SELF-INSPECTION SUBSYSTEM
Organizations that excel in health and safety management have a system to ensure self-inspections of the workplace are routinely scheduled. The system must include written procedures that:

• require the inspection team to include personnel qualified to recognize workplace hazards, top management, and employees who have knowledge of the written procedures and hazard recognition.

• determine the frequency of inspection and areas covered (Ideally, inspections are made at least monthly. The entire worksite must be inspected quarterly.),

• identify those responsible for conducting the inspections,

• detail the process for recording findings,

• set out responsibility for abatement, track identified hazards for timely correction, and

• require documentation of findings to go beyond the simple use of checklists.

Each site must operate a reliable system that enables employees to notify appropriate management personnel in writing about conditions that appear hazardous without fear of reprisal. The system must include:

• anonymous reporting,

• timely responses to employees, and

• tracking of hazard elimination or control to completion

INDUSTRIAL HEALTH SUBSYSTEM
The CSE requires an industrial health subsystem that includes:

• established procedures and methods for identification, analysis, and control of health hazards for prevention of occupational disease,

• a written program to address sampling protocols and methods to accurately assess employees' exposure to health hazards. Standard, nationally recognized procedures must be used for surveying and sampling as well as for testing and analysis.

• requirement that baseline and routine sampling be performed by an industrial hygienist or by safety staff members with special training in the specific procedures for the suspected or identified health hazards in the workplace.

• baseline survey to determine employees' exposure to health hazards, and

• provisions as required for expertise, time, technical equipment, and analysis beyond a baseline survey to determine the extent of environmental contaminants (physical, biological, or chemical) present in the workplace, and to quantify exposure so that proper controls can be implemented.

ACCIDENT INVESTIGATION SUBSYSTEM
To meet the CSE, an accident investigation subsystem must be in place and include:

• the requirement that all accidents and near-misses be investigated, and

• written reports of all investigations.

Accident and near-miss investigations must:

• be conducted by personnel trained in accident investigation techniques.

• document the entire sequence of relevant events,

• identify all contributing factors, emphasizing failure or lack of hazard controls,

• determine whether the safety and health management system was effective, and where it was not,

• provide recommendations to prevent recurrence,

• not place undue blame or reprisal on employees, although human error can be a contributing factor,

• assign priority, time frames, and responsibility for implementing recommended controls, and

• include a means to make results of accident investigations available to employees on request, although the actual investigation records need not be provided.

TREND ANALYSIS SUBSYSTEM
A trend analysis system must include Information such as injury/illness history, hazards identified during inspections, employee reports of hazards, and accident and near-miss investigations for the purpose of detecting trends. The results of trend analyses must:

• be shared with employees and management,

• be used to direct resources,

• result in prioritization of hazard controls,

• be used to determine or modify safety goals and objectives, and

• be reflected in updates to training curricula.

SOME THINGS TO CONSIDER
As you begin to assess your organization's worksite analysis capability and performance, you may want to ask the following questions:

• How do baseline surveys clearly document health and safety hazards associated with the workplace?

• How are job hazard analyses or process hazard analyses for routine jobs, tests, and processes conducted?

• What is the process and frequency for inspections and audits, and who is involved?

• To what degree have considerations for health and safety been included in the worksite analysis process?

• How are employees and managers involved in accident investigations?

• How are trend analyses used to determine where health and safety hazards exist?

GREAT IDEAS
1. Develop an online tracking system for safety and health issues, and give employees access to view and add new items.

2. Develop an orientation program for employees and contractors that includes information about hazards and how to report them.

3. Train and coach everyone in how to encourage coworkers to report hazards and changing worksite conditions.

This is an excerpt from the book "ZERO! Responsible Safety Management by Design" by Deb Potter, PHD with Carl Potter, CSP. Right Attitude Publishing. Purchasing information for this book, and others by Carl and Deb Potter, can be found at Right Attitude Publishing's website: www.rightattitudepublishing.com.

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