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Safety and Health Program Assessment Worksheet OSHA Form 33 Jim Barkley OSHCON Consultant Manager

Safety and Health Program Assessment Worksheet OSHA Form 33 Jim Barkley OSHCON Consultant Manager. Purpose.

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Safety and Health Program Assessment Worksheet OSHA Form 33 Jim Barkley OSHCON Consultant Manager

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  1. Safety and Health Program Assessment WorksheetOSHA Form 33Jim Barkley OSHCON Consultant Manager

  2. Purpose The intent of this presentation is to explain how OSHCON uses the Form 33, and show how employers might use it to measure and evaluate the strength and completeness of their safety and health programs. Form 33 Revised -- August 2007

  3. WHAT IS THE FORM 33? The Form 33 is an evaluation tool used by OSHA Consultation to assess an employer’s total safety and health management system when we perform Full Service -Comprehensive consultation visits. Form 33 Revised -- August 2007

  4. Relation To SHARP & VPP The Form 33, though completed for all consultations performed by OSHCON, has a critical scoring requirement for those companies vying for SHARP status. The S&H Program attributes that the Form 33 contains are the same attributes that VPP applicants must also successfully develop. Form 33 Revised -- August 2007

  5. History • First assessment worksheet was developed in 1984 • Evolved with the inception of OSHA’s 1989 Safety and Health Program Management Guidelines - Originally four Categories with 22, then 25 elements. • Current 58 attribute form launched in 2001. Form 33 Revised -- August 2007

  6. Attribute Types • Basic Items - 50 Attributes - Fundamental Building Blocks • Stretch Items (*) - 8 Attributes - Attributes of Excellence - Operate Best When Basic Attributes are fully in Place Form 33 Revised -- August 2007

  7. Rating Values Defined 0:No discernible or meaningful indication that the item is even partially in place 1:Some portion or aspect is present although major improvement is needed 2:Item is largely in place with only minor improvements needed 3:Item is completely in place Form 33 Revised -- August 2007

  8. Rating Values Defined NE:Not Evaluated - Recognizes that comprehensive evaluations are often incremental processes. NA:Not Applicable – Recognizes that there are organizational differences between larger and very small workplaces. Form 33 Revised -- August 2007

  9. Concept of an Organizational Safety and Health System • Operational Component • Managerial Component • Cultural Component Form 33 Revised -- August 2007

  10. Operational Component • Nineteen (19) Assessment Items • Concerns system output regarding workplace hazards and violations (unsafe and unhealthful conditions and activities) • Two (2) Sub-Components • Hazard Anticipation & Detection (Items 1-10) • Hazard Prevention & Control (Items 11-19) Form 33 Revised -- August 2007

  11. Managerial Component • Twenty (20) Assessment Items • Concerns effect of traditional managerial functions: • Planning • Controlling • Communicating • Three (3) Sub-Components • Planning & Evaluation (Items 20-25) • Administration & Supervision (Items 26-33) • Safety & Health Training (Items 34-39) • Directing • Staff Development • Motivating • Organizing • Staffing • Coordinating Form 33 Revised -- August 2007

  12. Cultural Component • Nineteen (19) Assessment Items • Concerns values and principles mutually held by members of an organization • Two (2) Sub-Components • Management Leadership (Items 40-49) • Employee Participation(Items 50-58) (Management leadership is needed to initiate change toward an improved safety and health culture, and employee participation is necessary to nurture and grow that culture.) Form 33 Revised -- August 2007

  13. All Three Components Are Interrelated O M C Form 33 Revised -- August 2007

  14. A Systematic Method for Rating Attributes • Incorporates the Concept of “Rating Cues” which arespecific facts or perceptions that prompt and support the rating of a relevant attribute. • Each attribute is worded as a positive statement. • Each rating cue will operate either to CONFIRM or to NEGATE an attribute statement. Form 33 Revised -- August 2007

  15. Sources of Rating Cues • Observations and Measurements • Interviews of employees and management at all levels • Review of Documents and Record keeping Form 33 Revised -- August 2007

  16. Cue Content • Indication of the existence (or absence) of the Attribute • Indication of the extent of the Attribute • Indication of the actual effect of the Attribute Form 33 Revised -- August 2007

  17. Multiple Cues Are Considered And Weighed Together • Initial Cue • Supporting Cues • Conflicting or Contradictory Cues Form 33 Revised -- August 2007

  18. “Effective” and “Effectively” No two words carry more weight in our Safety and Health Program evaluations. It is not enough to just have something in place, it must be EFFECTIVE. Attributes that are only partially in place, or partially complete, or in place most of the time, are not 100% effective, and generate negative cues. Form 33 Revised -- August 2007

  19. Using Cues to Score Attributes Form 33 Revised -- August 2007

  20. Examples Of Negative Cues Obviously, hazards and violations are negative cues. We would also include: • Latest date on Safety Manual is 2002. • “Safety Man” is keeping the place really safe, but it’s all up to him. • NEO very thorough, but occurs 1 month after hire. • Safety meetings not held when too busy. • Listed HAZCOM coordinator died 1 year ago. Form 33 Revised -- August 2007

  21. Examples of Positive Cues • Employees know what an MSDS is. • Has all the MSDS’s organized in a binder. • Facility exhibits good housekeeping. • Has stack of sign-in sheets for past safety meetings. • Has a safety committee. Form 33 Revised -- August 2007

  22. Examples of Better Positive Cues • Safety responsibilities built into every job description. • Formal annual review of all JHA/JSA’s. • Created a matrix chart to show who’s first aid card, certification, hearing test, etc., is due when. • Meeting minimum OSHA requirements gets you 2’s. • Exceeding minimum OSHA requirements gets you 3’s. Form 33 Revised -- August 2007

  23. Analysis Of S&H Program OSHCON is taught two ways to evaluate the Safety Program: Top-Down, and Bottom-Up Analysis. Most Consultants prefer Bottom-Up Analysis because it starts with determination of hazard/no hazard, document/no document, positive response/negative response. Form 33 Revised -- August 2007

  24. Bottom-Up Assessment Cultural Component: Management Leadership & Employee Participation ^ Managerial Component: Planning and Evaluation; Administration and Supervision; and Safety & Health Training ^ Operational Component: Hazard Anticipation and Detection; and Hazard Prevention and Control Form 33 Revised -- August 2007

  25. Bottom-Up Assessment • This generally occurs during the physical walkthrough of the workplace. Employs primarily Observations, Measurements, and Employee Interviews • Focuses on Hazards, Violations, and Program voids which are then linked to Operational Attribute(s) as negative cues. • Positive cues are similarly linked to one or more Attributes. Form 33 Revised -- August 2007

  26. Bottom-Up Assessment • Requires Analytical thinking to link Operational cues to Managerial and Cultural Attributes. You must identify the ROOT CAUSE, or you will be missing “The Gorilla” again. Form 33 Revised -- August 2007

  27. Hazard to System Linkage Form 33 Revised -- August 2007

  28. Linking A Hazard to the Operational Component Hazard Found: Damaged ladder in use. Could be due to breakdown in one of the following: Form 33 Revised -- August 2007

  29. Linking an Operational Failure to the Managerial Component Form 33 Revised -- August 2007

  30. What Is The Source of the Problem (Hazard) ? (2) Inspection program exists but ladder is defective; • (26) An employee is designated to inspect ladders; • (27) Employee knows he is responsible for inspections; • (28) Employee has been told he’s accountable for the job; • (29) Employee has knowledge and skills to do effective inspections; • (30) Employee has the authority to get the job done; • (31) Employee has the resources available to correct; • (32) Organizational policies promote the performance of his S&H responsibilities. Form 33 Revised -- August 2007

  31. OPERATIONAL COMPONENT WEAKNESS…. Attribute #33 – Organizational policies do not result in correction of non-performance of safety and health responsibilities. The company says it is tough on safety accountability but overlooks non-performance. No one has ever been disciplined. Now we look for a link to the Cultural Component. Form 33 Revised -- August 2007

  32. Linking a Managerial Failure to the Cultural Component During interviews of employees and supervisors we find that: #41, “Top Management considers S&H to be a line rather than a staff function.” and #50, “There is an effective process to involve employees in safety and health issues” both score low because… Form 33 Revised -- August 2007

  33. Linking a Managerial Failure to the Cultural Component The Owner has difficulty truly relinquishing primary safety responsibilities to others. He likes to be in control. His running the company, and busy schedule are resulting in his overlooking of accountability issues. What looked so good initially in the written Policies & Procedures Manual, is only in print – not fact. Form 33 Revised -- August 2007

  34. Linking a Managerial Failure to the Cultural Component • Bottom-Up analysis of an individual hazard may not reveal a clear link to the Cultural Component • Bottom-Up analysis of multiple hazards with common Managerial failures should provide much easier linkage to the Cultural Component. Form 33 Revised -- August 2007

  35. Realistically, back on Slide #28, we may have found that in addition to the Inspections, we had issues with other Operational Component Attributes. Form 33 Revised -- August 2007

  36. Hazard Found: Damaged ladder in use. Could be due to breakdown in one of the following: Form 33 Revised -- August 2007

  37. Likewise, any of the other Managerial Component Attributes from Slide 30 could have been found to be inadequate or ineffective. Form 33 Revised -- August 2007

  38. What Is The Source of the Problem (Hazard)? Slide 31 (2) Inspection program exists; • (26) An employee is designated to inspect ladders; • (27) Employee knows he is responsible for inspections; • (28) Employee has been told he’s accountable for the job; • (29) Employee has knowledge and skills to do effective inspections; • (30) Employee has the authority to get the job done; • (31) Employee has the resources available to correct; • (32) Organizational policies promote the performance of his S&H responsibilities. Form 33 Revised -- August 2007

  39. Finished Product With multiple negative and positive cues for multiple Attributes, the finished analysis, if drawn on paper, might create so many Bottom-Up tracks crossing over each other that the analysis looks like one of John Madden’s confusing play diagrams, or an air traffic controller’s screen. It can get that complicated. Form 33 Revised -- August 2007

  40. Finished Product The 58 Attributes are so interrelated, that I equate them to 58 marbles in a small bowl: You can’t move one, without causing several others around it to also move. In this same manner, I have found that successful implementation of an action plan to enhance one Attribute, can indirectly result in various degrees of improvement for 2-5 other attributes. Form 33 Revised -- August 2007

  41. The Pitch! Try the Form 33 at your workplace and see if it doesn’t help your safety program look better. If it doesn’t, you haven’t lost anything. But I think it will make a difference in the way you identify program problems, and solve them more effectively. Form 33 Revised -- August 2007

  42. QUESTIONS? Jim Barkley, OSHCON Consultant Manager 210-593-0070 ext 700 james.barkley@tdi.state.tx.us Fax 210-593-0103 Form 33 Revised -- August 2007

  43. I. Operational ComponentA. Hazard Anticipation & Detection Form 33 Revised -- August 2007

  44. Item 1.A comprehensive, baseline hazard survey has been conducted within the past five (5) years. Purpose:To determine if the organization, through site inspection and analysis, has developed a reasonably complete inventory of the S & H hazards existing at a certain time, to serve as the basis for subsequent action planning and priority setting. Form 33 Revised -- August 2007

  45. Item 2.Effective safety and health self-inspections are performed regularly. Purpose: To determine if personnel in the organization are performing effective S & H inspections on a regular basis. Form 33 Revised -- August 2007

  46. Item 3.Effective surveillance of established hazard controls is conducted. Purpose: To determine if the organization exercises ongoing diligence to detect situations in which previously established safety and health controls have become missing, defective, deficient, improperly applied or otherwise inadequate. Form 33 Revised -- August 2007

  47. Item 4. An effective hazard reporting system exists. Purpose:To determine if the organization has policies and procedures that operate to effectively confirm employee knowledge of hazard existence in order to facilitate planning and prompt hazard correction. Form 33 Revised -- August 2007

  48. Item 5.Change analysis is performed whenever a change in facilities, equipment, materials, or processes occurs. Purpose: To determine if the organization has effective policies and procedures that result in advance detection of potential hazards associated with planned or anticipated changes in the workplace. Form 33 Revised -- August 2007

  49. Item 6.Accidents are investigated for root causes. Purpose:To determine if the organization investigates accidents to identify underlying causes so that corrective action can be taken to prevent recurrence. Form 33 Revised -- August 2007

  50. Item 7.Material Safety Data Sheets are used to reveal potential hazards associated with chemical products in the workplace. Purpose:To determine if the organization is effectively utilizing the information contained in Material Safety Data Sheets to detect existing or potential hazards. Form 33 Revised -- August 2007

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