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© OTN - 58 Metric Safety Management System Audit 1 See if your company measures up to SHARP standards… Safety Management System Audit By Steven J. Geigle, CSHM OSHA Training Network

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© OTN - 58 Metric Safety Management System Audit 1

See if your company measures up to SHARP standards…

Safety Management System Audit

By Steven J. Geigle, CSHMOSHA Training Network

© OTN - 58 Metric Safety Management System Audit 2

58 Metric Safety Management System Audit

This safety management system audit is designed to as a tool to assess and evaluate the effectiveness of the employer's safety management system.

This evaluation tool parallels the safety management system evaluation conducted by OSHA consultants as a part of the OSHA's Safety and Health Achievement Recognition Program (SHARP). Companies working toward SHARP must have a full analysis and evaluation of all 58 elements in this audit evaluated.

All completed audit items should have some justification and/or recommendations under the comment section for questions rated as 0 and 1. All completed assessments should be included and/or referenced in the report sent to the employer.

Categories: The audit is divided into the following seven categories (or elements):

I. Hazard Anticipation and Detection,

II. Hazard Prevention and Control,

III. Planning and Evaluation,

IV. Administration and Supervision,

V. Safety and Health Training,

VI. Management Leadership, and

VII. Employee Participation.

Metrics: Each item or sub-element is listed as a survey question. In OSHA's SHARP there are 58 metrics which are considered as building blocks to effective safety and health management systems. All 58 metrics are positive statements which the evaluator agrees with varying degrees of continuity.

Rating Description

0 No discernable 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

NE Not Evaluated: Recognizes that comprehensive evaluations can be incremental

NA Not Applicable: Must have justification in the comments box why the item is not applicable

Rating Instructions

Each metric has six possible ratings as described in the following table.

© OTN - 58 Metric Safety Management System Audit 3

Rate each metric based on the cues (discussed below) and other information. To rate a metric, simply put one of the ratings listed above in the box next to the metric.

Rating Cues: A rating cue is a specific fact or perception helps justify the rating given to a metric. Each metric is worded as a positive statement. All rating cues listed below the metric either support/confirm or oppose/negate the statement. Each cue gives added weight to the rating for the metric. The following table shows how cues are used to determine ratings.

Rating Value

0 No CONFIRMING cues. Eliminated by a single CONFIRMING cue

1 Requires a few CONFIRMING cues and one or more NEGATING cues

2 Requires multiple CONFIRMING cues and a few NEGATING cues

3 No NEGATING cues. Eliminated by a single NEGATING cue

Place a plus (+) or minus (-) next to each cue listed below a metric. Cues are found in observations and measurement, interviews, and reviews of documentation. There can be multiple cues: initial cues, corroborating cues; and conflicting cues.

Comments: The comment section is used to recommend how to improve in the specific metric. Ratings that are "0" or "1" should include a recommendation for improvement. Use the comment area to write a justification for the NA rating.

Some Suggestions

• In reality, there is a very small gap between the 0 (zero) rating and the 1 (one) rating and between the 2 (two) rating and the 3 (three) rating.

• There is a large gap between the 1 (one) rating and the 2 (two) rating. That gap is the difference between mostly no and mostly yes.

• Look for things that are done well and reinforce these things with personnel for their good efforts.

• The more you can encourage small positive steps, the greater chance that significant positive change will follow and the greater the opportunity for long-term improvement.

• Finally, consider networking with another SHARP company. Networking among SHARP companies is encouraged and has proven to be beneficial to both those companies being mentored as well as to those companies doing the mentoring.

© OTN - 58 Metric Safety Management System Audit 4

1. A comprehensive, baseline hazard survey has been conducted within the past five (5) years.

I. Hazard Anticipation and Detection

58 Metric Safety Management System Audit

a. Surveys are conducted frequently enough to timely and effectively address hazards.

b. Surveys are performed by competent and qualified individuals that can effectively and thoroughly understand the hazards of the industry.

c. The survey results in an updated hazard list or survey report (action plan).

d. The survey results in effective controls for hazards found.

e. The survey drives immediate corrective action on items found.

f. The survey tries to include outside personnel to help prevent tunnel vision and maintain objectiveness.

g. The survey was completed by a certified specialist.

h. The survey identified all serious hazards associated with the facility and resulted in appropriate hazard control programs.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

© OTN - 58 Metric Safety Management System Audit 5

• The baseline hazard survey should be documented in a written report as a requirement for a rating of "3" on this metric.

• Qualified persons such as OSHA evaluators, private evaluators, insurance loss control specialists, or appropriately trained and experienced employees of the organization should conduct the baseline hazard survey.

• The word "comprehensive," used here, does not mean perfect or all-inclusive. It does mean that major operations, especially high-risk operations, during all shifts are included in the baseline survey. It also means hazard categories normally associated with the type of business are addressed in the survey.

• The 5-year time-frame, although a common planning horizon, is somewhat arbitrary. The evaluator will question the validity of your baseline hazard survey, even one conducted during the previous five years, if subsequent changes in the organization appear to nullify the survey‘s relevance or accuracy. Due to the rapid change that occurs in most organizations, a baseline hazard survey older than five years will usually not be accepted without justification.

• No comprehensive baseline survey is effective unless each identified hazard is immediately corrected or appropriately scheduled for correction in the organization‘s action plan for safety and health.

• Deficiencies found in this metric may also indicate problems in these metrics: 22,23, and 54

© OTN - 58 Metric Safety Management System Audit 6

2. Effective safety and health self-inspections are performed regularly.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

a. Inspections of the workplace are conducted in all work areas.

b. Inspections identify new, reoccurring, or previously missed safety or health hazards and/or failures in hazard control systems.

c. Inspections are conducted at least quarterly at fixed work sites, weekly at rapidly changing sites, and as frequently as daily where necessary.

d. Inspectors have been adequately trained in workplace safety and health rules.

e. Logs, checklist, or other type of written reports are used to document formal inspections.

f. All hazard findings are addressed as soon as practically possible.

g. Hazards identified do not appear on future inspections.

h. The responsibility for inspections rests with more than one person.

i. The responsibility for inspections is scattered throughout the organization.

j. Inspections are conducted by teams.

k. Appropriate time is provided to conduct the inspections.

l. The use of tools (such as digital cameras, palm pilots, and computers) are used in the process.

© OTN - 58 Metric Safety Management System Audit 7

• Inspections are defined as periodic activities or events involving observation and/or testing of selected safety and health aspects of the work and workplace. Essentially, an inspection is a systematic comparison of observed status to expected or desired status. Inspections may be formal or informal.

Formal inspections usually involve the use of checklists and often result in the issuance of inspection reports. Complex inspections should always be supported by a checklist and conducted on a formal basis. The written documentation associated with formal inspections (checklists, logs, reports, etc.) may be used to support a rating of "3" on this metric if the documentation indicates that such inspections were thorough and conducted on a regular basis.

Informal procedures may be effective for routine and limited inspections in which the inspection coverage can be systematically addressed by rote. The thoroughness and consistent performance of informal inspections will usually require evaluation by interview.

• The term "regularly" means recurrence within understood limits (daily, weekly, monthly, quarterly, etc.) and does not necessarily mean a set pattern or firm schedule. The appropriate frequency of inspections depends on the stability and criticality of the factors covered by each inspection. The period of time between inspections may indicate the degree to which the employer tolerates safety and health system failures.

• Self-inspection requires the organization to exercise an internal capacity to conduct effective safety and health inspections. Ideally, this capacity will not reside in a single individual, but will be diffused throughout the organization. Workers should perform or participate in the performance of safety and health inspections of their own work areas or operations. Team efforts are highly desirable, especially for general inspections.

• No inspection is effective unless each identified hazard is immediately corrected or appropriately scheduled for correction in the organization‘s action plan for safety and health.

• Documented quarterly inspections by supervisors and trained members of the safety committee, when the evaluator verifies them as effective are positive cues for this item.

• Deficiencies found in this metric may also indicate problems in these metrics: 19, 22, 23, and 54

© OTN - 58 Metric Safety Management System Audit 8

3. Effective surveillance of established hazard controls is conducted.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

a. Established hazard controls are in place and operational.

b. The hazard controls are prioritized with the emphasis on engineering controls, safe work practices, and administrative controls before PPE.

c. Employees understand the hazard control associated with their work areas.

d. Monitoring evaluation of hazard controls is on-going and known to and by the work force.

e. Supervisors receive training in surveillance of established hazard controls.

f. At least some employees receive training in surveillance of established hazard controls.

g. Surveillance activity is required supervisory duty and is tracked in some fashion.

h. Some type of trend analysis of tracked surveillance activity is done.

i. Trend analysis of tracked surveillance activity results in improved performance of established hazard controls.

© OTN - 58 Metric Safety Management System Audit 9

• Surveillance (observation) is similar to inspection in that both are concerned with the way things are, compared to the way they should be. Surveillance, however, is constant or ongoing while inspection is periodic. This means that surveillance normally provides a shorter time-tolerance for system failures than do inspections. On the other hand, inspections are usually more structured, systematic, and thorough than surveillance. Together, however, these two complementary hazard detection techniques provide the best means to ensure early detection of existing hazards.

• This metric will be evaluated by evaluator observations. Whenever evaluators observe established controls (engineering controls, PPE, safety rules, safe work practices, etc.) are being violated, there is indication that surveillance is missing or ineffective. Likewise, when evaluators observe that established hazard controls are in place and operative, there is indication that surveillance is effective.

• This metric can also be evaluated by interview. Employees, particularly supervisors, can be asked to describe the key safety and health controls associated with their work areas, operations, or job duties; how such controls are monitored; and what steps are taken when problems are detected.

• Surveillance of hazard controls is not effective unless control failures are immediately corrected or appropriately scheduled for correction in the organization‘s action plan for safety and health.

• Deficiencies found in this metric may also indicate problems in these metrics: 14, 23, 26, and 54.

© OTN - 58 Metric Safety Management System Audit 10

4. An effective hazard reporting system exists.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

a. A system for employee hazard reporting is in place and is known to all employees.

b. The system allows for the reporting of physical and behavioral hazards.

c. Corrective action is taken promptly on all confirmed hazards.

d. While waiting for final correction, the employer finds ways to protect those affected.

e. All personnel are aware that hazards can develop within existing jobs, processes and/or phases of activity.

f. The system provides for self-correction of hazards when possible.

g. Employees are provided positive reinforced or incentive for using the system.

h. There is an informal method of hazard reporting for employees to report hazards to their supervisors.

i. There is a formal method available to employees to report hazards on a form to the safety department.

j. Reported hazards are collected and analyzed and used to set priorities and action planning on addressing hazards in the workplace.

k. There is a mechanism for formal and informal hazard reporting to promptly communicate (to the person reporting the hazard) the status and intended action regarding the reported hazard.

l. All hazards reported are communicated to the work force in some manner.

m. Few hazards are noted in the workplace.

© OTN - 58 Metric Safety Management System Audit 11

• The existence and design of an organization‘s hazard reporting system is analyzed by interviewing managers, supervisors, workers. The best hazard reporting systems have both centralized (formal) and decentralized (informal) features.

The centralized component of hazard reporting provides a common point for collection of reported hazard information across the organization. In addition to employee reports, hazard incidence information collected at the organizational level includes the results of surveys, analyses, and formal inspections of the workplace, providing a broader information base for priority setting and action planning. In larger organizations, the safety director or safety committee usually collects such information. In very small organizations, the owner-manager or a designee is usually responsible.

The decentralized component allows direct reporting of a hazard to the individual with primary responsibility for the affected work area, operation, or personnel. This direct reporting procedure normally facilitates prompt correction of the hazard by the responsible person closest to the problem. Workers reporting hazards to their supervisors is an example. However, workers should always have the option of reporting to the organizational level whenever they feel that correction of a directly reported hazard has been neglected or ineffective. Likewise, supervisors should always forward to the organizational level any worker hazard report for which the supervisor is unable to take appropriate corrective action.

• A crucial factor in hazard reporting system effectiveness is that each individual who reports a hazard receives prompt feedback concerning when and how the hazard will be corrected or an objective explanation why no corrective action will be taken. Although hazard correction status reports are sometimes provided to employees, such reporting is more often informal. Therefore, evaluation of the feedback feature normally requires interviews with employees who have reported hazards.

• The basic objective of a hazard reporting system is early detection and reporting of hazards effectively known to employees. A hazard is "effectively known" when the employee is both aware of the existence of the hazardous condition or activity and understands, at least generally, the possible harm it represents. Therefore, when uncovering previously unreported hazards, and employees should have effectively known such hazards, the underlying problem may be a training problem, a reporting problem, or both. Interviews with employees will be needed to make a determination.

• Deficiencies found in this metric may also indicate problems in these metrics: 10, 35, 40, 49, 50, and 54.

© OTN - 58 Metric Safety Management System Audit 12

5. Change analysis is performed whenever a change in facilities,equipment, materials, or processes occurs.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

a. Changes in space, processes, materials, or equipment at the facility are planned.

b. Affected personnel are made aware of planned changes prior to implementation.

c. A comprehensive hazard review process exists and is used for all changes.

d. The hazard review (analysis) process encourages recommendations for improvement, which are implemented prior to start-up.

e. The analysis process involves competent, qualified specialists appropriate to the process being evaluated.

f. There is a formal, written process for change analysis.

g. Affected employees are involved in the change analysis.

h. Change analysis procedures include revisions of Job Hazard Analysis (JHA‘s), Standard Operation Procedures, lockout methods, PPE, and other program elements affected by the change.

© OTN - 58 Metric Safety Management System Audit 13

• A change analysis program is essentially planning-for-planning. It is, at minimum, a set of policies designating responsibilities for current and future planning activities involving changes in facilities, equipment, materials, or processes, including the safety and health aspects of such changes. Ideally, responsible parties will be in "line" positions. The change analysis program should also include planning procedures that ensure the safety and health input of appropriate personnel such as safety staff, the safety committee, and affected supervisors and workers.

• Change analysis is primarily a hazard anticipation function. Use metrics 11-19 to evaluate the degree to which the organization has successfully addressed correction of any hazards or potential hazards it has identified by change analysis.

• Hazards identified indicate a deficiency in this metric when such hazards could have been identified, and therefore prevented, by effective change analysis.

• Absence of hazards associated with recently implemented changes in facilities, equipment, materials, or processes is suggestive that change analysis in the organization is effective.

• Some OSHA consultation projects have added "changes in environment" to their consideration in evaluating this metric for employers not engaged at fixed work sites.

• Deficiencies found in this metric may also indicate problems in these metrics: 26, 39, 40, 49, and 54.

© OTN - 58 Metric Safety Management System Audit 14

6. Accidents are investigated for root causes.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

a. Workplace policy requires a thorough investigation of all accidents and incidents.

b. All accidents and incidents are investigated as required by policy.

c. All investigations are conducted by personnel trained in accident/incident investigation techniques.

d. All investigations include input from all affected parties and witnesses, where possible.

e. All investigations determine "root causes" and underlying factors.

f. Recommendations designed to adequately address root causes are made as a result of all investigations and result in prompt corrective action.

g. Completed investigative reports are routed to appropriate levels of management and knowledgeable staff for review.

h. Investigations are done by management and employees.

i. Results of investigations are shared with the work force.

j. Top management reviews all accidents and incidents to review if root cause was identified adequately.

k. Standard forms are used to document all accidents and investigations.

l. Top management participates in investigations.

© OTN - 58 Metric Safety Management System Audit 15

• Accident investigation must be conducted as a formal procedure, even in the smallest of organizations. Therefore, every employer should establish policies to ensure that thorough and timely accident investigations are specified, performed, and recorded. Although the procedures are formal, the implementing policies in very small organizations may be unwritten and informal, requiring verification by interviews with responsible parties.

• Organizational policy should (1) specify the class of accidents that require investigation. Regulation requires investigation of the class of accidents that involve recordable injuries and illnesses, but the employer may also require investigation of the class of accidents that involve only property losses. Organizational policy should (2) assign responsibilities for performance of accident investigations. Normally, such responsibilities rest with the appropriate supervisor, the safety committee, safety staff, or some combination of these personnel. However, there is an opportunity for top management to exhibit visible safety and health leadership by participating in accident investigations. Organizational policy should (3) adopt a standard recording form for all accident investigations. This standard record may be a workers compensation First Report of Injury form, the OSHA Injury and Illness Incident Report (Form 801), or an equivalent record developed by the organization.

• The objective of an accident investigation is not to assign blame, but to identify root causes of the accident so that corrective measures can be taken. Hazards--unsafe or unhealthful conditions or activities--are involved in all accidents. The underlying personal, organizational, job-related, and environmental factors that result in or allow the existence of these hazards are the root causes of the accidents. Considerable skill and diligence is often required to ascertain the root causes of an accident, and this phase of the accident investigation should be conducted by a qualified person such as the safety manager or safety committee. Records or reports of completed accident investigations are the best source of information to judge if root causes are being discovered by the organization. As a rule-of-thumb, any accident investigation that metrics single causation has not adequately addressed root causes.

• Individuals with accident investigation responsibilities can be interviewed to learn if they understand and acknowledge the importance of root cause analysis.

• Accident investigation is not effective unless identified hazards and underlying root causes are immediately addressed or appropriately scheduled for correction in the organization‘s action plan for safety and health.

• Deficiencies found in this metric may also indicate problems in these metrics: 23, 26, 36 and 40.

© OTN - 58 Metric Safety Management System Audit 16

7. Material Safety Data Sheets are used to reveal potential hazards associated with chemical products in the workplace.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

a. Employees understand the hazards introduced to their jobs by chemical use.

b. Hazards identified in MSDS‘s are effectively controlled.

c. Employees have seen and understand the MSDS(s) applicable to the chemicals they use.

d. Applicable MSDS information is incorporated into written job hazard analysis forms.

e. MSDS‘s are periodically reviewed in order to determine if a safer product could be used, or if current JHA‘s address the hazard adequately.

f. Information on the MSDS is used by personnel performing change analysis to identify potential hazards related to new chemicals being introduced into the workplace.

g. The Safety Committee reviews MSDSs to address the prevention, elimination, and/or control of hazards posed by chemical products.

© OTN - 58 Metric Safety Management System Audit 17

• This metric and the hazard communication standard (29CFR1910.1200) are closely related, but not redundant. The hazcom standard does not directly address the prevention, elimination, or control of workplace hazards posed by chemical products. Rather, its focus is on communication of information about potential hazards and possible protective measures. Nevertheless, the process of detecting workplace hazards associated with chemical products, as incorporated in this metric, cannot be effective until Material Safety Data Sheets for all hazardous products have been obtained and reviewed by the employer as required in the hazcom standard.

• Hazards identified may indicate deficiencies in this metric if such hazards were not effectively known to the employer, but would have been revealed by review of relevant Material Safety Data Sheets.

• The process of detecting workplace hazards from information in Material Safety Data Sheets is not effective unless such identified hazards are immediately corrected or appropriately scheduled for correction in the organization‘s action plan for safety and health.

• Deficiencies found in this metric may also indicate problems in these metrics: 26, 29, 36, 40, and 54.

© OTN - 58 Metric Safety Management System Audit 18

8. Effective job hazard analysis is performed.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

a. There are hazard analysis systems designed to address routine job, process, or phase hazards in place at the facility.

b. Hazard analysis systems identify or prompt corrective or preventive action to reduce or eliminate work site hazards.

c. All tasks, job processes, or phases of activity are analyzed.

d. All job processes, or phases of activity are analyzed whenever there is a change, when a loss incident occurs, or on a schedule of no more than 3 years.

e. Upon implementation of the corrective or preventive actions identified by the hazard analysis process, the written hazard analysis is revised to reflect those actions.

f. Employees are involved in the hazard analysis process.

g. Accident and incident investigation leads to job hazard analysis when appropriate.

h. Job hazard analysis addresses safety, health, and ergonomic hazards.

i. There is a standard and uniform format used to document job hazard analysis.

j. JHA‘s are posted at work stations.

© OTN - 58 Metric Safety Management System Audit 19

• Job hazard analysis (JHA) is a formal technique for hazard detection involving careful study and recording of each step in a job, identifying existing or potential hazards associated with each step, and determining the best way to perform the job to reduce or eliminate these hazards. Informal examination of a job does not constitute job hazard analysis. In most cases, completed worksheets will be available to document that the organization is performing job hazard analyses.

• Review of completed job hazard analysis worksheets should reveal the effectiveness with which the procedures have been conducted.

• Hazards identified may indicate deficiencies in this metric if the hazards could have been detected, and therefore corrected, by effective job hazard analysis.

• Job hazard analysis can also include job safety analysis, environmental health and safety analysis, phase hazard analysis, etc.

• Almost all jobs are candidates for job hazard analysis, but it is a rare organization that has up-to-date worksheets completed for every job in the workplace. Therefore, job hazard analysis is an ongoing effort in most organizations that employ this hazard detection technique. However, jobs should be scheduled for attention on a priority basis, with higher priority being assigned to jobs having the highest rates of accidents and disabling injuries, jobs where —close calls“ have occurred, jobs where major changes have been made in processes and procedures, and jobs involving new workers.

• Deficiencies found in this metric may also indicate problems in these metrics: 20, 26, and 36.

© OTN - 58 Metric Safety Management System Audit 20

9. Expert hazard analysis is performed.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

a. The comprehensive hazard review process involves competent, qualified specialists appropriate to the workplace.

b. All hazard analyses identify corrective or preventive action to be taken to reduce or eliminate the risk of injury or loss, where applicable.

c. All corrective or preventive actions identified by the hazard analysis process have been implemented or addressed.

d. Hazard analysis surveys are routinely updated, using personnel competent in the fields of safety, industrial hygiene, ergonomics, and risk management.

e. Outside professional resources are taken advantage of (associations, insurance loss control, private and public evaluators, etc.).

f. Findings of expert hazard analysis are shared with the work force.

© OTN - 58 Metric Safety Management System Audit 21

• Expert hazard analysis does not include hazard detection activities, such as routine inspections, that the organization should perform on its own.

• Industrial hygiene testing, ergonomic evaluations, and other specialized safety and health services requested by employers and provided by OSHA evaluators should be considered positive factors in assessing this metric. Likewise, specialized consultation services recommended by OSHA evaluators performing onsite visits may be considered negative factors in evaluating this metric when such services are rejected or deferred by the employer (unless the employer obtains the needed services elsewhere).

• Evidence that an organization has engaged insurance loss control professionals, consulting engineers, private safety or health evaluators, medical personnel or other experts in specialized safety and health analyses of its workplace is commendable and a very positive factor to be considered in evaluating this metric. Absent such evidence, however, the onsite evaluator may nevertheless consider this metric fully in place unless an unmet need for expert hazard analysis has been identified.

• Expert hazard analysis is not effective unless the identified hazards are immediately corrected or appropriately scheduled for correction in the organization‘s action plan for safety and health.

• Deficiencies found in this metric may also indicate problems in these metrics: 23, 40, and 45.

© OTN - 58 Metric Safety Management System Audit 22

10. Incidents are investigated for root causes.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

a. Workplace policy requires the reporting of all actual and "near miss" accidents.

b. All investigations determine "root causes."

c. All accidents and incidents are investigated as required by policy.

d. Results of accident investigations are corrected immediately or scheduled for correction in the organization‘s action plan.

e. Accident investigators have received appropriate training.

f. All accidents and incidents are reported as required by policy.

g. Workplace policy requires a thorough investigation of all accidents and incidents.

h. Personnel understand the definition of an incident in the workplace.

i. Personnel in the workplace understand the importance of reporting incidences and do so.

j. There is a formal incident reporting form.

© OTN - 58 Metric Safety Management System Audit 23

• A safety and health incident is a "close call" event that does not result in an OSHA recordable injury or illness. Such incidents are important, however, because they are numerically predictive of accidents that do involve serious injury. Incident investigation programs are difficult for employers to implement successfully, especially in small organizations. The difficulty lies in defining those events to be reported as incidents, and ensuring that such incidents are, in fact, reported. When fully in place, however, it indicates an exceptional safety and health system.

• The organization can maintain an accurate first aid log with root cause analysis performed for log entries. Incident logs, near miss logs, or other means of recording and analyzing incidents can also be effective.

• To score "2" or "3" on this metric, the organization must create and promote the use of incident reporting procedures. This could be a no-fault or anonymous reporting mechanism (such as a special form) integrated into the established hazard reporting system (metric 4). All reported incidents would be subjected to root cause analysis. Effectiveness of incident reporting and analysis can be evaluated by review of reporting system records, root cause analysis reports, and employee interviews.

• Incident investigation is not effective unless (1) employees are "thanked" for reporting, and (2) identified hazards and underlying causes are immediately corrected or appropriately scheduled for correction in the organization's action plan for safety and health.

• Deficiencies found in this metric may also indicate problems in these metrics: 4, 26, 49, and 54.

© OTN - 58 Metric Safety Management System Audit 24

11. Feasible engineering controls are in place.

II. Hazard Prevention and Control

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

a. Hazard controls are in place at the facility.

b. Hazard controls are selected in appropriate priority order, giving preference to engineering controls, safe work procedures, administrative controls, and personal protective equipment (in that order).

c. Once identified, hazards are promptly eliminated or controlled.

d. Management, supervision, and the Safety Committee understand and can explain the hazard controls in the correct priority.

e. Employees understand and can explain the hazard controls in the correct priority.

• An engineering control is any change in facilities, equipment, tools, or process that eliminates or reduces a hazard. Such changes are usually physical changes involving some level of planning or design.

• Under OSHA‘s current "Hierarchy of Controls" policy, a feasible engineering control must be implemented even if the method does not completely control the hazard.

• Interim measures are required until engineering controls are in place.

• A rating of "3" on this metric indicates that there are no outstanding hazards requiring control by engineering methods. Organizations in this category may sometimes include improved engineering controls in their action plan. Such improvements will not negatively affect the organization‘s rating on this metric, if existing engineering controls adequately address the associated hazard.

• Deficiencies found in this metric may also indicate problems in these metrics: 23, 45, and 55.

© OTN - 58 Metric Safety Management System Audit 25

12. Effective safety and health rules and work practices are inplace.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

a. The rules are clearly written.

b. The rules relate to the safety and health policy.

c. The rules address potential hazards.

d. Observations demonstrate that all employees are following safe work rules.

e. Standards cover all work and workplaces at the facility and are readily available to all members of the work force.

f. There are effective means of communicating rules to the work force, such as training classes, employee safety handouts, rules posted in the workplace, and one-on-one discussions between employees and supervisors.

g. Employees support the rules and monitor one another to ensure compliance.

h. Employees have input into the development of workplace safety rules.

• Workplace rules apply to general areas of conduct (e.g. "No horseplay" and "No smoking in this area.")

• Safe work practices apply to specific operations or tasks (e.g. "Hearing protection required while operating this equipment.")

• To be effective, a workplace rule or work practice (1) must exist, (2) must be correct and sufficient, (3) must be communicated, and (4) must be followed. evaluators may determine that improvement is needed for any or all of these requirements.

• Rules or work practices may be formally or informally communicated to workers. Formal communications should be written and include employee manuals, operating manuals, plans, posters, postings on bulletin boards, and work aids. Informal communications are usually verbal and include training, supervisory instructions, and peer influence. Communication is best when formal and informal methods are used in conjunction.

• Deficiencies found in this metric may also indicate problems in these metrics: 34, 36, 43, 55, and 56.

© OTN - 58 Metric Safety Management System Audit 26

13. Applicable OSHA-mandated programs are effectively in place.

• A "mandated program" is a set of managerial and operational requirements required by rule, that are directed toward a specific safety and/or health objective. Examples of mandated programs are Hazard Communication, Hearing Conservation, Lock-Out/Tag-Out, and Confined Space Entry. Mandatory programs do not give employees options. They must comply.

• Evaluation of this metric is a 2-step procedure. First, determine the mandated programs that areapplicable to the organization. Next, determine if the applicable programs have been fully and effectively implemented by the organization.

• Deficiencies found in this metric may also indicate problems in these metrics: 24, and 55.

a. Required programs are fully in place and operational.

b. Employees and management understand and support the need for mandated programs.

c. Required programs are evaluated and updated at least annually.

d. Employees are involved in the review.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

© OTN - 58 Metric Safety Management System Audit 27

14. Personal protective equipment is effectively used.

• Personal protective equipment (PPE) may be used by an organization as an interim measure or as the last line of defense against a hazard. To be effective, however, PPE must be appropriate, available, carefully maintained, and properly used. There are management issues with each of these criteria that should be addressed in assessing this metric.

• Personal protective equipment assessment documentation and personal protective equipment training for affected employees are positive cues for this item.

• Deficiencies found in this metric may also indicate problems in these metrics: 3, 34, 36, and 45.

a. PPE assessment has been completed and documented.

b. Employees understand the need for, use of, and care of PPE associated with their jobs.

c. PPE on site is appropriate to the hazards.

d. Employees use the PPE that is provided.

e. PPE is properly donned and kept appropriately clean.

f. There is documented PPE training for all affected employees.

g. The need for specific PPE in the workplace is adequately communicated by the means of training, postings, signs, JHA‘s, etc.

h. The PPE is properly sized for each employee.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

© OTN - 58 Metric Safety Management System Audit 28

15. Housekeeping is properly maintained.

• Overall housekeeping can be an indicator of effective safety and health systems because many of the organizational factors that determine good housekeeping are similar to the factors that result in safety and health performance.

• In assessing this metric, focus on those aspects of housekeeping that have direct bearing on safety and health. Examples include aisles marked and free of tripping hazards, clear emergency exits, flammables and combustibles stored away from sources of ignition, incompatible chemicals not stored together, prompt cleaning of spills, clean restrooms, and effective waste management.

• Deficiencies found in this metric may also indicate problems in these metrics: 26 and 45.

a. Aisles and exit ways are clear and unobstructed.

b. Housekeeping is a regular task rather than an afterthought.

c. Routine processes which generate waste have housekeeping procedures built-in to them.

d. Storage areas are kept in a clear and orderly condition.

e. There is a written policy regarding housekeeping in the workplace and all personnel have been instructed in the policy and understand it.

f. Supervisors enforce the housekeeping policy.

g. There are specific and routine housekeeping inspections.

h. Appropriate accountability measures are in place to address poor housekeeping.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

© OTN - 58 Metric Safety Management System Audit 29

16. The organization is properly prepared for emergency situations.

a. All potential emergency situations which may impact the facility are identified.

b. A facility plan to deal with all potential emergencies has been prepared in writing.

c. The plan incorporates all elements required by law, regulation, and local code.

d. The plan is written to compliment and support the emergency response plans of the community and adjacent facilities.

e. The plan is current.

f. The plan is tested regularly with drills and exercises.

g. Community emergency responders are involved, where appropriate, in the facility drills and exercises.

h. The plan is effective at limiting the impact of the emergency on the facility and the work force.

i. Emergency communication systems are installed, operational, and redundant.

j. The communication systems are tested at regular intervals (at least monthly).

k. Emergency directions are available, correct and accurate in all spaces, corridors, and points of potential confusion.

• Organizations should be prepared for any emergency situation that can be reasonably anticipated. Emergency situations include fire, natural disasters known to the area, catastrophic failures in the company or neighboring facilities, workplace violence, and perhaps, terrorist acts.

• Assessment of this metric is a 3-step procedure. First, determine the types of emergency situations for which preparation is indicated. At a minimum, each organization should be prepared for fires and relevant natural disasters. Second, determine if the organization has engaged in planning and developed adequate emergency procedures to address the areas of concern. These emergency procedures, which are normally written and posted, serve as the primary information source in the second step. Third, determine the organization‘s state of readiness to carry out the adopted procedures. Evidence of successful periodic drills is the best indicator of readiness.

• Deficiencies found in this metric may also indicate problems in these metrics: 17 and 57.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

© OTN - 58 Metric Safety Management System Audit 30

17.The organization has an effective plan for providing competent emergency medical care to employees and others present at the site.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

a. The facility has a plan for providing emergency medical care to employees and others present on the site.

b. Competent emergency medical care is available on all shifts.

c. The emergency medical plan is followed when medical emergencies arise.

d. Emergency medical care is provided in accordance with standardized protocols.

e. On site emergency medical personnel are certified to at least the basic first aid and CPR levels.

f. Off site providers of emergency medical care, when utilized, are medical doctors, registered nurses, paramedics, emergency medical technicians, or certified first responders.

g. There is an on site nurse.

h. There are first aid personnel who are required to provide first aid as part of their job duties.

i. First aid training is offered to all personnel.

j. There are appropriate plans to direct outside emergency medical personnel into the workplace to the correct location.

k. First aid supplies are appropriate for the workplace, and there is a procedure to ensure they remain stocked.

l. All personnel are aware of the emergency medical plan and how to implement it, given their individual responsibilities.

m. There is a routine training class to review the emergency medical plan with personnel.

n. Outside contractors, vendors, and others are provided adequate instruction to ensure their emergency medical care while they are in the workplace.

© OTN - 58 Metric Safety Management System Audit 31

• Every organization should have procedures specifying when and how to summon ambulance or paramedic services. Such procedures should be written, posted, and familiar to employees, especially supervisors.

• When the response time for such emergency medical services is not sufficient to meet the needs of an organization, onsite interim response capability is required. In the absence of a plant nurse, most organizations need interim first aid and CPR capabilities provided by onsite individuals holding current certifications. First aid kits and related equipment should be stocked to meet the particular anticipated needs of the organization.

• Organizations having operations that pose serious danger to emergency medical responders should not be rated —3“ on this metric without demonstration that such responders have been duly notified of the potential danger and the precautions needed to conduct a safe response.

• Deficiencies found in this metric may also indicate problems in these metrics: 16 and 57.

© OTN - 58 Metric Safety Management System Audit 32

18. Effective preventive maintenance is performed.

a. A preventative maintenance program is in place at the facility.

b. Maintenance recommendations from manufacturers or builders are being followed for all applicable facilities, equipment, machinery, tools, and/or materials.

c. The preventative maintenance system ensures that maintenance for all operations in all areas is actually conducted according to schedule.

d. Operators are trained to recognize maintenance needs and perform or order maintenance on schedule.

e. Predictive maintenance procedures are incorporated into the system.

f. The preventative maintenance procedures go beyond operation-related equipment to cover the maintenance of engineered hazard controls and emergency equipment as well.

g. There is a scheduled shut-down to address preventative maintenance issues.

h. Operators give positive remarks about the PM of the machines and equipment they operate.

i. There is a PM policy which not only addresses the issue of production, but also addresses safety.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

© OTN - 58 Metric Safety Management System Audit 33

• Preventive maintenance is important to the organizational safety and health system because equipment failures can cause accidents affecting operating personnel and because maintenance workers can be injured due to the hectic pace associated with emergency repairs.

• Preventive maintenance is used as a generic term in this item. Technically, preventive maintenance refers to scheduled maintenance. The schedule is normally based on recommendations of the equipment manufacturer. There should be a log indicating if maintenance was performed according to schedule.

• Predictive maintenance is based on periodic testing, such as vibration analysis. In this approach, maintenance actions are undertaken only when test results indicate a need. Records will normally be available to document that an organization has implemented a predictive maintenance approach. Another approach is the plant shutdown for overhaul of major equipment or processes. The practice of plant shutdown can be easily determined by interview.

• The evaluator should recognize that, typically, organizations employ a variety of preventive and non-preventive maintenance methods as determined by technological and economic considerations. And preventive maintenance is not necessary for all equipment and facility components in order to have a safe and healthful workplace. Therefore, in assessing this metric, the evaluator should focus on:

1. past accidents and incidents in which maintenance deficiencies were contributing factors,

2. identified hazards involving maintenance problems,

3. potential equipment failures with foreseeable safety and health consequences, and

4. high-risk emergency repair scenarios.

Particular attention should be devoted to the maintenance of engineered hazard controls and emergency equipment.

• Deficiencies found in this metric may also indicate problems in these metrics: 26 and 45.

© OTN - 58 Metric Safety Management System Audit 34

19. An effective procedure for tracking hazard corrections is in place.

a. The tracking procedure flags and tracks hazards until they are adequately addressed.

b. The system covers items identified from various sources, including self-inspections, employee recommendations and reports, Safety Committee, and maintenance logs.

c. Employees are aware of and comfortable using the system.

d. The hazard tracking system prompts feedback after the hazard is addressed.

e. The tracking hazard system uses a computerized spreadsheet format to identify hazards, assign responsibility for completing, completion dates, and follow-up.

f. Employees are allowed to initiate work orders to be placed on the hazard correction form involving safety and health.

g. A review of the tracking hazard form shows

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

• Timely correction of every identified hazard is critical to an effective safety and health system. There should always be some kind of written method to document the progress and status of hazard correction. The degree of sophistication in the tracking method will decrease with company size. Among larger organizations, a work-order system will usually be in place. Progressive companies often allow any employee to initiate a work order involving safety and health issues. In some organizations, the safety and health committee initiates and tracks hazard correction with progress reported in the minutes. Among very small organizations, the owner/operator should track hazard corrections the same way other important business tasks are tracked. Often this will involve entries in a calendar or appointment book.

• If there has been a prior consultative visit to the organization and hazards were identified, the employer‘s adherence to established correction due dates suggests that an effective tracking system is in place.

• Items identified multiple times in safety committee minutes, self inspection reports, employee hazard reports, etc. indicate potential problems with tracking systems.

• Deficiencies found in this metric may also indicate problems in these metrics: 23 and 28.

© OTN - 58 Metric Safety Management System Audit 35

20. Workplace injury/illness data are effectively analyzed.

• Workplace injury/illness data should be analyzed to identify injury and illness types and to detect trends and patterns. Results of the analyses are useful in detecting hazards and setting priorities for hazard correction.

• Written analysis of data involving less than 10 injuries and illnesses is not always necessary. Interpretation of such small sets of data should be readily apparent without manipulation. However, responsible persons in the organization should have reviewed the data and be able to describe their conclusions in interviews. Also, note that combining data for multiple years can increase the size of the data set, thereby possibly justifying formal analysis.

• A score of "3" on this metric indicates that the organization undertakes collection and effective analysis of its injury and illness data or that less than 10 injuries and illnesses were recorded over the part three years, and responsible persons in the organization have informally interpreted those small data sets.

• Deficiencies found in this metric may also indicate problems in these metrics: 25, 48 and 58.

III. Planning and Evaluation

a. A system exists which tracks safety and health related trends at the facility.

b. The system addresses trailing indicators, including accidents, occupational injuries and illnesses, hazards identified, and complaints from employees and others.

c. The system addresses leading indicators of safety and health effectiveness, including employee attitudes and employee behaviors.

d. Affected personnel understand the need to systematically, accurately and consistently provide updated information to the system for tracking.

e. Trend data is consistently provided to all facility personnel.

f. All personnel are fully aware of safety and health trends, causes, and means of prevention.

g. Trend data is utilized to drive improvement and prevention activities.

h. The Safety Committee and other employees participate in analyzing workplace injury/illness data.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

© OTN - 58 Metric Safety Management System Audit 36

21. Hazard incidence data are effectively analyzed.

• Hazard incidence data should be analyzed to identify hazard types and to detect trends and patterns. Results of the analyses are useful in setting hazard prevention priorities.

• As in the analysis of injury and illness data, formal analysis of data involving fewer than 10 recorded hazards is not required, although informal analysis is appropriate. It is important that the facility look for the root cause to determine what factors allowed the hazard(s) to exist.

• A score of "3“ on this metric indicates that the organization undertakes collection and formal analysis of its hazard incidence data or that less than 10 hazards were recorded over the past three years, and responsible persons in the organization have interpreted those data.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 25, 48 and 58.

a. All written reports of inspections are retained for a period sufficient to show a clear pattern of inspections.

b. Statistical summaries of all routine inspections are prepared, charted and distributed to all personnel so as to show status and progress at hazard elimination.

c. The Safety Committee analyzes hazards to identify deficiencies in the safety and health management system.

d. A method exists for systematic tracking of recommendations, progress reports, resolutions, and outcomes.

e. The system provides for data collection and display as a means to measure the success of the system in resolving identified hazards.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

© OTN - 58 Metric Safety Management System Audit 37

22. A safety and health goal and supporting objectives exist.

a. A set of safety and health goals exist in writing.

b. The goals relate directly to the safety and health policy or vision.

c. Objectives exist which are designed to achieve the goals.

d. The goals and objectives are able to be evaluated and revised as needed.

e. A reliable measurement system exists to indicate progress on objectives toward the goal.

f. The measurement system is consistently used to manage work on objectives.

g. The objectives can be easily explained by others within the workplace.

h. Measures used to track objective progress are known to the work force.

i. Goals are specific, measurable, achievable, result-oriented, and clear time frames.

j. Management visibly communicates their support of the goals to the work force.

k. There are concrete examples that the goals and objectives are being met.

l. Employees had input into the development of goals and objectives.

m. Goals and objectives are developed based on audits and analysis of the effectiveness of the Safety and Health Program, along with other safety and health related data.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

© OTN - 58 Metric Safety Management System Audit 38

• A "goal" is a broad statement of organizational intent. It sets the sights of the organization on a major achievement. Most goals are long-range in nature, involving multiple years of planning efforts. Some goals, however, are not time framed at all, representing instead the organization‘s commitment to maintain or continuously improve already existing levels of excellence. Goals may or may not be measurable or directly achievable.

The Safety and Health Program Assessment Worksheet envisages a single safety and health goal that brings coherence and unity-of-purpose to the organization‘s safety and health system. Nevertheless, an organization‘s desire to set more than one safety and health goal should not detract from the evaluator‘s assessment of this metric.

• Safety and health goals may be outcome-based or process-based. Outcome-based goals are those that focus on the occurrence of injuries and illnesses or associated monetary losses. Examples of goal statements that are outcome-based are "We will have no workplace injuries or illnesses over the next three years" or "We will reduce our recordable injury rate by 80 percent over the next three years." The former goal represents zero tolerance, while the latter represents incremental improvement. As a rule, goals involving incremental advancement are preferable to zero-tolerance goals for those organizations that have considerable room for improvement in their outcome statistics.

Another issue associated with outcome-based goals is the potential for such goals to stimulate organizational and individual under-reporting of injuries and illnesses. Great care must be taken to ensure that organizations do not seek their outcome-based goals in a manner that discourages reporting of accidents, injuries, and illnesses.

Process-based goals are those that focus on operational and organizational safety and health characteristics, with little or no emphasis on injury or illness outcomes. Examples of process-based goals are "We will achieve an acceptable rating on the Safety and Health Program Assessment Worksheet within three years" or "We will achieve SHARP status within 18 months."

• The first step in achieving a safety and health goal is the establishment of a set of objectives that support the goal. Objectives should be stated in terms of SMART criteria, i.e., Specific, Measurable, Achievable, Result-oriented (tied to the goal), and Time-framed (usually less than one year).

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 48 and 57.

© OTN - 58 Metric Safety Management System Audit 39

23. An action plan designed to accomplish the organization‘s safety and health objectives is in place.

Comments:

______________________________________________________________________________

______________________________________________________________________________

a. A plan is in place to implement the objectives of the Safety and Health Program.

b. The plan objectives are designed to achieve the stated goals.

c. The objectives relate to deficiencies identified in periodic assessments or comprehensive review.

d. Objectives in the action plan are clearly assigned to responsible individuals.

e. The action plan includes a measurement system to track progress on each objective.

f. Actions planned to accomplish objectives are specific and short-termed.

g. Employees are involved in the development of and implementation of the action plan.

h. Top management visibly supports the completion of the action plan.

i. Top management is involved in the development of and completion of the action plan.

j. The organization communicates the progress of the action plan to the work force and —celebrates“ successes with the work force.

• Actions that are planned to accomplish a safety and health objective should be short-term and highly specific. Complex actions should be broken down into steps, milestones, or other progress points. As with objectives, action statements should incorporate SMART criteria (see tip for metric 22). Ideally, action statements will begin with an action verb. Action statements should identify those responsible for the action and the planned completion date.

• The action plan is a list of all safety and health actions to be accomplished over the planning period. Typically, the planning period is one year in order to coincide with annual objectives (metric 22) and comprehensive review (metric 25). However, multiple sequential action plans of shorter duration (monthly, quarterly, etc.) can achieve the same result.

• Action statements (with milestones, if any), assigned responsibilities, and planned completion dates are the essential ingredients for all actions included in an action plan. Space for actual completion dates is desirable if progress is to be tracked directly on the plan. Actions should be correlated with relevant objectives by grouping or designation. A matrix format may be useful to depict actions that relate to more than one objective. Also, employers working to improve their Safety and Health Program Assessment Worksheet score may wish to code their objectives and/or actions with the relevant metric numbers.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 48 and 57.

© OTN - 58 Metric Safety Management System Audit 40

24. A review of in place OSHA-mandated programs is conducted at least annually.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

a. The review examines written materials, the status of goals and objectives, records of incidents, records of training and inspections, employee and management opinion, observable behavior and physical conditions.

b. The results of the review are documented and drive appropriate changes or adjustments in the program.

c. The review samples evidence over the entire facility or organization.

d. The results of the review are documented and drive appropriate changes or adjustments in the programs.

e. Employees are involved in the review.

f. The employer has a structured and scheduled system for conducting the review.

g. Findings are communicated to the work force.

© OTN - 58 Metric Safety Management System Audit 41

• Periodic reviews to evaluate the operational effectiveness of applicable OSHA-mandated programs are a good safety and health practice. Some program standards, e.g. the 1910.146 standard governing permit-required confined space entry programs, actually specify a requirement for such reviews. Note that each mandated program represents a cross-section of the organization‘s larger safety and health system and a thorough review of the mandated program entails not only identification of operational defects (metrics 1-19), but also any managerial or cultural problems (metrics 20-58) that may limit effectiveness.

• If the organization does not conduct periodic reviews of in-place mandated programs, a rating of "0" should be assigned to this metric.

• If the organization has only one mandated program in place, and conducts a nearly complete review of that program, then the evaluator should assign a rating of "2" to this metric. If review of the single program is thorough, a rating of "3" is appropriate.

• If the organization has more than one mandated program in place and conducts periodic review of at least one, but not all of the programs, then the evaluator should assign a rating of "1" to this metric. A rating of "2" is indicated when all of the in-place mandated programs are periodically reviewed, but minor improvement is needed in the quality of some or all of these reviews. Where there are multiple mandated programs in place, a rating of "3" always requires effective periodic review of each program.

• Failure of the organization to implement an applicable OSHA-mandated program should be considered in the hazard identification portion of the consultation and in the rating of metric 13, rather than in the rating of this metric.

• Review of mandated programs presents an excellent opportunity for an organization to stimulate employee participation and exhibit management leadership.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 48 and 58.

© OTN - 58 Metric Safety Management System Audit 42

25. A review of the overall safety and health management system is conducted at least annually.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

a. Reviews are used to make positive changes in policy, procedures and programs.

b. The review includes all facets of the facility.

c. The Safety and Health Program is reviewed at least annually.

d. The review examines written materials, the status of goals and objectives, records of incidents, records of training and inspections, employee and management opinion, observable behavior and physical conditions.

e. The review process drives correction of identified deficiencies.

f. Evidence exists which demonstrates that program components actually result in the reduction or elimination of accidents.

g. Positive findings are communicated and celebrated with the work force.

h. Top management is directly involved with the audit.

i. Employee representatives are involved in the audit.

© OTN - 58 Metric Safety Management System Audit 43

• An annual audit of the organizational safety and health system should be conducted on a formal basis. The appropriate level of written documentation for the audit will vary with the size of the organization and the complexity of the audit. The annual safety and health audit should highlight the accomplishments and identify the failures of the past year. The audit should also ascertain the underlying reasons for any failures so that these issues can be addressed. Ideally, the audit will correlate action successes and failures of the past year with outcome results such as injuries and illnesses. This correlation can be used to determine if these actions should be extended, changed or dropped, and to determine if new actions and/or objectives should be initiated.

• A review of the entire safety and health system is characteristic of the highest performing safety and health systems, and it contributes incrementally to excellence in these systems once the related basic metrics, particularly metrics 20, 21, 22, and 23 are in place.

• Although the annual audit is concerned with accountability for safety and health performance at all levels of the organization, it is primarily a scorecard for top management leadership. For this

• reason, top managers should be directly involved in the audit process or, at least, keenly aware of the audit results.

• Some organizations have their safety and health system in a "continuous improvement" mode. The notion of an annual audit is not in conflict with this approach. The audit provides a "big picture" assessment of the overall impact that numerous small improvements are having on organizational performance.

• There are numerous ways to perform an annual safety and health audit. It may be conducted internally or externally. Corporate staff commonly perform external audits for small units of the company. Internal audits may be performed by the organization‘s safety committee or by a special team assembled for that purpose. Regardless of the method, it is essential that the audit process be data driven with top management endorsement. Also, the most effective audits involve input from all levels of the organization - managers, supervisors, and workers.

• The annual safety and health audit does not necessarily involve an inspection activity. Auditors may depend on previous inspection reports to conduct their analysis. However, annual audits may include inspections to verify or augment previous inspection results or to establish a new hazard baseline.

• Audits may be very brief in time and documentation if the organization successfully completed its planned safety and health actions, accomplished its objectives, and achieved the desired outcome results.

• Some organizations sponsor "celebrations" to announce or recognize the safety and health successes revealed by the annual audit. Such events tend to heighten employee awareness of and participation in workplace safety and health issues in a way that stimulates or solidifies a safety and health culture.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 48 and 58.

© OTN - 58 Metric Safety Management System Audit 44

26. Safety and health program tasks are each specifically assigned to a person or position for performance or coordination.

IV. Administration and Supervision

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

a. An individual, or group, is assigned responsibility for compiling and analyzing records for safety and health trends.

b. All elements of the company's Safety and Health Program are specifically assigned to a job or of position for coordination.

c. Individuals within the company can describe the specific safety and health duties assigned to them.

d. Assigned responsibility is documented.

• Although assignable tasks pertain to most aspects of an organizational safety and health system, the particular tasks selected for assignment should follow primarily from review of the Operational Component (metrics 1-19). These metrics almost always involve clearly assignable responsibilities.

For example, in assessing whether safety and health self-inspections are regularly performed (metric 2), the evaluator should determine if responsibilities for such inspections have been assigned. The training items (metrics 34-39) also frequently involve assignable responsibilities. Therefore, assessment of safety and health training can be expected to yield information relevant to metric 26.

• It is particularly important to examine the assignment of responsibilities for actions set forth in the organization‘s action plan, if any, because these tasks have direct bearing on achievement of current safety and health objectives.

© OTN - 58 Metric Safety Management System Audit 45

• The intent of this metric is simply to ascertain if managers and supervisors have designated individuals they intend to hold responsible for the various safety and health tasks of the organization. The degree to which such responsibilities have been successfully communicated to people who are empowered, motivated, and accountable for performance of the assigned tasks is the subject of other metrics.

• This metric is not concerned with responsibility in the sense of ultimate responsibility for workplace safety and health as placed on the employer by statute. It is concerned with the performance of specific safety and health tasks. Nevertheless, claims by very small owner/operators that they have retained total responsibility for all or most of the safety and health tasks in their small organizations may be accepted. Although such a one-person safety and health system may be workable in rare instances, more often these situations merely reflect the reluctance or inability of the employer to delegate. Regardless, the adequacy or inadequacy of such a situation will be revealed through the assessment and rating of other metrics.

• The notion that everybody is responsible is a common tenet in many organizations with strong safety and health cultures. This approach is great for some aspects of the safety and health system, such as following safety rules and reporting hazards. It is not acceptable for rating this metric, which requires individual responsibilities for performing specific safety and health tasks. In this view, if everyone is responsible, no one is responsible.

• The evaluator can simply ask managers and supervisors to identify the individuals or positions with assigned responsibility for the relevant tasks. For example, if accident investigation is a priority task, the evaluator may ask a manager – "Who is responsible for conducting accident investigations?" The manager may respond by indicating that supervisors are responsible for investigating all accidents in their area. This fact establishes a confirming cue for rating this metric. If the manager indicates instead that no one has been assigned responsibility for accident investigations, then a negating cue is established.

• If a hazard has been overlooked by the organization primarily because no one had responsibility for conducting a needed accident investigation, then the evaluator has established a negating cue for rating this metric. On the other hand, where evidence accumulated during a safety or health survey suggests that, at least sometimes, accident investigations are being performed; such evidence may provide a confirming cue for rating the metric.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 27, 28, 29, 30, 31, 32 and 33.

© OTN - 58 Metric Safety Management System Audit 46

27. Each assignment of safety and health responsibility is clearly communicated.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

a. The objectives are clearly assigned to responsible individual(s).

b. Clear roles and responsibility are established.

c. Assignments are in writing.

d. Each assignment covers broad performance expectations.

e. Personnel understand their responsibilities.

• Assessment of this metric will follow from the assessment of metric 26. In that metric, individuals responsible for performance of priority safety and health tasks were tentatively identified, based on the perceptions of the managers or supervisors to whom those individuals report. The intent of the present metric is to confirm that the responsible individuals are, in fact, aware of and understand their assignments. The simplest way to find out is to ask them. The major advantage of this method is that it provides systematic information on the communication of responsibilities for important safety and health tasks.

• Another method for assessing this metric is to ask selected members of the organization to list or describe the safety and health responsibilities they hold. This method provides an efficient way to gain limited information on where safety and health responsibilities reside in an organization, but for a broader range of task categories than does the method described in the bullet-point above. This method also reveals situations in which individuals have assumed an undelegated safety or health task in order to meet a need that may not be recognized by the manager or supervisor. Such situations are common in organizations with strong safety and health cultures and active worker participation.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 26, 28, 29, 30, 31, 32 and 33.

© OTN - 58 Metric Safety Management System Audit 47

28. An accountability mechanism is included with each assignment of safety and health responsibility.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

a. Authority to meet assigned responsibilities exists for all personnel.

b. Authority is granted in writing.

c. Methods exist for monitoring performance of responsibilities

d. .d All personnel, including managers, are held accountable to follow the rules.

e. Positive accountability systems are an integral part of the accountability mechanisms.

f. Responsibilities are being met appropriately and on time.

g. All personnel are held accountable for meeting their safety and health responsibilities.

h. Personnel meeting or exceeding responsibilities are appropriately reinforced for their behavior with positive consequences.

i. Members of management at all levels consistently address the safety behavior of others by coaching and correcting poor behavior and positively reinforcing good behavior.

© OTN - 58 Metric Safety Management System Audit 48

• An accountability mechanism is characteristic of the highest performing safety and health systems, and it contributes incrementally to excellence in these systems once the related basic metrics, particularly metrics 26, 27, 29, 30, 31, 32, and 33, are in place.

• Assessment of this metric will follow from assessment of metric 27, which is concerned with communication of task assignments. Effective monitoring by the delegator of the delegatee‘s performance of an assigned safety and health task is the central idea. This metric is derived from the time-tested management adage that what gets monitored is what gets done. At the time any safety or health task is assigned, both the delegator and the delegatee need to have a clear and consistent mutual understanding of how and when performance of the assignment will be measured. This need places great importance on effective communication of expectations and reporting methods at the time each assignment is made.

• Modern managers and supervisors use a variety of accountability mechanisms. These include regular written reports or memoranda, periodic personal conferences, timely briefings or oral reports to the delegator, and presentations at group meetings such as meetings of the safety committee.

• Computer reporting is increasingly important in business today. This may involve something as sophisticated as an electronic management information system or as simple as regular e-mail messages. Some delegators prefer the "open-door" method of monitoring delegated assignments. This is a form of "management by exception" that brings to the attention of the delegating authority only those problems that the delegatee is uncertain how to handle or unable to do so.

• The particular mechanism chosen by a delegator to ensure accountability for safety and health tasks should be consistent with that person's management style and compatible with the organization‘s culture. Also, it should be comparable to the mechanisms in place to ensure accountability for other organizational functions such as productivity and quality.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 26, 27, 29, 30, 31, 32 and 33.

© OTN - 58 Metric Safety Management System Audit 49

29. Individuals with assigned safety and health responsibilities have the necessary knowledge, skills, and timely information to perform their duties.

• Assessment of this metric will follow from the assessment of metric 27, which establishes that assignment of responsibility for each safety and health task has been made and acknowledged. The intent of the present metric is to determine if the responsible person knows how and when to perform the assigned task. This metric considers three types of learning that are necessary for effective task performance.

1. The term "knowledge" refers to understanding gained from study or experience. Knowledge relates to the "why" and "what if" issues associated with a task.

2. The term "skill" means ability. It refers to the "how" and "do it" aspects of a task. Skill is usually obtained by practice to proficiency.

3. The term "timely information" refers to advance data, instructions, alerts, warnings, or other communications that either trigger performance of a task or alter the way it should be performed. It relates primarily to the "when" aspects of task performance and is particularly important under hazardous or emergency conditions.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 26, 27, 28, 30, 31, 32 and 33.

a. All personnel with program assignments are familiar with their responsibilities.

b. Personnel with assigned safety and health responsibilities have had appropriate training or mentoring to enable them to understand and meet those responsibilities.

c. Personnel understand the programs or process to which they have been assigned.

d. Specific skills, knowledge, and information (for safety and health responsibilities) are documented to ensure that personnel assigned the responsibility have these needed qualities.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

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30. Individuals with assigned safety and health responsibilities have the authority to perform their duties.

a. Personnel believe they actually have the authority granted to them.

b. Personnel understand how to exercise the authority granted to them.

c. Personnel do exercise the authority granted to them.

d. Authority is exclusively within the control of the individual holding the responsibility.

e. Authority is documented and there is a formal method to ensure personnel recognize their authority.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

• Assessment of this metric will follow from the assessment of metric 27, which establishes that assignment of responsibility for a task has been made and acknowledged. The intent of the present metric is to determine if the responsible person has the necessary authority to perform the assigned task.

• At least three types of authority are necessary for a responsible person to perform assigned safety and health tasks effectively--these are (1) authority over the work, (2) authority over neededresources, and (3) authority over subordinates. Authority over the work means that the responsible person can make and implement operational decisions relative to the assigned task, including work stoppage if necessary. Authority over resources means that the responsible person identifies task-related resource needs and obtains or specifies and requisitions those resources. Resource needs may involve physical resources such as supplies or equipment as well as service resources such as training, repairs, maintenance, and housekeeping. If needed resources are not available, the responsible person must have the authority to make operational decisions that react to or compensate for the resource deficiency. Authority over subordinates means that the responsible person is able to make and enforce task-related assignments to others. All three types of authority are usually inherent to a line position, hence the advantage of safety and health as a line function.

• Any limitations to the authority of a responsible person should be clearly spelled out by the delegator at the time the assignment is made. Evaluation of such authority restrictions may reveal that the nominally designated responsible person is, in fact, not the responsible person because true responsibility entails authority.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 26, 27, 28, 29, 31, 32, 33 and 46.

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31. Individuals with assigned safety and health responsibilities have the resources to perform their duties.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

a. Adequate resources (personnel, methods, equipment, funds) to meet responsibilities are available to all affected personnel.

b. Necessary resources are within the control of the individual holding the responsibility.

c. Resources are being effectively applied by all personnel in order to meet responsibilities.

• Assessment of this metric will follow from the assessment of metric 27, which establishes that assignment of responsibility for each safety and health task has been made and acknowledged. The intent of the present metric is to determine if the responsible person has the resources necessary to perform the assigned task.

• Assessment of this metric may overlap assessment of metric 29, which concerns knowledge, skills, and information. If task resources are unavailable because the responsible person is unaware of the need for such resources, or because that person does not know how to obtain the resources, then the absence of resources reflects a negating cue for assessment of this metric and for assessment of metric 29.

• Assessment of this metric may also overlap assessment of metric 30, which concerns authority issues. If task resources are unavailable because the responsible person lacks the authority to obtain the resources, then the resource deficiency reflects a negating cue for assessment of this metric and for assessment of metric 30.

• If task resources are unavailable because the responsible person has neglected or chosen not to obtain the resources, then the resource deficiency reflects a negating cue for assessment of this metric alone. The evaluator may, however, also use the finding as evidence in assessing other metrics, particularly metrics 32-33 concerning motivation and metric 28 concerning accountability. The present metric (metric 31) is also the appropriate assessment point for task resource deficiencies that cannot be attributed to a particular cause.

• Resources include but are not limited to time, personnel, and money.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 26, 27, 28, 29, 30, 32, 33 and 44.

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32. Organizational policies promote the performance of safety and health responsibilities.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

a. There is a policy that promotes safety and health.

b. The policy is available in writing.

c. The policy is clear and straightforward.

d. The policy can be easily explained or paraphrased by others within the work force.

e. The safety and health policy fits within the context of other organizational values.

f. The safety and health policy guides all employees in making a decision in favor of safety and health when apparent conflicts arise with other values and priorities.

g. The policy provides for consequences that are Positive, Immediate, and Certain (PIC) from the perspective of the employee.

h. The policy is appropriately communicated throughout the organization including new employee orientation.

© OTN - 58 Metric Safety Management System Audit 53

• This metric is concerned with positive motivation for safety and health performance. It includes consideration of positive motivations for performance of the specifically assigned safety and health tasks that are evaluated in metrics 26-31. But it also includes the positive motivations applicable to the general safety and health activities and responsibilities that are incumbent on all members of the organization. Examples of desirable general behaviors include employee participation activities, following safety rules, and reporting hazards.

• The methods used to motivate employee safety and health behaviors in some organizations may be complex. A negating cue, in the context of this metric, is a hazard or potential hazard, for which lack of motivation on the part of one or more individuals, is a directly contributing factor. Because this type of analysis usually cannot distinguish between the need for positive motivation and the need for negative motivation, a negating cue for this metric often constitutes a negating cue for metric 33 as well.

A confirming cue in the context of this metric is obtained when a safety and/or health survey fails to reveal hazards or potential hazards for which lack of motivation is a directly contributing factor. The confirming cue provides positive evidence, often weak, that the metric is fully or partially in place. The strength of this type of cue is proportional to the scope of the survey and the degree to which evaluators are able to discern the influence of applicable motivational factors in eliminating or controlling hazards. In addition, a confirming cue for this metric may also constitute a cue for rating metric 33.

• In rating this metric, a single negating cue eliminates the possibility of a "3" value and a single confirming cue eliminates the possibility of a "0" value. The choice between selecting a "1" value and a "2" value will be a judgment call based on the relative weights of positive and negative evidence.

• Motivation is driven by the consequences of action or inaction as perceived by the individual. Major positive consequences for safety and health performance might include improved personnel evaluations, pay raises, bonuses, and promotions. However, smaller positive consequences, especially those based on recognition, are also quite effective in motivating safety and health performance. The most successful motivators, large or small, are "PIC" consequences. These are consequences that are Positive, Immediate, and Certain from the perspective of the employee.

• Also consider the "5-S's" for effective recognition. To be effective consequences should be (1) Soon, employees should be (2) Sure they will be recognized and why. Consequences should be perceived as (3) Significant, and they should be administered in a (4) Simple manner. Finally, the most effective recognition is (5) Sincere: Management's appreciation is genuine.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 26, 27, 28, 29, 30, 31, 33 and 45.

© OTN - 58 Metric Safety Management System Audit 54

33. Organizational policies result in correction of non-performance of safety and health responsibilities.

Comments:

______________________________________________________________________________

______________________________________________________________________________

a. The policy statement goes beyond compliance to address the safety behavior of all members of the organization.

b. Failure to meet assigned responsibilities are addressed and result in appropriate coaching and/or negative consequences.

c. Accountability data is used to revise goals and objectives so as to facilitate continuous safety and health improvement.

d. Safe work rules are understood and followed as a result of training and accountability.

e. Methods exist for monitoring performance.

• This metric evaluates policies designed to discourage safety and health non-performance. It includes consideration of disincentives intended to discourage non-performance of the specifically assigned safety and health tasks that are evaluated in metrics 26-31. But it also includes the negative motivators applicable to non-performance of the general safety and health activities and responsibilities that are incumbent on all members of the organization. Examples of undesirable general behaviors include breaking safety rules, refusing to wear required personal protective equipment (PPE), and ignoring established safe work practices.

• Negative and positive motivations are closely related subjects. The second and third bulleted assessment tips regarding positive motivations under metric 23 are applicable and significant to this metric too.

• Achieving superior safety and health performance requires confronting poor performance as well as recognizing good performance. But motivation, especially negative motivation, is not the appropriate method for correcting every performance problem. The first step in correcting poor safety and health performance is to determine the underlying cause of the problem. The type of analysis involved in assessing metrics 26-31 will reveal some of the common non-motivational obstacles to good performance. Poor work design may require job engineering. Poorly delegated task assignments may require clearer communication of expectations and consequences. Perhaps performance feedback has not been provided. Also, resources may not be appropriate or sufficient to the task or training may be inadequate.

• The employer should have in place a formal system of progressive disciplinary actions that is used when poor safety and health performance persists after obstacles to performance have been removed.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 26, 27, 28, 29, 30, 31, 32 and 47.

© OTN - 58 Metric Safety Management System Audit 55

a. An employee safety and health training program exists at the facility.

b. The training covers all legally-required subjects.

c. The training covers hazards (awareness, location, identification, and protection or elimination).

d. The training system ensures that the knowledge and skills taught are consistently and correctly applied by the employees.

e. Employees are fully trained in the use of controls and methods to protect themselves in their work area.

f. All members of the work force have been trained on the use of appropriate hazard analysis systems.

g. All personnel involved in inspections have been trained in the inspection process and in hazard identification.

h. Personnel can explain and demonstrate their role under the emergency medical plan.

i. Personnel are trained in the use of emergency equipment available to them and can demonstrate the proper use of the equipment.

j. Post-training knowledge and skills are tested or evaluated to ensure employee proficiency in the subject matter.

34. Employees receive appropriate safety and health training.

V. Safety and Health Training

Comments:

______________________________________________________________________________

______________________________________________________________________________

• The focus of this metric is on non-supervisory and non-managerial employees, i.e. workers. Training of supervisors and managers is addressed in metrics 36-39.

• The term "training“ is used in this metric as generic shorthand for any and all types of safety and health learning. It is not limited to skill development as normally associated with that word. Training may be formal or informal, and it may include methods as diverse as off-site workshops, OJT, and job aids.

• The evaluator should look for an organized safety and health training effort that identifies any training needs, determines the best way to meet those needs, delivers the needed training in a timely manner, and evaluates the effectiveness of the training provided. Viewed in this way, training becomes an organizational safety and health task that can be systematically assessed under metrics 26-33.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 29, 35, 46, 53 and 56.

© OTN - 58 Metric Safety Management System Audit 56

35. New employee orientation includes applicable safely and health information.

• If the employer does not provide employee orientation, a rating of "0" should be assigned to this metric. Likewise, a rating of "0" is appropriate if orientation is provided without safety and health information.

• An orientation session is not expected to cover all of the detailed and job-specific safety and health information needed by every new employee. Orientation is not a substitute for the training assessed in metric 34. At a minimum, however, orientation should cover the employer‘s announced safety and health policy, general safety and health rules, major hazards and protections, and emergency procedures. Re-orientation may be necessary when an employee changes job duties, if the change involves significant new hazards, protections, or emergency procedures.

• A rating of "3" on this metric is indicated only when orientation is provided that includes appropriate safety and health information for both new employees and, as needed, for employees who are assuming new duties.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 29, 34, 46, 53 and 56.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

a. Orientation covers the facility safety system (policy, goals and objectives, operations, tools and techniques, responsibilities, and system measurement).

b. Orientation covers the facility emergency procedures.

c. The orientation is provided to all new employees and all personnel working on site, including vendors, temporary workers and contract workers prior to exposure to workplace hazards.

d. There is follow-up action to determine the retention of orientation training for new employees, and there

e. are provisions for retraining when deficiencies are noted in the follow-up. e There is a formal and documented program which is used for new employee orientation.

f. New employee orientation is reviewed in the annual Safety and Health Program audit.

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36. Supervisors receive appropriate safety and health training.

a. A supervisory safety and health training program exists at the facility.

b. The training is provided to all supervisors.

c. Training is regularly evaluated for effectiveness and revised accordingly.

d. Post-training knowledge and skills are tested or evaluated to ensure supervisory proficiency.

e. Supervisors receive the same training as employees in their department.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

• The term "supervisor" means the first-line supervisor. These individuals are close to the work and have direct responsibility for personnel doing the work. In very small organizations, the supervisor is probably the owner/operator. The first prerequisite for effective safety and health supervision is an understanding of the hazards, protections, and emergency procedures associated with the supervised work.

• The evaluator should look for the same type of organized safety and health training effort provided for employees (metric 34).

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 29, 37 and 46.

© OTN - 58 Metric Safety Management System Audit 58

37. Supervisors receive training that covers the supervisory aspects of their safety and health responsibilities.

• Supervisory effectiveness is key to safety and health performance. Although supervisors may have job-related knowledge of hazards, protections, and emergency procedures, this is often not enough. They need to be able to train and motivate their subordinates to recognize the hazards, use the protective measures, and follow the emergency procedures. The supervisory skills needed to accomplish this are rarely included in hazard-based training. Supervisors may need coaching or specialized training to acquire these skills. Training that develops supervisory skill may be general or, ideally, directed to safety and health issues.

• Supervisory training is characteristic of the highest performing safety and health systems, and it contributes incrementally to excellence in these systems once the related basic metrics, particularly metrics 2, 3, 4, 12, 14, 15, and 16 are in place.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 29, 36 and 46.

a. The training covers all subject matter delivered to employees.

b. The training covers the facility safety system (policy, goals and objectives, operations, tools and techniques, responsibilities, and system measurement).

c. The training covers supervisory safety and health responsibilities.

d. The training system ensures that the knowledge and skills taught are consistently and are correctly applied by the supervisors.

e. There is a form

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

© OTN - 58 Metric Safety Management System Audit 59

38. Safety and health training is provided to managers.

• The term "managers" includes top managers and middle managers.

• Training for managers should be sufficient to provide for their personal safety and health. It should also be adequate for them to exercise leadership roles regarding safety and health issues throughout the workplace.

• The evaluator should look for the same type of organized safety and health training effort provided for employees (metric 34).

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 29, 39 and 46.

a. A management safety and health training program exists at the facility (where applicable).

b. Safety and health training is provided to all managers.

c. The training covers all subject matter delivered to employees and supervisors to the extent necessary for managers to evaluate employee and supervisory knowledge and skills and to reinforce or coach desired safety and health behaviors.

d. Post-training knowledge and skills are tested or evaluated to ensure management proficiency in the subject matter.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

© OTN - 58 Metric Safety Management System Audit 60

39. Relevant safety and health aspects are integrated into management training.

• The premise of this metric is that managers who understand both the way and extent to which effective safety and health protection impacts the overall effectiveness of the business itself are far more likely to ensure that the safety and health management system operates as needed.

• Integrating relevant safety and health aspects into management training is characteristic of the highest performing safety and health systems, and it contributes incrementally to excellence in these systems once the basic metrics are in place.

• This metric should be assessed primarily with interviews with managers, especially the top manager. These interviews should query the manager‘s familiarity and concern with the organization‘s current loss status, including both direct and indirect losses, and how the organization‘s record compares to the performance of other companies in the same business and about the same size. Managers in organizations with high safety and health performance should be aware of the financial incentive to continue performing well. Managers should appreciate the positive effect of safety and health on employee recruitment, turnover, absenteeism, productivity, and morale. Assessment and rating of this metric by interviews is inherently subjective. In making a judgment, the evaluator should consider what the interviews have revealed about both the degree to which management comprehends the business consequences of safety and health performance and the extent to which that understanding is held by the various individual managers.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 29, 38 and 46.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

a. The training covers the facility safety system (management concepts and philosophies, policy, goals and objectives, operations, tools and techniques, and system measurement).

b. The training covers management safety and health responsibilities.

c. The training system ensures that the knowledge and skills taught are consistently and are correctly applied by the managers.

d. The training system for all employees is regularly evaluated for effectiveness and is revised accordingly.

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40. Top management policy establishes clear priority for safety and health.

• For the purpose of evaluating this metric, no organizational safety and health system formally exists until it is established by top management policy. The purpose of a policy statement is to establish the priority of safety and health relative to other organizational goals such as profitability, productivity, and quality.

• The policy on safety and health issued by top management must be effectively communicated to middle managers, supervisors, and employees. In most cases, this requires a written policy statement. However, in some very small organizations (no more than 10 employees) where policy is normally set and effectively communicated by oral instruction, there may be no need for a written policy statement.

• The availability of a written statement establishes that policy has been set, if the statement has been developed or endorsed by top management. evaluator needs to conduct interviews to confirm whether a written policy has been effectively communicated. Verification of an unwritten policy depends totally on interviews.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 22, 25 and 26.

VI. Management Leadership

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

a. The safety and health policy is supported by senior management.

b. The goals are supported by senior management and can be easily explained or paraphrased by others within the workplace.

c. Members of the work force can give examples of management's positive leadership.

d. Members of the work force credit management with establishing and maintaining positive safety values in the organization through their personal example and attention to the behavior of others.

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41. Top management considers safety and health to be a "line" rather than a "staff" function.

• The term "line" refers to any position in the organization, such as the production supervisor, having authority over the work and personnel performing the work. It is authority legitimized by a "line" of delegation from the top manager.

• The term "staff" refers to any position, such as the safety manager, that provides advice and support to line managers. However, the term "staff" is not synonymous with the support function of the business unit. Maintenance, sales, and marketing, for example, are support functions of a business, but the supervisors of these functions are in line positions.

• It is a common practice in organizations to hold the safety director or safety committee responsible for safety and health performance. This practice frequently results in nominally responsible individuals who do not have the necessary authority to perform their assigned safety and health duties (metric 30). In addition, assignment of responsibility for safety and health protection to a single staff member, or even a small group, may leave other members feeling that someone else is taking care of safety and health problems.

• This metric calls for judgment regarding the attitude of top management. The surest way to get information to support such a judgment is to ask the top manager. Confirming or negating information can be obtained by interviews with other personnel and by any assessments performed for metric 26.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 26 and 42.

a. Production supervisors are held accountable for safety and health in their departments.

b. All personnel are held accountable for their safety and health behaviors.

c. Performance evaluations of individual supervisors take into account the safety and health performance of the employees under their control.

d. Safety and health staff are utilized as a resource.

e. Supervisors and employees take ownership for the safety in their work area.

f. Program elements are managed and administered by supervisors and employees.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

© OTN - 58 Metric Safety Management System Audit 63

42. Top management provides competent safety and health staff assistance to line managers and supervisors.

• Staff support encompasses a wide range of activities and assistance. For example, this metric may involve top management providing a part-time or full-time safety director, as appropriate. The existence of a competent full-time safety manager, empowered and positioned organizationally near top management, is one of the most certain indicators of an advanced safety and health system and of the top manager‘s commitment to its effectiveness. In larger organizations, this metric may concern the justified need for specialized professionals (such as a plant nurse or industrial hygienist).

The exact nature of the staff support provided by a top manager should fit the particular needs and circumstances of the organization. In organizations with a company trainer, the top manager may dedicate a portion of the trainer‘s time to safety and health training. Some organizations need secretarial support for their safety and health committee, and many organizations need clerical support for maintenance of Form 300 logs and filing First Reports of Injury.

• Providing competent safety and health staff support to line managers and supervisors is characteristic of the highest performing safety and health systems, and it contributes incrementally to excellence in these systems once the basic metrics, particularly metric 26 and metric 41, are in place.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 41.

a. Competent safety and health personnel are made available as a resource to assist line managers and supervisors.

b. Clerical support is available as needed for safety and health related functions.

c. Safety and health issues are a priority topic during production meetings.

d. Outside resources such as trade associations, private and public evaluators are obtained as necessary.

e. Safety and health staff are available as a resource

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

© OTN - 58 Metric Safety Management System Audit 64

43. Managers personally follow safety and health rules.

• The premise of this metric is that, if managers give high priority to safety and health protection in practice, others will see the example and follow. On the other hand, where there is lack of management involvement in this area, a written or spoken policy of high priority for safety and health will have little credibility. Managers who wear required personal protective equipment in work areas and follow all other established safety and health rules demonstrate such involvement.

• Assessing adherence or non-adherence to established safety and health rules by managers or workers requires information about actual behaviors. This information may be direct or indirect. Direct information is obtained by observation. However, the likelihood of a evaluator actually observing a manager following or breaking a safety rule during a facility walk-around is not great. When the observed manager is seen breaking a safety rule, the infraction is a negating cue. When the observed manager is seen following a rule, it is a confirming cue because no hazard was created when the rule was followed. Indirect information on rule adherence by managers can be obtained through interviews with workers who often observe whether these managers avoid hazards by following safety rules. Interviews with the managers, themselves, may also be revealing.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 12.

a. Managers throughout the organization consistently follow the rules and behavioral expectations set for others in the work force.

b. Members of the work force perceive management to be consistently setting positive examples and can explain why they hold these positive perceptions.

c. Managers give high priority to practicing safe and healthful behaviors and to personally leading by example.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

© OTN - 58 Metric Safety Management System Audit 65

44. Managers delegate the authority necessary for personnel to carry out their assigned safety and health responsibilities effectively.

• This metric can be assessed by interviews with managers and, perhaps, by review of documents. Interviews should reveal management‘s philosophy and practice regarding delegation of authority to personnel with assigned responsibilities for safety and health tasks. The evaluator should learn from these interviews whether or not management grants the necessary authority over the work, authority over resources, and authority over subordinates.

• Interview is the most likely source of information, documents that contain information on delegated authority may exist in larger organizations. These documents may include the organization chart, position descriptions, and the charter of the safety and health committee.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 30.

a. Those with safety and health responsibilities are given the authority to meet those responsibilities.

b. Delegated authority for safety and health is clearly assigned.

c. Position descriptions not only specifically state the responsibilities of the position, but state the authority granted to carry out those duties.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

© OTN - 58 Metric Safety Management System Audit 66

45. Managers allocate the resources needed to properly support the organization's safety and health system.

• Assessment of this metric can be achieved by interviews with managers and, perhaps, by review of documents. Interviews should reveal management‘s philosophy and practice regarding allocation of resources for safety and health.

• A confirming assessment cue is established when managers report current allocations for safety and health purposes and /or plans for future allocations to achieve safety and health

• improvements. Resources include personnel or personnel-effort, supplies, equipment, facilities, and services.

• Interview of the owner/operator is the most realistic source of top-down information on resource allocation in very small organizations. In larger organizations, a safety and health budget or identifiable safety and health components in the general budget may exist as a source of information on the resources allocated to safety and health.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 31.

a. Safety and health considerations are included in the budget.

b. Top management ensures adequate resources are provided to meet safety and health responsibilities.

c. Emergency equipment appropriate to the facility (including sprinkler systems, fire extinguishers, first aid kits, fire blankets, safety showers and eye washes, emergency respirators, protective clothing, spill control and clean-up material, chemical release computer modeling, etc. is installed or available.

d. Emergency equipment is distributed in sufficient quantity to cover anticipated hazards and risks, is operational, and is tested at regular intervals (at least monthly).

e. In addition to budgeting for safety, management allocates personnel, personnel-effort, supplies, equipment, facilities, and services for safety.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

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46. Managers ensure that appropriate safety and health training is provided.

• This metric can be assessed by linking it to hazard-related information through metric 29.

• Assessment of this metric can be achieved by interviews with managers. Review of the six training metrics (metrics 34 through 39) provides the evaluator with specific information and issues to be addressed by the managers during interview.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 29, 34, 35, 36, 37, 38 and 39.

a. An employee safety and health training program exists at the facility.

b. The training covers all legally-required subjects.

c. Training policies and procedures indicate that legally required elements are the minimum acceptable levels of training.

d. Training procedures cover behavioral-based safety performance activities.

e. Management ensures the training is specific and applicable to the work task.

f. Managers use the annual program reviews to identify needed training.

g. Management performs follow-up to training to ensure the training is appropriate, understood, and being used, and driving the improvements desired.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

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47. Managers support fair and effective policies that promote safety and health performance.

• Assessment of the metric can be achieved by interviews with managers and, perhaps, by document reviews. Interviews should reveal management‘s philosophy and practice regarding motivation of performance for safety and health. This includes both the positive and negative aspects of motivation.

• In very small organizations, interview of the owner/operator is the most realistic source of information on how personnel are motivated for safety and health. In larger organizations, however, there may be a written disciplinary policy, personnel evaluation forms, position descriptions, and written policies on pay raises, bonuses, and promotions. Review of such documents should provide information to assess this metric.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 32 and 33.

a. The employer provides opportunities and mechanism(s) for employees to influence Safety and Health Program design and operation.

b. Safety and health policies promote positive behaviors while correcting deficient behaviors.

c. Where applicable, written policies spell out rewards for safe and healthful work activities.

d. Policies are established which link pay raises, bonuses, and promotions to personnel evaluations.

e. Position descriptions are developed to assist employees in their understanding of their responsibilities.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

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48. Top management is involved in the planning and evaluation ofsafety and health performance.

• The term "involved" means that the top manager is engaged at some appropriate level in organizational planning and evaluation relative to workplace safety and health.

• Some top managers may personally participate in such planning and evaluation activities. This level of involvement would be especially appropriate for the owner/operator of a very small business. In larger organizations, the top manager may simply receive and review reports and make decisions concerning recommendations. In any event, all top managers should be familiar with the safety and health planning and evaluation efforts undertaken by their organizations. This includes awareness of what has been done, who did it, what were the results, and what actions were taken in response.

• Review of the six planning and evaluation metrics (metrics 20 through 25) provides the evaluator with specific information and issues to be discussed with the top manager during interview.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 20, 22 and 25.

a. Top management is routinely involved in activities related to planning and evaluating facility safety and health performance.

b. Top management is held accountable for facility safety performance though their own performance evaluations.

c. Top management is familiar with and understands the organization‘s planning and evaluation efforts.

d. Members of the work force perceive management to be exercising positive leadership.

e. Top management is involved in regularly evaluating training for effectiveness.

Comments:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

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49. Top management values employee involvement and participationin safety and health issues.

• This metric calls for a judgment on the part of the evaluator regarding an attitude of top management. The surest way to get information to support such a judgment is to ask the top manager. The top manager should be able to describe how employee input on safety and health issues is solicited, and how voluntary participation in safety and health efforts of the organization is encouraged.

• Information obtained from interview with the top manager should be confirmed or negated by interview of other personnel and by any assessments performed for metrics in the Employee Participation section (metrics 50 through 58).

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 50, 51, 52, 53, 54, 55, 56, 57 and 58.

a. Top management actively encourages employees to be involved in safety and health activities.

b. Management can describe available avenues for employees to participate in safety and health activities.

c. Participation in the Safety Committee is respected and valued in the organization.

d. Supervisors and managers actively encourage use of the employee involvement systems and employees feel comfortable using those systems in all situations.

e. Several avenues have been established by upper management to solicit and gather employee input.

Comments:

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50. There is an effective process to involve employees in safety and health issues.

VII. Employee Participation

Comments:

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a. There are multiple avenues for employee participation.

b. The avenues are well-known, understood, and utilized by employees.

c. The avenues and mechanisms for involvement are effective in reducing accidents and enhancing safe behaviors.

d. Data related to key elements of safety and health performance are accumulated and displayed within the workplace to inform all personnel of progress being made.

e. Employees throughout the company are aware of the methods to involve employees.

f. There are open lines of communication between workers and forum meetings.

g. A Safety Committee is in place and functional.

h. That Safety Committee is structured in accordance with the Safety Committee rules.

i. There are mandatory safety meetings.

j. There is an open door policy.

k. There is a suggestion box type program.

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• Assessment of this metric should begin with interviews with management or staff to determine what, if any, process has been established for employee input on safety and health issues. An effective process for employee involvement should provide for (1) the solicitation of input, (2) the receipt of input, and (3) the acknowledgment of input. The established process may provide a single way or multiple avenues for soliciting, receiving, and acknowledging employee inputs.

Common methods for soliciting input are postings, paycheck flyers, e-mail postings, chain-of-command distributions, and company-wide meetings. Common standing methods of receiving employee inputs on safety and health issues are chain-of-command reporting, managerial open-door policies, suggestion boxes, organizational e-mail systems, and direct reporting to the safety director or safety and health committee.

• A highly effective way of both soliciting and receiving employee input is to ensure that employees are represented in small group meetings where safety and health issues are discussed. Safety committees are one example of this approach. In evaluating the process that provides acknowledgment, it is important to remember that any acknowledgment message should not only confirm that the employee input was received, but it should also provide feedback to the employee concerning how the information or suggestion was used. There is no single best way to achieve employee input on safety and health issues.

• Much depends on the culture of the organization and the management styles of the managers. The best system is the one that works for the organization.

• Information obtained in assessing metrics 51 through 53 (which pertain to employee involvement in specific safety and health issues) may also be relevant to the assessment of this metric.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 49, 51, 52, 53, 54, 55, 56, 57 and 58.

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51. Employees are involved in organizational decision-making in regard to safety and health policy.

• The term "involved" means that the thoughts, suggestions, concerns, objections, or support of employees concerning safety and health policy issues are sought, obtained, and considered by policy makers before decisions are made. It does not mean, or suggest, that employees should be allowed to usurp the decision-making authority that is vested in management.

• Assessment of this metric should begin with interviews of management, particularly the top manager. During these interviews, the evaluator should ask the managers to identify major safety and health policies that have been adopted by the organization and describe how employee involvement influenced these decisions. The top management policy setting safety and health as an organizational value and any policies regarding positive or negative motivations for safety and health should be included in the discussion.

• If the interviews with managers reveal effective employee involvement in policy-making decisions, each example of such involvement may support a confirming cue for evaluating this metric. Negating cues are indicated where there is evidence that policy-making lacks employee involvement. Confirming or negating information may be obtained for both types of cues by interviews with other personnel.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 40.

a. Employees accept personal responsibility for ensuring a safe and healthful workplace.

b. Employees have a substantial impact on the design and operation of the Safety and Health Program.

c. Employees have significant input to the rules.

d. Safety Committee members work with management to review and revise the safety and health policies.

e. Employees are involved in annual program reviews.

f. Employees are involved in change analysis.

Comments:

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52. Employees are involved in organizational decision-making in regard to the allocation of safety and health resources.

• The term "involved" means that the thoughts, suggestions, concerns, objections, or support of employees regarding allocation of safety and health resources are sought, obtained, and considered before decisions are made. It does not mean, or suggest, that employees should be allowed to usurp the decision-making authority that is vested in management.

• Assessment of this metric should begin with interviews of management, particularly the top manager. During these interviews, the evaluator should ask the managers to identify resource allocations for safety and health and describe how employee involvement influenced these decisions. The discussion might include allocation of all or any of the following resources: personnel, personnel-effort, supplies, equipment, facilities, or services.

• If the interviews with managers reveal effective employee involvement in resource allocation for safety and health, each example of such involvement may support a confirming cue for evaluating this metric. Negating cues are indicated where there is evidence that the decisions surrounding safety and health resource allocations lack employee involvement. Confirming or negating information may be obtained for both types of cues by interviews with other personnel.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 31 and 45.

a. Employee input is sought in regard to the future allocation of safety and health resources.

b. The Safety Committee is given the opportunity to provide feedback on planned distribution of safety and health assets.

c. The resource allocation goes beyond just budget, and includes allocation of personnel, supplies, equipment, facilities or services.

Comments:

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53. Employees are involved in organizational decision-making in regard to safety

• The term "involved" means that the thoughts, suggestions, concerns, objections, or support of employees concerning issues related to safety and health training are sought, obtained, and considered before decisions are made. It does not mean, or suggest, that employees should be allowed to usurp the decision-making authority that is vested in management.

• Assessment of this metric should begin with interviews of management, particularly the top manager. During these interviews, the evaluator should ask the managers to identify safety and health training decisions that have been made by the organization and describe how employee involvement influenced these decisions. Training decisions include decisions to provide training as well as decisions not to provide training. Training decisions may involve the training topic, who will deliver the training and how, who will receive the training, and when and where.

• If the interviews with managers reveal effective employee involvement in safety and health training decisions, each example of such involvement may support a confirming cue for evaluating this metric. Negating cues are indicated where there is evidence that the decisions surrounding safety and health training lack employee involvement. Confirming or negating information may be obtained for both types of cues by interviews with other personnel.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 29, 34, 35, 46 and 56.

a. Employees are provided with the opportunity to develop and provide training to peers.

b. Employees have the opportunity to evaluate and update training programs.

c. The employer actively encourages employees to be involved in developing and delivering training plans for the facility.

Comments:

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54. Employees participate in hazard detection activities.

Comments:

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a. Employees actively participate and contribute to discussions of hazard correction activity (generally at crew meetings).

b. Employees have input in the development of inspection procedures and employee reporting systems.

c. The hazard detection system provides rapid and regular feedback to employees.

d. Employees are involved in the analysis of the job, process, or phase of activity which applies to their assigned work.

e. All members of the work force have ready access to and can explain the key elements of the hazards analysis which applies to their work.

f. Personnel at all levels of the organization are routinely involved in safety and health inspections.

g. Employees are active participants in the determination of collection methods, collection, analysis, and intervention selection for hazard detection activities.

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• The term "participate" means that employees are actively engaged in hazard detection activities, preferably on a voluntary basis.

• Hazard detection activities are the subject of those metrics in the Hazard Anticipation and Detection section (metrics 1 through 10). Assessment of these metrics may reveal information that can support an assessment of the present metric also.

• Assessment of this metric by interviews can proceed in two ways. The first way is the more systematic approach that focuses on employee participation in a specific hazard detection activity such as inspections. In this case, managers, supervisors, or workers are asked to identify who conducts inspections. In the second approach, selected employees are asked to identify their own participation in hazard detection activities. This approach is particularly suited to activities, such as hazard reporting, that are random in nature.

• A combination of the approaches will provide the best overall assessment of the metric. Each example of employee participation in hazard detection revealed by either interview method constitutes a confirming cue for assessing this metric. However, negating cues are established only where employee participation in a hazard detection activity is both lacking and appropriate. For example, expert analysis activities may not require employee participation.

• Finally, there can be no employee participation if needed hazard detection activities are not being performed at all. These situations represent not only operational deficiencies, but also lost opportunities to stimulate employee participation, and should be considered a strong negating cue for assessing this metric.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 1 thru 10, 21 and 49.

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55. Employees participate in hazard prevention and control activities.

• The term "participate" means that employees are actively engaged in hazard prevention and control activities, preferably on a voluntary basis.

• The activities covered in this metric are the subject of those metrics in the Hazard Prevention and Control section (metrics 11 through 19). Assessment of these metrics may reveal information that can support an assessment of the present metric also.

• Assessment of this metric can be achieved through interviews with managers, supervisors, and workers. Managers or supervisors can be asked to give examples of employee participation in organizational projects such as designing engineered safety and health controls or establishing safe work practices. Interviews with workers can be used to confirm, negate, or expand on the information provided by managers and supervisors. Worker interviews may also reveal the degree to which individuals endorse and adhere to the company‘s established safety and health protections.

• A confirming cue is established for assessing this metric by each example of employee participation in a hazard prevention or control project and by each interview that reveals active commitment to safety and health protections. Negating cues follow from worker interviews that indicated these individuals are not actively committed to established safety and health protections, and from evidence of projects or other organizational efforts addressing safety and health protections that should have, but did not, include employee participation.

• Evidence that workers voluntarily take personal initiative to prevent risk to themselves and co-workers suggests a strong confirming cue for this metric.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 11 thru 19, 21, 23 and 49.

Comments:

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a. Members of the affected work force actively participate in the comprehensive hazard review process.

b. Safety Committee members evaluate and/or orchestrate hazard prevention and control activities.

c. Workers have authority and feel free to refuse unsafe work.

d. Employees are involved in developing hazard prevention strategies and activities.

e. The facility actively supports and values employee participation in hazard prevention and control activities (such as control hierarchy, safe work rules and procedures, program evaluation, PPE usage, emergency planning and facility maintenance).

f. Employees are encouraged and do take action on self-correcting or minimizing risk.

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56. Employees participate in the safety and health training of co-workers.

• Employee participation in safety and health training of co-workers is characteristic of the highest performing safety and health systems, and it contributes incrementally to excellence in these systems once the basic metrics, particularly metrics 34 and 35, are in place.

• It is unreasonable to expect that every worker in an organization be engaged in some sort of co-worker training, and such an expectation must be excluded in assessment of this metric.

• In most organizations, there are individuals who have the ability and desire (or at least willingness) to help in the development of their co-workers. These individuals often make excellent instructors because of their experience-based credibility. When the subject matter is safety and health, the visibility of an employee instructor adds to the safety and health culture of the organization.

• Mentoring by an experienced employee can be an especially effective way to instill safety and health in a new employee. The mentoring and coaching activities that take place in an organization are often unofficial and informal. For this reason, interviews with employees are needed to uncover the true extent of employee-provided guidance for safety and health that may be taking place. Confirming cues for this metric are suggested when the evaluator ascertains that employees are participating in formal training of their co-workers on safety and health issues.

• Confirming cues are also indicated when the evaluator determines that employees are engaged in formal or informal mentoring or coaching of new workers with regard to safe and healthful work practices. However, demonstrating a negating cue for this metric will be difficult because the decision to participate in training, mentoring, or coaching usually rests with the individual employees and not with the organization.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 29, 34, 35 and 49.

Comments:

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a. Employees are involved in the planning and preparing of training topics.

b. Employees conduct training classes.

c. Employees are involved in evaluating and updating training as needed.

d. Employees mentor with each other, using existing policies such as JHA or process hazard reviews.

e. Employees provide on-the-job training and coaching to co-workers.

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57. Employees participate in safety and health planning activities.

• The term "participate" means that employees are actively engaged in safety and health planning activities.

• metric 22 and metric 23 are also concerned with safety and health planning activities. Assessment of these metrics may reveal information relevant to assessment of this metric as well.

• Assessment of this metric can be achieved through interviews with managers, supervisors, and workers. Managers and supervisors can be asked to identify the major safety and health planning activities undertaken by the organization and describe how employees participate in these activities. The process of setting the organization‘s safety and health goal and supporting objectives and the process used to develop an action plan should be included in the discussion. If any safety and health benchmarking activities have been undertaken by the organization, these activities should also be discussed in the interviews. Information obtained from interviews with managers or supervisors can be confirmed, negated, or expanded through interviews with other personnel.

• Each example, derived from the interviews, of employee participation in safety and health planning activities constitutes a confirming cue for assessment of this metric. Each example of a safety and health planning activity conducted without employee participation is a negating cue. When an organization does not conduct the activities necessary to produce the critical safety and health planning products - goal, objectives, and action plan - this is a sure indication that employees are not participating in planning activities, and is a strong negating cue for assessing this metric.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 20 thru 25 and 49

Comments:

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a. Employees are active participants in the action planning process.

b. Workers are allowed access to information needed to make informed decisions.

c. Employees are active participants in evaluating the facility safety and health planning activities.

d. Company goals, objectives, and action plans are developed with employee involvement.

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58. Employees participate in the evaluation of safety and health performance.

• metrics 20, 21, 24, and 25 are also concerned with evaluation of organizational safety and health performance. Assessment of these metrics may yield information relevant to assessment of this metric as well.

• Assessment of this metric can be achieved through interviews with managers, supervisors, and workers. Managers and supervisors can be asked to identify the major safety and health evaluation activities undertaken by the organization and describe how employees participate in those activities. The annual comprehensive review, review of OSHA-mandated programs, and analyses of injury/illness data or hazard incidence data are examples of evaluation activities that should be discussed. Information obtained from interviews with managers and supervisors can be confirmed, negated, or expanded through interviews with other personnel.

• Each example, derived from the interviews, of employee participation in safety and health evaluation activities constitutes a confirming cue for assessment of this metric. Each example of a safety and health evaluation activity conducted without employee participation is a negating cue. When an organization does not conduct evaluations of its safety and health performance, this is a sure indication that employees are not participating in evaluation activities and a strong negating cue for assessing this metric.

• Deficiencies found in this metric may also indicate problems may exist in these metrics: 20, 21, 24, 25 and 49.

a. The Safety Committee makes an annual review of the Safety and Health Program.

b. Employees are regularly involved in evaluating the safety policies for effectiveness and revising them accordingly.

c. Employee input is considered an important part of supervisory and management safety performance reviews.

d. As part of an annual review system, employees are interviewed or surveyed to gather their input.

Comments:

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