Effective shop safety programs minimize job-related injuries and lost time; improve job efficiency, productivity and morale; and save money. Such programs take into account technician training, shop layout and design, worker negligence and poor housekeeping among other elements.
A good starting point for establishing a successful shop safety program is to perform a job hazard or job safety analysis (JHA/JSA). As that old management adage states: "If you can't measure it, you can't manage it."
A JHA/JSA is a technique that concentrates on job tasks as a way to identify hazards before they occur. It focuses on the relationship between the worker, the task, the tools and the work environment. The overall objective is to identify uncontrolled hazards in order to take steps to eliminate or reduce them to an acceptable risk level.
The majority of injuries that occur today are due to unsafe behaviors, not unsafe conditions. Hazardous conditions only account for about three percent of workplace injuries.
"The key to a successful JHA process is the effective implementation of solutions to reduce the risk of employee injury," maintains Cheryl Sunshine, Ryder System's director of safety and loss prevention, fleet management solutions, west region. "To identify the optimal solution, there is a hierarchy of effectiveness to control the hazard, which is as follows:
• Eliminate the hazard.
• Substitute the hazard.
• Implement engineering controls.
• Implement administrative controls.
• Require personal protective equipment."
Elimination is the most effective approach to control a hazard, but it is not always possible, she explains. For example, in a shop setting, many processes that are necessary to maintain a vehicle will have inherent risks, such as handling toxic materials like diesel fluid or other chemicals. While the safest action would be to eliminate the toxic material altogether, this is not always possible because of the vehicle's requirements.
"The hierarchy of a hazard analysis is therefore used to assess how best to reduce the hazard to protect the employee from injury," says Sunshine.
PROGRESSIVE STEPS
The first part of the JHA/JSA process is to break down the job into its smaller steps, says Travis Rhoden, workplace safety editor, at J.J. Keller & Associates, the nation's leader in risk and regulatory management solutions. This is usually done by observing the worker performing the job and listing each step in order of occurrence.
The documented steps need to cover each step, but they should not be overly detailed to the point that the document is unnecessarily long, he cautions. "When listing the steps, pay attention to location of objects and position of workers, as well as characteristics of objects, for example the weight of parts being used or carried. These may seem like insignificant details, but when it comes to identifying hazards later in the JHA/JSA, particularly ergonomic related hazards, these details are critical.
"Once all steps in a job have been identified, next examine each step to determine the hazards that exist or that might occur," continues Rhoden. "Some hazards will be more obvious than others. For example, it may be easy to identify the moving parts on a grinding wheel as being hazardous, but what about the burrs on the casting that is being ground? Could these pose laceration hazards to the employee's hands?
"What about the weight of the casting? If the employee dropped it, could it cause a foot injury? And, what about all of the twisting and turning the employee does to move the part over to the grinder? Is this an ergonomic hazard?"
These are the types of details a good JSA/JHA process will uncover," he notes.
It can be difficult to identify all steps in a job and all potential hazards. That's why it is important to involve the employees who will be performing the job in the JHA/JSA process, says Rhoden. Employees often have the most insight in order to have an accurate and complete list of steps and hazards; this is particularly true of the non-routine elements of the job.
The third part of the JHA/JSA process is to consider what control methods will eliminate or reduce hazards that have been identified, says Rhoden. The most effective controls are engineering controls that physically change a machine or work environment to prevent employee exposure to the hazard - for example, guarding moving parts of a grinder. After engineering controls, the next line of defense is administrative controls - e.g., adding a table for workers to pick parts from, rather than picking from a box on the floor, as well as training workers not to twist while lifting.
The final control option, personal protective equipment (PPE), should only be considered if engineering and/or administrative controls are not feasible or do not fully control the hazard, he says. By way of example, foot protection may need to be worn if the possibility of dropping a heavy object cannot be eliminated.
COMPLETE INVOLVEMENT
"The job hazard/job safety analysis requires the involvement of management in order to provide the proper support in terms of change management, as well as financial support for the ultimate solutions that are developed," says Bob Tschippert, head of the Zurich's Global Automotive Industry Segment for the Americas. "The analysis should include a listing of the most frequent losses, as well as the severity. In many cases, the owner or manager may not even be aware of the situation or losses that have occurred."
Zurich is an insurance-based financial services provider with a global network of subsidiaries and offices.
According to Tschippert, the analysis also requires the involvement of the workers because they can "provide the real-world view of activities that create hazards. Solutions that make their jobs more difficult or more complex will not be implemented without employee buy-in."
Safety goggles are a great example, says Tschippert. Even with a management mandate, many workers will not use them. However, when workers come to understand the severity of eye injuries, and the number of accidents are tracked and communicated to all employees, there will be a change of behavior and a culture of safety develops.
Another key part on the development of a safer workplace involves proper training, he adds. "In the current economic environment, one of the first things to be cut from a budget is training. This approach is usually penny wise and pound foolish as the amount of savings is minute in relation to the exposure that is created.
"Training personnel is essential to eliminate unsafe and unhealthful work practices. It's not if a loss will occur, it is when and how expensive it will become."
SAFETY COMMITTEES
One more important component to improving shop safety is the creation of a shop safety committee. When structured properly - deciding exactly what the safety committee's role will be, how it will be staffed, etc., and run effectively, a strong safety committee can highlight safety problems, point out corrective action, help investigate accidents and conduct periodic safety self-audits.
Another benefit of a shop safety committee is that because technicians are members of the committee, they raise their own personal safety consciousness.
Through tasks such as incident analysis, inspections and reviewing safety suggestions, safety committee members will usually develop a strong appreciation for safety, with an eye for prevention and root-cause analysis, says Rhoden of J.J. Keller.
"Safety committee members are also a voice on the floor for safety," he says. "In many cases, shop employees may respond better to a suggestion from a safety committee member who knows the shop's challenges, rather than a rule or recommendation handed down from management. Similarly, other shop workers may feel more comfortable discussing safety and health concerns with a peer who is on the safety committee versus going to management."
To that end, it is critical that the safety committee be visible. "One of the common reasons safety committees are not successful is they spend too much time debating issues or reviewing records, leaving little time for making improvements," points out Rhoden. "Employees need to see that the safety committee can get things done and is not just a paper committee."
"Committees can also increase visibility by conducting shop inspections on a routine basis and providing training, safety talks or safety information on a regular basis," Rhoden says. "The needs of the shop can change on a weekly, if not daily, basis. The safety committee needs to adjust to these changes and respond to them in a timely fashion."
When forming a safety committee, he recommends that a cross-section of employees be involved. "This is needed so that the committee has a knowledge base for all types of operations, and also to ensure each area and shift has a voice on the committee.
"Members should generally serve a staggered but set period of time, often a couple of years, and rotate out, so that all employees have the opportunity to participate, and also to keep 'fresh eyes' on the committee."
COMMITTEE STRUCTURE
The safety committee process at Ryder is an integral element of the company's Safety, Health and Security program. Involvement of every employee in safety and health issues is the key factor in maintaining a safe and healthy work environment.
The safety committee structure at Ryder allows for a safety committee at the business unit level - which encompasses a number of service facilities, as well as a safety committee at the individual shop level.
Chaired by the director of operations, the Business Unit Safety Committee meets once a month and sets the goals and priorities for the safety committees at the individual facilities, explains Sunshine of Ryder System. At the shop level, seven members from the shop team, who are rotated on an annual basis, are in charge of safety and are each responsible for a different safety area for their facility. The shops also hold their own monthly safety meeting to address safety issues and ensure employees are aware of proper procedures.
One additional tool that Ryder uses is its STAR (Safety Tracking and Reporting) system, which is an application through which shops receive their safety assignments for the month and all the materials for their monthly safety meeting. Through STAR, the shops can keep track of the status of their safety assignments and the assignments that have been completed.
"This has been a critical tool in helping Ryder to standardize its safety assignments and procedures across its network of more than 800 service facilities," Sunshine says. "By using the STAR system, Ryder can ensure that the shops are receiving the information they need to operate safely and are completing the requisite training."
Ryder's safety committee arrangement empowers all employess to have responsibilities and authority for safety improvements. "Employees working in the shop every day know the opportunities and generate innovative solutions to make their job safer," she says.
Employer responsibilities under OSHA
Employers have certain responsibilities under the Occupational Safety and Health Act of 1970. This legislation set federal standards for safe and healthful working conditions and imposed fines for failure to meet them.
The following list is a summary of the most important responsibilities:
• Provide a workplace free from serious recognized hazards and comply with standards, rules and regulations issued under the OSHA Act.
• Examine workplace conditions to make sure they conform to applicable OSHA standards.
• Make sure employees have and use safe tools and equipment, and properly maintain this equipment.
• Use color codes, posters, labels or signs to warn employees of potential hazards.
• Establish or update operating procedures and communicate them so that employees follow safety and health requirements.
• Provide medical examinations and training when required by OSHA standards.
• Post, at a prominent location within the workplace, the OSHA poster (or the state-plan equivalent) informing employees of their rights and responsibilities.
• Report to the nearest OSHA office within eight hours any fatal accident or one that results in the hospitalization of three or more employees.
• Keep records of work-related injuries and illnesses. (Note: Employers with 10 or fewer employees and employers in certain low-hazard industries are exempt from this requirement.)
• Provide employees, former employees and their representatives access to the Log of Work-Related Injuries and Illnesses (OSHA Form 300).
• Provide access to employee medical records and exposure records to employees or their authorized representatives.
• Provide to the OSHA compliance officer the names of authorized employee representatives who may be asked to accompany the compliance officer during an inspection.
• Not discriminate against employees who exercise their rights under the OSHA Act.
• Post OSHA citations at or near the work area involved. Each citation must remain posted until the violation has been corrected, or for three working days, whichever is longer. Post abatement verification documents or tags.
• Correct cited violations by the deadline set in the OSHA citation and submit required abatement verification documentation.
UNSAFE BEHAVIOR
"At Ryder, we promote a 'Find and Fix' or 'Find and Report' philosophy," says Sunshine. "This means it is the employee's responsibility to say something when they identify an unsafe condition."
Ryder authorizes every employee to act as captain of the ship when immediate action is required to correct potentially unsafe conditions or situations and expects them to take whatever actions are required to correct these conditions or situations when there is not enough time for resolution through the normal levels of responsibility.
Ryder's Captain of the Ship policy states that all employees have the right freedom to make these decisions without fear of retribution, and management will support employees' decisions and not pressure them to take unsafe risks.
Further, the policy holds employees accountable for accidents they are involved in that occur as a result of unsafe conditions that they know about prior to the accident and that should have caused them to stop the work activity involved in the accident.
OSHA STANDARDS
The Occupational Safety and Health Administration (OSHA) administration - the regulatory agency for workplace safety - is "really pushing" Injury and Illness Prevention Programs (I2P2), notes J.J. Keller's Rhoden. While a rule hasn't been proposed yet, it is anticipated OSHA will require employers to implement elements such as management commitment, employee participation, hazard identification and control, training and program evaluation, with the goal of having the employer "find and fix" the hazards in the workplace, regardless of whether there is a specific OSHA standard.
The I2P2 will also likely mandate that employers establish safety committees, or an equivalent communication mechanism, conduct regular self-inspections, document accident investigations and so on. "Many companies already do these types of things, but currently there is no OSHA requirement for it, so OSHA is hoping to change that," Rhoden says.
OSHA held some stakeholder meetings on I2P2 earlier this year. Transcripts are available at http://www.osha.gov/dsg/topics/safetyhealth/index.html.
The agency is also in the process of revising its Right-To-Know (or Hazcom) Regulations. OSHA published a proposed rule in September 2009, held stakeholder meetings earlier this year and is hoping to have the final rule in place in the fall of 2011, says Rhoden.
"The revisions would drastically change the Hazcom requirements by aligning them with the GHS (Globally Harmonized System of Classification and Labeling of Hazardous Chemicals)," he says. "This will result in changes to the way chemicals are classified - e.g., 'health hazard,' 'flammable liquid,' etc., as well as to the way information about the chemicals are communicated to employees.
"There will be a new labeling system that uses pictograms and signal words, along with a new format for Safety Data Sheets - formerly called Material Safety Data Sheets."
As of April 2010, OSHA now requires its compliance officers to not only check that required training has been provided, but that the training is provided in a language and vocabulary that employees understand, adds Rhoden.
5 step to increasing safety awareness in the workplace
The STOP (Safety Training Observation Program) training series from science-based products and services company DuPont provides a path to workplace safety excellence by making safe behavior and workplace conditions part of the work culture, thus preventing injuries and incidents.
The basic tool in STOP training is the STOP Safety Cycle. As described in DuPont's "Safety Currents Express" newsletter, the STOP Safety Cycle has five steps to help workers eliminate unsafe acts and unsafe conditions as they do their job.
• Decide - Before beginning any activity, decide to make safety the first priority. "When you decide to put safety first, you commit yourself to safety awareness. This is for your benefit and the benefit of others."
• Stop - Before starting an activity, come to a complete stop. "Give your full attention to the entire area, what's going on there and what you'll be doing."
• Observe - Observe for unsafe acts and unsafe conditions.
• Think - "As you think about what you've observed, consider how your safety or the safety of others will be affected by using a questioning attitude" and ask:
+ What unexpected things might happen during the job?
+ What injuries could occur if the unexpected happens?
+ How can this job be done more safely?
• "Use good judgment to answer these questions. This helps you think through the job and determine how it can be done more safely.
• Act - "Finally, act, applying good judgment to take whatever action is needed to eliminate unsafe acts and unsafe conditions."
SAFETY SIGNS
Hazards exist in every workplace, and employers have a responsibility to warn their employees of these hazards, say officials at Lab Safety Supply (LSS), North America's leading business-to-business direct marketer of industrial and safety supplies. One of the easiest ways to accomplish this is with accident prevention signs.
Two agencies cover accident prevention signs: OSHA and the American National Standards Institute (ANSI), an organization which creates voluntary standards through consensus.
OSHA's specifications for accident prevention signs and tags are detailed in its 29 CFR 1910.145.; ANSI's regulations are: Z535.1-2006, Z535.2-2002, Z535.4-2007 and Z535.5-2002.
Which requirements should be followed, OSHA or ANSI? According to LSS officials, where OSHA has specific requirements, they must be followed. In the absence of OSHA requirements, ANSI standards should be followed. Any applicable federal, state or municipal regulations must also be followed.
OSHA and ANSI classify safety signs according to use, note LSS officials, and both organizations have similar definitions for these signs. OSHA's three classifications of signs are:
1. Danger - Indicates an immediate hazardous situation and that special precautions are necessary.
2. Caution - Warns against potential hazards or caution against unsafe practices.
3. Safety instruction signs
- Used where there is a need for general type instructions and for suggestions and reminders that are relative to safety measures.
OSHA and ANSI also have specific requirements for marking physical hazards, LSS officials say. OSHA's designation of what color various equipment and signage should be painted for universal and easy identification and warnings include:
• Red - This denotes danger, stop, firefighting or fire protection equipment.
• Yellow - Indicates the need to take caution and pay attention to potential hazards, for example, a non-moving piece of equipment or areas such as low beams, overhead fixtures, steps and objects that protrude.
• Orange - Warns of dangerous parts of machinery, such as energized or moving parts that could cause injury.
• Blue - Signifies caution is needed before starting up or moving repair equipment.
• Green - Designates first aid equipment or any type of safety equipment, like exit signs and showers.
• Black and White - Usually painted in a wide stripe pattern of alternating black and white, or occasionally, a black and white checker pattern, this marks traffic areas, such as stairways, and gives directional guidance.
