Presented by: Robert Ikenberry, California Engineering Contractors

1. Creating a Contractor Safety Program that Works Presented by: Robert Ikenberry, California Engineering Contractors

2. Introduction This webinar has been developed to provide guidance in developing a company safety program for contractors who apply industrial coatings. The webinar will identify the core elements and requirements for developing a company safety program that incorporates good safety practice as well as regulatory requirements, and complies with the current OSHA guidelines for a company safety program

3. Learning Outcomes • At the end of this webinar, you will be able to: • Define and understand the proper steps and components needed to create a quality company safety program

4. Why Develop a Contractor’s Safety Program? • A safety program is a legal requirement • OSHA requires contractors to develop specific safety programs • Construction Standard, Section 1926.20 requires all employers in the construction industry to regularly inspect sites for hazards, provide PPE and train workers on hazards they may encounter

5. Safety Program • A safety program should include the following core elements: • Management leadership and employee participation • Hazard identification and assessment • Information and training • Evaluation of program effectiveness (enforcement)

6. Benefits of a Safety Program Lower accident rates Reduced job disruption from minor accidents and injuries Reduced worker compensation premiums More Productive workers

7. Steps to Create a Safety Program • Use SSPC Guide 17, Guide to Developing a Corporate Safety Program for Industrial Painting and Coating Contractors as a template • In current version of SSPC Volume 2 – Systems and Specifications

8. Steps to Take to Create a Safety Program Step 1: Make a Management Commitment Step 2: Designate a Safety Coordinator Step 3: Develop the Basics Step 4: Develop the Specifics Step 5: Develop a Code of Safe Practices Step 6: Put it All Together

9. Step 1 • Make a management commitment and: • Get a copy of the applicable regulations • Federal and state • Create a signed written policy statement endorsed by executive management • Review any programs the company already has in place • Review the firm’s accident history • Look for any patterns • Look for connections between type of injury and type of work

10. Step 1 Federal standards from OSHA are compiled in chapter 29 of the Code of Federal Regulations www.osha.gov State OSHA plans may have additional requirements (they must be “at least as effective as” the Federal standards)

11. Step 2 Designate one individual to have the primary responsibility of acting as safety coordinator

12. Step 2 • Some requirements for an effective safety coordinator are: • Good communication skills • Knowledge of the business • Basic background in science and chemistry • High reading and comprehension skills • Good organizational skills • Perseverance

13. Step 2 The safety coordinator should assign responsibilities for preparing specific components of the program using a checklist

14. Safety Program Checklist • The safety program must: • Contain a management commitment statement • Designate safety responsibilities • Define discipline for safety policy violations • Provide recognition for superior safety efforts • Define training and employee communication

15. Safety Program Checklist (continued) • The safety program must: • Provide for task-specific hazard analysis • Provide for jobsite safety inspections • Provide a procedure for correction of unsafe conditions • Provide compliance verification • Define accident and illness reporting • Define accident investigation • Define record keeping

16. Management Statement The management statement states that the program has the full support and authority of company management

17. Management Statement • An example of a signed written policy statement is: • Our company is committed to provide facilities, equipment and management to assure a safe working environment for employees and to achieve the lowest possible personal and financial loss due to accidents and injuries

18. Designate Safety Responsibilities • Who is responsible for safety at: • The management level • The project management level • The field operations level • The supervisors level • The contractor level

19. Define Discipline for Policy Safety Violations • Describe how violations of the safety program will be handled • Discipline should be defined as: • Progressive • Consistent • Fair

20. Recognition for Superior Safety Effort Workers who demonstrate superior safety attitudes, effort and thought should be rewarded

21. Training and Employee Communication Explain how safety procedures and policies should be communicated to the workers in the field Encourage employee feedback Define who will act on employee suggestions and complaints

22. Work Place Hazard Analysis • Tasks, equipment, procedures and work sites must be analyzed to identify hazards or potential hazards • Checklists for these may be helpful: • Job (task) Hazard Analysis (JHAs) • Jobsite inspections • Equipment inspections (manlift, forklift, scaffold, vehicles, major equipment)

23. Correction of Unsafe Conditions • Correct unsafe conditions by providing: (Generally in this order…) • Revised work practices • Changes in equipment • Training • Protective equipment

24. Compliance Verification Determine how you will verify that identified unsafe practices, procedures, equipment or conditions have been corrected

25. Accident and Illness • Develop a process for how accidents are to be reported to management and determine: • Who must make the report • Who receives the report • What action will be required

26. Accident Investigation • All accidents should be investigated and the safety program should define: • Who will conduct the investigation • What format will be followed • Who will receive the reports and what action will be taken

27. Record Keeping • The safety program should explain: • What general safety records must be kept • Who will maintain the records • What summary reports will be prepared • Special retention times, where applicable • (30 years for medical records)

28. Record Keeping • The following checklist may be useful for record keeping: • Are all occupational injuries and illnesses, except for minor injuries requiring only first aid, being recorded as required in the OSHA 300 log? • Are employee medical records and records of exposure to hazardous substances up-to-date with current OSHA requirements?

29. Record Keeping Have the required OSHA training records been kept current and are they easily accessible for review? Have arrangements been made to maintain records for the term of employment plus required retention? (30 years for medical) Are inspection tags, operating permits and other records up-to-date for such items as firefighting equipment, elevators, air pressure tanks, etc.?

30. Step 3 • Form a safety committee • Many states actually require or encourage a joint safety committee of employees and supervisors as part of their OSHA or worker compensation regulations

31. Step 3 • The safety coordinator should set a reasonable timetable for the development of a safety program and define individual responsibilities such as: • When will you have a listing of all the specific training and procedures necessary • Who will complete them • When will they be completed • Who will inventory the hazardous materials and develop the Hazard Communication (HAZCOM) program

32. Step 3 The safety coordinator should set intermediate milestones requiring progress reports to be submitted at least once a month

33. Step 3 Once all the material has been submitted from the safety committee, the safety coordinator drafts the master safety program using the checklist provided earlier in the presentation

34. Step 4 • Use the draft program procedures to analyze the hazards and ask: • Do workers ever use or encounter materials containing toxic products? • Do workers enter tanks or pits? • Do workers work with lead based paints? • Do worker work in high noise operations?

35. Step 4 • Do workers ever use or encounter materials containing toxic products? • If YES, then develop a HAZCOM program • List all hazardous materials within the organization • Make sure all MSDSs are on hand and learn how to interrupt them • Set up a master file and method of getting the information and copies of the MSDSs to the field

36. Step 4 • Do workers ever spray materials containing toxic products? • If Yes, then develop a respiratory protection program • Cover respiratory fitness clearance (evaluation by LHCP) • Training in proper selection, use and maintenance of respirators • Cover fit testing • Provide for periodic re-evaluation

37. Step 4 • Do workers enter tanks or pits? • If YES, then the company needs a permit-required confined space program

38. Step 4 • Do workers work with lead based paints? • If YES, then the company should have a comprehensive lead safety program

39. Step 4 • Do worker work in high noise operations? • If YES, then indicate the need for a hearing conservation program

40. Step 4 • The following hazards require OSHA training and may require a Competent or Qualified Person: • Blood Borne Pathogens • Confined Spaces, Permit Required • Fall Protection • First Aid • Hazard Communication Standard • Hearing Protectors • Ladders • Lead Paint Hazard

41. Step 4 • Continued: • Lockout and Tagging Circuits • Portable Fire Extinguishers • Powered Industrial Truck Operator Training • Respiratory Protection • Scaffolding • Power Operated Hand Tools • Personal Protective Equipment • Access to Employee Exposure and Medical Records

42. Step 5 • A code of safe practice should be developed for each identified risk such as: • Fire (Materials, Storage, Use, Emergency Response) • Health (Toxic exposures) • Physical (Falls, Struck by, Pinch-points, Heat/Cold stressors)

43. Step 5 A code of safe practice is a listing of brief standard work practices or procedures that are designed to improve safety and reduce risk The code summarizes general safety rules that do not fit into a specific program such as HAZCOM or Confined Space

44. Step 5 • Weekly safety meetings should be given by supervisors at all work sites • Include requirement and attendance at these meetings in the code of safe practice • Provide supervisors (or whoever instructs) with training on appropriate topics and effective safety meetings • Relate to actual jobsite safety issues

45. Step 6 • How will this information reach the people who need to use it? • Provide training, which may include: • Written materials • Video presentations • Verbal instructions from a supervisor • Consider how you will document that training is effective

46. Step 6 • The safety training must include information on: • The nature of hazards and how to recognize them • What is being done to control hazards • The protective measures the employee must follow to prevent or minimize exposure to the hazard • The employee’s rights and employer’s responsibilities included in OSHA or other standards relating to the hazard

47. Summary With a management commitment to safety, a dedicated safety coordinator, and some effort, a painting contractor, whether small or large, can prepare an effective safety program and reap the benefits of reduced accidents, lower insurance premiums, improved worker morale and productivity, and freedom from government citations and fines