Virginia Occupational Safety & Health Compliance Division. Tami M. De Nio

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1 Virginia Occupational Safety & Health Compliance Division Tami M. De Nio Sr. VOSH Enforcement & Investigation Tidewater Office Norfolk, VA

2 Recordable Injuries and their Impact VOSH REQUIREMENTS FOR RECORD KEEPING OSHA IP2P Business & Budget; Loss & Risk DIRECT & INDIRECT COSTS OF AN INJURY/ILLNESS EQUIPMENT/PRODUCTION/WORKFORCE

3 Direct Costs of Injuries/Illnesses Direct costs of the most disabling workplace injuries in the U.S. averaged $47.6 billion per year between 1998 and 2008

4 Indirect Costs of Injuries/Illnesses Examples: Wages not covered by workers compensation Administrative time Costs of training replacement employees Lost productivity & manpower hours Replacement costs of damaged material Can be 1.1 to 4.5 times the direct costs

5 Core Elements Flexible, commonsense, proven tool to find and fix hazards before injuries, illnesses, or deaths occur. Six core elements: Management leadership Worker participation Hazard identification and assessment Hazard prevention and control Education and training Program evaluation and improvement

6 Recordkeeping in the Now (Mandatory) OSHA FORMS Form 301 FRI report Form 300 acts as your LOG of incidents. Form 300A a numerical summary of incidents (Non Mandatory) Continuous Improvement (analysis of incidents) Analysis (Trends) Periodic Reviews for Correction/Preventative Actions (controls)

7 To IP2P or not to IP2P? Instead of simply reporting on workplace incidents and fixing problems after the fact, I2P2 would force companies to have a system of identifying and fixing hazards before injuries or illnesses occur. Based on the successful Voluntary Protection Program (VPP), I2P2 call on businesses to: 'Find and fix' workplace hazards Engage management and employees in companywide injury and illness prevention program Employ hazard prevention analysis and controls

8 Safety & Health Mgmt System Mgmt Commitment + Employee Involvement Planning & Development, Measure & Accountability, Improvement Safety & Health Training Documents & Worksite Analysis Hazard Prevention & Controls

9 Management Commitment Management must take an active role in reviewing the effectiveness of the system to include documented near misses. If you are reviewing incidents, it s too late.

10 Employee Involvement It s all About Culture

11 Recordkeeping Not just for Incidences anymore. Yes, I did that. No, I didn t document it. Certify your Hazard Assessments, JSA s/jha s. Record Findings of Facts, Results, Troubleshooting, Measurable(s), etc. Document any concerns, suggestions, complaints, feedback, etc. that were discussed verbally. Trend Analysis on maintenance activities. Date all action items when they were completed.

12 Recordkeeping Not just for Incidences anymore. Document and Record for Analysis in order to Find and Fix Hazards ^ Machines and Equipment : PM s, Testing/Inspections, LOTO, Electrical Safety, Traffic Areas, Guarding, Security & Stability, Energy, Impact ^ Processes; Training,Housekeeping, JSA s/jha s, Safety Meetings & Reviews ^ What If s for Placing Safeguards: Worst Case Scenario, Emergency, Human Factors, Social/Environmental Factors

13 Recordkeeping Analysis

14 Clues 3 recordables on January 12 : Your HR person who is on the safety committee recalls that was the day of 10 employees were layed off. Was that the Root Cause? How did Management handle this prior, during and after? What support or provisions were given to employees who had to make up for the loss? Were Supervisors trained effectively to know how this effects production, quality and Safety? How often is Kary Grant the scheduler out in that area? If often, has he become complacent? Kary stated that he never used to come out to the area because his assistant used to conduct the staging checks. What was the Root Cause? Is he rushed, experiencing the stress of having to do the work of 2 schedulers since the layoff? If he is never out in that area, then what type of hazard awareness training has he had when working around this area? Has he been missing any safety meetings or training sessions?

15 Clues Any connection with Incidents 3, 7, 8, 9? Storage Racks are Damaged from Forktrucks, Operators are driving right up to employees, Damaged parts (mirrors) on forktrucks, siphon was damaged and PPE such as face shields and goggles were severely scratched up. Are operators driving carelessly? Should Operators receive discipline? Re training? What was the Root Cause? Has Customer orders increased this year? If so, by how much? Were any forklift Operators layed off? Is Maintenance inspecting the integrity of the storage racks? Was Maintenance given any verbal communication from the warehouse supervisor that the rack was hit or leaning? Did the Supervisor know the rack was damaged had had the authority to remove it from use? Who is responsible for PPE in the battery charging area? Did anyone report this to a supervisor or safety mgr?

16 Clues The Welders had to open up the parts area to make room for an additional welding area for a new customer. There are no welding sleeves available to the employees who weld in the new area and employees are not wearing FR clothing, aprons. What was the Root Cause? Employee misconduct for not wearing their PPE? Is there enough PPE and if so, what is the condition? Has there been any communication to management that PPE is worn or ineffective? Have they received training on how to care and inspect their PPE? Is there an effective way to communicate to management about lack of PPE?

17 Finding the Hazards 3 Critical Areas to Observe: 1) Physical Hazard In running nip points, chemical, noise, fall hazards, etc. 2) Behavioral Complacent, Communication, Fear, Anger, Depression, Worry, etc. 3) Training Matches the work, hazard awareness, refresher How much training is given at one time, new hire? How does this person learn? (Audio visual hands on)

18 Fixing the Hazard Everyone is Responsible! The best ideas for removing the hazard will come from the person who does the work. Involve them in the process! The best feedback to know if your selection of PPE is effective is an employee survey. Don t wait for a list of recordable(s). The best years for production, profit and attendance and morale, a decrease in property damage, employee turnaround and most importantly injuries and illnesses, is ONLY when there is a sense of responsibility and ownership for the system that BEGINS WITH MANAGEMENT. Trust amongst each other grows and the recognition of character and integrity becomes easy.

19 Questions