# Presentation: 367680

## Veterans Health Administration
Occupational Safety and Health

Basic Safety Training for
 Top Management Officials

**Occupational Safety and Health**
**	****	****	**
**Basic Safety Training for**
** ****Top Management Officials**

- 1

**Notes:**
This training package consists of three sections (Department Safety and Health Program,  Facility Safety and Health Program, and a Walk-around Inspection) that can be presented together or separately.  Each section should be tailored to address the specific concerns of the facility and of the officials attending the presentation.  It is recommended that the presentation be coordinated by Regional and facility OSH personnel and that all three sections be presented in one training session.  Such coordination is intended to demonstrate the interworking of the two programs and the necessity of a close working relationship between Regional and facility personnel. 

Facility Directors, Associate/Assistant Directors, and Chiefs of Staff should attend this presentation at the time of their appointment.  Other facility officials and the local safety representative should be invited to attend the presentation anytime it is offered.

This training is required by 29 CFR 1960.54 “Training of Top Management Officials” and is intended to inform top management officials of their responsibilities concerning occupational safety and health, to describe the benefits of an effective OSH program, and to obtain their understanding and support concerning the allocation of time and resources for OSH initiatives, many of which will have long term returns.

The speaker’s notes are intended to provide guidance to the presenter and are not intended to be read to the participants. Presenters are encouraged to tailor the presentation to suit their objectives and to build upon their experience for examples, etc.

## 

Regional Industrial Hygienist: ________________
Regional Safety
	and Fire Protection Engineer: ______________
Regional Safety Manager: ___________________

Phone Number: __________________
Fax Number: ____________________
E-mail: _________________________

**Regional Industrial Hygienist: ________________**
**Regional Safety**
**	****and Fire Protection Engineer: ______________**
**Regional Safety Manager: ___________________**
**Phone Number: __________________**
**Fax Number: ____________________**
**E-mail: _________________________**
**	**

**Departmental ****Occupational Safety and Health Program**

- 2

**Notes:**
Departmental Safety and Health Program:

Appropriate information should be entered in the blanks.  This slide should be verified and updated for each presentation.

## Objectives of Presentation

**Increase understanding and support for the safety and health program**
**Inform top management officials of their responsibilities concerning safety and health**
**Highlight the benefits of an effective safety and health  program**
**Comply with Federal regulations **

- 3

**Notes:**
These topics will be discussed in more detail as the presentation progresses:
Increase Understanding and Support:  The intent of this training is to explain the Department’s, the Region’s, and the facility’s role in the safety and health program and  to convince top management that this program deserves their support.

Top Management Responsibilities:  Safety and health are the responsibility of all employees, but the responsibility of top management is more than that.  They have to identify resources for long term solutions also which is never easy. 

Benefits of Effective Safety and Health Programs:  Safety and health initiatives have many benefits; however, when the safety and health program does not work and a serious injury or fatality occurs, most often top management officials have to notify the family of the employee injured or killed.  The major intent of this training is to eliminate the reason for such calls. 

Comply with Federal Regulations:  Training of top management officials is required by 29 CFR 1960.54.  Periodic update training (e.g., as part of management conferences, etc.) is also required.

.

## Customers of Safety and Health Program

**Employees**

**Patients**

**Visitors**

**Volunteers**

- 4

**Notes:**
The primary customers of the VA OSH program are the employees and the volunteers.  The OSH program impacts every VA employee from the Secretary  to the first day volunteer at the smallest  facility.  Of all VA personnel the ones that come in contact most with the beneficiaries, patients, and visitors are the employees and the volunteers.  When employees and volunteers are not able to work or their ability to work is impaired because of an on-the-job injury, our beneficiaries, patients, and their families do not receive the quality of services they deserve.  The direct customers of the VA safety and health program are our employees and our volunteers - our most valuable resources; the indirect customers are those we serve - the veterans and their families.

## Benefits of An Effective Safety and Health Program

**Reduce Costs of OWCP****	****	****	****	**
**Increase Productivity****	****	****	****	**
**Increase Employee Morale****	****	****	**
**Increase Rapport with Employees/Unions****	****	****	****	**
**Reduce Outside Compliance Intervention****	****	****	****	****	**
**Minimize Bad Publicity****	****	****	****	**
**Improve Facility Image (VSOs, Community)****	****	****	****	****	**
**Minimize Disruption of Services Provided**

- 5

**Notes:**
The benefits of a safety  and health program are long term in nature.  Since we often plan for the short term, safety and health require that we may need to look at many issues differently.

	Reduce Cost of OWCP:  The only way to minimize OWCP costs is to eliminate/prevent injuries and illnesses.  Even the best OWCP case management can only assure that costs are appropriate.

	Increase Productivity:  Every employee away from work or whose capacity to work has been reduced by an on-the-job injury or illness, reduces the amount of work that gets completed.

	Increase Employee Morale:  When all employees are at work, ready to work, morale increases.  Also, safety and health issues give management an “opportunity” to show how much it cares for its employees.

	Increase Rapport with Employees/Unions:   One area on which both management and unions can agree is safety and health.  It makes sense for both management and labor.  When management demonstrates that serious issues will be addressed promptly, many minor issues are settled without the need for intervention from the top management.

	Reduce Outside Compliance Intervention:  Employee complaints should be minimized as a result of an effective safety and health program.  Inspectors from outside of VA should recognize effective programs.

	Minimize Bad Publicity:  Work-related fatalities, serious incidents, etc. should be minimized if the safety and health program is effective.  When such incidents occur, the facility should closely evaluate the incident to determine all causes and develop and implement appropriate corrective actions.

	Improve Facility Image:  Regaining an image once it has been tarnished can be impossible.

	Minimize Disruption of Services Provided:  Prevention is less time consuming and less stressful than resolving an issue (such as a fatality, violation, etc.) after it has occurred.

## Top Management Involvement

**Words**
**Actions**
**Resources**

**Reflect**
**Commitment**

- 6

**Notes:**
If VA’s top management doesn’t demonstrate its commitment to safety and health, facility OSH programs are ineffective and inefficient.

	Words - Employees need to be periodically reminded of management’s commitment to safety and health.  A memorandum to all employees stating this commitment should be periodically updated and distributed.

	Actions - Employees need to see top management officials involved in safety and health initiatives (e.g., training, promotion initiatives, etc.) and to see them take strong action to correct hazards. 

	Resources - Employees need to be aware that management has provided resources to correct deficiencies identified.

Discuss some methods that demonstrate the commitment of top management by their follow-up on safety issues of importance to the facility and its employees.

## Potential Limits to An Effective Safety and Health Program

**Complicated Regulations **
**Safety and Health May Be Used for Ulterior Motives**
**Priorities Sometimes Appear to Conflict**
**	****	****	**
**Everyone Considers Themselves Safe**
**	****	****	**
**Safety Hazards Become Accepted as Normal**
**	****	****	****	****	**
**Prevention IS NOT Exciting**
**	****	****	****	**

- 7

**Notes:**
Complicated Regulations:  Volumes of OSHA, JCAHO, EPA, and other similar regulations are difficult to interpret.  Facility management should rely on facility, Regional, and Central Office  safety and health personnel to provide support in this area.

Safety and Health Is Not Free:  Resources must be provided for training, PPE, etc.  Corrective actions may require extensive renovation.

Safety and Health May Be Used for Ulterior Motives:  Employees and unions sometimes use safety concerns to deflect criticism concerning performance.  All safety concerns should be addressed separately and not allowed to diffuse concerns about performance.  Resource limitations should not be used to avoid correcting hazards.

Priorities Sometimes Appear to Conflict:  Because many safety initiatives have a long term impact or require the expenditure of funds up front, it sometimes “appears”  that they conflict with other initiatives.  However, safety-related corrective actions can provide significant benefits to areas impacted.  

Everyone Considers Themselves Safe:  A recent study found that over 70% of all drivers in the United States considered themselves excellent drivers, but you only need to drive down the street to find the other 30%.

Serious Safety Hazards Become Accepted As Normal:  People often walk past broken or ungrounded electrical receptacles and are not concerned enough to implement a facility-wide program to correct the hazards expeditiously until someone receives a shock or is electrocuted.

Prevention IS NOT Exciting:  Everyone runs to see where the fire is, but no one runs to see the fire prevention training.

## 
OSH Act - Section 19				
Executive Order 12196 (February 26, 1980)			
Executive Order 12566 (September 26, 1986)			
29 Code of Federal Regulations 1960					
Directive 7700 and Handbook 7700.1				
Secretary’s Letters (June 1, 1993, Goals, etc.)

**OSH Act - Section 19****	****	****	****	**
**Executive Order 12196 (February 26, 1980)****	****	****	**
**Executive Order 12566 (September 26, 1986)****	****	****	**
**29 Code of Federal Regulations 1960****	****	****	****	****	**
**Directive 7700 and Handbook 7700.1****	****	****	****	**
**Secretary’s Letters (June 1, 1993, Goals, etc.)**

**Occupational Safety and Health Program**

- 8

**Notes:**
OSH ACT - Section 19:  Requires the Secretary to “establish and maintain occupational safety and health programs and to provide safe and healthful places and conditions of employment.”

Executive Order 12196:  Requires that ALL Federal employees be provided places and conditions of employment free from recognized hazards, that comply with all standards promulgated by OSHA, and where unsafe or unhealthful working conditions are promptly abated.

Executive Order 12566:  Requires Federal employees to wear a seat belt when occupying the front seat of a vehicle, while on official travel.

29 CFR 1960:  Each Federal agency must “develop and implement a comprehensive occupational safety and health program.”

MP-3, Part III:  This document defines the VA occupational safety and health program.

Secretary’s Letters:  Secretary Brown emphasized his support to the VA OSH program and established OSH goals for the first time in FY 1994.

## To reduce or eliminate work-related injuries/illnesses 				
To minimize the severity of injuries/illnesses that occur					
To assure compliance with applicable OSH regulations and standards (e.g., OSHA, JCAHO, etc.)					
To implement safe work practices			
To provide a safe and healthful work environment for VA employees, in accordance with the VA’s Mission and Goals Statement

**To minimize the severity of injuries/illnesses that occur****	****	****	****	****	**
**To assure compliance with applicable OSH regulations and standards (e.g., OSHA, JCAHO, etc.)****	****	****	****	****	**
**To implement safe work practices****	****	****	**
**To provide a safe and healthful work environment for VA employees, in accordance with the VA’s Mission and Goals Statement**

**Objectives of VA Safety and Health Program**

- 9

**Notes:**
The objectives of the VA OSH program reflect all of the requirements of the applicable regulations and have an impact on every VA facility.  Achievement of the objectives will minimize costs, increase productivity and morale, and will reflect favorably on the facility and the Department.

Indicators (a tool used to measure, over time, an organization’s performance of functions, processes, and outcomes (JCAHO 1994)) and sentinel events (an occurrence that when noted, requires intensive assessment (JCAHO 1994)) used by Central Office and the facility  to determine effectiveness of the facility safety and health program should correlate directly with these objectives.

## Central Office Organization - DASHO

**10**

**Notes:**
The Assistant Secretary for Human Resources and Administration (006) has been been appointed by the Secretary to serve as the Designated Agency Safety and Health Official (DASHO) for the Department.  The DASHO is responsible to “manage and administer” the Department’s safety and health program. _______________________ is the DASHO.

The Office of Occupational Safety and Health (00S1) provides support and assistance to the DASHO concerning safety and health issues. __________________________ is the Director of the Office of Occupational Safety and Health.

Note:  Ensure that the names inserted are current.

## Central Office Organization - VHA

- 11

**Notes:**
This slide and the speaker’s notes may be impacted by the proposed Veterans Health Administration reorganization.  Please revise to assure that the most current organizational chart is presented.

## Regional Organization

- 12

**Notes:**
This slide and the speaker’s notes may be impacted by the proposed Veterans Health Administration reorganization.  Please revise to assure that the most current organizational chart is presented.

## 
Conduct Annual and Preoccupancy OSH Inspections

 Perform Follow-up Reviews 

Review/Comment On Project Designs and Specifications				
Provide Support and Guidance
OSHA
JCAHO
EPA
NFPA (Life Safety Code)
OWCP (Costs, Recordkeeping, Accident Investigation)

**Conduct Annual and Preoccupancy OSH Inspections**
** ****Perform Follow-up Reviews **
**	****	**
**Review/Comment On Project Designs and Specifications****	****	****	****	**
**Provide Support and Guidance**
**OSHA**
**JCAHO**
**EPA**
**NFPA (Life Safety Code)**
**OWCP (Costs, Recordkeeping, Accident Investigation)**

**Regional Responsibilities: VA-wide (VHA, VBA, NCS, etc.)**

- 13

**Notes:**
Regional responsibilities are generally classified as oversight and consultation.  Regional and facility personnel should closely work together, so that it is understood and recognized whether the Regional personnel are providing oversight or consultation.  Additionally, it is sometimes difficult to recognize when recommendations must be addressed because of the severity of the hazard.  Federal regulations (OSHA standards) must be addressed.

	Oversight:  Annual workplace and follow-up inspections are required by 29 CFR 1960 and Executive Order 12196.  The Department has identified these oversight responsibilities as essential because safety and health can sometimes be overlooked in our efforts to achieve the mission and goals of the Department.

	Consultation:  The services provided by state and local government (such as local fire marshal plan reviews and inspections, etc.) are not provided to Federal facilities.  Plan and specification reviews are extremely beneficial and often identify deficiencies that would be costly to correct upon completion of a project.  Safety and health standards are complex, and the expertise of Regional personnel is an invaluable resource for VA facilities.   

## Local Safety Representative

Training
Basic Safety for Local Union Safety Representatives
Specialized Training at Facility

Effective Safety Programs Should Reduce Number Of Safety and Health Related
Employee Complaints
Grievances

**Training**
**Basic Safety for Local Union Safety Representatives**
**Specialized Training at Facility**
**Effective Safety Programs Should Reduce Number Of Safety and Health Related**
**Employee Complaints**
**Grievances**

**Encourage Union Participation in the Safety and Health Program**

- 14

**Notes:**
Local Safety Representatives:  Union locals may designate a local safety representative.  The facility safety and health office should work closely with this individual to assure that safety and health concerns of the unions are addressed expeditiously.

Training:  In order to assure that the local safety representative can contribute effectively to the facility safety and health program, the facility should provide the training listed.

Employee Complaints Related to Safety and Health:  Although all employees have the right to request that OSHA or Regional personnel perform an inspection of alleged hazardous conditions at VA facilities, it is preferred that employees work within the facility safety and health program to address their concerns.  When employees understand the facility safety and health program and have confidence that their concerns will be addressed appropriately, they do not involve outside organizations as often. 

Grievances Related to Safety and Health:  Safety or health-related deficiencies addressed by a grievance should be looked into and corrected expeditiously.

## Indicators/Sentinel  Events (Department/Regions) FY 1994

**Lost-time Claims Rate****	****	****	**** 3.62**
**Cost of OWCP Claims****	****  ****	****$145,000,000**
**OSHA Citations****	****	****	****	****  535**
**JCAHO - OSH Related Grid Scores****	****  1.68**
**Training****	****	****	****	****	****85.50%**
**Management Involvement****	****	****    TBD**
**Sentinel Events**
**	****	****Fatalities FY 1994****	****	****         3**
**	****	****Willful, etc. Citations****	****	****       39**
**	****	****JCAHO Score 3 or More****	****                      59**
**	****	****OSHA Inspections - Complaints           40**
**	****	**

- 15

**Notes:**
This slide should be revised by the person presenting the Regional portion of this presentation to include the indicators/sentinel events that top management officials feel are beneficial to them and updated with the most current information available.

## Secretary’s Goals FY 1994

**46 (26.7%) VHA Facilities Including ___________________________________**** ****Met FY 1994 Goals **
**Secretary’s Goals FY 1995**
**Reduce Lost-time Claims Rate By 2%**
**Reduce Number of Lost-time Claims for Leading Category of Injury/illness****	****	****	****	****	**
**Members of Facility Safety and Health Committee Attend Meeting of Nationally Recognized Safety and/or Health Organization****	****	****	****	****	**
**Others**

- 16

**Notes:**
The name of the facility should be inserted on this slide, if the facility achieved the Secretary’s goals for FY 1994, otherwise the line should be deleted 

The goals listed on this slide should be revised to address the goals of particular interest to facility management.  See Appendix D: Occupational Safety and Health Goals for FY 1995. 

.

## OWCP Claims Rates

**Lost-time Claims Rate    =****	**** **_**Number of Lost-time Claims X 100**__**	**__**	**__**	**__**	**__**	**_**	****	**** Number of Employees**
**Total Claims Rate ****	****= ****	**_**Number of Claims Submitted X 100**_
_**	**__**	**__**	**__**	**__**	**__**	**_**Number of Employees**
**All Rates Per 100 Employees**
- _	__	__	__	__	__	_

- 17

**Notes:**
This slide shows definitions of the lost-time claims rate and the total claims rate, as computed by VA Central Office.  These rates are used throughout VA to evaluate facility safety and health program effectiveness.  There are other methods of computing these rates; however, this is the only method used throughout VA.  Presenters should be prepared to explain - how  they determine the rates that they use.  Enter the information below, so that it is available during your presentation.

Our lost-time claims rate for FY _____ = __________

Our total claims rate for FY  _____ = __________

Lost-time claims rate for VA (National Average) =3.65 (FY1994)

Total claims rate for VA (National Average) =5.53 (FY1994)

## Occupational Safety and Health Program at VA Medical Center
	       __________________________							

Industrial Hygienist: __________________
Safety Manager: ______________________
Safety Specialist: ____________________	

Phone Number: _______________
Fax Number:___________________
E-Mail:________________________

**	****       ****__________________________****	****	****	****	****	****	****	**
**	****	****	****	****	****	**
**Industrial Hygienist: __________________**
**Safety Manager: ______________________**
**Safety Specialist: ____________________****	**
**Phone Number: _______________**
**Fax Number:___________________**
**E-Mail:________________________**

- 18

**Notes:**
Facility Safety and Health Program:

This slide starts the facility portion of the presentation.

Appropriate information should be entered in the blanks.  This slide may need to be revised for each presentation.

## Facility Organization - Safety and Health

- 19

**Notes:**
This slide shows a facility organization for safety and health.   If the facility organization varies from that shown above or in the following slide, substitute it with your facility’s organization.  Drop this slide or the following  slide, whichever one is not representative of your facility.

Facility Directors are responsible for:
          (1)  Assuring that employees are provided a safe and healthful workplace (a workplace  that complies with OSHA standards),
          (2)  Assuring that staffing and funding are adequate to implement a comprehensive safety and health program,
          (3)  Developing plans to achieve the annual OSH goals established by the Secretary/DASHO,
          (4)  Assuring that maintenance, repair, and construction comply with applicable safety and health standards, 
          (5)  Assuring that OSH support is provided to local VA facilities,
          (6)  Other responsibilities listed in MP-3, Part III.

Associate/Assistant Directors:  Serve as the chairperson of the safety committee and are involved in the daily implementation of OSH program initiatives.

## Facility Organization - Safety and Health

- 20

**Notes:**
This slides shows a facility organization for safety and health.  If the facility organization varies from that shown above or in the previous slide, substitute it with your facility’s organization.  Drop this slide or the previous slide, whichever one is not representative of your facility.

Facility Directors are responsible for:
          (1)  Assuring that employees are provided a safe and healthful workplace (a workplace  that complies with OSHA standards),
          (2)  Assuring that staffing and funding are adequate to implement a comprehensive safety and health program,
          (3)  Developing plans to achieve the annual OSH goals established by the Secretary/DASHO,
          (4)  Assuring that maintenance, repair, and construction comply with applicable safety and health standards, 
          (5)  Assuring that OSH support is provided to local VA facilities,
          (6)  Other responsibilities listed in MP-1, Part III.

Associate/Assistant Directors:  Serve as the chairperson of the safety committee and are involved in the daily implementation of OSH program initiatives.

## Developing safety and health-related policies, programs, and procedures for the prevention of injuries/illnesses							
Coordinating the facility safety and health programs					
Assisting with safety and health-related issues such as:
Training
Accident investigations
Light-duty assignments
Operations and maintenance procedures	 		     throughout facility
Medical surveillance (IH)						
Maintaining safety and health records (including personal sampling records)							
Performing hazard surveillance surveys (Quarterly - High Hazard Areas, Semiannual - Entire Facility)

**Coordinating the facility safety and health programs****	****	****	****	****	**
**Assisting with safety and health-related issues such as:**
**Training**
**Accident investigations**
**Light-duty assignments**
**Operations and maintenance procedures****	**** ****	****	****     throughout facility**
**Medical surveillance (IH)****	****	****	****	****	****	**
**Maintaining safety and health records (including personal sampling records)****	****	****	****	****	****	****	**
**Performing hazard surveillance surveys (Quarterly - High Hazard Areas, Semiannual - Entire Facility)**

**Safety/Industrial Hygiene Responsibilities **

- 21

**Notes:**
Facility safety and health are not just the responsibility of the safety office or of safety and health personnel.  Every employee, supervisor, and top management official has safety and health responsibilities.
A few of the responsibilities for employees are listed below:
	 (1) Following safe work procedures (wearing required personal protective equipment, etc.), 
          (2) Recognizing unsafe conditions and correcting those conditions under their control,
          (3) Reporting unsafe conditions and practices, and work-related injuries and illnesses to supervisory personnel, and
          (4) Attending safety and health training.

Responsibilities for supervisors are listed on the speaker’s notes page 28, slide 22.

Safety and health personnel are managers of the facility safety and health program; they are not solely responsible for its development or its implementation. 

## Safety/Industrial Hygiene Responsibilities (Cont.)

**Assisting service chiefs/supervisors to identify and control hazardous chemicals, biological agents, and/or physical agents****	****	****	**
**Performing sampling and monitoring****	****	****	**
**Evaluating the results of personal and environmental sampling and monitoring****	****	****	****	****	****	**
**Approving personal protective equipment provided****	****	****	****	****	****	**
**Reviewing/commenting on safety and IH-related portions of project designs and specifications**

- 22

**Notes:**
A few of the responsibilities for supervisors are listed below :
	 (1) Enforcing safety rules, regulations, and standards within their area of responsibility (including initiating disciplinary action, as appropriate),
	(2) Encouraging employee suggestions concerning improving safety and health in the workplace,
	(3) Investigating injuries and illnesses that occur to employees they supervise,
	(4) Assuring their employees are trained to perform their work safely.

Notice the use of the word assisting on the slide.  Service chiefs and supervisors are responsible for the safety and health of the personnel they supervise, not safety and health personnel.

## Purpose - Facility OSH Committee

**To provide assistance and support to the facility Director concerning OSH issues and to serve as a focal point for facility-wide safety management issues.**

- 23

**Notes:**
The facility safety and health committee, when effective, can support the facility Director and resolve many issues before it becomes necessary to intervene.  The committee must be aware of top management’s commitment to safety and health. 

Words - Safety and health committee members need to be periodically reminded of management’s commitment to safety and health.

Actions - Safety and health committee members need to see top management officials at safety committee meetings periodically and to see them take strong action to correct hazards. 

Resources - Safety and health committee members need to be aware that management has provided resources to correct deficiencies identified.

Top management officials should periodically evaluate committee activities to assure that the committee is carrying out its responsibilities.  If they are not, training or guidance may be required.

## Assisting in the development, revision, and evaluation (CQI) of safety and health-related policies, programs, and procedures						
Reviewing/commenting on safety and health inspection reports (JCAHO, OSHA, etc.)					
Recommending/monitoring resource allocations for safety and health					
Identifying safety and health hazards or program deficiencies						
Developing and evaluating effectiveness of corrective actions					
Promoting safety and health throughout the facility						
Meeting JCAHO requirements

**Reviewing/commenting on safety and health inspection reports (JCAHO, OSHA, etc.)****	****	****	****	****	**
**Recommending/monitoring resource allocations for safety and health****	****	****	****	****	**
**Identifying safety and health hazards or program deficiencies****	****	****	****	****	****	**
**Developing and evaluating effectiveness of corrective actions****	****	****	****	****	**
**Promoting safety and health throughout the facility****	****	****	****	****	****	**
**Meeting JCAHO requirements**

**Facility Safety and Health Committee**
**Responsibilities**

- 24

**Notes:**

Top management officials should periodically evaluate the effectiveness of the facility safety and health program.  Certainly indicators and sentinel events are one method of assuring top management that the program is effective.  Additionally, the facility safety and health committee can perform more in depth evaluations that address the comprehensive safety and health program or specialized aspects of the program that are of particular interest.

The safety and health committee should be one of the best committees of which to be a member.  Members should positively impact safety and health problems at the facility and should feel that they are contributing to the safety and health of all volunteers and employees.  Members should be involved in exciting activities to promote safety and health at the facility and should be confident of top management’s support.   

CQI:  Continuous Quality Improvement

## Occupational Safety and Health Administration (OSHA)

**Develop Safety and Health Standards****	****	****	****	**
**Inspect Federal Agencies**
**Fatality**
**Accident Requiring Hospitalization of 3 ****	****	****or More (Catastrophe)**
**Employee Complaint**
**Targeted Inspection Program**

- 25

**Notes:**
OSHA, which was created by the OSH Act of 1970, develops workplace safety and health standards and is authorized to inspect Federal facilities.  OSHA cannot currently fine Federal facilities.  While on one hand not being able to levy fines eliminates one area of conflict (that private medical centers have), it may result in an increased number of citations when OSHA inspects Federal facilities.  When OSHA identifies a violation, the following questions should be asked:
	1.  What corrective action will eliminate the hazard?
	2.  What changes to the facility safety and health program are required to assure that this hazard does not reoccur?

Employee Complaints:  Any VA employee can complain to OSHA or to the Region, either of which will conduct an inspection to determine the validity of the complaint.

Targeted Inspection Program:  Each year OSHA identifies Federal facilities to be inspected based on the facility’s OWCP lost-time claims rate for the previous year.  Generally, if your facility is above the average rate for Federal facilities and has not been inspected within 3 years, your facility will be inspected.  OSHA’s targeting level for FY 1995 is _____ .

## Components of OSHA Inspection

**Components of OSHA Inspection**

**	****Under 29 CFR 1960 **OSHA has the right to conduct unannounced inspections.
**  ****Opening Conference****	****	**
- Purpose of Inspection
- Management/Union				Representation
**	****Records Review**
- Injury/Illness Log
- Exposure/Records
- Medical Records

- 26

**Notes:**
This slide and the following slide describe the procedure OSHA follows when they inspect a VA facility.  

Opening Conference:  The opening conference is  simply a meeting with facility officials to describe the nature of OSHA’s inspection.  Facility officials should ask any questions that they may have concerning the inspection itself, any resulting reports, scheduling, resolution of conflicts, etc.

Records Review:  OSHA compliance officers probably will review  the documents listed.  Recordkeeping deficiencies are some of the most frequently cited violations.

The OSHA evaluator has the authority:
 Enter without delay, and at reasonable times, any building, installation, facility, construction site, or other area, workplace.
 Inspect and investigate during regular working hours and at other reasonable time, and within reasonable limits and in a reasonable manner places of employment.
Question privately any employee, any supervisory employee, and/or any official in charge of an establishment.

Inspections can be conducted in conjunction with an OSHA evaluation

## Components of OSHA Inspection (Cont.)

**Walk-around Inspection**
- Interview Employees
- Take Measurements
- Take Exposure Samples (IH)
- Pictures
**Closing Conference**
- Review Alleged Violation (s)
- Discuss Abatement/Citation (if 		applicable)
- Management/Union 				Representation

- 27

**Notes:**
Walk-around Inspection:  Although individual compliance officers conduct walk-around inspections differently, later in the presentation top management officials will be given an opportunity to participate in a brief exercise that is similar to the OSHA inspection.

Closing Conference:  Upon completion of the inspection the compliance officer will meet with facility officials to discuss any deficiencies that were identified.  A formal report (OSHA 2H - Form) will be prepared at a later date, if the facility is being cited; however, the closing conference should be used to clarify any deficiencies identified and to initiate the process of developing interim and final corrective actions.  Facility officials should ask any questions they have concerning the inspection and the deficiencies identified.

Regional and JCAHO inspections have many similarities to OSHA inspections.    

## 
Options, if violation(s) cited:
Implement recommendations
Request informal conference (15
		 days from receipt of Notice)

Posting of OSHA Notice - 3 working days or until abated

Letter of Corrective Action

Interim corrective action must 
		address hazard (periodic
           progress reports)

OSHA may conduct Follow-up 
		Inspection

**Options, if violation(s) cited:**
- Implement recommendations
- Request informal conference (15
- 		 days from receipt of Notice)
**Posting of OSHA Notice - 3 working days or until abated**
**Letter of Corrective Action**
**Interim corrective action must **
**	****	****address hazard (periodic**
**           ****progress reports)**
**OSHA may conduct Follow-up **
**	****	****Inspection**

**Resulting Actions**

- 28

**Notes:**
See Appendix E: DASHO Letter 91-3: Occupational Safety and Health Administration Inspections and Notices of Unsafe and Unhealthful Working Conditions and Appendix F: (DRAFT) Federal Employer Rights and Responsibilities Following an OSHA Inspection. 

Letter of Corrective Action:  The OSHA Area Director  must be promptly notified in writing that appropriate corrective action has been taken (within the time set forth in the OSHA notice).

Interim Corrective Action Must Address The Hazard:  The facility must preclude an accident related to a deficiency cited during an inspection.  Often this may require interim corrective actions because the hazard identified cannot be corrected immediately, either because of a lack of funding, or the need for approval from a higher authority, etc.  Interim corrective actions may require administrative controls or the use of personal protective equipment until engineering controls can be implemented.  If interim corrective actions are necessary, periodic progress reports to OSHA may be required.

## Disagreements Concerning OSHA Citations

**If a Federal facility disagrees with an OSHA citation, submit a written appeal to the:**
**OSHA Regional Office Within 5 Days of Informal Conference****	**
**Office of Federal Agency Programs (Washington, DC) Within 15 Days of OSHA Regional Office Response**
**Federal Agencies DO NOT have the right to contest an OSHA notice**
**DASHO Notified, If Violation(s)**
**Willful**
**Repeated **
**Failure to Abate**

- 29

**Notes:**
Definitions: Willful Violation:  A violation in which the employer either knowingly failed to comply with a legal requirement (purposeful disregard) or acted with plain indifference to employee safety.
	Serious Violation:  When the workplace hazard could cause an accident or illness that would most likely result in death or serious physical harm, unless the employer did not know  or could not have known of the violation.
	Repeated:  If the agency has been cited previously for the same or a substantially similar condition and if OSHA’s regionwide inspection history for the agency lists a previous serious citation issued or the facility has received an other-than-serious violation within the past 3 years, a repeat violation will be issued.
	Failure to Abate:  Any hazards that have not been abated by the abatement date specified on the OSHA Notice will be cited as a failure to abate.

## Injury/Illness Prevention Initiatives

**Injury/Illness Review Board**
- Meets Monthly
- Started Date
**Promotional Activities**
- Driver Safety: Memorial Day
- Fire Prevention Week
**Training**
- Supervisors 95% Completed
- Tuberculosis Prevention
- OSHA Required
**Inspections**
- Semi-annual Survey:  Date
- Regional Annual:  Date
- OSHA:  Date
**Other**
- Infection Control Evaluating Needles
- Safety Committee Evaluating Training

- 30

**Notes:**
This slide should be revised by the presenters so that prevention initiatives implemented at the facility are addressed.  This is an opportunity to show  accomplishments and initiatives  that have been successful, and deserve the support of top management officials.

## Indicators/Sentinel  Events:  VAMC _______________ FY 1994

**Lost-time Claims Rate****	****	****	****##.##**
**Cost of OWCP Claims****	****	****  $###,###.##**
**OWCP Costs Per Employee    ****	****         $###.##**
**OSHA Inspection - Citations****	****	****   ###**
**JCAHO - OSH Related Grid Scores****	****   ###**
**Annual OSH Inspection Deficiencies****	****   ###**
**Training****	****	****	****	****### %**
**Met Secretary’s Goals FY 1994****	****Yes/No**
**Sentinel Events****	****	****	****None**

- 31

**Notes:**
This slide should be revised by the person presenting the facility portion of this presentation to include the indicators/sentinel events that top management officials feel are beneficial to them and updated with the most current information available. 

## Staffing:	# Safety Manager(s) and 				Engineer(s)
			# Safety Specialist(s)
			# Industrial Hygienist(s)
			# Industrial Hygiene 					Technician(s)
			# Clerical Support (Full-time)
			# Clerical Support (Part-time)		
Office Space:	Building _____, Room _______	
Telephone:	_____________,  Fax:   _______	
Computer Support:  ### SX/DX (CD ROM, Modem)

**	****	****	****# Safety Specialist(s)**
**	****	****	****# Industrial Hygienist(s)**
**	****	****	****# Industrial Hygiene ****	****	****	****	****	****Technician(s)**
**	****	****	****# Clerical Support (Full-time)**
**	****	****	****# Clerical Support (Part-time)****	****	**
**Office Space:****	****Building _____, Room _______****	**
**Telephone:****	****_____________,  Fax:   _______****	**
**Computer Support:  ### SX/DX (CD ROM, Modem)**

**Current Resources**

- 32

**Notes:**
This slide must be revised by the person presenting the facility portion of the presentation to show  the number of people on the staff at the facility and other appropriate information.  This portion of the presentation is to inform top management officials of current resources provided for the facility safety and health program and to identify any additional resources required.

## Facility Safety and Health Budget

**Consultants/Laboratory Support****	****	****$#,###.##**
**Personal Protective Equipment**
**	****Safety Shoes****	****	****$###. ##**
**	****Eye Protection****	****	****$###. ##**
**	****Respirators****	****	****$###. ##**
**	****Miscellaneous****	****	****$###. ##**
**	****	****Subtotal****	****	****	****	****$#,###. ##**
**Reference Materials****	****	****	****	****$#,###.##**
**Training Materials****	****	****	****	****$#,###.##**
**Equipment****	****	****	****	****	****$#,###.##**
**Supplies****	****	****	****	****	****$#,###.##**
**Promotional Materials****	****	****	****$#,###.##**
**Travel****	****	****	****	****	****	****$#,###.##**
**Total****	****	****	****	****	****	****$#,###.##**

- 33

**Notes:**
This slide must be revised by the person presenting the facility portion of the presentation to show  the current funding provided for the facility safety and health program.  Make sure the arithmetic is correct.

Note:  Funding for personal protective equipment may be included in Service operational funds, but not in the safety and health budget.

## 
Basic Safety for Medical Center Safety Personnel 	Yes/No 
Laboratory Safety				Yes/No
Hazard Communications			Yes/No
Respiratory Protection			Yes/No
Asbestos (AHERA)				Yes/No
Infectious Diseases (TB, etc.)			Yes/No
Other: __________________			Yes/No								

Additional Safety Training Required

**Basic Safety for Medical Center Safety Personnel ****	****Yes/No **
**Laboratory Safety****	****	****	****	****Yes/No**
**Hazard Communications****	****	****	****Yes/No**
**Respiratory Protection****	****	****	****Yes/No**
**Asbestos (AHERA)****	****	****	****	****Yes/No**
**Infectious Diseases (TB, etc.)****	****	****	****Yes/No**
**Other: __________________****	****	****	****Yes/No****	****	****	****	****	****	****	****	**
**Additional Safety Training Required**

**Training Received By Facility Safety and Health Personnel**

**Other: __________________________________________**

- 34

**Notes:**
This slide must be revised by the person presenting the facility portion of the presentation to show  safety and health-related training received by facility safety and health personnel and any additional training required.  The training listed appears to be what is minimally required to implement an effective safety and health program at the medical center level.  All safety and health professionals should complete the “Basic Safety for Medical Center Safety Personnel;” however, only one safety or health professional at the facility would be required to complete the other training listed.

## 
Basic Safety Training for Supervisors	##%
Facility Safety and Health Committee	##%
Motor Vehicle Operators				##%
Respiratory Protection				##%
Hazard Communications				##%
Asbestos O/M Workers				##%
Others:								

Additional Safety Training Required

**Basic Safety Training for Supervisors****	****##%**
**Facility Safety and Health Committee****	****##%**
**Motor Vehicle Operators****	****	****	****	****##%**
**Respiratory Protection****	****	****	****	****##%**
**Hazard Communications****	****	****	****	****##%**
**Asbestos O/M Workers****	****	****	****	****##%**
**Others:****	****	****	****	****	****	****	****	**
**Additional Safety Training Required**

**OSH Training Received By Facility Employees**

**Other: ________________________________**

- 35

**Notes:**
This slide must be revised by the person presenting the facility portion of the presentation to show safety and health-related training received by facility employees and any additional training required.  The training listed does not address all required safety and health training; however, this slide enables the presenters to identify areas where additional training should be provided and to identify strengths of the facility’s safety and health training program.

## Facility Safety and Health Program Needs

**Staffing - Adequate/Inadequate**
- One Industrial Hygienist Needed
- Number of Safety Personnel Adequate
**Resources - Adequate/Inadequate**
- Funding Levels Adequate
- CD ROM Needed (Reduce Filing, Less Costly)
**Training - Safety Professionals**
- Confined Space Training Needed
- Respiratory Protection Training Needed
**Training - Employees**
- 100% of Supervisors Trained (Basic)
- 50% of Supervisors Trained (Advanced)
**Other (Policies/Procedures) - PPE policy needs to be updated**

- 36

**Notes:**
This slide must be revised by the person presenting the facility portion of the presentation to summarize the discussion of the four previous slides.  If a specific area is adequate, that should be so stated.

## Walk-around Safety and Health Inspection

**Review Safety and Health Manuals and Records **
**Interview Employees**
**Take Exposure Samples and Measurements**
**Document Hazards Identified (Notes, Pictures, etc.)**
**Develop Interim and Permanent Corrective Actions**

- 37

**Notes:**
Walk-around Inspection:

This slide introduces the walk-around inspection.  This section can be scheduled separately, can be included as part of the facility portion of the presentation, or as part of the complete presentation.  It is recommended that the walk-around inspection be limited to 30 minutes and it should emphasize one area or issue of interest to the officials attending the presentation.  The success of this portion of the presentation will depend upon the area or issue being evaluated and upon the experience and enthusiasm of the presenter.  For this reason, Regional and facility safety and health personnel should work closely together to identify the area or issue to be addressed and to determine the most effective person (or persons) to lead the walk-around inspection.  The walk-around inspection should address both positive and negative aspects of the area or issue being evaluated.  Preplanning is essential to the success of this portion of the presentation.

## Area(s) To Be Evaluated

**Applicable Standards**

-   Personal Protective Equipment
-   Eyewashes
-   Tuberculosis Isolation
- (Insert specific references concerning the areas to be inspected.)

-   Histology Laboratory
-   Tuberculosis Isolation Area
-   Other Laboratories
- (Select areas of the medical center where
- known deficiencies exist that are of interest
- to the person(s) attending the presentation.)

- 38

**Notes:**
This slide must be revised by the person conducting the walk-around inspection portion of  the presentation, so that the area or issue to be evaluated as part of the walk-around inspection is addressed.  The presenters should identify areas of the facility that have well known deficiencies that are of interest to the attendees.

The bottom of this slide should reference the specific standards that will be evaluated during the walk-around inspection and should clearly state the deficiencies that may be observed.  Do not reference individual OSHA standards, etc.  Top management does not need that level of detail.

Even if you walked through the area to be inspected just before the presentation, it will be difficult to predict what the physical environment (e.g., hazards, deficiencies, procedures in process, etc.) will be during the walk-around inspection portion of the presentation.  Encourage top management officials to walk-around on their own later,  just to see the similarities and  the changes.

Emphasize the use of questioning employees and visual observation.  Stress the similarity between this walk-around inspection and the inspections performed by JCAHO and OSHA. 

## Follow-up

**Words**
** ****Actions**
** ****Resources**

**Reflect**
**Commitment**

- 39

**Notes:**
This slide allows the presenters to emphasize the role of top management officials in the walk-around inspection - but more importantly in the safety and health program itself.

	Words:  If top management does not talk about safety and health, why would employees?

	Actions:  If top management does not act to correct safety  and health hazards, why should employees?

	Resources:  If top management does not provide resources for safety and health, why would employees?

## Handout - Indicators/Sentinel Events (Department and Region) FY 1994

**Lost-time Claims Rate****	****	****	**** 3.62**
**Cost of OWCP Claims****	****  ****	****$145,000,000**
**OSHA Citations****	****	****	****	****  535**
**JCAHO - OSH Related Grid Scores****	****  1.68**
**Training****	****	****	****	****	****85.50%**
**Management Involvement****	****	****    TBD**
**Sentinel Events**
**	****	****Fatalities FY 1994****	****	****         3**
**	****	****Willful, etc. Citations****	****	****       39**
**	****	****JCAHO Score 3 or More****	****                      59**
**	****	****OSHA Inspections - Complaints           40**
**	****	**

**40**

**Notes:**
This slide is included as the handout for the Regional portion of the presentation and is identical to slide 15.  If printed out as a handout, make sure that the figures presented in slide 15 are identical to the figures  presented in the handout.

Enter the correct values in the slide portion of Powerpoint and print out the copies of the handout by printing slide 40.  It is recommended that TOPMGTBW.ppt be used for printing out the handouts. 

## Handout - Indicators/Sentinel Events (Facility) FY 1994

**Lost-time Claims Rate****	****	****	****##.##****	**
**Cost of OWCP Claims****	****	****  $###,###.##**
**OWCP Costs Per Employee    ****	****         $###.##**
**OSHA Inspection - Citations****	****	****   ###**
**JCAHO - OSH Related Grid Scores****	****   ###**
**Annual OSH Inspection Deficiencies****	****   ###**
**Training****	****	****	****	****### %**
**Met Secretary’s Goals FY 1994****	****Yes/No**
**Sentinel Events****	****	****	****None**

**41**

**Notes:**
This slide is included as the handout for the facility portion of the presentation and is identical to slide 31.  If printed out as a handout, make sure that the figures presented in slide 31 are identical to the figures  presented in this handout. 

Enter the correct values in the slide portion of Powerpoint and print out the copies of the handout by printing slide 41.  It is recommended that TOPMGTBW.ppt be used for printing out the handouts.