The Hazard Identification, Prevention and Control aspect of the Safety & Health Management System: Part 3 of 4

| OSHA, USF Safety Florida

Dear Reader,

This element of the Management System focuses on developing a current and complete inventory of the safety and health hazards at the workplace, sometimes referred to as a comprehensive baseline hazard assessment.  It includes assessing how the hazards are controlled and worker exposure to them. The inventory serves as the basis for priority setting (i.e., policy, goals, and objectives). It requires the expertise of an internal or external qualified individual to conduct the baseline hazard assessment. 

Another aspect of hazard identification includes effective safety and health daily, weekly, or monthly inspections and audits of routine and non-routine operations to determine if processes have changed. Small employers should also conduct systematic, job-specific hazard analyses (JHAs) to identify and address conditions and work practices that may lead to worker injury or illness when performing all tasks. Effective JHAs also result in a worker being knowledgeable about the hazards of their job and how to use controls properly.

Operational changes are prone to incidents and injuries. As such, policies and procedures must be developed that result in the advance identification and correction of potential hazards associated with planned or anticipated changes in the work or workplace in routine, nonroutine, and emergency operations.  Change management is a proactive approach to maintaining safe and healthful working conditions by ensuring that changes in operations, workstations, or workflow; introducing new equipment, materials, or processes; personnel changes; or other significant organizational changes from other businesses (e.g., contractors) at a site are evaluated for potential hazards and related risks, including hazards associated with foreseeable emergencies.  

In general, there should be multiple methods of incident reporting to facilitate the identification and elimination of hazards by all personnel. These include reporting equipment malfunctions (e.g., to maintenance), unsafe conditions such as blocked exits, icy sidewalks, or liquids on the floor (e.g., to the housekeeping department), and chemical odor concerns (e.g., to the production manager or safety coordinator). To be effective, any hazards identified need prompt correction and may entail ensuring damaged or non-functional equipment is taken out of service and interim protective measures implemented. The employer must have an effective plan that describes how selected controls will be implemented promptly. Timely correction of every identified hazard is critical to an effective safety and health program. 

Employers should use root cause analysis techniques to investigate incidents and near misses to identify contributing factors, especially those related to the management system, which contributed to the incident/near miss. They should follow the hierarchy of controls for eliminating, preventing, or controlling workplace hazards. While engineering solutions are the preferred method, the employer should consider first and foremost elimination (i.e., physically remove a hazard), then substitution (i.e., replace a hazard with a less hazardous solution), followed by engineering controls (i.e., isolate the worker from the hazard). When engineering solutions are not feasible, safe work practices and administrative controls should be used, followed by personal protective equipment (PPE) as a last option, which will require proper selection, sizing, distribution, training, usage, maintenance, and monitoring.

The USF SafetyFlorida Consultation Program has provided free, confidential compliance assistance to thousands of Florida’s small employers for over 20 years. It can assist in developing management systems to reduce illnesses and injuries in the workplace. Our consultants hold over 150 years of combined occupational health and safety leadership experience from various industries such as private manufacturing, construction, mining, and government. To request a confidential, no-cost consultation, please visit www.usfsafetyflorida.com or call toll-free (866) 273 1105.

Stay Safe,

Dr. Brian L. Warrick, Ph.D., CSP, CIH
Program Director, USF SafetyFlorida