Elements of an Injury and Illness Prevention Program The Governor's Executive Order #194 can be summarized into the following 13 required elements. 1. Accident prevention policy/mission statement 2. Written performance/accountability standards and objectives for managers and supervisors to: a. Reduce injuries and illnesses b. Enhance workplace health and safety 3. Compliance activities and programs. 4. Designated agency safety coordinator 5. Health and safety committees 6. Written safety rules and practices 7. Health and safety training and education 8. Health and safety inspections/surveys 9. Loss prevention and control techniques 10. Health and safety promotion and awareness programs 11. Accident investigation and reporting procedures 12. Worker’s Compensation claims management 13. Early return to work programs Each of these 13 elements is described on subsequent pages. Accident Prevention Policy/Mission Statement Your agency's commitment to employee health and safety shows in the decisions you make and the specific actions you take to develop and promote your program. Both reflect the priority your agency places on these issues. Employees (and supervisors) in return will respond to that level of commitment. Every successful organization realizes that maximum efficiency and quality can only be achieved by eliminating or controlling potential hazardous work practices before they result in a workplace injury or illness. Agencies can begin developing an effective injury and illness prevention program by integrating this philosophy into their entire operation and organizational values. One way to visibly demonstrate this philosophy and the commitment of top- management is to develop an accident prevention policy or mission statement. Your policy/mission statement should clearly communicate to your employees the value in which health and safety protection is held in your agency in relation to other organizational values and objectives. Your policy/ mission statement should also make the order of priorities clear so that all employees will know what choice to make if a conflict occurs between employee health and safety and another organizational value. Several examples of policy/mission statements can be found in Appendix B. In for your health and safety policy to be effective, you must clearly communicate your policy to all your employees by both explanation and example. For example, you may want to explain your policy in group meetings and/or express your commitment in a letter sent to each employee. You should also consider posting your mission statement throughout each of your locations. Your policy is also communicated by example when managers and supervisors follow all
and their sources, physical examination reports, employment records, and other information. Refer to State Statute 101.055 for additional information. Documentation of Your Activities Essential records, including those legally required for worker’s compensation, medical surveillance and COMM/OSHA standards, must be maintained for as long as required. Keep in mind that any inspection or survey conducted by the Department of Commerce or an outside consultant may require you to demonstrate the effectiveness of your recordkeeping program. Written documentation of required safety and health training must also be maintained. The documentation must specifically include the employee's name or other identifier, training dates, type(s) of training and the name of the training provider. These records should be kept for at least three years. In addition to the compliance requirements previously described, the following is a summary of the key COMM/OSHA regulations and statutes. If you have questions concerning specific compliance requirements, contact the Department of Commerce, Division of Safety and Building at (608) 267-4434. Summary of Key State Statutes and COMM/OSHA Regulations. State Statute 101.055 Key requirements: Employers have a legal obligation to provide a safe and healthful working environment The authority to conduct inspections and enforce standards is given to the Department of Commerce Employers must maintain records of injuries and illnesses Employers must maintain employee exposure records Employers must notify exposed employees of his/her monitoring results and any corrective action taken Employers must post a summary of employee rights and protections - DILHR Notice SBD 9301-P (4,92) (see Appendix A - for further detail) Employers must not discriminate against employees who file a complaint with the Department of Commerce. Access to Employee Exposure and Medical Records OSHA 1910.1020 Required Elements: Provide of access to medical and exposure records to employees and designated representatives Provide employee notification of access rights at time of initial employment and annually thereafter Retention of records (30 Employee Emergency and Fire Prevention OSHA 1910.38 Required Elements: Action plans in writing to ensure employee safety from fire and other emergencies Written plan must include - Escape procedures, route assignments - Shutdown procedures - Method to account for personnel - Rescue and medical duties - Preferred means of reporting emergencies - Names and persons/departments to contact - Employee training Occupational Exposure OSHA 1910.95 Required elements: A Hearing Conservation Program is needed whenever employee noise exposures equal or exceed an 8-hour
The frequency of these inspections depends on the operations involved, the magnitude of the hazards, the proficiency of employees, changes in equipment or work processes and the history of workplace injuries and illnesses. Several COMM/OSHA standards also require certain equipment and processes be inspected on a regular basis (See Appendix M). Inspections should be conducted by personnel who, through experience and/or training, are able to identify actual and potential hazards and understand safe work practices. Written inspection reports should be prepared and reviewed by and/or the safety committee. This review will assist in prioritizing problems and verify completion of previous corrective actions. Overall inspection program results should also be reviewed for positive or negative trends. To guarantee the success of your inspection program, hazards must be corrected or controlled as soon as they are identified. For those hazards that can not be immediately abated, establish a target date for correction. You also need to provide interim protection to the affected employees while efforts to abate the hazard are proceeding. A written tracking system, such as a log, helps you monitor the progress of hazard correction. A comprehensive self-administered inspection checklist is provided in Appendix N. 9. Loss Prevention and Control Techniques An effective Health and Safety Program relies on the use of various loss prevention and control techniques to prevent or control hazards that contribute to work-related injuries and illnesses. Hazards in the workplace take many forms, including air contaminants, tasks involving repetitive motions, chemical spills, equipment with moving parts, extreme heat or cold, noise, fire and toxic materials such as silica and asbestos. There are seven basic methods or techniques to prevent or control these hazards before they result in an injury or illness. 1. Engineering Controls The most preferred method for controlling health and safety hazards is to eliminate or control the source of the hazard by the use of engineering controls. Some examples of engineering controls include: * Ergonomically designed tools, equipment and workstations * Isolation or enclosure of hazardous processes or noisy equipment * Mechanical exhaust systems/booths for controlling toxic materials * Substitution of products that are not hazardous or less hazardous than the product(s) currently in use * Replacement of potentially unsafe equipment or machinery with new equipment/machines that meet or exceed safety standards * Electrical or mechanical safety interlocks and guards for machine hazards * Provisions to shutdown and lockout machinery when performing service or repair
* Fire prevention systems 2. Procedural Controls When engineering controls are not feasible or affordable, or when guards or enclosures on equipment must be temporarily removed to conduct repairs and/or when employees are performing nonroutine hazardous work such as confined space entry, procedural controls should be used to protect the safety and health of workers. Procedural controls include work rules, general work practices and specific written safe operating procedures. The following techniques should be used to insure that employees always follow these procedural controls: * Work practice training to help workers understand why special precautions are needed * Positive reinforcement to promote and encourage safe work habits * Correction of unsafe performance * Disciplinary action, if needed, to enforce safety rules and protect employees and visitors Procedural controls are effective in preventing accidents, however, they are only as good as the management systems that insure their constant use. 3. Personal Protective Equipment A further method of controlling exposure to hazards when worker exposure cannot be completely engineered out of normal operations and maintenance work is to provide personal protective equipment (PPE). The term PPE includes safety glasses, goggles, face shields, aprons, hard hats, hearing protectors, chemical resistant clothing and gloves, steel toed shoes and respirators. Many COMM/OSHA standards require certain of personal protective equipment depending upon the level and duration of exposure. There is also a section in the Federal Standards (29 CFR 1910 Subpart 1) which specifically addresses PPE. If respirators are worn at your worksite, a written respirator program is also required (See 29 CFR 1910.134). The keys to the effective use of PPE to control hazards are: * Proper selection based on a written hazard assessment * Proper fit and comfort * Employee and supervisory training * Replacement procedures for damaged or worn part and equipment * Consistent enforcement 4. Administrative Controls Administrative controls should only be used when methods are not feasible to control hazards. They include rotation of workers through different jobs, longer rest breaks, and additional relief workers. The purpose of these controls is to reduce worker exposure to toxic substances, extreme temperatures or to ergonomic hazards often found in highly repetitive tasks. Administrative controls however require ongoing and consistent training and enforcement to be effective. They also are costly and increase the workload of supervisors. Because of these limitations, administrative controls should always be used in conjunction with other
controls and replaced, when feasible, with more effective methods. 5. Medical Programs and Surveillance Medical Programs The availability of first aid and emergency medical assistance is essential in order to minimize the harmful consequences of injuries and illnesses. The nature of the services needed for your agency/institution will depend on the potential seriousness of injuries and the healthhazard exposures which may occur and/or the proximity of a clinic or hospital to your worksite. The key components of an effective occupational medical program for the treatment of injured or ill employees include: * Written policy and procedures * Adequate training and assignment of emergency responders and first aid personnel (if applicable to your worksite) * Reliable outside medical resources and consultation on matters relating to worker's health * First aid supplies, bloodborne pathogens protective equipment for emergency responders and biohazard clean-up kits * Medical record retention system and aid logs Medical Surveillance Medical surveillance involves the systematic collection and evaluation of employee health data and medical tests to identify specific instances of illness or health trends that may suggest an adverse effect from workplace exposures. Many OSHA standards specify that employees exposed to certain potentially harmful substances (i.e., lead, asbestos, etc.) above the permissible "action level" and/or employees who are required to wear respirators or hearing protection must receive (at no cost to employees) an initial and sometimes an annual physical examination. Employees who develop signs or symptoms of a medical problem to an exposure or who are assigned to a known problem area should also be included in the medical surveillance program. A comprehensive medical surveillance program will: 1) help identify serious unknown hazards or deficiencies in your hazard control system; 2) provide for early detection of medical problems; 3) lower lost work days and medical costs; and 4) improve employee morale and productivity. Appendix O the types and extent of medical surveillance required by COMM/OSHA standards. 6. Emergency Planning Planning and training for emergencies are essential in to minimize the harmful consequences of an emergency incident. If personnel are not thoroughly trained to react to emergencies so that their responses are immediate and precise, they may expose themselves and others to greater danger rather than reduce their exposure. The types of emergencies that may arise at your worksite depends on the nature of your operations and its geographical location. They could include fire, severe weather, chemical spills and bomb threats. A written plan must be developed to address each of these emergency situations. The extent to which training and drills are needed will depend on the potential severity
Appendix L: Required/Recommended Health and Safety Training for Public Employees TYPE OF ACTIVITY/TRAINING LEGAL AUTHORITY (REGULATION) WHO RECEIVES HOW ESTIMATED TIME NEEDED Accident Prevention Signs OSHA, 1910.145(c)(f) All employees Initial/Periodic 30-60 minutes Aerial Lifts Affected employees Initial/Periodic 1 hour Asbestos OSHA, 1910.1001(j)(7) Employees exposed to asbestos at or above Action Level or excursion limit Custodial employees in areas containing asbestos Initial/Annual Initial/Annual 3-4 hour 1-2 hours Back Injury Prevention Recommended training All employees Periodic 1-4 hours Bloodborne Pathogens OSHA, 1910.1030(g)(2) Designated first aid responders, possibly maintenance staff Initial/Annual 3 hours - First responders 1 hour - General awareness 1,3 Butadiene OSHA 1910.1051(l)(2) Employees exposed at or above action level/PEL Initial/Annual 1-2 hours Carcinogens - Regulated Area OSHA 1910.1003-1016(e)(5) Employees entering area Initial/Periodic 1 hour Confined Entry Authorized entrants/attendants or rescue personnel Initial/Annual 4-8 hours 4-8 of additional training Department of Commerce Compliance Seminar Recommended training Managers/supervisors, safety coordinators Periodic 6-8 hours Electrical Safety OSHA, 1910.332(b)(1) Employees working on/near or with electrical equipment Initial/Periodic 1-2 hours
TYPE OF ACTIVITY/TRAINING LEGAL AUTHORITY (REGULATION) WHO RECEIVES HOW OFTEN ESTIMATED TIME NEEDED Emergency Response/Spills OSHA, 1910.120(e) Personnel expected to respond Initial/Annual 4-24 based on job duties Emergency Training/Fire Prevention OSHA, 1910.38(e-f) All employees Initial/Periodic Change in plan 30-90 minutes depending on class Employee Rights/Responsibilities Statute 101.055 All employees Upon Hire 1 hour Ethylene Oxide (ETO) OSHA, 1910.1047(j)(3)(iii) Employees exposed to ETO Initial/Annual 1 hour Fall Protection OSHA, 1926.503(a) All exposed workers Initial/Periodic 2-3 hours Fire Extinguishers OSHA, 1910.157(g) Designated employees, floor captains Initial/Annual 30-60 minutes depending on size Fixed Extinguishing Systems OSHA, 1910.160(b)(10) Employees who service these systems Initial/Annual 1 hour Flammable and Combustible Liquids OSHA, 1910.106(b) All employees who handle, store or dispense these products Initial/Periodic 1 hour Formaldehyde OSHA, 1910.1048(n) Employees with exposure Initial/Annual 1 hour Hazard Communication OSHA, 1910.1200(h) All employees exposed to chemical hazards Initial/Periodic 1-2 hours - basic awareness about chemical hazards, labling, MSDS’s disposal and details about written program 1-2 hours - specialized training
TYPE OF ACTIVITY/TRAINING LEGAL AUTHORITY (REGULATION) WHO RECEIVES HOW OFTEN ESTIMATED TIME NEEDED Hazardous Waste * OSHA, 1910.120(e) All employees working at hazardous waste sites Initial/Annual 8-40 hours, depending on job assignment Indoor Air Quality Recommended training Building managers, supervisors, safety coordinators , safety committee members Periodic 3-4 hours Non-Ionizing Radiation OSHA, 1910.97 Areas where these materials are used Initial/Periodic 1 hour Laboratory Safety OSHA, 1910.1450(f) All laboratory employees Initial/Periodic 1-2 hours depending on class size Laundry Equipment OSHA, 1910.264(d) Employees using laundry machines Initial/Periodic 1 hour Lead OSHA, 1910.1025(l) Employees exposed to lead Initial/Periodic Annual if exposed Action Level 1-2 hours Lockout/Tagout OSHA, 1910.147(c)(7) All authorized and affected employees Initial/Periodic 1-2 hours Liquified Petroleum(LP) Gases OSHA, 1910.110 All employees who handle or dispense these products Initial/Annual 1 hour Medical Services/First Aid OSHA, 1910.151(a)(b) First aid providers Initial/Every three years 8 hours Occupational Noise Exposure OSHA, 1910.95(k) Employees working in high noise areas Initial/Annual Change in work 1-2 hours TYPE OF ACTIVITY/TRAINING LEGAL AUTHORITY (REGULATION) WHO RECEIVES HOW OFTEN ESTIMATED TIME NEEDED
Office Health and Safety Recommended training Office supervisors and employees Initial/Periodic 2-3 hours Personal Protective Equipment OSHA, 1910.132(f) Employees required to wear PPE Initial/Change in work/PPE use 20-30 minutes for each type of PPE Power Presses OSHA, 1910.217(h)(13) Employees exposed to power presses Initial/Periodic 1 hour Powered Industrial Trucks OSHA, 1910.178(l) All operators of PIT’s Initial/Periodic 1-3 hours Respiratory Protection * OSHA, 1910.134(k) All employees required to wear a respirator Initial/Annual * Change in work 1-2 hours Safety Fundamentals for Supervisors Recommended training Managers/supervisors, safety coordinators Initial/Periodic 4-8 hours Servicing of Single and Multi-Piece Rim Wheels OSHA, 1910.177(c) Maintenance garage employees Initial/Periodic 1 hour Stress Management Recommended training All employees Periodic 2 hours Upper Body Cumulative Trauma Recommended training All employees involved in repetitive activities Periodic 1-3 hours Display Terminals Recommended training Employees who work on VDT’s Initial/Periodic 2-3 hours Ventilation (Personal Protection, Open Tanks) OSHA, 1910.94(d) **REMOVED** Employees working around open surface tanks Initial/Periodic 1 hour * Agencies should consult other sources for the training requirements required by EPA/DNR environmental regulations. Note: These estimated times needed to provide training for each training course is the estimated amount of time needed for the employee to obtain a minimum level of competency. More or less time may needed depending on class size and the experience of the attendees. Appendix M: COMM/OSHA Required Checklist
Standard Subject Required Coverage Frequency 1910.25(d)(1)(x) Portable wood ladders All wooden ladders Frequently 1910.26(c)(2)(vi) Portable metal ladders ladders that tip over, or are exposed to oil and grease Immediately 1910.27(f) ladders All fixed ladders Regularly 1910.37(a)(4) Automatic sprinkler systems All systems Periodic 1910.37(e) Fire alarm signaling system All systems tested (non-supervised and supervised) Non-supervised - 2 months; supervised - annually 1910.66(i)(1) Powered platforms for exterior building maintenance All powered platforms Before being placed into service; every 12 months; maintenance test every 30 days; governor and secondary braking system annually. 1910.67(c)(2)(i) Vehicle-mounted elevating and rotating work platforms Extensible and articulating boom platform lift controls Each day prior to each 1910.67(c)(2)(xii) Vehicle-mounted elevating and rotating work platforms Aerial life before travel Prior to moving 1910.67(c)(3) Vehicle-mounted elevating and rotating work platforms Electrical Per ANSI A92.2 1910.68(e)(1) Manlifts Steps, rails, landings, belts, illumination, motors, brakes, limit switches, etc. Every 30 days; Limit switches must be checked weekly 1910.94(a)(3)(i)(a) Abrasive blasting Slit abrasive-resistant baffles Regularly
1910.103(b)(1)(vi) Gaseous hydrogen systems All piping, tubing and fittings After installation 1910.103(c)(1)(vii) Liquefied hydrogen systems All field-erected piping After installation 1910.104(b)(4)(iii) Bulk oxygen systems High pressure gaseous oxygen containers As stated by ASME and DOT 1910.104(b)(8)(iv) Bulk oxygen systems All piping After installation 1910.106(b)(2)(v)(i) ground tanks with flammable or combustible liquids Flow capacity of tank venting devices 12 inches and smaller in nominal pipe size As appropriate 1910.106(b)(5)(vi)(l) All tanks Independent pumping units Periodically 1910.106(b)(7)(i) All tanks Independent pumping Periodically 1910.106(c)(7) Piping, valves and fittings Hydrostatically or pneumatically tested; joints and connections Before being covered, enclosed or placed in use 1910.106(e)(5)(v) Flammable and combustible liquids All fire protection facilities Periodically 1910.106(e)(8) Flammable and combustible liquids Hot work Prior to the work 1910.106(f)(4)(vi) Flammable and combustible liquids Relief devices on pumps on wharves Yearly 1910.106(f)(4)(vii) Flammable and combustible liquids Pressure hoses and couplings on wharves Appropriate to the service Standard Subject Required Coverage Frequency 1910.106(g)(3)(v)(f) Flammable and combustible liquids Pressure piping system between pump discharge and connection for dispensing facility Alter installation/every 5 years
1910.110(h)(9)(vii) LP gases Piping After assembly 1910.111(d)(6) Anhydrous ammonia Containers for refrigerated storage that require field fabrication After re-assembly 1910.120(c) Hazardous waste operations and emergency response All hazardous waste sites Preliminary evaluation 1910.120(h) Hazardous operations and emergency response Exposed employees monitoring Initially/periodic 1910.120(l)(3)(v) Hazardous waste operations and emergency response Emergency response Initially/periodic 1910.134(d)(1)(iii) Respirators * Work area conditions and degree of the employee’s exposure As needed 1910.134(h)(1) Respirators * Cleaning and disinfecting As as necessary to maintain in a sanitary condition. After each use for respirators used during emergencies 1910.134(h)(3) (A,B C) Respirators * Inspection of all respirators Before and after each use and during cleaning SCBA's must be inspected monthly per the manufacturer’s instructions Standard Subject Required Coverage Frequency 1910.134(i)(1)(ii) Respirators * Air supply from compressor Frequently 1910.134(i)(4)(i) Respirators * Breathing air cylinders Tested and maintained as stated by DOT 1910.134(l)(1) Respirators* Effectiveness of the program Periodic 1910.147(c)(4) Lockout/Tagout Energy control procedures are implemented At least annually
3.1 Engineering techniques where feasible and appropriate. 1 2 3 4 5 3.2 Procedures for safe work which are understood and followed by all affected personnel as a result of training, positive reinforcement and correction of unsafe performance and, if necessary, enforcement through a clearly communicated disciplinary system. 1 2 3 4 5 3.3 Provision for personal protective equipment. 1 2 3 4 5 3.4 Administrative controls, such as reducing the duration of exposure, when needed. 1 2 3 4 5 3.5 Provision for facility and equipment maintenance so that hazardous conditions are prevented. 1 2 3 4 5 3.6 Planning, preparation and training for emergencies and the conducting of periodic drills so that the response of all parties to emergencies will be "second nature". 1 2 3 4 5 3.7 Establishment of a medical program which includes availability of first aid and medical care so that harm will be minimized if an injury or illness does occur. 1 2 3 4 5 4.0 Health and Safety Training for employees, supervisors and managers in to 4.1 Ensure that all employees understand the hazards to which they may be exposed and how to prevent harm to themselves and others from exposure to these hazards. 1 2 3 4 5 4.2 Ensure that employees accept and follow established safety and health and procedures. 1 2 3 4 5 4.3 Ensure that employees understand the proper use of personal protective equipment (PPE) including knowing when PPE is required, how to use the equipment and how to maintain it in good condition. 1 2 3 4 5 4.4 Ensure that employees know what to do in case of an emergency. 1 2 3 4 5 4.5 Ensure that supervisors understand their health and safety responsibilities. 1 2 3 4 5 4.6 Ensure that supervisors can analyze the work in to identify potential health and safety hazards and the potential harmful affects upon employees. 1 2 3 4 5 4.7 Ensure that supervisors and employees know how to properly maintain the required health and safety protection systems and equipment in their work areas. 1 2 3 4 5 4.8 Reinforce employee training on the nature of the potential hazards in work areas and on needed protective measures through performance feedback and, if necessary, enforcement of safe work practices. 1 2 3 4 5