Workplace Hazard Assessment

An OSHA requirement

Matt Mohler, CSA, Author

Facilities Director for Delta Systems Inc.

PCSC Steering Committee

PC LEPC

Assessment Differences Risk Assessment vs. Hazard Assessment

Risk Assessment – an estimate of the likelihood of adverse effects that may result from exposure to certain health hazards.

Hazard Assessment – an evaluation of a work place or work situation, as to the potential for hazards that an employee may encounter while performing work.

You cannot perform a Risk Assessment without identifying Hazards.

After performing a Hazard Assessment you identify the Risk exposure (or Risk Assessment) to employees.

These assessments work together!

Hazard Identification is only part of the process.

Over the last few years we have had other speakers explain about hazard recognition and what would likely lead to a citation or is a violation of a certain code. Obviously to perform the required WHA you must have an understanding of how to recognize and then correct those identified hazards so you can manage the risk, but… There is more you must do!

Hazard Assessment Requirement

OSHA identifies the need for hazard assessments within most of its areas of control.

Additionally DOT and the Federal Motor Carriers Safety Administration (FMCSA) also make comments regarding hazard analysis to identify which PPE must be worn, by who and when within the Motor Carrier Safety Assistance Program, (MCSAP).

OSHA takes this a step further for two areas.

Hazard Assessment Requirement

OSHA requires that the employer verify that the required occupational (workplace) hazard assessment has been performed through a document.

This applies to Maritime Shipyards and General Industry;

1915.152(b)(4) for Shipyards

1910.132(d)(2) for General Industry

Construction is not specifically directed to perform the assessment, it is recommended to help comply with the general PPE requirements in 1926.28

General Industry Assessment

1910.132(d)(1) The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of PPE. If such hazards are, or likely to be present, the employer shall:

(i) Select, and have each affected employee use, the types of PPE that will protect them from the identified hazard(s)

(ii) Will communicate selection decisions to each affected employee, and,

(iii) Select PPE that properly fits each affected employee.

Performing the Assessment

Subpart I – PPE appendix B compliance guidelines

While surveying consideration should be given to the basic hazard categories:

(a) Impact (struck by)

(b) Penetration

(c) Compression (roll-over)

(d) Chemical

(e) Heat

(f) Harmful dust

(g) Light (optical) radiation [sun burn]

- Be sure to survey all areas where work is performed!

Organize the Data

Once the walk through survey is complete prepare the information for analysis.

The Safety Manager and/or the Safety Team must filter which hazards will remain after following the Hierarchy of Controls.

Once remaining hazards are identified selection of PPE type should begin. Not a specific type, in general; for example: safety glasses, hearing protection, fall protection, hand protection, etc.

Once identified, work with affected employees for training and fit following the standard. (1910.132)

Certifying the Assessment

1910.132(d)(2) The employer shall verify the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identified the document as a certification of hazard assessment.

You must perform an assessment to identify hazards, not PPE. Selection of PPE comes later.

It must be in writing – make a report of findings.

It must be certified (signed) – not by those performing the assessment.

On page 6

Certifying the Assessment

The person certifying or signing the assessment should be someone of authority, at that location, for the company. President, CEO, COO

Typically this document (report) is prepared by the Safety Manager or Safety Team (committee)

The document should be a summary of the findings, the actions taken or being taken to manage the hazards via the Hierarchy of Controls.

Any hazard remaining that employees have a risk of exposure to will require the use of PPE and will be identified within the document.

PPE selection happens with employees.

1910.132(d)(2) - Document must identify as a certified workplace hazard assessment.

The document must provide the dates of the assessment.

The EMPLOYER must certify that the assessment and the required report have been completed. My opinion, in this case, the employer is the highest person of authority at each location.

This model is used to show how to properly controls hazards. It is far better to eliminate hazards than to give someone PPE and hope it works well.

Hierarchy of Controls

OSHA recognizes that some hazards cannot be completely eliminated, substituted or completely engineered out.

In these cases Administrative Controls are the next best step. If after all before mentioned options the employee remains exposed, then PPE shall be used.

PPE is always the last resort! (within reason)

There are few exceptions where PPE can be used even though engineering controls are available. It will always come down to protecting the employee before cost is considered.

De minimis hazard violation may also be considered.

www.osha.gov/dte/library/ppe_assessment/ppe_assessment.html

Checklist Ready for Use PPE Assessment Guide

PPE Assessment Guide

You should document employees that have been corrected for not (properly) wearing the selected PPE when required! Failing to enforce the use of PPE will work against you should you have an accident and OSHA gets involved.

Subpart I, App. B Non-mandatory Compliance Guidelines

#7 Reassessment of hazards.

It is the Safety Officers responsibility to reassess the workplace hazard situation as necessary, by identifying and evaluating new equipment and processes, reviewing accident records, and reevaluating the stability of previously selected PPE.

- Performing regular JSA’s and/or area inspection on new equipment, work cells, hazmat and good accident investigation you can easily keep up with and identify new hazards.

- Employee safety suggestions and near miss reviews can also be helpful.

Subpart I, App. B

Non-mandatory Compliance Guidelines

Tips Document everything! Consider preparing a before and after document. Keep hand written notes If you assign tasks to others, keep track and notes. - it all is good evidence should OSHA want to see what you did.

Potential crushing hazard. Operator sitting at table would not know if someone was in the way of putting down the gaylord. Installing a guard around the unit keeps others from getting to close. This guard has each post in a floor hole to prevent it from moving.

There were numerous complaints of people getting hit by the door when employees were coming out of the office. Although the hazard is still present, this sign alerts employees of the potential of the door swing out towards them.

Knock-out missing in box allowing exposure to electrical circuit. A knock-out plug was installed to abate the hazard.

Available on osha.gov Publication # 3151-12R 2003 Covers everything required within the 1910.132

BWC Publications

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Tips

Do not confuse JSA/JHA with WHA!

JSA – Job Safety Analysis

JHA – Job Hazard Analysis - same thing, different name

WHA – Workplace Hazard Assessment – if you missed it!

Be careful only reading others info (including mine) and not referencing the standard. For example;

Keep Safety Simple!

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