Industrial Safety

MIKE BOVA| GENV 549 & ENV 489

Meeting 3 Learning Objectives

Understand:
➢ The components of an effective safety management system
➢ OSHA’s inspection priorities
➢ OSHA’s violation categories
➢ The 4 types of OSHA reportable injuries
➢ How to calculate worker injury rates
➢ The financial implications of risk assessments
➢ The purpose of an accident investigation and the three most common accident
investigation techniques

Safety and Health Programs

Mike’s Consolidated List of Program Elements:
1. Management Leadership
2. Accountability, Responsibility, and Authority
3. Employee Participation
4. Hazard Assessment and Control
5. Employee Information and Training Loading…
6. Incident Reporting, Investigation & Analytics
7. Post-Injury (Post-Loss)Management
8. Evaluation of Program Effectiveness

Safety and Health Program Elements

1. Management Leadership
➢ Must visibly commit to safety policy/value statement
➢ Safety program must be documented
➢ Responsibilities & accountabilities must be clearly defined
➢ “Walk the walk” & “Talk the talk”

Safety and Health Program Elements

2. Accountability, Responsibility, and Authority
➢ Safety performance should be included in performance reviews
➢ Safety responsibilities should be defined by position
➢ Programs must stress individual accountability for actions and
behaviors Loading…

Safety and Health Program Elements

3. Employee Participation
➢ Safety committees
➢ Focus groups and project teams
➢ Employees should conduct safety inspections
➢ Program should encourage reporting of unsafe conditions & actions
➢ Incorporate safety into employee recognition programs

Safety and Health Program Elements

4. Hazard Assessment and Control
➢ Must have systematic identification of workplace conditions
➢ Safety audits or assessments
➢ JSAs/JHAs/Risk Assessments

Safety and Health Program Elements

5. Employee Information and Training
➢ Transparency
➢ Must have training strategy
➢ Must integrate training programs
➢ Classroom/lecture is least effective method!

Safety and Health Program Elements

6. Incident Reporting, Investigation & Analytics
➢ Protocols for incident response, reporting, investigation and analysis
➢ Incident reporting escalation & communication protocols
➢ Process for regulatory reporting
➢ Defined investigation criteria & dedicated investigators
➢ Analysis of “integrated” incident data

Safety and Health Program Elements

7. Post-Injury (Post-Loss)Management
(As applied to employee injuries)
➢ Obtain best medical treatment(s)
➢ Return injured worker to job as soon as medically possible
➢ Develop transitional duty opportunities
➢ Develop relationships with medical providers

Safety and Health Program Elements

8. Evaluation of Program Effectiveness
➢ Must have pre-planned evaluation process with documented results
➢ Similiar to internal audit functions
➢ Monitor results & data
➢ Create dashboards to communicate results, Loading…
or incorporate into existing reports.

Safety & Health Program

Maturity Assessment & Model

Safety & Health Capability Maturity Model Descriptions

Sources: HHS Cybersecurity Maturity Model (2020), Carnegie Mellon University Capability Maturity Model Integration (CMMI) (2013), Reliant ESH Maturity Roadmap (2020)
Level 0 - Initial Level 1 – Managed Level 2 – Defined Level 3 – Quantitatively Managed Level 4 - Optimized 4
Unprepared Reactive Standardized Reviewed Anticipatory
Not Performed Developing Maintained Evaluated Feedback
Ad Hoc Controlling Compliance Competence Team Synergies
Metrics

Overall Practice Lacking necessary information
to take effective action;
unaware or unable to respond
to current or emerging issues
Basic platforms and processes
in place to react to business
requirements; cannot
proactively prevent problems
from arising
Defined platforms and
processes in place for
regulatory compliance and
some non-regulatory
practices.
Platforms, structure and organizational processes Platforms, structure and
in place to proactively address current issues and organizational processes in
challenges place to proactively address
future issues and challenges

Strategy Identify Risks Tighten Controls Loosen Control Connect silos

Establish Controls Develop Supervision Leadership Coaching Form Partnerships
Develop Leadership Establish Accountability Clarify Direction Develop scorecard
Align Workforce Train Workforce Build Teamwork Teach Problem-Solving

Leadership Reactive Directive Enforcing Coaching Empowering

Specific roles and Risk Analysis

responsibilities not clearly Establish Controls
Safety Manager(s) established Design Training Grunt Guardian Guru

Engagement Siloed Belonging Buying in Participating Owning

Culture Non-participative Forming Dependent Independent Interdependent

Competence Lacking necessary Safety Students Safety Amateurs Safety Pros Safety Team Players
competencies to understand
and assess hazard risk

Metrics Metrics not incorporated into Lagging Indicators Lagging Indicators Lagging Indicators Balanced Scorecard for
decision making process Compliance Indicators Leading Indicating Safety
Participation Metrics
(Digital Dashboard)

S&H Program Maturity Assessment

Program Maturity
Element Key Characteristics & Strategic Plan Implications
Level
Survey results and experience with the on-going pandemic confirmed a deep organizational commitment to employee safety
Management and health. Corporate Risk Management’s strategic efforts to enhance leadership accountability and monitor Total Cost of
Leadership 4 Risk (TCOR) across all operational risk exposures is essential to maintaining this level of maturity for safety and health
leadership.

Corporate Risk Management’s efforts to enhance leadership accountability and monitor Total Cost of Risk (TCOR) across all
Accountability, operational risk exposures is essential to improving this level of maturity for safety and health leadership.

Responsibility, 3
and Authority

By partnering with L&D, a well-established platform exists for soliciting and acting on Employee
Employee feedback and suggestions. Employees actively engaged in safety committee and off-the-job safety
Participation 4 activities.

OSHA Inspection Priorities

1. Imminent danger situations
Hazards that could cause death or serious physical harm

2. Fatalities and catastrophes

Deaths, hospitalization, amputation or eye loss.
Employers must report to OSHA:
A. Deaths within 8 hours.
B. Hospitalizations, amputations and eye losses within 24 hrs.

3. Employee Complaints
Employees may request anonymity

OSHA Inspection Priorities (continued)

1. Referrals (of hazard information)
Referrals from other federal, state or local agencies, individuals, organizations or
the media receive consideration for inspection.

5. Follow-up Visits

2. Planned or Programmed Investigations

Inspections aimed at specific high-hazard industries or individual workplaces that
have experienced high rates of injuries and illnesses

OSHA Violation Categories

1. Willful Violation
•Employer knowingly commits or commits with plain indifference to the law.

•Penalties of up to $156,259 may be proposed for each willful violation

•If an employer is convicted of a willful violation that has resulted in the

death of an employee, the offense is punishable by a court-imposed fine or by
imprisonment for up to six months, or both. A fine of up to $250,000 for an
individual, or $500,000 for a corporation, may be imposed for a criminal
conviction.

OSHA Violation Categories (cont’d)

2. Serious Violation
•Substantial probability that death or serious physical harm could result and
that the employer knew, or should have known, of the hazard.

•A mandatory penalty of up to $15,625 for each violation is proposed.

•Penalty may be adjusted downward, based on the employer's good faith,

history of previous violations, the gravity of the alleged violation, and size of
business.

OSHA Violation Categories (cont’d)

3. Other Than Serious Violation
•Has a direct relationship to job safety and health, but probably would not
cause death or serious physical harm.

•A proposed penalty of up to $15,625 for each violation is discretionary

•A penalty may be adjusted downward by as much as 95 percent, depending

on the employer's good faith (demonstrated efforts to comply with the Act),
history of previous violations, and size of business. When the adjusted
penalty amounts to less than $100, no penalty is proposed.

OSHA Violation Categories (cont’d)

4. Repeated Violation
• May ring a fine of up to $156,259 for each such violation.

5. Failure to Abate Prior Violation

• May bring a civil penalty of up to $15,625 for each day the violation
continues beyond the prescribed abatement date.

6. De Minimis Violation
• Have no direct or immediate relationship to safety or health.

• Documented in the same way as any other violation, but are not included
on the citation.

Recordkeeping & Reporting

Why Keep Records?
➢ Metrics/Monitoring
➢ Evaluate Performance
➢ Legal Requirement(s)
➢ May be Required via proposal/bid specs

Recordkeeping & Reporting

OSHA Recordkeeping Criteria
➢ Is the injury work-related?
➢ Did the injury result in medical treatment (beyond first aid?)
➢ Did the injury result in transitional or restricted job duties?
Did the injury result in time away from work?

OSHA Recordkeeping & Reporting

OSHA Reportable Injuries
➢ The following injuries must be reported to OSHA area office:

1. Any fatality (within 8 hours*)

2. Any in-patient hospitalization (within 24 hours*)
3. Any amputation (within 24 hours*)
4. Any loss of an eye (within 24 hours*)

* The clock starts once the employer receives a notification of the incident

➢ Even if an industry/organization is exempt from OSHA 300 recordkeeping requirements, they are
required to report the occurrence of any of the above 4 types of injuries to OSHA.

OSHA Recordkeeping & Reporting

OSHA Recordable Injuries
➢ All injuries which require treatment beyond first aid must be recorded on an
employers OSHA 300 log

➢ Many industries are exempt from OSHA 300 log requirements

➢ All OSHA reportable injuries are recordable

(Assuming your organization is required to keep OSHA logs)

➢ Not all OSHA recordable injuries are reportable

Recordkeeping & Reporting

OSHA Reportable, OSHA Recordable and Workers Compensation
Injuries

➢ Not all workers compensation cases are OSHA recordable

Example: Slip and fall in cafeteria

➢ Not all OSHA reportable cases are workers compensation cases

Example: Heart attack while at work

Incident Rates
➢ Compares frequency of incidents with similar organizations in
within an industry group
➢ OSHA tracks injuries and illnesses through the US
➢ In US, industry rates are maintained by Bureau of Labor Statistics (BLS)
➢ 2 most common rates tracked:
➢ Total Recordable Case Rate (TRCR)
➢ Lost Workday Injury and Illness Rate (LWDII)

Incident Rates
➢ Total Recordable Case Rate (TRCR)
TRCR = (recordable injuries + recordable illnesses) X 200,000
Employee hours worked – annually