Blog

Introduction

We all live in a world of numbers. Numbers surround our life, our family, our work, and our time. We wake up to a set alarm. We check our bank account. The doctor gives us a report on test results. We love the scoreboard at a football game.

Numbers are everywhere.

In the world of workplace safety what are some numbers that we need to be aware of?

Let’s review some numbers that govern our workplace!

2

This is the rule for open holes in a construction walking working surface.

Hole means a gap or void 2 inches (5.1 cm) or more in its least dimension, in a floor, roof, or other walking/working surface. This one takes a minute to understand. How can a hole with a diameter of 2 inches create a hazard exposure? Can you trip? Maybe. How about an open hole on the third floor of a building under construction and a worker drops a 6-inch crescent wrench through the open hole and hits another worker below. Ouch!

19

This rule applies to construction walking working surfaces.

A stairway or ladder shall be provided at all personnel points of access where there is a break in elevation of 19 inches (48 cm) or more, and no ramp, runway, sloped embankment, or personnel hoist is provided. Personnel hoist? Really.

2

This rule applies to all excavations and trenches.

Employees shall be protected from excavated or other materials or equipment that could pose a hazard by falling or rolling into excavations. Protection shall be provided by placing and keeping such materials or equipment at least 2 feet (.61 m) from the edge of excavations, or by the use of retaining devices that are sufficient to prevent materials or equipment from falling or rolling into excavations, or by a combination of both if necessary. 

What is a spoil pile? Spoil piles are excavated materials consisting of topsoil or subsoils that have been removed and temporarily stored during the construction activity. This distance requirement ensures that loose rock or soil from the temporary spoil will not fall on employees in the trench.

3

This rule applies to all extension ladders in the workplace.

When portable ladders are used for access to an upper landing surface, the ladder side rails shall extend at least 3 feet (.9 m) above the upper landing surface to which the ladder is used to gain access; or, when such an extension is not possible because of the ladder's length, then the ladder shall be secured at its top to a rigid support that will not deflect, and a grasping device, such as a grabrail, shall be provided to assist employees in mounting and dismounting the ladder. 

By the way, this one of the top ten most violated OSHA standards in construction.

4   25

This is the rule for means of egress and access from trench excavations.

A stairway, ladder, ramp or other safe means of egress shall be located in trench excavations that are 4 feet (1.22 m) or more in depth so as to require no more than 25 feet (7.62 m) of lateral travel for employees. This requirement is also violated on a repeated basis.

4  19.5 21

Where oxygen deficiency (atmospheres containing less than 19.5 percent oxygen) or a hazardous atmosphere exists or could reasonably be expected to exist, such as in excavations in landfill areas or excavations in areas where hazardous substances are stored nearby, the atmospheres in the excavation shall be tested before employees enter excavations greater than 4 feet (1.22 m) in depth. 

Some toxic gases and vapors are heavier than air and could settle at the bottom of a trench excavation and pose an airborne contaminant hazard. Safe oxygen levels are around 21 %.

5 2500

This is the rule on protecting workers in a trench excavation.

Each employee in an excavation shall be protected from cave-ins by an adequate protective system except when excavations are made entirely in stable rock, or excavations are less than 5 feet (1.52m) in depth and examination of the ground by a competent person provides no indication of a potential cave-in. 

A trench excavation protective system is defined as a method of protecting employees from cave-ins, from material that could fall or roll from an excavation face or into an excavation, or from the collapse of adjacent structures. Protective systems include support systems, sloping and benching systems, shield systems, and other systems that provide the necessary protection.

Just a note: a cubic yard of soil weighs, on average, 2500 lbs.

Let’s look at some OSHA fall hazard requirements. Fall hazards take the award for the most confusing OSHA numbers.

6  4  15  30  10

This is the rule for working next to unprotected sides and edges. 

Each employee on a walking/working surface (horizontal and vertical surface) with an unprotected side or edge that is 6 feet (1.8 m) or more above a lower level shall be protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems. This is a construction requirement.

How about these: 

This is the rule for working on unprotected sides and edges in the general industry. The employer must ensure that each employee on a walking-working surface with an unprotected side or edge that is 4 feet (1.2 m) or more above a lower level is protected from falling.

There are two fall protection requirements when erecting steel.

Each employee engaged in a steel erection activity who is on a walking/working surface with an unprotected side or edge more than 15 feet (4.6 m) above a lower level shall be protected from fall hazards by guardrail systems, safety net systems, personal fall arrest systems, positioning device systems, or fall restraint systems.

Each worker who is a steel beam connector shall be protected from fall hazards of more than two stories or 30 feet (9.1 m) above a lower level.

The one that trips up most safety professionals is the fall protection requirements for scaffolds.

Each employee on a scaffold more than 10 feet (3.1 m) above a lower level shall be protected from falling to that lower level.

And finally, the reporting numbers.

8  24

This is OSHA’s reporting rule for serious outcomes at a jobsite or any other private business.

Within eight (8) hours after the death of any employee as a result of a work-related incident, you must report the fatality to the Occupational Safety and Health Administration (OSHA), U.S. Department of Labor.

Within twenty-four (24) hours after the in-patient hospitalization of one or more employees or an employee's amputation or an employee's loss of an eye, as a result of a work-related incident, you must report the in-patient hospitalization, amputation, or loss of an eye to OSHA.

This was just a small sample of the numbers located in the OSHA regulations. 

Are you starting or revamping an occupational safety and health program? Well, here is some good advice: The steps are simple, but the process is not easy.

In November of 2016, the Occupational Safety and Health Administration, OSHA, issued an updated Recommended Practices for Safety and Health Programs. The last time OSHA issued recommendations for establishing a safety and health program was 1989.

The new recommendations give employers an excellent blueprint on starting and maintaining an occupational safety and health program.

“The Recommended Practices are designed to be used in a wide variety of small and medium-sized business settings. The Recommended Practices present a step-by-step approach to implementing a safety and health program, built around seven core elements that make up a successful program.”

Source: https://www.osha.gov/safety-management

Here are the seven core steps:

1. Management Leadership

2. Worker Participation

3. Hazard Identification and Assessment

4. Hazard Prevention and Control

5. Education and Training

6. Program Evaluation and Improvement

7. Communication and Coordination for Host Employers, Contractors, and Staffing

Agencies

1. Management Leadership

This is perhaps the most difficult step.

Management provides the leadership, vision, and resources needed to implement an effective safety and health program. Management leadership means that business owners, managers, and supervisors:

 Make worker safety and health a core organizational value.

 Are fully committed to eliminating hazards, protecting workers, and continuously improving workplace safety and health.

 Provide sufficient resources to implement and maintain the safety and health program.

 Visibly demonstrate and communicate their safety and health commitment to workers and others.

 Set an example through their own actions.

Action Items to accomplish the first step.

Action item 1: Communicate your commitment to a safety and health program.

Action item 2: Define program goals.

Action item 3: Allocate resources.

Action item 4: Expect performance.

Action item 1: Communicate your commitment to a safety and health program.

A clear, written policy helps you communicate that safety and health are primary organizational values –as important as productivity, profitability, product or service quality, and customer satisfaction.

2. Worker Participation

Workers need to be involved.

To be effective, any safety and health program needs the meaningful participation of workers and their representatives. Workers have much to gain from a successful program and the most to lose if the program fails. They also often know the most about potential hazards associated with their jobs. Successful programs tap into this knowledge base.

Worker participation means that workers are involved in establishing, operating, evaluating, and improving the safety and health program. All workers at a worksite should participate, including those employed by contractors, subcontractors, and temporary staffing agencies.

In an effective safety and health program, all workers:

 Are encouraged to participate in the program and feel comfortable providing input and reporting safety or health concerns.

 Have access to the information they need to participate effectively in the program.

 Have opportunities to participate in all phases of program design and implementation.

 Do not experience retaliation when they raise safety and health concerns; report injuries, illnesses, and hazards; participate in the program; or exercise safety and health rights.

Action Items to accomplish the second step.

Action item 1: Encourage workers to participate in the program.

Action item 2: Encourage workers to report safety and health concerns.

Action item 3: Give workers access to safety and health information.

Action item 4: Involve workers in all aspects of the program.

Action item 5: Remove barriers to participation.

3. Hazard Identification and Assessment

Hazard recognition is a key component.

One of the root causes of workplace injuries, illnesses, and incidents is the failure to identify or recognize hazards that are present or that could have been anticipated. A critical element of any effective safety and health program is a proactive, ongoing process to identify and assess such hazards.

To identify and assess hazards, employers, and workers:

 Collect and review information about the hazards present or likely to be present in the workplace.

 Conduct initial and periodic workplace inspections of the workplace to identify new or recurring hazards.

 Investigate injuries, illnesses, incidents, and close calls/near misses to determine the underlying hazards, their causes, and safety and health program shortcomings.

 Group similar incidents and identify trends in injuries, illnesses, and hazards reported.

 Consider hazards associated with emergency or non-routine situations. Determine the severity and likelihood of incidents that could result from each hazard identified and use this information to prioritize corrective actions. Some hazards, such as housekeeping and tripping hazards, can and should be fixed as they are found. Fixing hazards on the spot emphasizes the importance of safety and health and takes advantage of a safety leadership opportunity.

Action Items to accomplish the second step.

Action item 1: Collect existing information about workplace hazards.

Action item 2: Inspect the workplace for safety hazards.

Action item 3: Identify health hazards.

Action item 4: Conduct incident investigations.

Action item 5: Identify hazards associated with emergency and non-routine situations.

Action item 6: Characterize the nature of identified hazards, identify interim control measures, and prioritize the hazards for control. So, why is it not easy? One reason is that the value an organization puts on safety is rarely as important as the values an organization puts on cost, quality, and production.

Other critical barriers that make this process not so easy:

 Labeling safety and health elements as “programs.” Safety programs, like television programs, have a start and finish.

 A better alternative is to think of safety as a process versus a program.

 Compliance with federal standards is important, but it’s not necessarily the answer. OSHA is understaffed and operates on a budget less than most federal agencies.

 It seems that OSHA’s fundamental principle is “accidents are caused by things, not by people.”

 We think of safety professionals as managers versus leaders of a process.

Stay tuned for Part 2.

Getting close to that time of year safety department!

The OSHA Form 300 A is the summary of work-related injuries and illnesses. It must be completed after the end of the year and summarize the number of recordable injuries and illnesses that occurred in the previous year.

When completing your OSHA Form 300 A that summarizes the data on the OSHA 300 log, you first want to ensure that your 300 Log form of work- related injury illnesses is complete and correct. After reviewing your OSHA Form 300 Log, take the totals from that to create the OSHA 300 A Summary.

OSHA also requires that the 300 A summary be certified with a signature from a company executive. You will need to post 300 A summary from February 1st. April 30th of 2024. in a visible location where the company would normally post news or other information for employees.

Just a few comments regarding the term “posted/post/posting”. Think about how organizations share company information with employees. When was the last time you received information from a bulletin board?

Recommendation: On February 1 st of 2024, use the 300 A Summary as a tool that demonstrates management commitment. Email, yes, email a copy of the completed and signed 300 A Summary to frontline supervisors and recommend that they take a few minutes and share that information with all employees in the organization. Document it as a safety meeting.

These forms must be kept for five years. In addition, if a government representative, for example, OSHA, asks to see these forms, you must provide copies of these forms within four business hours. Some companies are required not only to post their 300 A summary, but also to submit them electronically to OSHA through the Injury tracking application located in the link below.

https://www.osha.gov/news/newsreleases/national/07172023

This final rule requirement has been updated and will be effective on: 01/01/2024

Look for more information on this new and updated OSHA rule in the December 2023 Blog.

Requirement

At the end of the year, OSHA requires you to enter the average number of employees and the total hours your employees worked on the OSHA 300 A Summary.

If you don’t have these figures, here is some help to guide you in completing the information. If you pay about the same number of employees every pay period throughout the year (e.g., about 100), then you can use that number as your annual average employment. If the number of employees fluctuates from pay period to pay period (e.g., your business is seasonal, or your establishment grew, or shrank during the year), then you should use the formula below to calculate the employment average.

How to figure out the average number of employees who work for your establishment during the year.

#1. Add up and then enter the number of employees your establishment paid in each pay period during the year. Be sure to include all employees: full-time, part-time, temporary, seasonal, salaried, and hourly.

#2 Count and then enter the number of pay periods your establishment had during the year. Be sure to include any pay periods when you had no employees. For example, enter 26 if you have biweekly pay periods or 52 if you have weekly pay periods.

#3 Divide the number of employees by the number of pay periods

#4 Round the answer to the nearest next highest whole number. Write the rounded number in the blank on the 300 A Summary page marked:

Annual Average Number of Employees

How to figure out the total hours all employees worked

#1 Include hours worked by salaried, hourly, part-time, and seasonal workers, as well as the hours worked by other workers subject to day-to-day supervision by your establishment (e.g., temporary help service workers).

#2. Do not include vacation, sick leave, holidays, or any non-work time, even if employees were paid for it.

#3. If your establishment keeps records on only the hours paid or if you have employees who are not paid by the hour, please estimate the hours that the employees work. If this number isn’t available, you can use this optional guideline to estimate it.

Optional Guideline

#1. Find the number of full-time employees in your establishment for the year.

#2. Multiply by the number of work hours for all full-time employees in a year.

#3. This is the number of full-time hours worked.

#4. Then add the number of overtime hours as well as the hours worked by other employees (part-time, temporary, seasonal).

#5. Round the answer to the highest whole number.

#6. Write the rounded number in the blank on the summary page marked:

Total hours worked for all employees last year.

Note: Review your annual average number of employees to ensure it makes sense.

Review these questions to check yourself:

Is it about the same as the number of employees working at your establishment on any given day?

Is it bigger than your smallest number of employees in a pay period?

Is it smaller than your biggest number of employees in a pay period?

If the answer to any of those questions is no, then the calculation may be incorrect.

Note: You cannot divide the total number of W-2’s by the number of pay periods to calculate average employment. You must add up the number of employees paid in each pay period and then divide that number by the number of pay periods.

Here is a link for more information:

https://www.osha.gov/recordkeeping/forms

Happy Posting!

Introduction:

The requirement for private employers to record and report certain injuries and illnesses was one of the many cornerstones that are found in the Occupational Safety and Health

Act of 1970.

In the development of the OSHA Act congress saw a need to have employers use a system to track injuries and illnesses. In doing so, employers would have a database that could be used to address any hazards in the workplace that have gone unattended.

Excerpt from the OSHA Act: Section 8, paragraph (c) (2)

“The Secretary, in cooperation with the Secretary of Health and

Human Services shall prescribe regulations requiring employers to maintain accurate records of, and to make periodic reports on work-related deaths, injuries, and illnesses other than minor injuries requiring only first aid treatment and which do not involve medical treatment, loss of consciousness, restriction of work or motion, or transfer to another job.”

January 19, 2001, OSHA issued an updated version of the original standard in the

Federal Register.

The final rule contains provisions mandating the recording of work-related injuries and illnesses that must be entered on the OSHA 300 (Log) and 301 (Incident Report) forms. It sets out the recording requirements that employers are required to follow in recording cases.

The final rule also mandates that each employer who is required by OSHA to keep records must record each fatality, injury, or illness that is work-related, is a new case, and not a continuation of an old case, and meets one or more of the general recording criteria:

 Death

 Days Away from Work

 Restricted Work Activity (commonly called “light duty”)

 Transfer to another job (Yes this is a recordable!)

 Other recordable (like hearing loss or one stitch to the finger)

The updated standard contains a table that points employers and their recordkeepers to the various sections of the rule that determine which work-related injuries and illnesses are to be recorded.

These sections lay out the requirements for determining whether an injury or illness is work-related, if it is a new case, and if it meets one or more of the general recording criteria. In addition, the table contains a row addressing the application of these and additional criteria to specific kinds of cases (needlestick and sharps injury cases, tuberculosis cases, hearing loss cases, medical removal cases, and musculoskeletal disorder cases).

The following is a decision tree, or flowchart, that shows the steps involved in determining whether a particular injury or illness case must be recorded on the OSHA forms.

Key Point

What are the OSHA reporting requirements the employer must comply with? This part of the OSHA rule was updated September 18, 2014.

 All employers are required to notify OSHA when an employee is killed on the job or suffers a work-related hospitalization, amputation, or loss of an eye.

 A fatality must be reported within 8 hours.

 An inpatient hospitalization, amputation, or eye loss must be reported within 24 hours.

Be prepared to supply the following information when reporting: Business name; names of employees affected; location and time of the incident, brief description of the incident; contact person and phone number.

So, when do the eight hours start? OSHA requirement seems a little vague. Here is a recommendation. Use the death certificate as a legal time of death.

All employers should have a policy and procedure that outlines what to do in the event of a fatality occurs in your organization. Using a death certificate as a legal time of death is a good point to add to the policy. Also, as an employer, you have 8 hours to report. Use this time to do your investigation and get all the details, and report 7.5 hours after the incident.

Do I have to report the fatality, inpatient hospitalization, amputation, or loss of an eye if it resulted from a motor vehicle accident on a public street or highway?

If a motor vehicle accident occurred in a construction work zone, you must report the fatality, inpatient hospitalization, amputation, or loss of an eye.

If a motor vehicle accident occurred on a public street or highway, but not in a construction work zone, you do not have to report the fatality, inpatient hospitalization, amputation, or loss of an eye to OSHA. However, the fatality, inpatient hospitalization, amputation, or loss of an eye must be recorded on your OSHA injury and illness records if you are required to keep such records.

Be aware that some cases that are not reportable may still be recordable.

For more information, go to this link: 1904.39 - Reporting fatalities, hospitalizations, amputations, and losses of an eye as a result of work-related incidents to OSHA. |

Occupational Safety and Health Administration

Key Point

Are there exceptions to the recording of a work-related injury or illness?

This becomes interesting. If a worker is hurt at work but the review of the injury or illness falls into one of the following exceptions, the employer does not have to record the incident.

Here they are:

You are not required to record injuries and illnesses if ...

 At the time of the injury or illness, the employee was present in the work environment as a member of the general public rather than as an employee.

o Example: The worker is there to pick up their check and is not scheduled to work that shift.

 The injury or illness involves signs or symptoms that surface at work but result solely from a non-work-related event or exposure that occurs outside the work environment.

o Example: heart attack at work due to a lifestyle issue.

 The injury or illness results solely from voluntary participation in a wellness program or in a medical, fitness, or recreational activity, such as blood donation, physical examination, flu shot, exercise class, racquetball, or baseball.

 The injury or illness is solely the result of an employee eating, drinking, or preparing food or drink for personal consumption (whether bought on the employer’s premises or brought in).

o For example, if the employee is injured by choking on a sandwich while in the employer’s establishment, the case would not be considered work-related.

o Note: If the employee is made ill by ingesting food contaminated by workplace contaminants (such as lead) or gets food poisoning from food supplied by the employer, the case would be considered work-related.

 The injury or illness is solely the result of an employee doing personal tasks (unrelated to their employment) at the establishment outside of the employee’s assigned working hours.

 The injury or illness is solely the result of personal grooming, self-medication for a non-work-related condition, or is intentionally self-inflicted.

o For example: An employee gets mad at the potato chip vending machine and breaks the glass to get his bag of chips. The injury was a severe laceration to the hand and forearm requiring sutures (stitches). And yes, it’s not recordable.

 The injury or illness is caused by a motor vehicle accident and occurs on a company parking lot or company access road while the employee is commuting to or from work.

o Note: There are two commutes a day: from your home to your first business stop and from your last business stop to home. Injuries and illnesses that happen during the commute are not recordable.

 The illness is the common cold or flu (Note: contagious diseases such as tuberculosis, brucellosis, hepatitis A, or plague are considered work-related if the employee is infected at work).

 The illness is a mental illness. Mental illness will not be considered work-related unless the employee voluntarily provides the employer with an opinion from a physician or other licensed health care professional with appropriate training and experience (psychiatrist, psychologist, psychiatric nurse practitioner, etc.) stating that the employee has a mental illness that is work-related.

o Example: Your boss drove you crazy.

Stay tuned for more.

More than 100 of OSHA’s current standards contain requirements for training.

Furthermore, a comprehensive workplace safety program needs to include training.

Quality safety and health training helps prevent work-related injuries and illnesses.

Effective training also encourages workers by educating and empowering them to advocate for safer working conditions. Several factors contribute to successful training.

One of the most important is ensuring that the training facilitator exhibits safety and health expertise, sound instructional skills, and flexibility.

Overview of Best Practices for Training Adults. Training providers and instructional facilitators who recognize and embrace characteristics of sound training and principles of adult education will maximize the benefits of the training for their participants.

“Treat Learners Like Adults”

Here are some tips for training adults.

1. Adults are people with years of experience and a wealth of information. Focus on the strengths learners bring to the classroom, not just gaps in their knowledge. Provide opportunities for dialogue within the group. Tap their experience as a major source of enrichment to the class. Remember that you, the teacher, do not need to have all the answers if you know where to go or who to call to get the answers. Students can be resources to you and to each other.

2. Adults have established values, beliefs, and opinions. Demonstrate respect for differing beliefs, religions, and value systems. and lifestyles. Let your learners know that they are entitled to their values, beliefs, and opinions, but that everyone in the room may not share their beliefs. Allow debate and challenge innovative ideas.

3. Adults are people whose style and pace of learning have probably changed. Use a variety of teaching strategies, such as small group problem solving and discussion. Use auditory, visual, tactile, and participatory teaching methods. The reaction time and speed of learning may slow, but the ability to learn is not impaired by age. Most adults prefer teaching methods other than lecture.

4. Adults relate new knowledge and information to previously learned information and experiences. Assess the specific learning needs of your audience before your class or at the beginning of the class. Present single concepts and focus on the application of concepts to relevant practical situations. Summarize frequently to increase retention and recall. Material outside of the context of participants’ experience and knowledge becomes meaningless.

5. Adults are people with bodies influenced by gravity. Plan frequent breaks, even if they are two-minute stretch breaks. During a lecture, a short break every 45 to 60 minutes is sufficient. In more interactive teaching situations, breaks can be spaced 60 to 90 minutes apart.

6. Adults have pride. Support the students as individuals. Self-esteem and ego are at risk in a classroom environment that is not perceived as safe or supportive. People will not ask questions or participate in learning if they are afraid of being put down or ridiculed. Allow people to admit confusion, ignorance, fears, biases, and different opinions. Acknowledge or thank students for their responses and questions. Treat all questions and comments with respect. Avoid saying “I just covered that” when someone asks a repetitive question. Remember that the only foolish question is the unasked question.

7. Adults have a deep need to be self-directed. Engage the students in a process of mutual inquiry. Avoid merely transmitting knowledge to students, expecting total agreement. Do not “spoon-feed” the participants.

8. Individual differences among people increase with age. Consider differences in style, time, types, and pace of learning. Use auditory, visual, tactile, and participatory teaching methods.

9. Adults tend to have a problem-centered orientation to learning. Emphasize how learning can be applied in a practical setting. Use case studies, problem-solving groups, and participatory activities to enhance learning. Adults want to immediately apply the added information or skills to current problems or situations.

10. Adults need to know “what is in it for me?” The latest information and skills must be relevant and meaningful to the concerns and desires of the students. Know what the needs of individuals in your class are. Students do not wish to learn what they will never use.

Additional Note. The learning environment must be physically and psychologically comfortable

Remember:

Adult students remember 10% of what they hear

35% of what they see

65% of what they hear and see.

For more information on adult learning in a safety and health system environment, open this link from www.osha.gov:osha3824.pdf

OSHA believes that contemplated changes to a process must be thoroughly evaluated to fully assess their impact on employee safety and health and to determine needed changes to operating procedures. To this end, the Process Safety Management standard contains a section on procedures for managing changes to processes. Written procedures to manage changes (except for “replacements in kind”) to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process must be established and implemented. These written procedures must ensure that the following considerations are addressed prior to any change:

• The technical basis for the proposed change,

• Impact of the change on employee safety and health,

• Modifications to operating procedures,

• Necessary time period for the change, and

• Authorization requirements for the proposed change.

Employees who operate a process and maintenance and contract employees whose job tasks will be affected by a change in the process must be informed of, and trained in, the change before the startup of the process or the startup of the affected part of the process. If a change covered by these procedures results in a change in the required process safety information, such information also must be updated accordingly. If a change covered by these procedures changes the required operating procedures or practices, they also must be updated.

What is Management of Change (MOC)?

Management of Change, or MOC, is the best practice used to ensure that safety, health, and environmental risks are controlled when a company makes changes in its facilities, documentation, personnel, or operations. When decisions and changes are made rapidly, safety and health risks can increase, resulting in disasters such as explosions at the oil refinery and detergent plant described in the U.S. Chemical Safety and Hazard Investigation Board’s 2001 “Management of Change” safety bulletin. There are many other notable examples of how even simple changes at a worksite have led to tragedy. At worksites where highly hazardous chemicals are used, the Process Safety Management (PSM) rules apply, and proper application of Management of Change is not just a best practice but is a requirement. In these cases, an MOC program is used to ensure all changes to a process are carefully reviewed, and any hazards introduced by the change are identified, analyzed, and controlled before resuming operation. MOC often seems deceptively simple in concept, but can be highly effective in the prevention of accidents and can be used as best practice at worksites where the Process Safety Management rule does not apply.

When is MOC used?

A business need or opportunity becomes a project or business solution and requires changes in the workplace that can affect processes, systems, people, or organizational structure. Think about whether implementing this change improves your safety program and makes good business sense.

One obvious benefit of Management of Change is avoiding the consequences of unforeseen safety and health hazards through planning and coordinating the implementation of change in your facility. This is why Management of Change is required in the PSM rules when highly hazardous chemicals are used.

What are the benefits of MOC?

 It minimizes unplanned adverse impacts on system integrity, security, stability, and reliability for the business process being altered or added.

 It maximizes the productivity and efficiency of staff planning, coordinating, and implementing the changes.

 It provides a stable production environment.

 It ensures the proper level of technical completeness, accuracy of modifications, and testing of systems before implementation.

 It provides an appropriate level of management approval and involvement.

How do you effectively design and implement MOC?

Managing change begins with a discussion of the types of changes being considered that could affect workplace safety and health, including effects that may not be obvious. Procedures for managing these changes should be written and regularly reviewed to reduce the risk associated with any changes. Changes being considered must be thoroughly evaluated for how they affect employee safety and health. Sometimes there is a domino effect, where one change leads to more changes, and you will need to determine if the changes being considered prompt additional changes to operating procedures.

Your MOC program must specify what types of changes are to be managed, for example, physical alterations to equipment or new operating procedures. A proper MOC system also requires that any change be evaluated before implementation. The level of evaluation can depend on the degree of change and how critical it is to the safety and health of your operations. Employees, as well as maintenance and contract workers whose work will be affected by the change, must be informed and trained on the new equipment, process, or whatever the change includes. This must be done before the startup of the process or the startup of the affected part of the process. Managing change also means updating any safety and health information, operating procedures, or practices related to the new procedures.

Elements of an effective MOC Program:

 Procedures that consider:

o The technical basis for the proposed change.

o Impact of the change on employee safety and health.

o Modifications to operating procedures.

o Time needed for the change.

o Authorization required for the proposed change.

 Steps to identify hazards before the changes are made.

 Methods to screen and classify changes.

 Keys to identifying hazards in changes.

 Methods for documenting MOC reviews.

 Procedures to make approvals and authorizations workable.

 Plans to educate and prepare personnel regarding the changes.

 Methods for updating Process Safety Information, procedures, and other Process Safety Management information.

 Steps for effective implementation.

 Procedures for reviewing and revising any existing MOC Program.

Best Practices in MOC

1. Compile safety information on the products, equipment, materials, or processes that are changing and write policies and procedures to incorporate the current information. Be sure to include information on how to investigate incidents, audit compliance with safety and health procedures, and plan for emergency responses.

2. Establish a way to gather employee input on the changes, such as interviews, group discussions, or surveys. Incorporate employee comments and suggestions into your draft policy and procedures.

3. Write instructions for all employees on every process in which changes are involved. The procedures must be clear, include steps for performing every operation, cover safety information, state what to do in the event of an emergency, and be readily available to the employees performing the procedures.

4. Train employees on the changes. Emphasize any safety and health hazards and what to do in the case of an emergency. The training must take place before an employee is allowed to operate the equipment or perform the job that the changes were related to.

5. Establish written procedures for what you do the next time you have a change in safety and health management.

The Voluntary Protection Program Participant’s Association (VPPPA) has compiled a

directory of best practices. The directory can be obtained through the VPPPA website at

www.VPPPA.org publications.

VPPPA - Workplace Health and Safety