HAZARD CATEGORIES

Introduction – Hazard Analysis and Control

Hazard Analysis and Control – In the first module, we began a discussion of the concepts of “hazard” and “exposure” in preparation for a further look in this module. Here we will take a closer look at the five general hazard categories and 13 more specific hazard categories. All this will help you improve your knowledge and skills in proactive hazard identification to help eliminate hazards in the workplace.

Five General Hazard Areas – Hazard Analysis and Control

All workplace hazards exist in five general areas:

• Materials – liquids, solids, gases, etc.
• Equipment – includes machinery, tools, devices
• Environment – noise, temperature, atmospheres, workstation design
• People – anyone in the workplace (i.e., employees, guests, customers or contractors)
• System – flawed policies, programs, plans, processes, procedures, and practices

“Recognized” Hazards – Hazard Analysis and Control

When you conduct a walkaround inspection you are usually looking for hazardous materials, equipment, and environmental factors. These first three hazard areas represent hazardous physical conditions (think of these as hazardous “states of being”) in the workplace which, according to various studies*, cause only about three percent of all accidents in the workplace. It’s interesting to note, that hazardous conditions are what OSHA inspectors primarily cite as violation. What does that mean? Well, OSHA is very good at uncovering the conditions that don’t cause many accidents. It’s a flawed system, but it’s all we have. That also explains why there is little correlation between the most frequently cited violations and the most frequent causes of injury.

Sober and Focused – Hazard Analysis and Control

The fourth category, “People,” refers to any employee (or others) at any level of the organization who may not be “sober and focused” on the work they’re doing. For example, an employee might be in a hazardous “state of being” if they are:

• under the influence of legal/illegal drugs;
• poorly trained or educated;
• worried about a family illness; or
• mentally or physically incapable of doing the job safely

Remember, an employee who is distracted in any way from the work they’re doing should also be considered a “walking” hazardous condition that increases the likelihood of an unsafe behavior. Unfortunately, OSHA does not usually “catch” employees working in an unsafe manner, so you don’t see unsafe behaviors described in OSHA citation reports too often.

Hazardous Materials – Hazard Analysis and Control

Nearly every production job involves the use of hazardous materials including chemicals for cleaning, stripping, or degreasing parts and equipment. Maintenance workers who enter enclosed or confined spaces are also exposed to toxic substances.

Solvents: Solvents are used to dissolve various materials. Those commonly used include:

Exposure occurs by inhalation, ingestion, and absorption primarily through skin contact. Skin exposure may result in dermatitis or skin rash, edema or swelling, and blistering. These exposures can result from chemical splashes and spills, from directly immersing one’s hands into solvents and chemicals, from contact with solvent-soaked clothing or solvent-wet objects, and from the use of improper personal protective equipment. Solvents can dissolve the body’s natural protective barrier of fats and oils leaving the skin unprotected against further irritation.

In addition, inhaling or ingesting solvents may affect the central nervous system, acting as depressants and anesthetics causing headaches, nausea, drowsiness, dizziness, complaints of irritation, abnormal behavior, general ill-feeling, and even unconsciousness. These symptoms should be viewed as visible signs of potential disease. Excessive and continued exposure to certain solvents may result in liver, lung, kidney, and reproductive damage, as well as cancer.

Acids and Alkalis: Acids and alkalis may cause serious burns if they are splash into the eyes or onto the skin. If vapors or mists are inhaled, they may result in a burning of the linings of the nose, mouth, throat, and lungs.

Metals: Employees are exposed to metals primarily by skin contact and by inhalation of metal dusts and fumes. Exposure may cause headaches, general ill-feeling, anemia, central nervous system and kidney damage, and reproductive problems, as well as cancer.

Gases: Gases are used in many operations and may combine with other substances to produce toxic gases such as phosgene, ozone, and carbon monoxide. Workers can be exposed to these and other gases during work. Potential exposure to gases occurs through inhalation. Such exposure may produce eye damage, headaches, shivering, tiredness, nausea, and possible kidney and liver damage.

Plastics and Resins: Inhalation or skin contact may occur when curing resins; cutting, heating, or stripping wires; or cutting, grinding, or sawing a hardened product. Exposure to these substances may result in skin rash and upper respiratory irritation.

Polychlorinated Biphenyls (PCBs): PCBs are used as insulators in some electrical equipment and present a potential hazard to workers. Exposures to PCBs may cause skin disorders, digestive problems, headaches, upper respiratory irritations, reproductive problems, and cancer.

Fiberglass and Asbestos: Fiberglass and asbestos are also used as fillers in epoxy resins and other plastics, in wire coatings or electrical insulation, and in printed circuit boards. Uncontrolled exposures may produce skin and upper respiratory irritations and, in the case of asbestos, cancer.

Solids: Solids like metal, wood, plastics. Raw materials used to manufacture products are usually bought in large quantities, and can cause injuries or fatalities in many ways.

Gases: Gases like hydrogen sulfide, methane, etc. Gas may be extremely hazardous if leaked into the atmosphere. Employees should know the signs and symptoms related to hazardous gases in the workplace.

Hazardous Equipment – Hazard Analysis and Control

Hazardous equipment includes machinery and tools.

• Hazardous equipment should be properly guarded so that it’s virtually impossible for a worker to be placed in a danger zone around moving parts that could cause injury or death. A preventive maintenance program should be in place to make sure equipment operates properly. A corrective maintenance program is needed to make sure equipment that is broken, causing a safety hazard, is fixed immediately.
• Tools need to be in good working order, properly repaired, and used for their intended purpose only. Any maintenance person will tell you that an accident can easily occur if tools are not used correctly. Tools that are used while broken are also very dangerous.

Hazardous Work Environments – Hazard Analysis and Control

Are there areas in your workplace that are too bright, dark, hot, cold, dusty, dirty, messy, wet, etc.? Is it too noisy, or are dangerous gases, vapors, liquids, fumes, etc., present? Do you see short people working at workstations designed for tall people? Such factors all contribute to an unsafe environment. You can bet a messy workplace is NOT a safe workplace!

Noise Exposure: Many work places are inherently noisy and potentially hazardous to employees. Continuous noise and instantaneous noise bursts can damage the hearing of employees. A hearing conservation program should be established if you think noise levels are a potential threat to the health of your employees. OSHA consultants, your insurer, or a private consultant are all available to help you determine noise levels in the workplace.

Electric Shock: Electricity travels in closed circuits, normally through a conductor. Shock occurs when the body becomes part of the electric circuit. The current must enter the body at one point and leave at another. Shock normally occurs in one of three ways. The person must come in contact with:

• both wires of an electric circuit,
• one wire of an energized circuit and the ground, or
• a metallic part that has become “hot” by being in contact with an energized wire or conductor, while the person is also in contact with the ground.

Illumination: It’s important to make sure illumination is adequate for the job being performed. Too much direct or indirect glare can, over time, cause eye strain. Too little light can result in an injury. More on this topic in course 711, Introduction to Ergonomics.

Informal Observation and Formal Observation Programs – Hazard Analysis and Control

An informal observation process is nothing more than being watchful for hazards and unsafe behaviors throughout the work shift. No special procedure is involved. All employees should be expected to look over their work areas once in a while.

One of the most effective proactive methods to collect useful data about the hazards and unsafe behaviors in your workplace is the formal observation program because it includes a written plan and procedures. For example, safety committee members or other employees who may be assigned to complete a minimum number of observations of safe/unsafe behaviors during a given period of time. This data is gathered and analyzed to produce graphs and charts reflecting the current status and trends in employee behaviors. Posting the results of these observations tends to increase awareness and lower injury rates. But, more importantly, the data gives valuable clues about safety management system weaknesses.

Observation is important because it can be a great tool to effectively identify behaviors that account for 95 percent of all workplace injuries. The walkaround inspection, as a method for identifying hazards, may not be as effective as observation in identifying unsafe behaviors.

Note: An important policy for successful formal observation procedures is that they are not, in any way, linked to discipline. Observers should not discipline or “snitch” on employees: To do so ensures any observation program will fail as an accurate fact-finding tool. I recommend using only employees who do not have authority to discipline as observers in the program. If you must use managers or supervisors, make sure they do not observe in their own areas of responsibility, and make sure they understand the policy regarding “no discipline” as a consequence of an observation. It is also important for observers to express appreciation when safe behaviors are observed, and remind or warn employees to use safe practices if they are not performing a task safely.

Comprehensive Surveys

Comprehensive surveys are not the same as interviews or inspections. An interview is a verbal exchange conducted one-on-one, preferably in private, and has the potential to gather more information. An inspection is often done by employees at the workplace who walk around observing the workplace and asking questions in public.

Comprehensive surveys ideally should be performed by people who can bring to your worksite fresh vision and extensive knowledge of safety, health, or industrial hygiene. Because there are few professional consultants equipped to do comprehensive surveys in all three areas, the best approach is to use a team consisting of outside specialists: a safety professional and an industrial hygienist.

We encourage you to take advantage of OSHA’s safety and health consultative services if available in your state. Just call your local OSHA field office and schedule a visit. Workers’ compensation insurance providers and other insurance companies offer expert services to help their clients evaluate safety and health hazards. Private consultants may also provide excellent specialized services to help determine workplace hazards.

For an industrial hygiene survey you should, at a minimum, inventory all chemicals and hazardous materials in the plant, review your hazard communication program, and analyze air samples. For many industries, a survey of noise levels and a review of the respirator program also will be vital. Companies participating in OSHA’s SHARP and VPP must conduct initial comprehensive surveys.

Interviewing Employees

Interviews differ from surveys. Whereas surveys ask many people the same questions, an interview is a one-on-one process that asks unique questions. Outside experts may or may not conduct interviews during comprehensive surveys. If they do, that’s great. If they don’t, it becomes important for someone in-house conduct the interviews. A wealth of information, over and above what might be possible from a survey, may be obtained by conducting interviews with employees.

When conducting the interview keep the following tips in mind:

• Put the person at ease.
• Keep the purpose of the interview in mind: It’s to get the employee’s help in determining the types of hazards that exist in his or her work area. Go to the work area to conduct the interview. Just because you are familiar with the location or the employee’s job, don’t assume that things are always the same.
• Explain the purpose and your role. Tell the employee exactly why you are conducting the interview to reduce any initial reluctance to participate.
• Stress that the information given is important. It may help eliminate hazards that have the potential to kill, injure or produce illness. Information given may also help to make the work procedure more efficient too.
• Be friendly, understanding, and open minded. Try to keep the interview informal. Your approach is important. Make sure they sense that you care about their safety.
• Be calm and unhurried. If you are agitated, or in a hurry to get the interview over, you’ll be sending a negative message that the employee will see.
• Let the individual talk. Don’t interrupt while they are talking. It’s easy to think you have all the information. Many important facts may not be uncovered if you cut them off.
• Ask background information, name, job, etc . . . This just helps to smoothly transition into the actual interview. Small talk…then get to business.
• The key initial statement. Ask the witness to tell you about the hazards they are aware of. Don’t ask them if they know of any hazards: they could easily just say “no.”
• Don’t ask leading questions. They are not on trial.
• Ask follow-up questions. This will help to clarify particular areas or get specifics.
• Do not put the person on the defensive. If there are hazards present, don’t in any way question the employee in a manner that might accuse or blame them of wrong doing.
• Try to avoid yes and no answer questions. Ask open-ended questions. One effective question is…”Tell me about the procedures for…”
• Actively listen. Repeat the information given. Rephrase. Communicate to understand.
• Take notes. Notes should be taken very carefully, and as casually as possible. Let the individual read them if desired.
• Use a tape recorder. But always get permission from the employee first. Offer to give them a copy of the tape if they hesitate.
• Thank the employee. Conclude the interview with a statement of appreciation for their contribution.
• Be available. Ask them to contact you if they think of anything else.
• Provide feedback. If possible, advise the person the outcome of the interview.

Workplace Inspections

Inspections are the best understood and most frequently used tool to assess the workplace for hazards. Much has been written about them, and many inspection checklists are available in various OSHA publications. The term “inspection” means a general walk-around examination of every part of the worksite to locate conditions that do not comply with safety standards. This includes routine industrial hygiene monitoring and sampling.

Sometimes the term, “audit” is substituted for the term “inspection.” Actually, an audit is a little different. The audit is actually an evaluation tool because the process involves giving a numerical rating of some kind to items that are being audited. While inspections involve locating hazardous conditions, audits more generally involve locating ineffective or missing safety programs.

Inspection Frequency

The regular site inspection should be done at specified intervals. The employer should inspect as often as the type of operation or character of equipment requires. Think about the most hazardous operation or location in your company. How often are safety inspections conducted there?

OSHA expects all places of employment to be inspected by a qualified person or persons as often as the type of operation or the character of the equipment requires. Defective equipment or unsafe conditions found by these inspections should be replaced or repaired or remedied promptly.

Safety committees can play an important role in the success of the hazard identification and control program. The safety committee can assist the employer in evaluating the employer’s accident and illness prevention program, and submit valuable written recommendations to improve the program where applicable. In addition, the safety committee can:

(i) Establish procedures for workplace inspections by the safety committee inspection team to locate and identify safety and health hazards;

(ii) Conduct regular workplace inspections; and

(iii) Recommend to the employer how to eliminate hazards and unsafe work practices in the workplace.

The inspection team can document in writing the location and identity of the hazards and make recommendations to the employer regarding correction of the hazards. Regular inspections of satellite locations should be conducted by the committee team or by a person designated at the location.

I’m sure you can see from the above discussion that a regular inspection by the safety committee may not be sufficient to ensure hazards are effectively identified. The frequency of the safety inspection is really a judgment call for the employer, but at a minimum, medium and large fixed worksites should be inspected completely at least every quarter, with some part of the inspection occurring each month. The frequency of a safety inspection depends on the nature of the work and workplace. More frequent change and higher probability for serious injury or illness requires more frequent inspection. For construction sites, daily inspections are a must because of the rapidly changing nature of the site and its hazards.

At small fixed worksites, the entire site should be inspected at one time. And even for the smallest worksite, inspections should be done at least quarterly. If the small worksite uses hazardous materials or involves hazardous procedures or conditions that change frequently, inspections should be done more often.

Sound Safety Inspection Policy: All employees should inspect their area of responsibility at the beginning and end of each shift, and bridge the inspections with continual observation. If a hazardous condition is observed, eliminate it if you safely can, or report it immediately.

What Should We Inspect?

A methodical inspection will follow a checklist based on the inventory of hazards and the preventive actions and controls designed to reduce or eliminate worker exposure. Regular site inspections should be designed to check each one of those controls to make sure that hazards are contained.

Do not overlook areas outside of the production mainstream. Your search for common hazards and OSHA standards violations should cover the entire worksite, including all office areas.

Who Should Inspect?

From your reading earlier, you already know that the safety committee may be responsible for conducting regular safety inspections. But that is where it ends, and that should not be. Supervisors and other employees should be conducting safety inspections on a regular basis.

Supervisors.: Employers should make it the supervisor’s responsibility to inspect his/her work area at the beginning of every shift to ensure equipment and personnel are ready to work safely. This can be particularly helpful when other shifts use the same area and equipment or when after-hours maintenance and cleaning are routinely done.

Employees: Involving employees in all aspects of the safety and health program, including hazard identification and control, is smart business. Get as many employees involved as you can.

Get Educated in Hazard Identification

Safety and health staff: Employees who specialize in safety and health can be an excellent source of help in providing the necessary education and training on hazard identification. In a small business, the specialist may be a Production/Quality Control manager or another member of management with many important duties in addition to safety and health.

Inspector Training Options

Employees: All employees should have training in the hazards that they may be exposed to during work. When they are responsible for workstation inspections, employees also should have specific training in how to inspect. On-the-job training with the supervisor can be an excellent strategy to ensure adequate education (understanding of consequences) and training (the how-to) is conducted.

Supervisors: All supervisors should be properly educated about their safety responsibilities. They should have training in identifying and controlling the hazards that workers under their supervision are likely to encounter. When they are responsible for area inspections, supervisors should have specific training on how to conduct safety inspections. Formal course work may not be necessary, but the training should be provided by someone who is competent (has experience and training).

Safety committee members and employees: All safety committee members and employees should understand the potential hazards to which they might be exposed and the ways they can protect themselves and their fellow workers. Those who are involved in inspections need training in recognizing and controlling all the potential hazards of the worksite. They will also need written guidance, tips for inspecting, and some on-the-job training by safety and health staff or other specialists.

Written Inspection Reports

In all but the smallest and least dangerous of workplaces, written inspection reports are necessary to record hazards discovered, responsibility assigned for correction, and tracking of correction to completion. Formal safety inspections should include a written report with recommendations for corrective action.

A written record will help ensure:

• Assignment of responsibility for hazard correction.
• Tracking of correction to completion.
• Identification of problems in the controls system when the same types of hazards keep appearing even after correction is verified.
• Identification of problems in the accountability system.
• Identification of hazards for which no prevention or control has been planned.

Of course, having such written records will be most helpful if they are read by someone knowledgeable in the safety and health program. This person then can provide top managers with summaries of problems.

Beware of “Tunnel Vision”

If you use experts from within your company, be on guard for “tunnel vision,” which can lead to a failure to spot hazards in areas not directly related to your firm’s primary function. You want your maintenance shop, for example, to be just as safe as your production line. OSHA frequently finds unguarded saws and grinders, non-code electrical wiring, and other basic safety hazards in areas that are outside the main production process but regularly used by employees.

Review Documents

Assessing the workplace would not be complete without thoroughly reviewing existing documents to determine what kinds of hazards have existed in the workplace prior to the assessment. Actually, document review may be considered both an assessment tool and an analysis tool. Not only are we able to determine the hazards that have caused accidents in the past, we can analyze to uncover trends in the types, locations, date/time, etc. for accidents.

You need to review these documents to assess workplace hazards:

• OSHA 300 Log (of course)
• OSHA Form 301, Injury and Illness Incident Report
• Maintenance work orders
• Accident reports
• Safety committee minutes
• Safety suggestions
• Training evaluations