person should perform repairs.

Visual Pre-Operational Inspection NEEDS OKAY ATTENTION

Obvious Damage Leaks (Hydraulic, Brake, Transmission Fluid) Nameplate, Capacity, Safety Markings (i.e. No Riders) In Place, Legible, Understood Housekeeping (In the Cab and Around Equipment) Tires/Wheels Condition (Proper Inflation, Gouges, Cracks, Etc.) Forks (Cracks, Bends, Warps, and Wear) Carriage and Locking Pins (Cracks and Bends in Carriage, And Pins Locked And In Place) Load Rest (Warps, Cracks, Tautness) Mast (Warps, Twists, Etc.) Chains (Broken, Worn, Tautness) Hoses (Worn, Rubbing, Leaking) Overhead Guard (Secure) Seat belt (If Applicable)

LPG, Gas, Diesel

Engine Oil Level Fuel Level Radiator Water Level

Electric

Electrolyte Level Battery Connections Dash Control Panel (Lights and Gauges Operational) Horn and Warning Devices (Operational) Lift Mechanism (Raise & Lower Forks to Max & Min Height; Check for Smooth Operation.) Tilt Mechanism (Operates smoothly. Mast moves All the Way Forward and Backward) Side-Shift (Moves Smoothly) Directional Controls and Steering (Smooth Movement) Foot Brake (Pedal Holds and Unit Stops Smoothly) Parking Brake (Should Hold Against Slight Acceleration) Dead man’s Seat Brake (Should Hold when Operator Rises From Seat) Clutch and Gearshift (Smooth Shifting, No Jumping or Jerking) Leaks (Check Cylinders and Hoses for Leaks after Above Checks)

______________________________________ ______________ Employee Signature Date

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Motor Vehicle Operations Managing Motor Vehicle Operations

A Management Brief: Reducing the Risk of Motor Vehicle Operations

Use of motor vehicles is essential to the operations of most companies and has become an essential element in the delivery of most, if not all services. Driving can account for a large portion of an employee’s daily work schedule and the potential for loss is significant.

Although personal injury and property damage are the most frequent causes of loss, the negligent operation of motor vehicles is equally important.

Motor vehicle related incidents also frequently generate hidden costs. These costs, both tangible and intangible, include but are not limited

• Lost employee workdays

• Disruption or delays in operations or projects

• Impaired ability to respond to requests for service

• Equipment loss or loss of use

• Shaken public confidence

• Reduced employee morale

• The diversion of funds earmarked for other purposes to pay for motor vehicle related losses

• Increased insurance premiums

Besides the routine use of vehicles to deliver services, public safety employees regularly and public works personnel occasionally respond to requests for emergency assistance. Emergency response often requires that employees exceed posted speed limits and disregard traffic control devices. These circumstances dramatically increase the potential severity of incidents related to emergency operation. Claims alleging negligent operations are a likely and expected consequence of this activity.

Risk Control Considerations

We often refer to motor vehicle accidents as unexpected, undesired, at times even tragic, but unavoidable occurrences. The truth is, however, that these accidents are usually preventable.

There will be the occasional incident that involves a so-called act of nature. For example, a tree limb that lightning has struck might fall on a parked vehicle. However, an analysis of the root causes of these types of claims reveals that they, too, are often preventable. In our example, a tree inspection program might have prevented the incident that led to the claim. Because we generally can determine fault, Michigan recently changed the official reporting term from “traffic accident” to “traffic crash.” The change indicates that most leading experts in the field now recognize that accidents are preventable.

To have an effective -- and complete -- risk control program, a County must deal with the safety and liability exposures inherent to motor vehicle operations. A successful, coordinated program can reduce the potential for severe and unexpected losses. It can also contribute to the Pool and Fund’s continued ability to service its membership efficiently and cost effectively.

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A program cannot succeed unless everyone in the organization buys into, acknowledges, and accepts their assigned responsibilities. Every department should participate. Executive management should monitor and coordinate departmental efforts to assure consistency of approach and to prevent a duplication of resources (developed or expended).

Supervisory Considerations

Because they are critical to successfully implementing and monitoring a motor vehicle risk reduction program, managers and supervisors should understand their role and the importance of their individual efforts and actions. They must be able to persuade their subordinates that commitment to and compliance with the program is important. A lack of management commitment can undermine an otherwise effective program.

To assure commitment, you should:

• Empower supervisors, both in policy and practice, to enforce policy directives.

• Articulate your expectations about their responsibilities in the policy. Let them know that:

o The program’s overall success depends on their ability to manage their employees and their activities.

o You will hold them accountable.

o Failing to supervise adequately might result in corrective action. Any action will be consistent with applicable employment and disciplinary policies or collective bargaining agreements.

• Reinforce this message constantly both in training and staff meetings.

• Recognize managers and supervisors whose actions positively affect motor vehicle related losses in their department or area of assigned responsibility. Use:

o Certificate or plaque presentations

o Press releases and local media coverage

o Special articles in the County or departmental newsletter

o An incentive, reward or bonus program

o Assignment to the risk control safety committee

Summary

Implementing a comprehensive motor vehicle operations program can reduce the potential for civil liability losses, improve employee safety, and show your good faith effort to manage your risk exposures. However, the program will succeed only if management supports it.

Implementing a program will also positively influence and mitigate your vehicle related loss experience and your overall risk profile. Pool and Fund underwriters and reinsurers occasionally review this profile as one of the determining factors in establishing premium rates. The potential benefits of a well planned, concerted, and coordinated attack on vehicle related loss exposures far out weighs the expenditure of time, manpower, and monetary resources required to establish and maintain it.

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Motor Vehicle Operations Self-Assessment

Accidents involving vehicles continue to be one of the most frequently experienced losses for many organizations. Losses include employee injuries, damage to vehicles and property, lost work time, and interrupted services. In addition, accidents create liability concerns from alleged negligent operations. It is, therefore, critical that every organization evaluate its motor vehicle procedures and correct identified deficiencies. You can begin your assessment by asking yourself the following questions.

Does your organization:

1. Evaluate the management of its motor vehicle program? Yes No 2. Properly screen, hire and train its employees?

Yes No

3. Have a Motor Vehicle Operations Policy?

Yes No

4. Have a good vehicle inspection and maintenance program?

Yes No

Do you: Conduct periodic analysis of vehicular losses? Reduce future injuries by taking precautionary measures? Make sure your supervisors enforce policy directives? Encourage and reward good performance?

Do you: Have and consistently follow procedures for hiring safe

drivers? Do you periodically check the driving records of employees

who operate equipment? Do you provide initial and ongoing training to ensure

responsible and safe motor vehicle operations? Do you discipline employees who violate vehicular policies?

An Operations Policy should: Identify and establish a Risk Control Committee to review

accident data and develop programs. Review loss data to determine the cause of incidents. Require the inspection of facilities, equipment, and safety

equipment. Establish procedures to hire and educate employees. Establish performance requirements that employees must

follow. Set maintenance procedures for equipment.

Do you: Have a routine vehicle maintenance program? Keep extensive maintenance and repair records? Train service personnel adequately? Require drivers to report damage and repairs needed

before using equipment? Follow the Uniform Vehicle Code regarding the inspection

of vehicles?

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Developing a Motor Vehicle Operations Policy

Developing a sound motor vehicle operations program and policy is crucial to reducing your exposure to loss. A properly developed policy will guide the actions of all employees who operate vehicles as part of their jobs.

Form a risk control-safety committee

Review data and develop motor vehicle operations policies and programs (or add this function to your existing safety committee). This committee should:

• Include representatives from each department.

• Gather ideas, information, and expertise from both internal and external sources.

• Have the authority to address identified risk exposures.

• Review and investigate all motor vehicle related incidents or losses to determine:

o If possible, the incident’s root cause

o If the incident was preventable, and if so, how

o If misconduct or a violation of policies, procedures, or the law contributed to the accident

o If existing policies, procedures and training programs adequately address the cause of the incident, or if they need modification to address this particular category of loss

o If safety equipment, or the lack of it, was a factor

• Meet at least annually to review written policies, current training programs, updated loss information, and other materials. This review determines if the program

o Is reaching its goals and objectives

o Continues to satisfy contemporary standards

o Complies with recent changes in the law or new federal mandates

o Requires modification to reflect current needs or servicing commitments

Conduct a Loss Analysis

The committee should:

• Identify the specific nature of losses by department and for the agency as a whole.

• Evaluate how effective existing policies, procedures, operating practices, or programs have been in addressing actual losses.

• Inspect all the County’s locations to identify hazards that might affect the safe operations of vehicles at these sites.

• Inspect and evaluate existing safety and emergency equipment and analyze future needs.

• Develop a policy that requires the use of seat belts and other safety devices. The policy should prohibit the modification, removal, or disabling of installed or available safety devices.

• Prioritize actions and projects.

o Address actual loss experience first.

o Prioritize the review of other exposures common to public agency operations, and

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o Assess other categories in which the agency has not yet suffered a loss.

• Develop an integrated approach to controlling motor vehicle exposures that:

o Contributes to the County’s overall goals and objectives

o Addresses operational needs, such as emergency vehicle responses, that are unique to specific departments

Policy Development and Implementation:

The committee should develop a detailed motor vehicle policy.

• The policy should include the following elements:

o Screening and hiring specifications for positions that require employees to operate motor vehicles as part of their overall job assignment;

o Specific licensing requirements, based on job assignment;

o Guidelines for vehicle use;

o Rider/passenger eligibility requirements (only employees and only when necessary to the job);

o Occupant protection and passenger safety programs;

o Requirements for vehicle maintenance, replacement, and inspection as well as documentation of these activities;

o Accident review and analysis procedures;

o Employee training requirements;

o Program oversight responsibilities at all levels of the agency

o Mandatory compliance with all applicable state laws or local ordinances

• Although the policy should apply, for the most part, to all departments, it should:

o Allow for modification for specific areas.

o Allow for special operational requirements, such as emergency medical response or the operation of heavy equipment.

• The policy should include, if possible, a recognition or incentive program for drivers to promote morale and encourage conformance to departmental objectives and directives. Examples include:

o Uniform pins

o Certificates

o Notification of local media sources

o An additional vacation day

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Hiring and Training to Reduce Losses

Selecting and retaining good drivers is essential to reducing the risks of motor vehicle operations. Managers and supervisors need to establish performance standards that reflect the skills and prerequisites for satisfactory performance. These standards should address operating motor vehicles where relevant to employees’ job responsibilities. Having these standards in place makes the job of selecting employees easier and can reduce the need to deal with performance problems later.

We recommend that all companies develop and implement a comprehensive motor vehicle operations policy and program. Hiring and training are important components of such a program.

Screening, Hiring, and Retaining Safe Drivers:

Investing time in the selection process can help managers and supervisors to hire good employees. One of the best ways to avoid performance problems is to avoid hiring “problem” employees.

Establish a procedure for hiring safe drivers that managers and supervisors follow consistently.

• Use an application form that provides sufficient information about the applicant for pre-screening purposes.

• Interview the applicant to determine his or her general suitability as an employee and to uncover any information about the applicant’s ability to operate motor vehicles safely and responsibly.

• Perform reference checks on all candidates. Talk to previous employers to obtain information about the candidate’s abilities and character.

• Examine applicants’ driving records carefully and consistently as a routine part of the screening, background investigation, and hiring process.

• Reject applicants with poor driving records for positions that require vehicle operation. The following is a partial list of conditions or convictions that should cause immediate concern:

o Two at fault accidents in the past three (3) years, or

o Two minor traffic convictions in the past three (3) years, or

o A combination of one (1) at fault accident and one (1) minor traffic conviction in the past three (3) years, or

o Operating under the influence of liquor or drugs, or

o Operating with an unlawful blood alcohol content, or

o Failure to stop or report an accident, or

o Negligent homicide, manslaughter, assaults involving the operation of a motor vehicle, or

o Driving on a suspended or revoked license

• Verify that applicants possess, or are eligible to obtain, any special license endorsements the law requires for the type or types of vehicle they will operate in performing their duties. Here we speak primarily of the Commercial Driver’s License (CDL) requirements.

• Determine the candidate’s physical and mental fitness to operate motor vehicles after you extend a job offer.

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Develop and consistently use a procedure for checking employees’ driving records.

• Check all employees’ driving records at least annually.

• Consider reassigning current employees with unacceptable records to non-driving related positions.

• Assign a specific individual to oversee the license review and screening process. This individual should also manage the entity’s compliance with Commercial Driver’s License, federal random drug testing and other legal requirements. The review should conform to the guidelines in your motor vehicle operations policy.

Remember, the legal system generally views a violation of the law as prima facie evidence of negligence. You cannot afford to have the court find you negligent during the defense of litigation. Compliance is a crucial component of an effective risk control program.

Provide initial and ongoing training to ensure that all employees have the skills and knowledge necessary to operate motor vehicles safely and responsibly.

The lack of sound training can seriously reduce the benefits that you can otherwise expect from a concerted risk control effort. Training in all areas or activities that are obvious, expected, or routinely associated with employees’ specific job assignments or responsibilities is now necessary to successfully defend against claims of this type.

Equally important, inappropriate, or insufficient training has a negative impact on employee safety. Ignorance of safety practices and policies, improper use of safety equipment, and unsafe equipment handling are leading and frequent contributors to employee injuries.

Therefore, we recommend that you:

• Train new employees at hire and before assigning them to operate a motor vehicle. Training should include testing for both knowledge and skills to verify that employees can perform acceptably on the job.

• Train existing employees at least annually. Training should

o Provide employees with the knowledge they need to operate their vehicles safely.

o Provide all employees with routine, formal training on your organization's written vehicle operations policy.

o Provide supervisors with specialized training. This training should clearly define their responsibilities for program and policy implementation, monitoring, oversight, and line level conformance.

• Document all training appropriately and carefully. Such documentation can be very beneficial in defending a claim. At a minimum, training records for each individual should include:

o The instructor’s name

o The date, time and location of training

o The trainee’s name and signature

o A copy of the training outline

o Proof of participant understanding (quiz)

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We highly recommend using written tests. The tests should be “pass” or “fail “and set achievable and realistic standards.

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Motor Vehicle Inspection and Maintenance

Overview

To protect the safety of employees and extend the life of the fleet, inspections, and maintenance should be an important part of any organization’s Motor Vehicle Operations Program.

Conscientious inspections and maintenance have many benefits.

• Increased Productivity: Regular inspections and preventive maintenance minimize lost work time because of vehicle breakdowns. They are also are less disruptive than emergency repairs because they can uncover minor problems before they lead to major repairs.

• Reduction in Accidents: Brake, steering or other component failure can contribute to accidents.

• Good Public Relations: Clean, well-kept vehicles project a professional and safety conscious image and can contribute to good public relations. In addition, drivers take pride in a well-maintained vehicle and are more likely to drive safely if the vehicle is clean and mechanically sound.

Preventive Maintenance Program

Development of an adequate and efficient maintenance program requires the following:

• Required maintenance at the intervals the manufacturer specifies to maintain the warranty

• An evaluation of factors such as speed, routes, and traffic conditions when establishing maintenance requirements

• An evaluation of the fleet’s composition -- the more vehicles of a specific type available, the easier it is to schedule maintenance without altering workloads and services.

• The more standardized the fleet, the easier it is to track manufacturer’s requirements, to order components, and to obtain information regarding recalls or other issues relating to safe operation

Management Responsibility

Management should:

• Support the maintenance program, making sure that it is established and well supervised. This includes controlling the maintenance-operations schedule so that it provides safe equipment for operational needs.

• Provide equipment, tools, and adequate shop facilities necessary for the program to work.

• Make sure that maintenance personnel receive training that upgrades their knowledge and job skills through County meetings, retraining sessions, special and manufacturers' schools.

• Establish an incentive and award program to encourage employee participation and compliance.

Driver's Responsibility

Drivers should be responsible for the condition and safe operation of their assigned vehicles. They should check their vehicles for possible defects and report them according to County policy.

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Maintenance Records

Forms serve a three-fold purpose:

1. Provide a record of vehicle maintenance needs. The records assist in evaluating the efficiency of the maintenance system.

2. Develop a schedule of work that needs doing.

3. Provide a record of completed maintenance and its cost.

The five forms that are basic to any vehicle-maintenance program are:

1. Vehicle Inspection Report: The report lists the different vehicle parts that drivers can inspect for defects. It also serves as a written communication between the driver and the shop for correction of defects.

2. Lubrication chart: Indicates what lubricants to use, what parts of the vehicle require lubrication and at what intervals.

3. Service and inspection report: Documents what components need repair and when personnel completed the work

4. Delivery ticket: Documents a record of each vehicle's consumption of fuel, engine oil, gear lubricant, and grease.

5. Vehicle history folder: Provides a complete up-to-date history of maintenance, parts, and labor costs.

Many of the major oil companies and vehicle manufacturers have useful preventive maintenance literature and forms available on request.

State Requirements

States whose traffic laws and ordinances conform to the Uniform Vehicle Code have provisions for the inspection of motor vehicles and components. The Uniform Vehicle Code recommends that fleet operations use the American Standard Code D7 of ANSI on Inspection Requirements for Motor Vehicles as a basis for meeting minimum inspection requirements.

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Vehicle Inspection Procedure 1. Approach vehicle; look for leaks of coolant, fuel, or lubricants under the vehicle. Note body condition.

2. Under hood, check battery water level, oil level (and last oil change date), transmission fluid level, belt and hose condition and adjustment. Fill windshield washer reservoir.

3. Start engine for warm up. Check for abnormal noise and gauges for normal readings. Try steering wheel for excess play.

4. Depress brake pedal for excessive travel, mushy or hard feel.

5. Check horn and windshield wipers. Turn on all lights including emergency flasher. Check high and low beam.

6. Check tire inflation and tread.

7. Check emergency equipment including fire extinguisher, first aid kit, emergency triangles, spare tire, jack, spare fuses, and bulbs.

8. Walk around vehicle checking lights and reflectors.

9. Recheck all gauges, fasten seat belt, turn off lights, and check the parking/emergency brake.

10. Make test stop within one block. Check operation of transmission.

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Sample Motor Vehicle Safety Policy and Program Vehicle Safety Program Guideposts

• Designate someone with management responsibility to coordinate vehicle safety activities. Top management should fully support a vehicle safety program and inform employees of it orally and in writing.

• Obtain Motor Vehicle Reports on all drivers who might drive vehicles for the organization before hiring them and annually thereafter.

• Establish a policy and procedure that defines the standards employees must meet to drive vehicles for the organization. The generally accepted practice is to select drivers with fewer than two at fault violations or two accidents or one of each within the previous three years. A DUI in the last five years should disqualify a candidate or an employee for a position requiring the driving of organization vehicles.

• Consider transferring current drivers having violations that exceed this number to non-driving jobs.

• Use a thorough job application form to establish a driver’s past job history.

• Consider making the job offer contingent on the employee successfully completing a pre-employment physical examination. The examination should determine the driver’s ability to meet the organization’s performance standards for drivers.

• Contact previous employers for references. Ask about the candidate’s driving history.

• Conduct a thorough credit check to determine the applicant’s personal management abilities.

• Consider requiring a written test and a road test as a qualifier for drivers who might drive unique equipment or equipment with which they are not familiar.

• Investigate all accidents thoroughly review the report as soon as possible. Determine if the accident was preventable.

• Establish a vehicle inspection and preventive maintenance program on a time or mileage basis and keep records to substantiate these activities.

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Sample Motor Vehicle Policy and Program

Introduction

How our drivers handle vehicles and the County maintains them can directly affect worker safety and the County’s reputation.

Each year motor vehicle-related injury claims continue to increase. Insurance pays most direct costs of these accidents; however, the County pays indirect costs. These indirect costs may include increased premiums, loss of vehicle use, vehicle replacement costs, loss of employee productivity, deductible payments, increased paperwork, etc.

Purpose

The purpose of this fleet safety policy and procedure is to assure that each employee who operates a vehicle on County business maintains acceptable standards of proficiency and safety.

Policy and Practices

[Name of County] wants to eliminate any conditions that adversely affect the well-being of our employees and threaten our financial stability through accidental losses.

Employees shall operate all vehicles that they use for County business safely and economically. To accomplish this, employees must comply with the following practices:

1. All drivers will have a valid state driver's license for the vehicles they operate.

2. Employees will comply with all applicable motor vehicle laws. The vehicle operator is responsible for any traffic citations.

3. [Name of County] prohibits unauthorized passengers or drivers to either operate or ride in the vehicle.

4. Employees will always wear seat belts, whether operating or riding as a passenger in the vehicle.

5. Employees will report and participate in the investigations of all vehicle collisions or property damage accidents according to policy.

6. Employees will use County vehicles for official use only.

7. Employees may not take home County vehicles overnight except as follows:

o Employees may take home a County vehicle for one night when job duties take place late at night after normal working hours or early in the morning before normal working hours with consent of department head or designee.

o Employees may take a vehicle home when their supervisors have assigned them to be "on 24-hour call" for department emergencies.

o Employees may take home a vehicle for more than one night only if the department head specifically authorizes it in writing.

8. County vehicles shall always be available for County business.

9. Employees may use County vehicles for travel to lunch if they are on business or in a location where driving to obtain their personal vehicles would result in an extra and unnecessary expenditure of time and money.

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10. Employees will operate vehicles only when they are in safe operating condition. Each employee driving a vehicle on business shall inspect the vehicle to assure that the vehicle is in sound operating condition.

11. Each driver's privilege to operate a vehicle on official business extends only as long as the driver operates the vehicle in a safe and efficient manner. A record of "preventable" accidents shall result in appropriate disciplinary action.

12. Employees performing work that requires the operation of a County vehicle must notify their immediate supervisors if their license expires, is suspended, or is revoked. Failure to report shall be cause for disciplinary action.

13. The [Job Title] shall be responsible for coordinating County Fleet Safety and Loss Control programs in cooperation with the Risk Manager (Safety Director) and Personnel Office.

14. Supervisors and managers will select employees who will be required to drive full or part-time with care. No employee shall drive a County vehicle unless the employee’s supervisor has certified him or her to do so.

15. The Personnel Office shall maintain a Vehicle Operator Record on each employee.

16. Employees shall report all vehicle accidents and the County shall investigate the accident in accordance with related policies and procedures.

17. Vehicles shall contain appropriate warning and safety devices.

18. Employees shall not use personal vehicles on official business unless there is no County vehicle available and they obtain specific authorization to do so from their department manager.

Driver Selection, Training, Performance Evaluation & Monitoring

Driver Selection

Even when driving may be incidental to the employee’s primary job responsibilities, the consideration given to driver selection is often the most important factor that will affect County vehicle accidents. Therefore, [Name of County] expects managers and supervisors to comply with the following when hiring individuals who will drive vehicles:

Evaluate driver qualifications through the following:

• Previous Employer’s Reference -- Check to verify employment and to help determine the driving qualifications and history of the applicant.

• Motor Vehicle Records -- Check through the Secretary of State

• Personnel File if current employee -- Review to consider driver training received, record of preventable accidents, driving history, driving certifications, vehicle operator record, etc.

Managers and supervisors may consider drivers of County vehicles as qualified to drive when they

• Possess a valid driver's license of the proper class and a driving record that meets all performance and other standards specified in this administrative policy

• Are capable of passing a physical examination when a question of fitness to drive arises because of illness or injury

• Are capable of passing written tests on driving regulations whenever required

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• Are capable of passing driving tests

• Have demonstrated proficiency with the particular type of vehicle or equipment they will routinely operate.

Managers and supervisors must examine applicants’ driving records carefully and consistently as a routine part of the screening, background investigation, and hiring process. They must:

• Reject applicants with poor driving records for positions that require vehicle operation. The following is a partial list of conditions or convictions that should cause immediate concern:

o Two at fault accidents in the past three years, or

o Two minor traffic convictions in the past three years, or

o A combination of one at fault accident and one minor traffic conviction in the past three years, or

o Operating under the influence of liquor or drugs, or

o Operating with an unlawful blood alcohol content, or

o Failure to stop or report an accident, or

o Negligent homicide, manslaughter, assaults involving the operation of a motor vehicle, or

o A suspended or revoked license

• Verify that applicants possess, or are eligible to obtain, any special license endorsements the law requires for the type or types of vehicle they will operate in performing their duties. Here we speak primarily of the Commercial Driver’s License (CDL) requirements.

o Determine the candidate’s physical and mental fitness to operate motor vehicles after extending a job offer.

o The Personnel Office shall maintain a Vehicle Operator Record in each employee’s personnel file. Supervisors are responsible for reporting vehicle operator information to the Personnel Office.

Driver Training

To evaluate and assist drivers in maintaining an acceptable level of performance, [Name of County] shall periodically administer or arrange for attendance at a meeting on safe driving. This training shall take place at least annually.

Performance Evaluation and Monitoring

Drivers who perform carelessly or poorly behind the wheel may receive injuries, injure others, and contribute to decreased public confidence in the County. Therefore, managers and supervisors shall monitor and evaluate employees who operate vehicles. They must:

• Check all employees’ driving records at least annually.

• Assign a specific individual to oversee the license review and screening process. This individual should also manage the entity’s compliance with Commercial Driver’s License, federal random drug testing and other legal requirements. The review should conform to the guidelines in your motor vehicle operations policy.

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• Take appropriate corrective action for current employees with unacceptable records. Corrective actions may range from reassignment to non-driving related positions up to discharge. Falsification of information about driving records by employees is cause for immediate termination.

• Establish corrective actions necessary to restore employee to driving position and period for completion. Document actions taken.

• Forward all documentation of the annual review and the actions the supervisor has taken to Personnel.

Accident Reporting Procedures 1. An employee involved in an accident shall obtain appropriate medical treatment, if needed, as

outlined in the County’s health and safety policies.

2. The employee, if physically able, shall call for a police officer as provided in the reporting policies. The employee shall also request that all parties and properties concerned remain at the scene of the accident, if possible, until a law enforcement representative has released them.

3. Employees shall refrain from making statements regarding the accident to anyone other than the investigating police officer, representatives of the County’s, or an employee’s personal insurance provider. Employees shall limit statements to factual observations.

4. The Safety Director (or other designated individual) must receive a copy of all police reports and any accompanying statements within 48 hours. The Safety Director will report such accidents to the insurance carrier and the employee Health and Safety Committee chairperson.

5. If the collision involves an injury, the employee and his or her supervisor will file appropriate reports as provided by policy.

6. The employee shall fill out a Vehicle Accident/Incident Report within forty-eight (48) hours and submit it to his or her supervisor. The supervisor will send copies to the Safety Director for comment and then file the report with the Personnel Office for inclusion in the employee's personnel file.

7. If the accident may result in someone alleging liability against the County, the Safety Director shall also file the report with the insurance carrier. If the accident is serious, the Safety Director should report it to the insurance carrier immediately.

8. The employee shall report damage to the vehicle on the "Auto Accident Notice" form available from his or her supervisor.

9. The employee shall submit to a drug test as specified by policy.

Fleet Inspection and Maintenance

To protect the safety of employees and increase their productivity, reduce accidents, extend the life of the fleet, and maintain good public relations [Name of County] requires regular inspections and maintenance of vehicles as an important part of its Fleet Program.

Management

The management of [Name of County] supports the inspection and maintenance program. They will assure that adequate funding is available for the program and will hold managers and supervisors accountable for assuring that the program is well established and adequately supervised.

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Managers and Supervisors

Managers and supervisors are responsible for

1. Supporting the inspection and maintenance program -- they must ensure that the program is adequately supervised and effective. This includes controlling the maintenance-operations schedule so that it provides safe equipment for operational needs.

2. Providing equipment, tools, and adequate shop facilities necessary for the program to work

3. Ensuring that maintenance personnel receive training that upgrades their knowledge and job skills through County meetings, retraining sessions, special and manufacturers' schools

4. Supervising drivers to assure that they participate and comply with fleet inspection and maintenance requirements -- this may include establishing an incentive and award program to encourage employee participation and compliance.

Drivers

Drivers are responsible for the condition and safe operation of their assigned vehicles. [Name of County] requires drivers to check their vehicles for possible defects and report them according to policy.

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Driver Road Testing Program

Setting up the Course

Road testing is one means of determining how a driver applicant will perform once you employ him or her. A standardized road test should require applicants to handle the routine road hazards that they are likely to encounter daily as drivers for your organization (or department). Therefore, you should first plan the course on a map. The course should include streets, alleys, expressways, back roads, bridges, grades, overpasses, school zones, railroad crossings, controlled intersections, left turns, right turns, backing, and parking situations. An ideal test run will cover 10 to 20 miles.

Establishing Performance Standards

Measure the effectiveness of the road test by having several of your best drivers run the course. Use their average score to serve as a standard for qualification.

Administering the Road Test

Check the driver’s license of the applicant to determine that he or she has the license necessary for the class of vehicles he or she will operate. Provide the driver with a map of the course and give him or her instructions. Let the driver get the feel of the vehicle and become familiar with the controls by proceeding with the yard test of pre-tripping, backing, and parking before pulling onto the road.

Give directions for the route well in advance to avoid last minute maneuvers. Do not distract the driver with unnecessary conversation during the test.

Evaluating the Driver

The road test has three categories.

• Qualified - Meets your organization’s performance requirements.

• Needs Improvement - Demonstrates marginal performance that training can improve.

• Unqualified - Does not meet organization’s standards.

Since most drivers will not have a perfect score, you should use the road test results as a basis for future remedial driver training to upgrade their performance.

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Preventable Motor Vehicle Accidents

The National Safety Council's definition of a preventable accident is:

"A preventable accident is any occurrence involving a [Name of County] owned or operated vehicle which results in property damage and/or personal injury, regardless of who was injured, what property was damaged, to what extent, or where it occurred; in which the driver in question failed to do everything he reasonably could have done to prevent the occurrence."

Intersections

The driver is responsible for approaching intersections prepared to take such action as is necessary to avoid accidents, regardless of the actions of other drivers. Failing to obey the law or to heed traffic control devices on the other driver's part does not automatically make the accident non-preventable. In making a determination, you should consider the driver’s failure to take every precaution before entering the intersection. Rule an accident preventable if a driver fails to check cross traffic to determine that vehicles are going to stop, or if he forces the right-of-way instead of yielding.

You must carefully review accidents involving special intersections such as alleys, driveways, plant entrances, etc., to determine what action the driver could have taken to avoid the accident. Many of these intersections are blind and the other driver's vision is blocked. Therefore, you can consider the failure to slow down, sound a warning, or yield the right-of-way sufficient cause to rule the accident preventable.

Changing Traffic Lanes

Passing is a voluntary action and failure to pass safely indicates that the driver made a faulty judgment or a lack of consideration of all the factors affecting the maneuver. Actions of oncoming traffic or of the traffic the driver is passing do not excuse him or her. The driver should anticipate and consider these actions before starting the maneuver.

The professional driver yields to a passing vehicle by slowing down or moving to the right when necessary to avoid a sideswipe or cutoff.

Lane encroachment accidents on the highway or in merging traffic indicate an unwillingness to yield to vehicles or to wait for a safe break in traffic. Blind spots are not a valid excuse. The driver must use extra caution to allow for areas of limited vision.

The driver can avoid "squeeze plays" involving fixed objects or other vehicles by dropping back when it is apparent the other driver is forcing the issue or contesting a common portion of the road.

Pulling away from a parked position is a change of traffic lane and, as such, places responsibility on the driver pulling out. Any accident that results from your driver's actions while pulling out from the curb is preventable.

Failure to observe any of these defensive-driving techniques should result in a rating of preventable.

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Front-End & Rear-End Collisions

The driver can prevent front-end collisions by always maintaining a safe following distance. Tailgating is one of the most frequent causes of accidents and is never excusable. Regardless of abrupt or unexpected stops or actions of the driver ahead, the driver must be able to stop safely. The driver must pay attention to the road ahead to anticipate the actions of the vehicle in front. The driver should adjust his or her speed at night so that the stopping distance is no greater than the forward distance illuminated by the headlights.

Drivers risk having a car behind strike them by failing to maintain a safe following distance. Failure to signal intentions or failure to slow down gradually for traffic signals or grade crossings, thus trapping the following driver, should be cause for ruling the accident preventable.

Rolling back into a vehicle is the result of not keeping the vehicle under control and is preventable.

Backing

With rare exceptions, backing accidents always receive a rating of preventable. Even when a person is guiding the driver, the driver is responsible for backing safely. The guide is just an aid and cannot control the movement of the vehicle. The driver must make check clearances for him.

Turns

Any time a driver leaves a traffic lane, the complete responsibility for the maneuver is his or hers. Signaling is not enough. The driver must check traffic on both sides and to the rear carefully before making a change. “'Squeeze plays” resulting from left or right turns are the responsibility of the driver making the turn. If a driver fails to signal, signals too late, fails to properly position for the turn, to check mirrors before and during the turn or to take any other necessary defensive action, the resulting accident is preventable.

Accidents involving turns by other drivers require careful investigation. If the non-turning driver fails to recognize that a turn was pending from the actions of another vehicle and thus did not respond accordingly, or if he or she tried to force the right-of-way, the lack of defensive driving means the accident is preventable.

You should rule any accident involving a U-turn on your driver’s part to be preventable.

Vehicles Going in Opposite Direction

The head-on or sideswipe accident involving vehicles going in opposite directions is one of the most difficult to classify. Only by learning the exact actions of each vehicle prior to the accident can you determine whether the actions and maneuvers of the opposing vehicle should have given your driver adequate warning of a possible involvement.

If the opposing vehicle was passing and intruded into your driver’s lane and he or she failed to slow down, stop, or pull to the right, then the resulting accident is preventable because your driver failed to take proper defensive measures.

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In making a determination you should also consider whether the passing driver warned the other driver by horn or flickering headlights.

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Mechanical Failure

Before starting a trip, a driver should inspect the vehicle and report unsafe conditions. The driver should obtain immediate repairs if continued operation could cause an accident. If a mechanical failure that the driver should have reasonably detected causes an accident, the accident is preventable.

If a mechanical defect occurs or develops during a trip the driver should notify management. If the driver continues the trip without such notification and an accident results, then the accident is preventable.

Abusive driving that creates abnormal strain and leads to mechanical failure resulting in an accident is also preventable.

Weather

Rain, fog, snow, ice, and sleet do not cause accidents. They are environmental conditions to which the driver must adjust. Failure to adjust driving properly to the existing conditions or to get off the road if conditions are severe should be sufficient to decide that the accident was preventable. If the driver fails to use the appropriate weather-related equipment that you provide is a failure to adjust to conditions and any resulting accident to truck, cargo or property should receive the rating of preventable.

Fixed Objects

You should consider collisions with fixed objects such as low overheads, buildings, poles as preventable accidents. Asking a bystander's opinion on clearance does not relieve the driver of his responsibility. Resurfaced pavement causing low overhead and other changes in conditions along a route are not valid excuses.

Pedestrians, Bicycles, Motorcycles

The law generally considers that pedestrians have the right-of-way over vehicles even though their actions may be unorthodox. Shopping areas, school zones, play areas and areas of congested pedestrian traffic require reduced speeds; in many cases much below the posted limits. Rule any accident that results from the driver “going too fast for conditions" to be preventable.

Bicycles, mopeds, and motorcycles frequently perform sudden, unexpected maneuvers. A driver, who fails to reduce speed, pull over, or otherwise take precautions when this type of equipment is near, has failed to take proper defensive driving measures and the accident is preventable.

Parked Vehicles

Even though your vehicle is stationary, an accident can be preventable. Unconventional parking locations, crooked parking, double parking, failure to put out warning devices, and so on reveal a lack of defensive driving. These actions make an accident preventable.

You should consider roll-a-ways of a parked vehicle to be preventable in almost all cases. Failure to block the wheels properly, to turn the wheels against the curb, or to take any other precaution to avoid vehicle movement demonstrates a lack of defensive driving techniques. Therefore, you should consider any accident resulting from such failure as preventable.

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Non-Collision

Jack-knifing, over-turning, running off the road are generally the result of emergency action taken to avoid collision. Examine the driving immediately preceding the accident to determine whether the driver's speed was unsafe for conditions or if he or she was tailgating or driving in some other manner that did not permit him or her to keep the vehicle under control. Committing any of these errors results in the judgment that the accident was preventable.

You should judge dropping an improperly secured trailer when pulling out preventable if the driver could have foreseen the occurrence during his pre-trip inspection.

You must consider passenger accidents that do not involve collisions as preventable if they resulted from faulty driving.

Passenger injuries resulting from evasive action to avoid a collision are preventable if the driver failed to use defensive driving techniques, which would have eliminated the need for sudden or violent action. You must consider sudden starts or stops, speeding over bumpy roads, fast turns, and abrupt acceleration when operating a passenger vehicle as unsafe driving, even though such maneuvers would be acceptable with other types of vehicles. Any accidents resulting from such actions are preventable.

Damage to property or persons from projecting loads, losing part of a load, parts of the vehicle being loose (chains, doors) are preventable if the driver failed to properly secure them, or if the driver failed to secure them tightly during pre-trip inspection.

You should rule cargo damage resulting from violent maneuvers to avoid collision preventable if driving defensively would have eliminated the need for violent action. Damage caused by sudden starts, stops, fast turns, or speeding over bumpy roads, must be considered as a failure to adjust to conditions and is preventable.

Violations of Law or Your Organization’s Policy

If your driver violates the law or the organization’s policy and the violation contributes to or causes an accident, then the accident is preventable. This refers not only to moving vehicle violations, but also to technical violations such as the use of drugs to stay awake, lack of the required hours of sleep, or time off between trips.

Accident Situations Not Described

For any accident not described, you should apply the same type of reasoning as illustrated by the National Safety Council's definition of a preventable accident to it.

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Vehicle Struck From Behind

Have any of your County’s vehicles been struck in the rear? Many times these "non-preventable” accidents are really preventable because there is something your driver could have reasonably done to avoid the accident. Here are four things you can train your drivers to do to avoid this type of accident.

5. Signal Your Intentions

Use your directional signals (or arm signals) and brake lights.

6. Stop Smoothly

Come to a slow, smooth stop to alert a vehicle behind you that you are stopping. Abrupt stops might not give the driver behind you adequate warning that you are stopping.

7. Stay Away from Tailgaters

• Never allow a tailgater to make you angry. Simply slow down or move to the right. This generally encourages the driver to pass you.

• Increase the following distance between your vehicle and the one ahead of you. This will eliminate the need to brake suddenly and reduce the chance of a tailgater striking you.

• Force the driver to slow down, thereby making it easier for him to stop safely when you stop.

8. Avoid A Rear-End Collision When Stopped

Most rear-end collisions result from a driver striking your vehicle stopped in traffic. This may happen to you when you stop behind a driver who intends to make a left turn. To avoid another car striking you in the rear while stopped in traffic:

• Keep a foot on the brake to activate the brake lights.

• Stop at least 10 feet behind the vehicle ahead to prevent any domino effect. A good way to do this is to stop so you can see the rear tires of the vehicle ahead.

• Keep lights on at dusk or in rain and snow.

REMEMBER: The best "DEFENSE" against being rear-ended is to maintain adequate distance between you and the vehicle ahead of you.

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Sample Seat Belt Policy

(County Name) recognizes that seat belts are extremely effective in preventing injuries and fatalities in motor vehicle accidents.

Wearing your seat belt can reduce your risk of dying in a motor vehicle accident by up to 60%. We care about our employees and want to make sure that no one is injured or killed in a tragedy that could have been prevented by the simple use of a seat belt.

Therefore our county policy is that all employees must wear seat belts when operating any vehicle or equipment on county business.

All employees and their family members are strongly encouraged to wear seat belts whenever they are driving or riding in any vehicle at any time. Whether on or off the job, we don’t want to see you hurt.

Employees who violate this policy will be subject to disciplinary action, up to and including termination.

________________________________ ___________

Employee Signature Date

________________________________ ___________ Supervisor Signature Date

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Sample Usage of Wireless Communication Devices While Driving Policy

Employees are prohibited from using any cell phone, PDA or any wireless communication system (whether or not it is owned by the county) while:

1. operating any county owned vehicle, including off-road heavy equipment, at any time, to include both working and non-working hours.

2. operating any vehicle, including off-road heavy equipment, not owned by county while in the performance of his/her duties.

3. operating any vehicle, including off-road heavy equipment, while engaging in any business related to county operations.

Employees who must utilize cell phones, PDA or any other wireless communication system shall do so only after safely exiting traffic and parking the vehicle safely off the road. The vehicle shall remain parked off the roadway until all communication has been completed.

If the Appointing Authority determines the use of such communication and devices is a vital necessity of performing one’s job duties, the employees may be authorized to utilize the devices with a hands-free option.

In no circumstances may a county employee type, text or read any cell phone, PDA or any wireless communication system while operating any vehicle as described herein.

Employees who violate this policy and are involved in accidents or charged with traffic violations caused by or resulting from the use of a cell phone, PDA or wireless communication system while driving, are solely responsible for liabilities that result from such actions and are acting outside the line and scope of their duties.

In addition to compliance with this policy, all employees are expected to follow applicable state, federal and local laws or regulations regarding the use of cell phones and PDAs at all times.

Discipline:

Failure to follow this policy shall…… (each county will need to provide for discipline for those found to be violating the policy.)

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Ergonomics Program Repetitive Motion Injury Reduction

(Name of County) has developed this injury reduction program after recognizing that repetitive motion injuries are a major component of loss control and injury prevention.

Before we can control hazards, we must discover them. Monitoring is an effective means of acquiring hazard information. Monitoring comprises a set of observation and data collection methods that we use to detect and measure deviations from plans and procedures in current operations. Simply put, looking and deciding is a better process.

Monitoring is important to ascertain:

• That controls are functioning as intended;

• That workplace modifications have not altered conditions so that controls no longer function effectively; and

• That new problems have not crept into the workplace since we introduced the most recent controls.

Monitoring should involve four functions: hazard analysis, inspection, measurement, and accident investigation. A review of hazard recognition maybe warranted before becoming involved with repetitive motion injuries

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Ergonomics Fitting the Job to the Employee

In recent years, there has been a dramatic increase in the occurrence of cumulative trauma disorders (CTDs), or repetitive motion disorders, and other work-related injuries and illnesses due to ergonomic hazards. As a result, the number of OSHA penalties issued against employers for these types of ergonomics-related safety and health violations have increased.

Voluntary guidelines were developed, published, and distributed to assist employers in developing abatement programs for ergonomic hazards: OHSA's recommended ergonomics program includes the following four major program elements: worksite analysis, hazard prevention, medical management, and training and education.

In an effort to help employers and employees better understand ergonomic hazards, this program briefly examines the types of work patterns that may cause various CTDs and other musculoskeletal or nervous system disorders resulting from ergonomic hazards, and the methods employers can use to control or prevent their occurrence.

The term "ergonomics" means the study of work. Ergonomics helps adapt the job to fit the person, rather than forcing the person to fit the job. Adapting the job to fit the worker can help reduce ergonomic stress and eliminate many potential ergonomic disorders. The objective of ergonomics is to adapt the job and workplace to the worker by designing tasks, workstations, tools, and equipment that are within the worker's physical capabilities and limitations.

Ergonomics focuses on the work environment and items such as the design and function of workstations, controls, displays, safety devices, tools, and lighting to fit the employees' physical requirements and to ensure their health and well-being. It may include restructuring or changing workplace conditions to reduce stressors that cause CTDs and repetitive motion injuries.

Major causes of many current ergonomic problems are technological advances such task that are more specialized, increased repetition of tasks, and a lack of ergonomically designed technologies. Consequently, workers' hands, wrists, arms, shoulders, backs, and legs are subject to many repetitive twisting, forceful, or flexing motions during a typical workday. Some jobs still expose workers to excessive vibration and noise, eyestrain, repetitive motion and heavy lifting. In many instances, machines, tools, and the work environment are of poor design, placing undue stress on workers' tendons, muscles, and nerves. In addition, workplace temperature, cold and heat extremes may aggravate or increase ergonomic stress. Recognizing ergonomic hazards in the workplace is an essential first step in correcting the hazards and improving worker protection.

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Ergonomics Effects on Workers

Ergonomic stressors cause a variety of disorders and illnesses. The following paragraphs describe ergonomic hazards that affect the health of workers. Below are descriptions of some of the common types of cumulative trauma disorders, such as carpal tunnel syndrome, tendonitis, De Quervain's disease, and trigger finger, along with examples of jobs in which CTDs may occur. Other topics include hearing loss, back disorders, the range of potential health effects related to operating video display terminals (PCs), and the contribution of temperature stress to ergonomic disorders. This information should help employers and employees eliminate ergonomic hazards by identifying and assessing CTDs in the workplace.

Cumulative Trauma Disorders

Cumulative trauma, ore repetitive motion disorders, are disorders of the musculoskeletal and nervous systems which may be caused or aggravated by repetitive motions, forceful exertions, vibration, mechanical compression (hard and sharp edges), sustained or awkward postures, or by exposure to noise over extended periods of time.

CTDs can affect nearly all tissues--the nerves, tendons, tendon sheaths, and muscles, with the upper extremities being the most frequently affected. These painful and sometimes crippling injuries develop gradually over periods of weeks, months, and years, and result from repeated actions such as twisting and bending the hands, arms, and wrists. A common risk factor among these disorders is the use of force combined with repetitive motion over time.

Today, we recognize that CTDs are a major occupational health hazard in the workplace and account for the largest share of occupational illnesses known as "repeated trauma" disorders, according to the Bureau of Labor Statistics.

The most common occupational diseases associated with CTDs are tendon disorders such as tendonitis, tenosynovitis, De Quervain's disease, trigger finger, Raynaud's syndrome, and carpal tunnel syndrome.

Tendon disorders are very common and often occur at or near the joints where the tendons rub against ligaments and bones. The most frequently noted symptoms of tendon disorders are a dull aching sensation over the tendon, discomfort with specific movements, and tenderness to touch. Recovery is usually slow, and the condition may easily become chronic if steps do not occur to eliminate the cause.

• Tendonitis is a form of tendon inflammation that occurs when a muscle or tendon is repeatedly tensed from overuse or unaccustomed usage of the wrist and shoulder. With further exertion, some of the fibers that make up the tendon can actually fray or tear apart. The tendon becomes thickened, bumpy, and irregular in certain areas of the body and the injured area may calcify. Without rest and sufficient time for the tissues to heal, the tendon may become permanently weakened. Tendonitis is common among press operators, welders, painters, and workers using hand tools.

• Tenosynovitis is an inflammation or injury to the synovial sheath surrounding the tendon. These sheaths secrete synovial fluid that acts as a lubricant to reduce friction during movement. Repetitive motion using the hands and wrists may provoke an excessive secretion of synovial fluid with the sheath becoming swollen and painful. We know that high levels of repetitions per hour may produce symptoms associated with tendon sheath irritation in the hands.

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• With De Quervain's Disease, the tendon sheath of the thumb is inflamed. De Quervain's Disease is attributable to excessive friction between two thumb tendons and their common sheath. Twisting and forceful gripping motions with the hands, similar to a clothes-wringing movement, can place sufficient stress on the tendons to cause De Quervain's Disease. Housekeepers and other employees that must grasp items often perform these kinds of motions.

• Trigger Finger, another tendon disorder, is attributable to the creation of a groove in the flexing tendon of the finger. If the tendon becomes locked in the sheath, attempts to move that finger will cause snapping and jerking movements. The palm side of the fingers is the usual site for trigger finger. This disorder is often associated with using tools that have handles with hard or sharp edges. Carpenters and construction laborers are at risk of developing trigger finger.

• Reynaud's Syndrome, or white finger, is damage resulting from the blood vessels of the hand being subject to repeated exposure to vibration for long periods. The skin and muscles are unable to get the necessary oxygen from the blood and eventually die. Common symptoms include intermittent numbness and tingling in the fingers; skin that becomes pale, ashen and cold; and eventual loss of sensation and control in the fingers and hands. Exposure to extremely cold weather intensifies the condition. This illness is associated with the use of vibrating tools over time--e.g., pneumatic hammers, chain saws, and gasoline powered tools. After long-term exposure--perhaps 10 or 15 years working six to seven hours a day with vibrating tools--the blood vessels in the fingers may receive permanent damage. There is no medical remedy for white finger. If the fingers are fairly health, the condition may improve if exposure to vibration stops or is reduced.

• Other types of vibration may affect the entire body, producing overall fatigue and potential permanent damage. Vibration in conjunction with prolonged sitting may also result in degenerative changes in the spine. For example, drivers of tractors, trucks, buses, construction machines, and other heavy equipment may suffer from low back pain, and permanent abdominal, spinal and bone damage.

Carpal Tunnel Syndrome (CTS)

Another CTD that has received increased attention in recent years is carpal tunnel syndrome (CTS), which affects the hands and wrists. CTS is the compression and entrapment of the median nerve where it passes through the wrist into the hand--in the carpal tunnel. The median nerve is the main nerve that extends down the arm to the hand and provides the sense of touch in the thumb, index finger, middle finger, and half of the fourth or ring finger. When irritated, tendons housed inside the narrow carpal tunnel swell and press against the nearby median nerve. The pressure causes tingling, numbness, or severe pain in the wrist and hand--often felt at night. In addition, the pressure results in a lack of strength in the hand and an inability to make a fist, hold objects, or perform other manual tasks. If the pressure continues, it can damage the nerve, causing permanent loss of sensation and even partial paralysis.

CTS develops in the hands and wrists from repetitive and/or forceful manual tasks performed over a period. Many repetitive motions per day with no variations place stress on the wrists and hands, which can result in CTS.

Today, more than half of all US workers are susceptible to developing CTS. Anyone whose job demands a lot of repetitive wrist, hand, and arm motion - not always forceful or strenuous - might be a potential victim of CTS.

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In addition, employees are often unaware of the causes of CTS and do not know what they should do about them. They do not associate their pain with their work. When workers finally seek medical help, the medical provider may give the wrong diagnosis and the road to recovery takes more time and money than they had anticipated.

CTS is common among carpenters and PC operators. Since the early 1980's, there have been widespread reports CTS among many service-sector employees, including office workers who use PCs. CTS, among other health effects, is becoming a growing problem among PC users because of the numerous repetitive motions of key stroking data into the computer over long periods.

Back Disorders

Another CTD that accounts for a significant loss of productivity and large compensation costs to industry is back disorders. Next to the common cold and flu, a back disorder is the reason most often cited for job absenteeism.

Pulled or strained muscles, ligaments, tendons, and disks are perhaps the most common back problems and many occur to almost half of the work force at least once during a lifetime. Back disorders are included in this booklet as an ergonomic hazard because of the majority of workplace back disorders result from chronic or long-term injury to the back rather than from one specific incident.

When back muscles or ligaments are injured from repetitive pulling and straining, the back muscles, disks, and ligaments can become scarred and weakened and lose their ability to support the back, making additional injuries more likely.

Back disorders are frequently caused by cumulative effects of faulty body mechanics: excessive twisting, bending and reaching; carrying, moving, or lifting loads that are too heavy or too big; staying in one position for too long; poor physical condition; and poor posture.

Prolonged sitting stresses the body, particularly the lower back and the thighs, and may cause the lower back (lumbar) region to bow outward if there is inadequate support. This abnormal curvature (called kyphosis) can lead to painful lower back problems, a common complaint among office workers.

According to one source, truck drivers have the highest incidence of back injuries probably due to prolonged sitting in one position and from prolonged exposure to vibration. Many workers, however, may be at risk of developing back disorders, including those in industries such as construction, transportation, and health care.

Hearing Loss

According to data from the Bureau of Labor Statistics, noise-induced hearing loss is a disorder associated with repeated trauma. The degree to which hearing is affected depends on the intensity, frequency, duration of exposure, and individual susceptibility. Noise-induced hearing loss occurs gradually and can cause irreversible damage to the inner ear. Excessive noise in the workplace also is annoying and can affect worker performance. Research has shown that exposure to excessive noise also causes stress on other parts of the body resulting in increased muscle tension, a quickened pulse rate, and increased blood pressure. Workers exposed to noise sometimes experience nervousness, sleeplessness, and extreme fatigue.

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OSHA's occupational noise standard prohibits employers from exposing unprotected workers to noise exceeding an eight-hour time weighted average of 90 decibels and requires "engineering controls" or "administrative controls" to comply with the standard. The standard also requires a hearing conservation program that provides workers with personal protective equipment, such as earmuffs or plugs, to protect their hearing, wherever exposure is above an 8-hour time weighted average of 85 decibels.

Other Stressors

Other workplace stressors, such as temperature extremes, may increase the risk of ergonomic disorders. Recent studies have shown that work related accidents increase with both higher and lower workplace temperatures. Where temperature extremes require workers to use more force in performing their jobs, ergonomic stress and risk of ergonomic disorders may also increase. For example, cold temperatures can affect a worker's coordination and manual dexterity, thus requiring more effort and additional manual force to perform the same task or to maintain productivity levels. Likewise, hot and humid conditions may cause excessive fatigue or reduce the employee's work capacity, resulting in increased ergonomic stress. Such conditions may also require a worker to apply more force or effort in gripping hand tools or in using other equipment, which may further increase ergonomic stress and risk of ergonomic disorders.

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Ergonomics Hazard Prevention and Control

Worksite Analysis

The implementation of any sound occupational safety and health program, including a program to prevent and reduce ergonomic hazards, must include management commitment and employee involvement. There must be a visible involvement of top management showing that it has a serious commitment to such a program. Management commitment provides the organizational resources and motivating forces that are necessary to deal effectively with ergonomic hazards. This commitment also must provide for and encourage employee involvement in the ergonomics program and in decisions affecting their own safety and health. Employee involvement and feedback through clearly established procedures such as through employee health and safety committees, is an effective way both to identify existing and potential hazards and to develop and implement effective ways to abate such hazards.

Through this commitment and involvement, employers can develop effective ergonomic programs, which should include worksite analysis, hazard prevention and control, medical management, and training and education.

You should also develop procedures and mechanisms for evaluating the implementation of the ergonomics program and for monitoring its progress. Effective implementation also requires a written program for job safety and health as well as ergonomics that clearly establishes and communicates the employer's goals and plans.

Worksite analysis identifies problem jobs and risk factors associated with them. This essential preliminary step helps employers determine what jobs and workstations are the sources of the greatest problems. The most effective worksite analysis will include all jobs, operations, and work activities where there are ergonomic risk factors, regardless of whether the employer's medical records indicate ergonomic illnesses.

A thorough worksite analysis is important in order to successfully prevent or reduce all of the various ergonomic hazards to which a worker may be exposed. Workers exposed to an ergonomic hazard may develop a variety of symptoms and symptoms may be the result of a combination of problems that may exist in a single job or work station. For example, research has shown that various symptoms among PC operators result from problems in machinery, workstation, office environment and job design, or a combination of these. In addition, PC operators have experienced eyestrain, headaches, excessive, as well as neck, back and muscle pain, and stress. A comprehensive analysis of the worksite will identify the interplay of how various ergonomic hazards affect workers.

Prevention of ergonomic hazards entails the effective design of a job or jobsite and the tools or equipment used in that job. Based on information from the worksite analysis, an employer can establish procedures to correct or control ergonomic hazards using the appropriate engineering controls, equipment design or redesign; work practices; administrative controls; and if necessary, personal protective equipment.

Engineering Controls

Engineering controls are the preferred method of control since the primary focus of ergonomic hazard abatement is to make the job fit the person, not force the person to fit the jobs. You can accomplish this by designing or purchasing workstations and tools or equipment that are ergonomic.

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Workstations should have an ergonomic design to accommodate the full range of required movements among workers. Moreover, the design should accommodate the workers who are actually using them to perform the job--not just for the "average" or "typical" worker. The design of the workstation should permit the worker to adopt several different but equally healthful and safe postures that still permit performance of the job; there should be sufficient space for the knees and feet. Worktables and chairs should be height adjustable to provide proper back and leg support. Use seat cushions to compensate for height variation when chairs or stools are not adjustable. There should be definite and fixed space for all tools and materials.

Workstations that include PC terminals should have an ergonomic design for both computer and non-computer work. PC workstations should have adjustable and detachable keyboards, display screens that tilt up and down, brightness and contrast controls, and flexible copyholders that reduce the distance between the screen and source material. Install proper lighting and anti-glare filters to prevent glare from the PC screen; Place PCs in the workplace to minimize or diminish glare.

Eyestrain is the single largest category of complaints among PC users. Eyestrain is often worse for employees doing "intensive" work looking at an "interactive" terminal all day or continuously looking back and forth between hard copy and the screen. In addition, excessive overhead illumination that causes glare on the PC screen can result in eye irritation, eye fatigue, headaches, and blurred vision. At present, however, there is no evidence linking PC work to any permanent visual damage.

PC operators should have chairs that have armrests to support the wrists and forearms during prolonged keying that do not interfere with adjusting the chair or moving it close to the desk or work surface. It is important, therefore, that chair design accommodates the height and contour of the human body. Similarly, computer components such as the monitor, keyboard, and work surfaces should be at comfortable heights to prevent pain and stiffness in the neck, arms, back, shoulder, wrists, and hands.

To avoid back injuries, workstations should have design that allows lifting the load using both hands with the worker's chest facing the load. The workspace design should enable a worker to avoid the need for carrying objects overhead or for overreaching. For example, workstations design should enable workers to lift heavy loads at a height of 18 inches from the floor. In addition, workstations, jobs and processes should reduce or eliminate repeated manual lifting. You can accomplish this by incorporating mechanical lifts, and hand trucks where possible. It is also important that the work tools and equipment are of an ergonomic design. Most hand tools are designed for only occasional use, not for repetitive use over prolonged periods. When acquiring tools for regular use in an industrial setting, an employer should consider the following ergonomic features:

• Tools should be lightweight and the handle design should allow a relaxed grip so the wrists can remain straight.

• Tools should allow use with either hand and be of various sizes so both men and women can use them.

• The shape of tool handles should enable contact with the largest possible surface of the inner hand and fingers as well as conform to the functional anatomy of the hand. Avoid tool handles with sharp edges and corners.

• Select power tools to reduce the amount of human force and repetition required. Whenever possible, counterbalance the weight of the tool to make it easier to handle and to reduce vibration.

• To reduce tool vibration, fit special absorbent rubber sleeves over the tool handle.

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In addition to proper design of workstations, tools and equipment, maintenance of tools and equipment also is essential in helping to prevent or reduce ergonomic hazards. Maintain tools within the manufacturer's specifications, and keep tools sharpen. Proper maintenance also can help reduce vibration resulting from prolonged equipment operation.

Work Practices

An effective program for ergonomic hazard prevention and control also includes procedures for safe and proper work practices that managers, supervisors, and employees understand and follow. Key elements of a good work practice program include proper work techniques, employee training and conditioning, regular monitoring, feedback, maintenance, adjustments and modification and maintenance. For example, following proper lifting techniques can minimize back strain and injuries. Keep floors as clean and dry as possible to prevent slips and falls, and to help prevent back strain and injuries. Passageways should be free from obstructions that can result in accidents and injuries to the back.

Administrative Controls

Administrative controls also are an important element of an ergonomics program since they reduce the duration, frequency, and severity of exposure to ergonomic hazards. Provide frequent breaks or job rotation to reduce repetitive hand and body movements. Providing employees with short breaks every hour, when necessary, will help to reduce or avoid stress and back strain.

Personal Protective Equipment

Personal protective equipment may also be necessary to help prevent or reduce ergonomic hazards. For example, when vibrating tools are used, dampen vibration by using rubber-backed, low-pile carpet sections on the work surface. Employees may also wear gloves to reduce the effects of vibration and force. Select personal protective equipment with ergonomic stressors in mind so that such equipment reduces rather than contributes to ergonomic hazards. For example, as with proper workstation design, appropriate protective equipment should be of a design that fits the worker rather than force the worker to fit the equipment. Provide equipment in a range of sizes that accommodates the physical requirements of workers and the job and does not contribute to extreme posture or excessive force. Choose gloves carefully so that employees do not have to use excessive grip strength, which would add to ergonomic stress.

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Ergonomics Medical Management

Medical management is another important element of an effective ergonomics program. Proper medical management can assist employers in identifying and evaluating early signs and symptoms of CTDs and help eliminate or reduce the risk of developing CTDs. For example, to prevent various eyestrain problems, provide PC operators with optometric testing within the first six months of working on the PC and with periodic eye examinations to determine whether they need new or special glasses. In addition, to prevent future problems caused by CTDs, employers can establish standard procedures for the medical management of work-related illnesses or injuries.

Medical Program Issues

The following issues should be included in any ergonomics-related medical management program:

• Injury and illness recordkeeping

• Early recognition and reporting of CTD symptoms

• Systematic evaluation and referral

• Conservative treatment; restricted duty jobs, when necessary

• Systematic monitoring, including periodic workplace walkthroughs

• Adequate staffing and facilities

• Employee training and education

• Access to health care providers for employees

Proper training for physicians and occupational health professionals in the prevention of CTDs can help provide proper treatment to workers, monitor problems within the workplace, and maintain and provide updated information.

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Ergonomics Training and Education

Training programs will go a long way toward increasing safety awareness among both managers and employees. The purpose of training and education is to ensure that employees know enough about the ergonomic hazards to which they have exposure so they are better able to participate actively in their own protection. Suggestions and input form workers who are educated about ergonomic hazards can be very helpful in designing improved work practices to reduce ergonomic hazards.

A good ergonomic training program teaches employees how to use equipment, tools, and machine controls properly and shows them the correct way to do a variety of job tasks. As excessive force on joints and tendons is a principal cause of CTDs, you should train workers that they should keep their wrists straight and their elbows bent at a right angle while using tools requiring manual force. All side-to-side twisting of their wrists should be avoided, and their hands should be kept in line with their forearms while using tools or operating equipment. Employers should provide the appropriate controls or tools, as necessary, to reduce or eliminate deviations in the wrists.

To minimize or prevent back disorders, workers should be taught proper postures and lifting techniques. Using correct posture is important whether an employee is sitting, standing, pulling, pushing, lifting, or using tools or equipment. Training workers in general lifting techniques also can help reduce the strain leading to some kinds of back disorders. These techniques include the following: Avoid bending over to lift a load; instead, use the leg muscles to bend the knees to pick up and lower heavy loads. When lifting, keep the chin tucked in toward the load and use both hands to lift the load. Always keep a firm handgrip on the load to prevent unnecessary strain. Lift slowly in a smooth continuous motion. Avoid fast, jerky movements, and never lift or carry a heavy load above the shoulders. Avoid twisting at the waist when lifting a load. If turning is necessary, pivot on the feet. Twisting the upper body increases the risk of sprains and strain.

Conclusion

Ergonomists, industrial engineers, occupational safety and health experts, and other trained individuals believe that at least one-half of all workplace safety and health problems will undergo reduction by changes in ergonomic conditions. Those experts can learn to anticipate what might go wrong and alter the tools and environment to make the task safer in ergonomic terms.

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Ten Steps to Repetitive Motion Injury Reduction Job description should include physical requirements. Create an effective medical management program for cumulative trauma disorders including

pre-employment physicals. Periodic walk-through surveys should be conducted every month or whenever a particular job

task changes. Trained professional or health care providers should participate in the training and education of

all employees. Develop a working disciplinary policy for violations. Employees should be encouraged by supervisors to report early signs and symptoms of CTDs to

department heads. Job analysis completed for all "at risk" positions. Hazards appropriately addressed by management. Accident investigations conducted for all incidents and recorded on OSHA 200 Form. Program audit system in place and audit conducted at least annually.

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Bloodborne Pathogen Program

Purpose

Employers must prepare an infection control plan for all employees who handle, store, use, process, or disposes of infectious medical wastes. This infection control plan complies with OSHA requirement, 29 CFR 1910.1030, Blood Borne Pathogens. The plan includes requirements for personal protective equipment, housekeeping, training, and a procedure for reporting exposures.

Responsibilities

• The County Nurse or Physician will conduct the Bloodborne Pathogen Program and maintain records of training and inspections for this program.

• Management will ensure proper conduct of the program though inspections, record keeping and periodic audit.

Definitions

Biological Hazard -- The term biological hazard or biohazard means any viable infectious agent that presents a risk, or a potential risk, to the well being of humans.

Medical Wastes/Infectious Wastes -- All waste emanating from human or animal tissues, blood or blood products or fluids. This includes used first aid bandages, syringes, needles, sharps, material used in spill cleanup and contaminated PPE or clothing.

Universal Precautions --The term refers to a system of infectious disease control that assumes that every direct contact with body fluids is infectious. Therefore, employers must provide employees exposed to body fluids with protective equipment as though such body fluids carry blood-borne pathogens. Employees must handle all infectious/medical material according to Universal Precautions (OSHA Instruction CPL 2-2.44A)

Hazards

Unprotected exposure to body fluids presents the possible risk of infection from a number of bloodborne pathogens notably Hepatitis and HIV.

Hazard Control

Engineering Controls - prevention of exposure to bloodborne pathogens engineering controls include proper storage facilities and containers as well as disinfecting equipment.

Administrative Controls - prevention of exposure to bloodborne pathogen administrative controls include universal precautions, assignment of PPE, employee training, use of spill kits specifically designed for blood and body fluids, restricted access to waste collection points and waste disposal procedures.

Reporting and Record Keeping

(Name/title) will maintain any records that OSHA requires. We will maintain all reports (Training Certificates, Notice of HBV Vaccinations, exposure reports) for 30 years. We will record occupationally contracted HBV or HIV on the OSHA 300 Log of Occupational Injuries and Illnesses as an illness. We will record exposures to bloodborne pathogens from contact with sharps or body fluids on the OSHA 300 Log of Occupational Injuries and Illnesses if a physician prescribes treatment such as gamma globulin, hepatitis B immune globulin or hepatitis B vaccine.

Safety Manual



Training

All employees designated as first aid responders, first aid station personnel, and all custodial employees will receive initial and annual training by a qualified medical practitioner on the Bloodborne Pathogen Program.

All new and current affected employees will receive training at hire and before work assignment and annually thereafter. The content of the training program will include:

1. County Policy

2. Types and transmission of Blood-Borne Pathogens

3. General Safety Rules

4. Universal Precautions

5. Use of Personal Protective Equipment

6. Medical Waste Disposal Procedures

7. Post Exposure Treatment and Procedures

8. HBV Vaccinations

Documentation of training will be by Control of Blood-Borne Pathogens Training Certificate

All Employees not affected by this Program will receive an overview of the program requirements during scheduled department Safety Meetings with documentation by Safety Meeting Minutes Form.

Hepatitis-B Virus (HBV) Vaccinations

We will offer those employees who designated as first aid providers, first aid station personnel, and custodians or who have emergency response duties the Hepatitis-B Virus (HBV) vaccinations at County expense. Employees that transfer to a job or their job is reclassified to include exposure to blood-borne pathogens will be offered HBV Vaccinations within 10 working days of the transfer or reclassification.

HBV vaccination is not mandatory. If employees choose not to have the vaccination at the initial offering, they will have the opportunity to receive the vaccination when they are ready. The County will document the offer, acceptance or declination, and vaccination dates with the Notice of HBV Vaccinations Form.

Post Exposure Treatment and Notification Procedures

If an affected employee or an employee acting as a "Good Samaritan" has occupational exposure to HIV/HAV/HBV, the affected employee will report the exposure to (Name/Title). The County will arrange for the employee to undergo tests for HIV/HAV/HBV at County expense. Following the initial blood, employees who are seronegative will receive additional tests at six weeks, 12 weeks and six months to determine if transmission has occurred. During this period, the employee will follow the recommendations provided by the Physician.

An "occupational exposure" is a blood or body fluid contact from an injured or ill employee, vendor, or client to the affected employee or injury by a contaminated sharp object.

Following the report of exposure, (name/title)) will contact the exposure source and request that person undergo testing for HIV/HAV/HBV at County expense. The request is not mandatory and if refused will not affect that employee's future employment.

Whenever possible, we will arrange and pay for testing of the source individual's blood after we have obtained consent to determine HBV and HIV infectivity. (Hepatitis B surface Antigen, Hepatitis C Antibody and HIV Screen)

Safety Manual



During all phases of Post Exposure, we will maintain the confidentiality of the affected employee and exposure source on a "need to know basis". The results of any HIV/HAV/HBV tests conducted will be provided to the exposed and source employees within five business days of receipt.

General Procedures

We will provide and employees must use resuscitation equipment, pocket masks, resuscitation bags, or other ventilation equipment to eliminate the need for direct mouth-to-mouth contact when resuscitation is necessary.

Employees must not eat, drink, smoke, apply cosmetics or lip balm, or handle contact lenses in work areas where there is a potential for exposure to any health hazard.

Employees should wear the County provided protective clothing whenever there is a possibility that body fluids could splash on skin or clothing.

Gloves must be made of appropriate disposable material, usually intact latex or vinyl. Employees must use them in the following circumstances:

When the employee has cuts, abraded skin, chapped hands, dermatitis, or similar conditions

When examining abraded or non-intact skin of a patient with active bleeding.

While handling blood or blood products or other body secretions during routine laboratory procedures.

Employees must wash their hands immediately, or as soon as possible, after removal of gloves or other personal protective equipment and after hand contact with blood or other potentially infectious materials.

Employees must remove all personal protective equipment immediately upon leaving the work area, and if it is overtly contaminated, place in the designated area or container for storage, washing, decontamination, or disposal.

Medical Wastes

Medical/infectious waste, except for sharps (i.e., razor blades, broken glass, needles, etc.) capable of puncturing or cutting, must be contained in double disposable red bags conspicuously labeled with the words "INFECTIOUS WASTE" and "BIOHAZARD."

Infectious sharps must be contained for disposal in leak-proof, rigid puncture-resistant containers. Infectious waste contained as described above must be placed in reusable or disposable leak-proof bins or barrels that are conspicuously labeled with the words "INFECTIOUS WASTE" and "BIOHAZARD."

Disinfect all infectious agents, equipment, or apparatus before washing or disposing of them.

Floors and other surfaces that may be contaminated must be disinfected with a suitable germicide, such as 1:9 household bleach as often as necessary as determined by the supervisor.

Cuts

If employees have a cut or mucous membrane exposure to another person’s body fluids, they must report the incident immediately to (name/title).

Blood Exposure

All employees exposed to human blood and blood products must report to the (name/title) for information and possible inclusion in the Hepatitis B Immunization Program.

Infection Control Plan

The purpose of the Infection Control Plan is to protect the health and safety of the persons directly involved in handling the materials, County personnel, clients, vendors, and the general public by ensuring

Safety Manual



that we handle, store, and dispose of infectious medical waste SAFELY. This plan complies with OSHA requirement proposed for 29 CFR 1910.1030, Bloodborne Pathogens.

Universal precautions: Refers to a system of infectious disease control that assumes that every direct contact with body fluids is infectious and requires every employee exposed to be protected as though such body fluids were infected with blood-borne pathogens. All employees must handle infectious/medical material according to Universal Precautions (OSHA Instruction CPL 2-2.44A).

Employees must take the following universal precautions:

1. Gloves must be made of appropriate disposable material, usually intact latex or vinyl. Employees must use them:

a. when the employee has cuts, abraded skin, chapped hands, dermatitis, or the like.

b. when examining abraded or non-intact skin of a person with active bleeding.

2. Employees must wear gowns or aprons when splashes of body fluid on skin or clothing are possible.

3. Mask and eye protection are required when contact of mucosal membranes (eyes, mouth or nose) with body fluids is likely to occur (e.g. splashes or aerosolization).

4. We will provide pocket masks and resuscitation bags to eliminate the need for direct mouth to mouth contact.

Waste Disposal Plan

1. Employees must separate potentially infectious waste from other waste at the point of origin.

2. Employees should place potentially infectious waste, except for sharps (e.g. razor blades, broken glass, needles, etc.) capable of puncturing or cutting, in double disposable red bags conspicuously labeled with the words, "INFECTIOUS WASTE -- BIOHAZARD."

3. Spills/Disinfectants: Use a solution of household bleach diluted 1:9 with water to disinfect, following initial cleanup of a spill with a chemical germicide approved as a hospital disinfectant. Spills must be cleaned up immediately.

7. After removing gloves and/or after contact with body fluids, employees must wash hands and other skin surfaces thoroughly and immediately with soap or other disinfectant in hot water.

9. Liquid biohazard waste may be disposed of in the sewage system following chemical decontamination.

Appendix

Appendix

Accident Cause Analysis Worksheet

INSURED _____________________________________LOCATION _______________________________

ACCIDENT ANALYSIS PERIOD: FROM _______________________TO _____________________________

ACCIDENT CAUSES

UNSAFE ACTS NO. *% OF TOTAL

UNSAFE CONDITIONS NO. *% OF

TOTAL

IMPROPER HANDLING OF MATERIALS SLIPPERY FLOORS/STAIRS/AREAS

IMPROPER LIFTING DEFECTIVE FLOORS/STAIRS/AREAS

IMPROPER USE OF TOOLS OR EQUIPMENT INADEQUATE GUARDING

INATTENTION IMPROPERLY STORED MATERIALS

TAKING AN UNSAFE POSITION ROUGH OR UNEVEN SURFACES

FAILURE TO WEAR PROTECTIVE EQUIPMENT POOR HOUSEKEEPING

CLEANING OILING, AND ADJUSTING, ETC WINDBLOWN OR FLOATATION DUST

MOVING MACHINERY DEFECTIVE TOOLS OR EQUIPMENT

OTHER: UNSAFE DESIGN OR ARRANGEMENT

OTHER:

TOTALS TOTALS

3. *TOTAL NUMBER OF CAUSES-UNSAFE ACTS & UNSAFE CONDITIONS _____________________

2

INJURY SUMMARY

INJURY NUMBER PART OF BODY INJURED NUMBER

BRUISES EYES

CUTS & PUNCTURES HEAD

STRAINS TRUNK

EYE INJURIES ARMS

FRACTURES HANDS

DISMEMBERMENTS FINGER

DERMATITIS LEGS

BURNS FEET

SLIVERS TOES

MULTIPLE OTHER:

FATALITIES

OTHER:

NO. RECORDABLE INJURIES/ILLNESS

LOST WORKDAYS

HRS. WORKED BY ALL EMPLOYEES

INCIDENCE RATE RECORDABLE

INCIDENCE RATE LOST WORKDAYS

MONTH Per Month

Cum.

Per Month

Cum.

Per Month

Cum.

Monthly

Cum.

Monthly

Cum.

TOTALS

Personal Protective Equipment for Worker Protection Against HIV and HBV Transmission

TASK GLOVES APRON MASK EYEWEAR

Control of Bleeding w/ spurting blood X X X X

Bleeding control with minimal bleeding X

Emergency Child Birth X X X X

Blood Drawing X

Handling & Cleaning Instruments X

Cleaning Bio Spills X

Taking Temperature

Giving Injection X

Measuring Blood Pressure

The examples provided in this table are based on application of universal precautions. Universal precautions are intended to supplement rather than replace recommendation for routine infection control, such as hand washing and using gloves to prevent gross microbial contamination of hands (e.g., contact with urine or feces).

4

Self-Evaluation: Safety Program Effectiveness Written Safety and Health Program

NOTE: The Occupational Safety and Health Department has developed this form to guide employers and

employees as they develop a system to address workplace safety and health.

The employer’s workplace shall reflect the written system in its daily work practices and in the documentation of activities involving safety and health. Name: Address: Phone: Nature of Operations: Facility Manager: Safety & Health Employer Rep. Safety & Health Employee Rep: Management Commitment This work site meets its management commitment to safety and health through: (Check all that apply and place documents at end of this program.)

Written safety and health program with duties and accountability.

Designated safety and health person/department with duties and budget

Records showing safety and health goal setting and progress made

Safety and health performance as a part of regular employee/supervisor evaluation

Safety and health meetings, toolbox talks, agendas, minutes, actions taken

Safety and health suggestion/promotion/incentive programs

Employee Safety/Health Handbook (procedures, practices)

Posts OSHA poster

Management takes action on identified safety and health concerns.

Management sets, enforces, and follows safety and health rules.

Employee Involvement This work-site arranges for employee participation in the safety and health program through: (Check all that apply and place documents at the end of this program.) Employees represented on Safety and Health Committee including: (agendas, actions taken,

minutes).

Written employee hazard reporting system or suggestion program with action taken.

Negotiated safety and health contract language.

Designated employee safety and health representatives

Employees participate as trainers, inspectors, and problem-solvers.

Employer has documented completed or underway worker/manager safety and health projects.

Employees have input into the arrangement and content of safety and health training (including Toolbox Talks).

Process for employees to report hazardous conditions to job sites supervision.

Work Site Analysis

This work site tracks worker safety and health both before and after exposures and/or incidents through: (Check all that apply and place any documents at the end of this program.)

Log 300 properly maintained.

Form 301 properly filled out, including corrective actions

Accidents and near misses investigated with corrective actions and follow-up

Copies of written inspections and surveys (insurance company, private consultant, fire department, in-house) as required by Labor or Health Standard (i.e., hearing conservation)

Job safety and health analysis/written job descriptions with safety and health responsibilities

Ergonomic analyses

County has safety and health as a priority when planning, designing, or implementing a job, task, or process

A designated person makes regular work site inspections to identify hazardous conditions and initiate correction

6

Hazard Prevention and Control

This work site carries out an active program of identifying and controlling hazards through: (Check all that apply and place documents at the end of the program.)

Written system to assure guards, housekeeping and PPE are essentially in place.

Maintenance and repair schedules, orders, receipts for safety and health products

Written programs and procedures: lockout, respirator, Right-to-Know, confined space, infection control, asbestos, benzene, lead, hearing conservation, forklift permits, as required in place

Written disciplinary action against employees and/or supervisors for safety and health infractions, including remedies and follow-up

Timely reports of hazards and corrective actions

Safety work procedures.

Copies of OSHA standards

Engineering controls in place, ventilation, isolation, reflective

Shields, special tools, fixtures

First aid, return to work, light duty, medical controls, and emergency preparedness in place.

Employees and supervisors can state hazards of task/tool and safe work procedures.

Employees are aware firm has method for identification and correction of hazards and can recall examples.

Supervisors correct and reinforce safe and healthful work practices as part of daily routine.

Safety and Health Training

This work site provides information on safety and health protection to employees through: (Check all that apply and place documents at the end of this program.)

Training records: dates, trainees, and subjects

New employee training program

Standards based training in place: Right-to-Know, noise, lockout, lift truck, confined space, ergonomics, infection control, asbestos, Haz-power, tools, PPE, first air (documented).

Safety literature, bulletin board, posters, stickers

Apprentice or other off-site safety and health training can be documented

Supervisors can explain rules, procedures, for safety and health and how they teach and enforce them

Employees can explain how and why to do their jobs in a safe and healthful manner

Training takes place periodically and pertains to the hazards of the job

Employee Training - Sample Checklist

New Employee Training New employees will receive orientation after hire but before beginning actual work. The following is a checklist for training new employees:

Discussion of general safety rules

Explanation of safety rules and regulations

Discussion of safety devices

Reporting unsafe conditions and making suggestions about safety

Behavior on the job and rules of conduct

Proper lifting techniques

Safety awareness

Reporting injuries

First aid/CPR & (if applicable) Automated External Defibrillator (AED)

Required Personal Protective Equipment maintenance and use

Storage of materials and general housekeeping

Proper use of equipment

Hazardous materials and employee Right-To-Know

Departmental specific issues and performance based competency testing

Viewing of orientation video

8

Important Contact Information

Name Phone

Doctor:

Hospital:

Ambulance:

Insurance Co.

Claims Rep.

Fire Dept.

Police

EMS

Name of County (and/or Department):

List of Hazardous Chemicals

Hazardous Chemicals Operation/Area Used MSDS on File

10

Material Safety Data Sheet Checklist

You must ensure that each MSDS contains the following information:

YES NO REQUIREMENT

Product or chemical identity used on the label

Manufacturer's name and address

Chemical and common names of each hazardous ingredient

Name, address, and phone number for hazard and emergency information

Preparation or revision date

The hazardous chemical's physical and chemical characteristics, such as vapor pressure and flash point

Physical hazards, including the potential for fire, explosion, and reactivity

OSHA/OSHA permissible exposure limit (PEL), ACGIH threshold limit value (TLV) or other exposure limits

Emergency and first aid procedures

Whether OSHA, NTP, or IARC lists the ingredient as a carcinogen

Control measures such as engineering controls, work practices, hygienic practices, or personal protective equipment required

Primary routes of entry

Procedures for spills, leaks, and clean up

Hazard Communication -Training Checklist

Yes No REQUIRED ELEMENTS

Complete training program in place

Identification of employees who need training

Training provided before employee’s first assignment

Employee given specific information and training requirements of the Hazard Communication Standard

Employees receive training on the requirements of the standard, including a written program, and their rights under the law

Describes the different types of chemicals we use and the hazards associated with them

Instructs employees on the specific hazards of the chemicals and processes they work with and their proper use and handling

Informs employees of the hazards associated with performing non routine tasks

Teaches employees how to detect the presence or release of hazardous chemicals in the workplace

Provides training in the use of proper work practices, personal protective equipment and clothing, and other controls to reduce or eliminate employee exposure to the chemicals in their work areas

Provides training in emergency and first aid procedures and signs of overexposure

Provides a list of all the hazardous chemicals in our workplace in a readily accessible location

Employees responsible for this task know when and how to update hazardous chemical list

Have a material safety data sheet for each hazardous chemical in the workplace

Training explains how to use an MSDS

Provides employees with information about the list of hazardous chemicals and MSDS and where they can read them

Training explains labels and their warnings to employees

Includes a system to ensure that employees check all incoming hazardous chemicals for proper labels and data sheets

Contains procedures that ensure proper labeling or warning signs for containers that hold hazardous chemicals

Includes procedures for identifying and informing employees of new hazardous chemicals before introducing the chemicals into a work area

Procedure in place for informing employees of new hazards associated with the chemicals they already use

Includes method for evaluating the effectiveness of the training program and tracking who has received training

12

HEAD HAZARDS

Falling objects Flying Objects Electrical Hair entanglement Hot surfaces Chemicals Other: __________________________

EYE HAZARDS

Flying particles Molten Metal Chemical splash Electrical Sparks Weld flash Dust & dirt Other:

FACE HAZARDS

Impact hazards Heat Torch cutting Casting Welding High temperature Chemical exposure Other:

HEARING HAZARDS

Loud process and/or equipment Air and electrical impact tools Forging Logging Tree trimming Other:

FOOT HAZARDS

Falling objects Rolling Objects Wet process area Logging areas Powered lawn equipment Other: __________________________

HAND HAZARDS

Skin absorption Punctures Severe cut or laceration hazards Chemical or thermal burns Other: __________________________

BODY HAZARDS

Wet process area Chemical Sand blasting Buffing Polishing Hot liquids (water, grease, acids, etc.)

Other:

BREATHING HAZARDS

Spray finishing Fumes Vapors Dust Welding Foundries Permit required confined spaces

Other:

13

Employee Acknowledgement of PPE Training The following individual has received PPE, has been fit-tested, and has attended training. Employee: ____________________________________ Training Date: _________________ Name of Trainer: _____________________________________________________________ The following is a list of the PPE that this employee has received.

I acknowledge that I have received the above named equipment. I have had the opportunity to be properly fitted. I also acknowledge that I understand the training my employer provided. ________________________________________ Employee’s Name (Printed)

________________________________________ _____________________________ Employee’s Signature Date

Type of PPE

Date Issued

Manufacturer

Model

Serial or other #

14

Personal Protective Equipment -- Hazard Assessment County Name: ________________________________________________ Date of Assessment: ___________________ Site of Evaluation: _______________________________________________ Name of Person Completing the Assessment: ___________________________________

Job Classification or Workstation Hazard Source & Type Body Part Affected PPE Required Yes or No Type of PPE Required

15

Personal Protective Equipment Worksheet

Employer: Location: Workplace Assessed: Date(s): Hazards Assessed By:

EYE HAZARDS? YES NO REQUIRED PPE -- EYE

Frontal & side impact

Electrical arc

Molten metal

Chemical splash

Injurious light/heat radiation

Suspended particles

Extreme hot/cold splash

Other:

FACE HAZARDS? YES NO REQUIRED PPE -- FACE

Projectile impact

Chemical splash

Hot/cold splash

Electrical arc

Injurious heat radiation

Other:

Other:

FOOT HAZARDS? YES NO REQUIRED PPE -- FOOT

Falling objects

Rolling objects

Electrical contact

Sole puncture

16

Personal Protective Equipment Worksheet

HAND HAZARDS? YES NO REQUIRED PPE -- HAND

Barrier

Bump contact

Chemical burns

Cover

Electrical contact

Extreme Cold

FALL HAZARDS? YES NO REQUIRED PPE

Gloves

Hair enclosures

HEAD HAZARDS? YES NO REQUIRED PPE -- HEAD

Hood

Hoods

Insulating blanket

Lanyards

Lifelines

Line hose

Matting

Overhead falling objects

Puncture

Safety belts

Safety Harness

Severe abrasions

Severe lacerations

Side flying projectiles

Skin absorption

Sleeves

SPECIAL ELECTRICAL HAZARDS? YES NO REQUIRED PPE

Thermal burns

17

Personal Protective Equipment Training Log

Name Date Employee # TRAINER TRAINED IN PPE

18

Certification of Safety-Related Personal Protective Equipment Hazard Assessment

Employer: Location:* Workplace Assessed/Evaluated Dates: Name of Person Conducting Assessment:

This document certifies that ____________________________ has performed the PPE Hazard Assessment that OSHA requires.

Name of Person Certifying

Or type of work if employees do not work in fixed locations

19

Employee Notification of Noise Level Employee name:

Department: Unit:

Date of noise monitoring: As part of our ongoing efforts to ensure that our employees work in an environment which is as safe and hazard-free as possible, [Name of County] recently monitored you (your area) for occupational exposure to noise. Results obtained from this monitoring indicate your exposure level to be ___________ db, measured as an 8-hour TWA. The results of this monitoring indicate your exposure to be at, or above the “action level”, (85 DBA) which triggers a program of hearing conservation. Therefore, [Name of County] policy requires your participation in a program of hearing conservation that includes the following: 1. An audiometric test (a test that measures your ability to hear) 2. Selecting appropriate hearing protectors from those the County provides that you must wear while

performing your job. 3. Participation in a training program for hearing conservation Your Department Safety and Health Coordinator will contact you concerning these points. If you have any questions concerning any of the above, [Name of County] is available to discuss them with you at a mutually convenient time. The County expects and appreciates your continued cooperation in this important area of employee safety and health.

As evidenced by my signature below, I acknowledge receipt of this test data. Employee Signature Date

20

Audiological Examination

NAME: DATE: TIME: AM PM

DEPARTMENT: UNIT: SHIFT:

AGE: BASELINE:

FOLLOW-UP:

AUDIOGRAM (Check one box for each question) YES NO 1. Do you wear hearing protection while at work? 2. Do you have frequent headaches? 3. Have you had a cold in the last 2 or 3 weeks? 4. Have you had an ear infection in the last 2 or 3 weeks? 5. Have you ever had any sharp pain in the ears? 6. Have you had a hearing loss? 7. Do you have a ringing in the ears? 8. Any hobbies with loud noises involved (e.g., hunting, shooting, etc.)?

If “YES,” please specify:

RIGHT LEFT

2,000

3,000

4,000 NAME OF DOCTOR WHO CONDUCTED REVIEW: _______________________________________

COMMENTS:

DATE OF CALIBRATION: ________________ Discussed the following with the employee: YES NO 1. Adverse effects of noise 2. Demonstration of ear protectors 3. Care of ear protectors 4. Ear protectors recommended 5. Type of hearing protection recommended PLUGS MUFFS

EXAMINER’S SIGNATURE: DATE:

21

Employee Notification of Audiometric Test Results EMPLOYEE NAME: DATE OF AUDIOGRAM: DEPARTMENT: UNIT: As part of [Name of County]’s ongoing hearing conservation program, you were recently given an audiometric test. This test measures your ability to hear and detects any changes in your hearing ability. Check Applicable Boxes

In comparison with your baseline at time of hire your audiogram is normal.

Your current exam shows a standard threshold shift from the basal exam. You are required to wear hearing protection whenever you may have exposure to noise on and off the job. You have received training in the types of protection and instructed in their use.

Baseline will remain the same.

Repeat audiogram will become the revised baseline.

Repeat audiogram is required within 30 days. As evidenced by my signature below, I acknowledge receipt of this test result. Employee Signature Date

22

Respirator Use - Identification & Location of Exposures Worksheet Location Operation Contaminants Exposure Date

23

Respirator Selection Information Worksheet General Information

1. Work Description/Operation:

2. Anticipated Use Time:

3. Worker Activity Level:

4. Work Area Locations:

5. Work Area Characteristics:

6. Location of Hazardous Area Relative to Safe Area: ____________________________________ Specific Information

1. Oxygen content: ________ %

2. Air Contaminants: Chemical Name: Trade Name: Physical State (dust, fume, mist, gas, vapor):

3. Exposure Limit:

OSHA 8 hr. TWA: OSHA Ceiling: ACGIII 3 hr. TWA: ACGIII Ceiling: NIOSH 8 hr. TWA: NIOSH Ceiling: Other:

4. Warning Properties:

Eye Irritation Concentration: Respiratory Irritation Concentration: Odor Threshold Concentration:

5. IDLH Concentration:

6. Can substance be absorbed through skin? Yes No

7. Can substance cause skin irritation? Yes No

8. Chemical Properties:

Vapor Pressure: Lower Flammable Limit: Upper Flammable Limit:

9. Sorbent Efficiency:

10. Minimum Protection Factor Needed:

24

Respirator Selection Summary

Location

Operation

Respirator

Use

Air Contaminants

NIOSH Approval

25

Respirator Training Record

Name Department Respirator Type Use Date

26

Employee Training Record Part One

(Duplicate for each training session) Date: Trainer: ________________________________

Training Methods Used: _____________________________________________________________________

___________________________________________________________________________________

Training Session Time Length: ___________________________________________________________

Trainer Qualifications: ___________________________________________________________________

Person Filling Out Form: ____________________________________________________________ Employees Present:

Name (Printed) Signature

27

EMPLOYEE TRAINING RECORD Part Two – Attach to Part One

(Duplicate for each training session)

YES NO

Did employee wear a properly fit tested respirator?

Did employee have hands on training?

Were several types of respirators available?

Did employee receive an explanation for respirator selection?

Was respirator actually selected comfortable?

Did employee first try the respirator in normal atmosphere?

Did employee practice respirator use in test atmosphere?

Did employee receive an explanation of

The work process and the potential occupational hazard requiring respirator use

Of the potential physical and health effects of the occupational hazard

Of the engineering and administrative controls

The respirator functions and limitations

Cleaning and disinfection procedures

Proper maintenance and repair procedures

Correct storage methods

Emergency procedures for all contaminant(s), potential occupational hazards and work processes

Was respirator the exact one that employee will use? Is this an initial training session?

Is this a review training session?

Did supervisors and employees receive training?

After training, was there an assessment of employee competency?

What form did the assessment take? Did the employee achieve a satisfactory level? What type of respirator(s) did the employee use? :

28

Respirator Use & Maintenance Record

Respirator Type:

Manufacturer:

Model Number:

Date Placed in Service:

Assigned to:

Inspection and Maintenance Record:

Date Serviced By

29

Machine Guarding Check List Answers to the following questions should assist you in determining safeguarding requirements at a workstation or in evaluating potential machine guarding exposures.

Date: Department:

Workstation:

Requirements for All Safeguards Yes No

1. Do the safeguards provided meet the minimum OSHA requirements?

2. Do the safeguards prevent workers’ hands, arms, and other body parts for making contact with dangerous moving parts?

3. Are the safeguards firmly secured and not easily removable?

4. Do the safeguards ensure that no object will fall into the moving parts?

5. Do the safeguards permit safe, comfortable, and relatively easy operation of the machine?

6. Can the machine be oiled without removing the safeguard?

7. Is there a system for shutting down the machinery before safeguards are removed?

8. Can you improve existing safeguards be improved?

Mechanical Hazards

The point of operation:

1. Is there a point-of-operation safeguard provided for the machine?

2. Does it keep the operator’s hands, fingers, and body out of the danger area?

3. Have you uncovered evidence of tampering or removal of the safeguards?

4. Could you suggest a more practical, effective safeguard?

5. Can you modify the machine to eliminate the point-of-operation?

Power transmission apparatus:

1. Are there any unguarded gears, sprockets, pulleys, or flywheels on the apparatus?

2. Are there any exposed belts or chain drives?

3. Are there any exposed setscrews, key ways, collars, etc.?

4. Are starting and stopping controls within easy reach of the operator?

5. If there is more than one operator, are there separate controls?

Other moving parts:

1. Are there safeguards for all hazardous moving parts of the machine including auxiliary parts?

Non-Mechanical Hazards

Yes No

1. Are appropriate measures to safeguard workers against noise hazards in place?

2. Have special guards, enclosures, or personal protective equipment been provided, where necessary, to protect workers from exposure to harmful substances used in machine operation?

30

Electric Hazards

1. Is the machine installation in accordance with National Fire Protection Association and National Electrical Code requirements?

2. Are there loose conduit fittings?

3. Does the machine have proper grounding? 4. Is the power supply correctly fused and protected? 5. Do workers occasionally receive minor shocks while operating any of the machines?

Training

1. Do operators and maintenance workers receive appropriate training on why machines have safeguards and on how they should use them?

2. Have operators and maintenance workers received training in where the safeguards are located, how they provide protection, and the hazards against which they protect?

3. Have operators and maintenance workers received training in how and under what circumstances, they can remove guards?

4. Have workers received training in the procedures to follow if they notice guards that are damaged, missing, or inadequate?

Protective Equipment and Proper Clothing

1. Is protective equipment required?

2. If protective equipment is required, is it appropriate for the job, in good condition, kept clean, sanitary, and stored carefully when not in use?

3. Is the operator dressed safely for the job (i.e., no loose-fitting clothing or jewelry)?

Machinery Maintenance and Repair

1. Have maintenance workers received up-to-date instruction on the machines that they service?

2. Do maintenance workers lock out the machine from its power sources before beginning repairs?

3. When several maintenance persons work on the same machine, are multiple lockout devices in use?

4. Do maintenance persons use appropriated and safe equipment in their repair work?

5. Does the maintenance equipment itself have proper guarding?

6.

Have maintenance and servicing workers received training in the requirements of 29 CFR 1910.147, lockout/tagout hazard, and are the procedures for lockout/tagout completed before they attempt their tasks?

31

Vehicle Inspection Form

Vehicle Number Date Inspected Time Inspected Vehicle Year/Make/Model: Department: Driver’s Signature:

TIRES

Tire treads depth adequate for safety Inflation pressure adequate and equal X four No cracks, cuts or other damage evident Rims undamaged

WHEELS Lug nuts inspected and tightened Hubcaps secure or removed Oil level adequate Coolant level adequate (caution if engine hot)

ENGINE COMPARTMENT Brake fluid level adequate Battery condition acceptable Power steering fluid level adequate All belts tight and undamaged Brake system operation Steering system operation

VEHICLE INTERIOR Restraint systems operational Occupant hazards (sharp/protruding objects) Loose objects secured or removed

TRUNK Spare tire and jack secured or removed Unsecured items removed Emergency lights (overheads and/or wigwags) Headlights Taillights and brake lights

LIGHTING/WARNING EQUIPMENT Directional signals Spotlights Horn Siren (or simulator)

FUEL LEVEL TOPPED OFF Body Damage Noted:

Maintenance Comments/Notes:

32

Vehicle Check -- Repair Request

Vehicle #

Date

Operator Mileage

CHECK ITEMS WITH DEFECTS ONLY (X). Explain defects under REMARKS.

GENERAL CONDITION BEHIND THE WHEEL

Body, doors, window Gauges

Leaks Emergency Equipment

Windshield wiper, washer Heater/Defroster

Mirrors Horn

EXTERIOR Steering wheel

Head lights, tail lights Seat Belts

Signal brake lights ENGINE COMPARTMENT

Tires, wheels, spare Fluid levels

Exhaust Clutch

Suspension Belts

Emergency flashers Service Brake

Parking, emergency brake

Battery REMARKS:

REPORTING DRIVER MAINTENANCE

Repairs made

No repair needed

By

Date

33

Driver's Road Test

Driver's Name: Department:

License No: State:

Qualified For:

Auto Truck Tractor

This is to certify that __________________________, an applicant for a driving position, took a road test under my

supervision on ___________consisting of approximately __________miles of driving. In my opinion, this driver has

does not have sufficient driving skill to operate safely the type of commercial vehicle listed above.

Driver Supervisor _______________________________________________ Date _________________________ Department ___________________________________________________

QUALIFIED NEEDS

IMPROVEMENT NOT

QUALIFIED

PRE-TRIP INSPECTION

Service brakes (Lines, fittings)

Parking (hand) brake

Steering mechanism

Lighting devices and reflectors - headlights - high and low beam, clearance, taillights, stop lights, turn signals, reflectors, side markers, four-way flasher

Tires - Inflation, tread wear, cuts in sidewalls, mating, lugs or studs, grease leaks around hubs, mud flaps, valve caps, spare tire

Tests horn & windshield wiper(s), windows, and cleans/adjusts mirrors.

Coupling devices - fifth wheel, jaws, release lever on pintle hook, tow-bar, safety chains, converter gear, air lines

OPERATION

Putting vehicle in operation -- checks air pressure and instruments, emergency brake set, disengages clutch, warms up engine, proper gear selection, checks traffic, shifts smoothly, tests brakes

Using vehicle's controls and emergency equipment -clutch & transmission, brakes, steering, lights, tools, tire chains, emergency warning devices, fire extinguisher

Operating the vehicle in traffic and while passing other vehicles -- leaving curb, speed control, smoothness of operation, shifting gears, anticipates traffic problems, obeys traffic laws, signals properly, passes with sufficient space, and smoothly, uses mirrors

Turning vehicle - signals in advance, makes turn from proper lane, checks traffic before turning. Turns at reasonable speed into proper lane. Yields right-of-way.)

Braking and slowing the vehicle by means other than braking. Uses engine to reduce speed by shifting to lower gear smoothly.

Defensive Driving - good attitude, yields right-of-way, maintains good space cushion, slows down at intersections, and checks cross traffic at intersections

34

Compressed Gas Cylinders - Quick Quiz

Please indicate if the statement is true or false.

True False

Compressed gas cylinders can become a rocket if the valve sustains damage.

The color of a cylinder identifies what is in it.

It is important to secure gas cylinders at all times to prevent tipping.

You should keep cylinder valves closed whenever they are not in use or are unattended.

Oxygen and acetylene can be stored next to each other.

Participant Name Date:

Answers:

1. True

2. False

3. True

4. True

5. False

35

Ladder Inspection Checklist All Ladders

Consider steps or rungs loose if you can move them at all with the hand Loose nails, screws, bolts, or other metal parts Cracked, split, or broken uprights, braces, steps, or rungs Slivers on uprights, rungs, or steps Damaged or worn non-slip bases Rusted or corroded spots

Stepladders Wobbly from side strain Loose or bent hinge spreaders Stop on hinge spreaders broken Broken, split, or worn steps Loose hinges

Extension Ladders Loose, broken, or missing extension locks Defective locks that do not seat properly when the ladder is extended Deterioration of rope, from exposure to weather, acid or other destructive agents

Fixed Ladders Loose, worn, or damaged rungs or side rails Damaged or corroded parts of cage Corroded bolts and rivet heads on inside of metal stacks Damaged or corroded handrails or brackets on platforms Weakened or damaged rungs on brick or concrete slabs Base of ladder obstructed

36

Definitions

Cage: A cage or basket guard that is an enclosure that is fastened to the side rails of the fixed ladder or to the structure to encircle the climbing space of the ladder for the safety of the person who must climb the ladder.

Extension Ladder: Non-self-supporting portable ladder adjustable in length. It consists of two or more sections traveling in guides or brackets so arranged as to permit length adjustment. Its size is the sum of the lengths of the sections measured along the side rails.

Fixed Ladder: Ladder permanently attached to a structure, building, or equipment.

Individual-Rung Ladder: Fixed ladder each rung of which is individually attached to a structure, building, or equipment.

Ladder: An appliance usually consisting of two side rails joined at regular intervals by cross-pieces called steps, rungs, or cleats, on which a person may step in ascending or descending.

Ladder Safety Device: Device, other than a cage or well, designed to eliminate or reduce the possibility of accidental falls and which may incorporate such features as life belts, friction brakes, and sliding attachments.

Pitch: The included angle between the horizontal and the ladder, measured on the opposite side of the ladder from the climbing side.

Platform Ladder: A self-supporting ladder of fixed size with a platform provided at the working level. The size is determined by the distance along the front rail from the platform to the base of the ladder.

Rail Ladder: Fixed ladder consisting of side rails joined at regular intervals by rungs or cleats and fastened in full length or in sections to a building, structure, or equipment.

Railings: A railing is any one or a combination of those railings constructed in accordance with OSHA Standard 1910.23. A standard railing is a vertical barrier erected along exposed edges of floor openings, wall openings, ramps, platforms, and runways to prevent falls of persons.

Rungs: Ladder cross pieces of circular or oval cross-section on which a person may step in ascending or descending.

Section Ladder: Non-self-supporting portable ladder, nonadjustable in length, consisting of two or more sections of ladder so constructed that a worker may combine the sections to function as a single ladder. Its size becomes the overall length of the assembled sections.

Side-Step Ladder: This ladder makes an individual getting off at the top to step sideways to reach the landing.

Single Ladder: Non-self-supporting portable ladder, nonadjustable in length, consisting of but one section. Its size is the overall length of the side rail.

Special-Purpose Ladder: Portable ladder that represents either a modification or a combination of design or construction features in one of the general-purpose types of ladders previously defined, in order to adapt the ladder to special or specific uses.

Stepladder: Self-supporting portable ladder, nonadjustable in length, having flat steps and a hinged back. Its size is the overall length of the ladder measured along the front edge of the side rails.

Steps: Flat cross pieces of a ladder on which a person may step in ascending or descending.

Through Ladder: A ladder in which an individual getting off at the top must step through in order to reach the landing.

Well: A permanent complete enclosure around a fixed ladder that is attached to the walls of the well. Proper clearances for a well will give the person who must climb the ladder the same protection as a cage.

37

Back Injury Prevention Program - Essential Functions Analysis

Position Title:

Description of Function:

Purpose of Function:

Number of Employees Who Perform this Function:

Special Skills Necessary to Perform this Function:

Consequences if Function is not Performed:

Amount or Percentage of Time Spent Performing this Function

Does Collective Bargaining Require this Function?

Comments:

Analysis Conducted by:

Name Title Date

38

Back Injury Prevention Program - Job Assessment

Position Title:

Date:

Tasks Included Essential

Yes No 1. 2. 3. 4. 5. 6. 7. 8.

Physical Requirements

# of Times Hrs/Shift X/Shift Other

Lift Carry Bend Squat Climb

Physical Requirements of Essential Functions

# of Times Hrs/Shift X/Shift Other

Lift Carry Bend Squat Climb

Training Requirements:

39

Back Injury Prevention Program - Job Analysis

Position Title: ____________________________________________

Date: ______________________

Task: ___________________________________________________

Activity Physical Requirements

Tools & Equipment Used

Hazards Safe Procedure Training Indicated

40

Back Injury Prevention Program - Self-Inspection Checklist

Department: Date:

Shift:

ITEM YES NO COMMENTS GENERAL SAFETY

Employees briefed on safety policies?

Safety meetings conducted?

Safety rules enforced?

WORK AREA

Materials stored at proper height?

Floors kept dry?

Walkways free of obstacles?

Proper desk/counter height maintained?

Chairs ergonomically correct? TRAINING

All employees receive monthly training?

New and transferred employees receive

Management and supervisory staff receive

Injured employees receive additional

PERSONAL PROTECTIVE EQUIPMENT (PPE)

PPE provided?

PPE used?

PPE inspected monthly?

Use of PPE mandatory?

Use of PPE enforced?

OTHER EQUIPMENT

Necessary equipment available?

Mechanical equipment inspected daily before

Equipment properly maintained?

41

General Ergonomic Checklist

Yes No Do employees complain frequently about specific job aspects?

Are certain employees unable to perform the job because of age, gender, body strength, or other reasons?

Does this job often have breakdowns?

Have there been a high percentage of accidents as related to this job compared to other jobs?

Is productivity low?

Is there a high potential for disabling or serious injury to occur on the job?

Is absenteeism and/or turnover high?

Is this job recognized as a problem area?

What part of the body is most frequently affected by an injury? Miscellaneous comments:

42

Ergonomic Manual Material Handling Checklist Yes No Are unnecessary travel distances eliminated when moving materials? Are unnecessary motion or lifting activities eliminated when moving materials? Are walkways dry and unobstructed? Are walkways level and sufficiently wide? Are outside walkways designed as required? Is proper footwear worn-adequate traction, no slippage? Is material handling automated or mechanized as much as practical? Are tasks that impose extreme lifting requirements, even if infrequently, avoided? Where people must handle materials, have you evaluated the task to determine job requirements? If yes, are controls in place? - Is the weight reduced to a minimum? - Is the frequency of lifts reduced? - Is the vertical distance of lifts reduced? - Is the horizontal distance between the object and body minimized? - Are the lifts confined within the knuckle-to-shoulder zone? Are lifting aids provided and used as needed? Is training on lifting and safe work practices provided prior to job assignment? re weights balanced and easy to handle? Do you provide handholds for objects that workers must lift? Is twisting, pushing, pulling and carrying eliminated or minimized? Has JSA (Job Safety Analysis) been done on this job? Location: __________________________________________________________________ Department: __________________________________________________________________ Equipment: __________________________________________________________________ Job Description: _________________________________________________________________

_________________________________________________________________ Signature: _______________________________________________ Date: _____________

Ergonomic Task Design Checklist Yes No Are awkward positions or reaching tasks eliminated? Is static (prolonged muscle contraction with no movement) muscular work avoided? Are repetitive motions at a high rate (frequency or speed) avoided? Is the worker able to change his/her work posture (sitting or standing) often? Does the task avoid a variety of different working distances that may affect eye focus? Are clamps or supports for the work place available to avoid static work? Do you provide elbow, wrist, arm, foot, and backrests? Are necessary forces to be exerted within the capabilities of all employees:

Pulling? Pushing? Carrying? Twisting? Bending?

Are peak loads of a reasonable nature to avoid muscular effort? Can the stresses be reduced by using appropriate material handling equipment? Are parts or tools supplied in a correctly pre-adjusted manner? Are the tools unnecessarily heavy or massive? Are they supplied in a logical sequence? Are they within a comfortable reaching area for distance and height? Is it possible to carry out work with:

Arms and elbow in the neutral position (hanging loosely and close to the body)? Wrists in a straight position? Neck straight or less than a 15-degree angle (either forward or back)? A relaxed correct posture (in either sitting or standing position)? No extreme leaning over? No lengthy period of standing?

No extreme twisting or stretching? Minimal repetitive hand, arm, or shoulder movements in awkward positions?

Any "clothes wringing" motions of the wrist? Comments

Location: ________________________________________ Dept: _________________

Equipment: _______________________________________________________________

Job Description: ________________________________________________________________

________________________________________________________________

Signature: ________________________________________ Date: ____________

44

Ergonomic Work Space Checklist Yes No Is the height of the work surface adjustable for operators? Does the operator have the option of standing or sitting? Is the operating chair or seat comfortable? Is the chair suited to the task? Does it have adjustable height and backrest? Is it non-slippery? Is the chair stable on the floor at all times? Is the workspace adjustable for the smallest to largest worker with adequate clearance?

Heads? Arms? Legs? Feet?

Is lighting and visibility adequate? Do you provide individual task lighting where economically possible? Is the lighting bright enough? Does the work surface have even lighting? Does the lighting set-up minimize glare? Is there sufficient contrast for seeing? Comments Location: __________________________________________________________________ Department: __________________________________________________________________ Equipment: __________________________________________________________________ Job Description: _________________________________________________________________

_________________________________________________________________ Signature: _______________________________________________ Date: ____________