Osha Manager Role

Cascade ChapterAmerican Society of Safety Engineers

Safety Standards & ProceduresJanuary 2008

Standards / Procedures• Policy & Procedures• Corporate Standards

• Communications• Off-the-Job Safety

• Change Management


Review of What We Have Covered

• Various types of safety programs

• Looked at Scott Geller’s 10 Principles of Safety Management

• The role that management commitment and involvement plays in the process

• The role planning plays in the safety process


During Decembers Meeting

• The role that a Gap Analysis plays in the safety process

• How to conduct a Gap Analysis

• How effective safety processes do this annually to keep improving


Quote of the Session

Opportunity is missed by most people because it is dressed in overalls and looks like work.

Thomas A. Edison (1847 - 1931)


Safety Rules and Procedures

• Developing safety rules and procedures is an opportunity to shape our safety process

• Provides guidance for the process

• Sets the checks and balances

• Determines the route for our education.


First Quest Speaker

• Stefanie Corbitt

• Former VaOSHA Compliance Officer

• Masters in Industrial Hygiene - West Virginia University

• Worked as a safety manager in Texas

• Owns her own consulting firm – SSIOSHA in Brunswick, Georgia - email - [email protected]


The Rulemaking ProcessFederal

Three Kinds

• 6(a) Adoption of Consensus Standard

• 6(b) Permanent Standards

• 6(c) Emergency Temporary Standards


6(b) Standards Development• 6(b)(1)-(4) Procedures for Rulemaking

• 6(b)(5) Health Standards

• 6(b)(6) Temporary Variances 6(b)(7) Content of Standards 6(b)(8) National Consensus Standards


Standards Development

29 C.F.R. 1911– Request for Information– Advanced Notice of Proposal Rulemaking

(ANPR)– Notice of Proposed Rulemaking (NPRM)– Public Comment


Standards Development

• Public Hearings

• Post-hearing Comment

• Analysis

• Final Rule


Components of a Proposed Rule

Justification for Standard– Significant Risk– Material Impairment of Health– Economic Impact Analysis– Technical Feasibility Analysis– Proposed Rule


Components of a Final Rule

• Findings – Significant risk– Technical feasibility– Economic Impact

• Final Rule

• Justification for Decision

• Implementation Schedule


Challenges to a Final Rule

• Administrative Appeal

• Judicial Review– Standard for Review

• 60 days from date of publication

• Court of Appeals


Emergency Temporary Standards

• Imminent Danger

• Serious Effects

• Standard is necessary to prevent effects


Thanks Stef; Are there any questions before Stef goes to

pick up Ike?


OR-OSHA Rule Making Process

• Anyone can have a bill introduced to state legislation

• If passed OR-OSHA will adopt the rule

• OR-OSHA has to adopt a new federal rule within 90 days

• Can make changes to enhance the application for Oregon


OR - OSHA Rule Making Process

• Can Develop rules they feel are necessary to promote safety within the state

• Must prove:– Significant risk– Technical feasibility– Economic Impact

• Follows the same type of procedure as the federal process only on a state level


Standards That Require Written Programs

• Emergency Response• H2 & O2• HAZWOPER• PPE• Respiratory• PRCS• LOTO• Fire Brigades• Fire Extinguishers

• O2 Welding• Vertical Standards• Most of Subpart Z:

Asbestos, Pb, VC, Cd, Benzene, coke oven emissions, cotton dust, Acrylonitrile, Formaldehyde, MC*

• BBP• Access to Medical

Records• HCS & Lab Standard

*List not exhaustive


Additional OR-OSHA Requirements

• Safety Committee

• Written Health and Safety Plans


Things to Remember?

• All plant standards should be developed under the care and direction of a safety professional

• If the site does not have a safety professional then use insurance company Loss Control engineers, private consultants, or the OR-OSHA consultation service

• Care must be taken to understand the standard being adopted

• Must reflect the way the plant does the activity • Must be specific


What Should You Do

• Read the Standards• Consult References

– OROSHA Guidebooks, OSHA CPL, LOI, STD

– Magazines and Trade Publications– ASSE, AIHA Publication– DOD/DOE Directives and Procedures

• Adapting "canned" programs to your facility


Who Should Develop a Plant Standard?

Standards should be developed by individuals who will be required to follow them:– Safety Committee Members– Supervisors– Safety Managers (technical

assistance only)


Our Second Speaker

• Bob Riley

• Former plant Safety Manager for Mars, Incorporated at the Burr Ridge and Chicago, IL plants (over 20 years experience in the plant)

• Bob is a Haz Mat Expert

• Bob has his own consulting firm – Riley Associates – email – [email protected]


Standards and Procedures from A Safety Manager’s Perspective

• Are they really necessary?

• Are they simple and concise?

• Are they enforceable and enforced?

• Must not demand unreasonable effort?

• Was employee input used?

• Are they consistent?


Manager’s Responsibility

• Development of proper and co-operative attitudes toward safety in employees. – Personal example: The manager must set an

example by his/her personal behavior.– Enforcement

• Knowledge of safe work procedures and accident prevention techniques– Standards, SOP’s, Policy documents


Types of Standards and Procedures

• Technical– Engineering specifications– Machine Specific Lock out procedures– Confined space entry

• Behavioral– PPE compliance– “How To” SOP’s– Expectations


Safety Managers Role

• Provide technical input• Ensure that the standard or Procedure

follows current OSHA/OR-OSHA regulations

• Ensure that the procedure is feasible• Ensure that the procedure is kept up to

date• Develop appropriate communication and

training for the standard or procedure


The Managers’ Areas of Focus

• Do you reallyknow the Rules?– Educate yourselves– Educate your teams

• Take and delegate responsibility for safety standard development, implementation and enforcement – Share the knowledge and get input !

• “Walk the Talk”


Thanks Bob; Are there any Questions for Bob?


Standard Development Process• Obtain a copy of the OR-OSHA and or Federal

OSHA standard• Read and gain an understanding of the standard• Determine the application to the plant• Assemble a team of employees and managers to

assist in the writing of the plant procedure• Educate the team• Draft the procedure• Have management review the procedure• Implement the procedure (communicate it to the

plant and provide training)


Corporate – vs – OR-OSHA Procedures

• Many corporations require things that are not part of a OR-OSHA or Federal OSHA standard

• If this is the case, during an inspection the inspector will hold you accountable for compliance to your standard, not the OSHA standard


Things You Should NOT Do

• Provide copies of plant standards or procedures to a compliance officer to which that the officer is not entitled

• Give entire company safety manual to the compliance officer

• Provide the compliance officer access to a network computer containing the safety procedures


Safety Procedures Format• Develop a standard format for

safety standards and procedures• Common sections• Scope/Purpose• Responsibilities• Technical Section• Implementation• Appendix Section with forms and

support information• Review and Update section


Plant Format

• Be consistent• Title Block• Printer on date

good for one day on the bottom

INTRODUCTION TO THE ELECTRICAL WORK PRACTICES

Technical Document

(Note: Blue indicates potential link to attachment or to glossary.)

PURPOSE

This Mars, Incorporated, electrical work practices safety standard establishes procedures to protect workers from exposure to electrical shock and arc/flash burn hazards. The detailed safety-related work practices address risk reduction for both qualified and unqualified personnel working on or near energized equipment.

SCOPE

This standard applies to any Mars, Incorporated, associates; other workers; and on-site contractors who work on, near, or with electrical circuits and equipment in Mars facilities worldwide. All associates and on-site contractors must read, understand, and follow electrical safety practices as defined by this document, the local site safety requirements, and national directives. All associates and on-site contractors must follow electrical work practices (EWPs) as defined in EWP 1 and 2. The remaining EWPs are intended for associates and contractors who risk electric shock not reduced to a safe level as defined by local electrical installation and country code requirements. These are primarily associates and contractors who diagnose and troubleshoot electrical circuits. Each of these workers is required to be a Competent/Qualified person. A Competent/Qualified person is defined as an individual who is knowledgeable about equipment construction and operation and is trained in avoiding the electrical hazards of working on or near exposed energized parts. Competencies/qualifications vary as necessary to fit an individual’s job assignment. This standard does not address the specific requirements for lockout/tagout of electrical equipment. Where applicable, these requirements are addressed in Mars, Incorporated, site-specific equipment lockout/tagout (LO/TO) procedures and minor intervention instructions as described in the corporate standard Control of Hazardous Energy –Lockout/Tagout.

ROLES AND RESPONSIBILITIES

Responsibility and Accountability

The site Senior Supply Associate (SSA) has overall responsibility for implementation and adherence to this standard. The site Safety and Technical Managers will serve as Electrical Safety Program Coordinators with responsibility for day-to-day program coordination.

Managers are responsible for ensuring that all associates conform to the minimum guidelines and receive the required training to work safely around electrical equipment.


Communication of Standards and Procedures

• Establish a formal safety communication process

• Use:– safety committee members– Bulletin boards– Emails– Shift Meetings


Training

• Generic Training programs are good for communicating the basic standard information

• Each standard has specific training requirements


Change Management System

• Establish a formal Change Management system

• Document all updates and changes

• Provide information about changes to all affected employees


Policies & Procedures from a CSHO Perspective

– Is the document technically correct?– Has it been reviewed/documented?– Does it correlate to the process?– Is it followed?– Has communication & training been

implemented on the floor?


Policies & Procedures from a CSHO Perspective

• Corporate Standards exceed OSHA requirements

• Use of CPL and LOI

• Training CSHO (at your expense)


Next Month

• Checking the Safety Management System– Self Assessments– Corporate Audits– Safety Work Order Systems– Inspections & Audits– Incident Investigation– Performance Management– Open Item Tracking / Info Mgmt


Thanks for coming and have a safe month!

Business

Osha Manager Role