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What to Expect When You’re Inspected:
Benson Hall Case Study
Jude Van Buren, Dr.PH, MPH, DirectorEnvironmental Health and Safety
May 2015
Topics
> Recognizing occupational health and safety hazards
> What to do if Washington State Department of Labor and Industries (L&I) comes to your location
> Addressing health and safety concerns
> Promoting a UW safety culture
Responding to Safety Concerns
> The UW supports a culture of safety by
– Encouraging people to report safety concerns so injuries can be prevented
– Supporting proactive problem solving to address safety concerns and communicate with all affected
> Health and Safety Committees
> Safety Officers
– Targeting approaches to accident prevention (EH&S)
> And yet … anyone can report a safety concern to L&I at any time
Legally required and essential to promoting a safety culture
What Does a Safety Concern Look Like?
> Someone is injured, contracts an illness, or has an exposure at work
> Someone almost gets hurt (near miss)> Something doesn’t look safe> Comments:
– “Shouldn’t I be wearing gloves, mask, etc.?”– “That’s still broken”– “That doesn’t look safe”– “Someone could get hurt”– “Something smells weird”– “I sneeze and have itchy eyes at work, yet at home I’m
fine”
2014 Accidents at the UW
L&I inspector documenting scene
of table saw accident
Ladder placed on weeds covering mole hole
Indicating how employee was pinned to MRI magnet
What Do You See?
Someone could walk into this
Fall hazard:People must climb over hand railing to get on platform
Benson Hall Case Study
> Large distillation column in student laboratory; in use since 1966
> Floor-to-ceiling spiral staircase: requires stepping over stair railing to access platform
> Student safety concern expressed to instructor in pre-planning meeting was passed on to professor, department, and EH&S
> EH&S responded and was in the process of assessing and making recommendation for safe access
> Labor and Industries (L&I) responded on same day as EH&S
> L&I cited UW with safety violation (citation dropped on appeal)
Safety concern resulted in accident prevention
Benson Hall: Outcomeand Lessons Learned
> We did a lot of things right:– Promoted a culture of safety by
preplanning– Student felt comfortable enough to
report a safety concern– Chair and department supported
bringing concerns forward andmaking improvements
– Faculty/staff involved knew to call EH&S– Students involved learned the
importance of paying attention to safety and will take that into their careers
> Chemical Engineering purchased new staircase (hazard removed)
> It’s good to have fresh eyes looking for hazards> Even if you do everything right, L&I may still investigate
Perspectives on Safety Example:Broken Ladder
Worker might see:• That has been here
forever: this place is not kept up and isn’t safe
• They don’t care about me and my safety
• Do I have to call someone else to get them to care about this?
Supervisor might see:• Been here for a
while already, and no one has mentioned it
• No one has been hurt
• It’s probably not a problem
• I’ll maybe look into it
L&I might see:• Poor safety climate
here• Does anyone
inspect the ladders?• Has anyone been
trained?• Do they have any
safety procedures?• Are there other
hazards here? Better look
When Someone Reports a Safety Concern
Take action!
Can Address• Fix• Report in OARS• Communicate to
all affected
Can’t Address• Call EH&S• Communicate to all affected
• Limit access or close area
• Report in OARS• Create action plan and timeline to communicate to others
• Fix• Evaluate and collect feedback
Don’t Know• Call EH&S• Contact safety
committee member and building coordinator
• Tell supervisors• Report in OARS
Supervisor Responsibility
> Promote a safety climate
– Be a good example
– Discuss it in meetings
– Encourage and respond to safety concerns
> Ensure proper safety procedures are in place
– Have a health and safety plan and review it annually
– Ensure the appropriate people get the right training
– Submit accident reports for accidents, illnesses, and near misses:Online Accident Reporting System – OARSwww.ehs.washington.edu/ohsoars/
> Communicate about safety concerns
– Communicate steps taken to person who reported the concern
– Communicate broadly to others who could be exposed, and stop work if appropriate
> Contact EH&S if not sure how to address a safety concern
How and When an L&I Inspector Appears: L&I Regulatory Process
> Inspections are triggered by:
– Regulatory inspection schedule
– Allegations of unsafe workplace by anyone: employee, family member, union, public, media
– As a result of a worker hospitalization
– Something seen in a drive by or media report
> Inspector will look at more than reported issue (training records, safety procedures, written programs, other hazards)
> UW is seen as one entity in terms of safety records, incidents, and penalty increases for repeat violations
Citation Current Penalty New Base Penalty*
Lack of eye protection $400 $3,300
Lack of fall protection $800 $3,300
Ladder not extended past roof $800 $3,300
Total $2,800 $13,200
*If repeat citations: 1st repeat = 2X, 2nd repeat = 5X
UW Tacoma Roof Work Inspection 2013
Occupational Health 2015Penalty Increases (Labor & Industries)
What to Do if L&I Shows Up at Your Door
> Ask the inspector for identification.
> Call EH&S immediately; the inspector should wait for EH&S prior to initiation of inspection.
> Phase 1: Opening conference with management, union representation, and EH&S. Cause for inspection and inspection process explained.
> Phase 2: Walkaround of the areas related to allegations prompting the inspection.
> Phase 3: Document request, employee interviews, measurements, and additional visits to observe specific areas.
> Phase 4: Closing conference and results of inspection reported.
> Phase 5: Citation and penalty issued; appeal if warranted.
EH&S• Hazard/• Risk
Identified
EH&S• Hazard/Risk
Evaluation
EH&S• Hazard/Risk
Mitigation Recommenda-tions
Department• Hazard/Risk
Mitigation Implementa-tion
Outcomes•Injury Rate•Workers Comp $ Reductions
•No citations, NOVs
Health and Safety Responsibility: It’s Everyone’s Job
EH&S Consultation Services Dept Actions Outcomes
Example:Lab exposures tochemicals
• How used• Where
used• When used
• What PPE is needed
• Environmental modifications needed
• What training is needed
• Provide PPE• Ensure
training is received
• Modify environment if possible
• Zero exposure
• Zero complaints
• Zero lawsuits
The Takeaway
> We all contribute to a culture of safety
> Reporting a near miss or safety concern is essential
> Regulations drive safety, but a culture of proactive responses ensures safety
> Know your health and safety committee member:www.ehs.washington.edu/ohssafcom/index.shtm
Questions about reporting accidents?Contact Sherry Baron:206.543.0297, [email protected]
Accident Investigation Training for Supervisorshttp://www.ehs.washington.edu/psotrain/corsdesc.shtm
Contacts and Resources
> EH&S Dept phone: 206.543.7262 EH&S Dept email: [email protected]
> Subscribe to EH&S newsletter:www.ehs.washington.edu/news/index.shtm
> EH&S Trainingwww.ehs.washington.edu/psotrain/
> Online Accident Reporting Systemwww.ehs.washington.edu/ohsoars/
> Health and Safety Committeeswww.ehs.washington.edu/ohssafcom/index.shtm
Presidential Executive Order No. 55
> External EH&S review found current UW policy was unclear and safety responsibilities were not being realized campus wide
> Board of EH&S revised Presidential Order No. 55 to clarify responsibilities of community members, Health and Safety Committees, and the public
> Clarifies responsibilities for VPs, chancellors, deans, directors, chairs, supervisors, and faculty supervising academic activities: – Reinforce culture of health and safety and follow health and
safety plans– Provide oversight of facilities and practices to ensure a safe
work environment– Ensure sufficient authority and support for management, staff,
and Health and Safety Committees to implement health and safety regulations
– Assure compliance with health and safety training– Establish priorities and commit resources for correcting
deficiencies
www.washington.edu/admin/rules/policies/PO/EO55.html