Guidance on 6 Action Items to Address Facility Hazards

OSHA reports that Recommended Practices for Safety and Health Programs is one of its most popular guidance publications. The agency originally published this document in 1988 and issued the first update in October 2016. In that revision, OSHA stated that much had changed over the preceding 28 years in the nature of work, conditions in the workplace, employees themselves, and how employers and employees interact and work together to be productive in a safe and healthy environment.

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For example, the guidance notes:

• The nature of work is evolving as the economy continues to shift from a manufacturing to a service base and from a fixed to an often mobile workforce.
• Automation of work activities means that technology, computers, and robotics are being integrated into workplaces, often introducing new and different hazards.
• Greater diversity in the workplace means that people from different backgrounds and cultures are working alongside each other, often speaking different languages.
• An aging workforce and the rise of sedentary work and lifestyle means that some workers are at higher risk for work-related musculoskeletal disorders.
• There is greater recognition that workers in industries that some think of as safe (such as health care, lodging, retail, and transportation) face significant hazards.
• Increased temporary and contract employment and the rise of the “gig economy” mean that traditional relationships between workers and employers are shifting.

Six Action Items

These changes are reflected in hazard identification and assessment, one of the recommended practices, which the guidance defines as “proactive, ongoing process to identify and assess hazards that are present or that could have been anticipated.” The guide offers the following six action items or steps that can be taken to implement the recommended practice. Each item is accompanied by several steps, with an emphasis on employee input and participation.

1. Collect existing information about workplace hazards
   • Collect, organize, and review information with workers to determine what types of hazards may be present and which workers may be exposed or potentially exposed.
   • Input from workers may include surveys or minutes from safety and health committee meetings.
2. Inspect the workplace for safety hazards
   • Conduct regular inspections of all operations, equipment, work areas, and facilities. Have workers participate on the inspection team and talk to them about hazards that they see or report.
   • Document inspections so it can later be verified that the hazardous conditions are corrected. Take photos or video of problem areas to facilitate later discussion and brainstorming about how to control them and for use as learning aids.
3. Identify health hazards
   • Identify chemical, physical, and biological hazards, as well as ergonomic risk factors.
   • The guidance notes that identifying and assessing health hazards may require specialized knowledge. Small businesses can obtain free and confidential occupational safety and health advice services, including help identifying and assessing workplace hazards, through OSHA’s On-Site Consultation Program.
4. Conduct incident investigations
   • Develop a clear plan and procedure for conducting incident investigations so that an investigation can begin immediately when an incident occurs. The plan should cover items such as who will be involved; lines of communication; materials, equipment, and supplies needed; and reporting forms and templates.
   • Conduct investigations with a trained team that includes representatives of both management and workers.
   • Investigate close calls/near misses.
   • Identify and analyze root causes to address underlying program shortcomings that allowed the incidents to happen.
   • Communicate the results of the investigation to managers, supervisors, and workers to prevent recurrence.
5. Identify hazards associated with emergency and nonroutine situations
   • Identify foreseeable emergency scenarios and nonroutine tasks, taking into account the types of material and equipment in use and the location within the facility. Scenarios that may be foreseeable include fires and explosions, chemical releases, hazardous material spills, start-ups after planned or unplanned equipment shutdowns, and nonroutine tasks such as infrequently performed maintenance activities.
6. Characterize the nature of identified hazards, identify interim control measures, and prioritize the hazards for control
   • Evaluate each hazard by considering the severity of potential outcomes, the likelihood that an event or exposure will occur, and the number of workers who might be exposed.
   • Use interim control measures to protect workers until more permanent solutions can be implemented.
   • Prioritize the hazards so that those presenting the greatest risk are addressed first.