Evaluating and Improving your OSHA Programs

`By?STEVE?SAYER

“Paper doesn’t save people - people save people”

?– Dan Petersen, Safety Professional

Dan Petersen's remarkable career in occupational safety and health spanned more than 50 years as he penned award-winning articles and books such as his sublime 5-Star Rated - "Safety Management: A Human Approach," (pictured above), to educate countless Safety Professionals while developing one of the industry's original 'Company Safety Culture Measurement' techniques.

Save your pennies, nickels, dimes and quarters and buy a used copy on Amazon.

"Safety Management: A Human Approach," is worth every Lincoln penny.

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(The views and opinions expressed in this blog are strictly those of the author.)

There are a number serious safety and health hazards in the meat / poultry industry.

These hazards include exposure to high noise levels, dangerous equipment, slippery floors, musculoskeletal disorders, hazardous chemicals, including anhydrous ammonia when used as a refrigerant.

Musculoskeletal disorders comprise a large part of these serious injuries and continue to be common among meat packing workers - especially in the poultry sector.

In addition, meat packing workers can be exposed to biological hazards associated with *handling live animals (*zoonotic diseases) and exposures to feces and blood which can increase their risk for many diseases.

Common hazard control measures needed in the meat industry.

I included past LinkedIn blogs from my LinkedIn page that are germane to the recognized OSHA hazards that are highlighted below and are specific in details - including - several meatingplace.com references.`

Implementing an effective ergonomics program (when time permits, see OSHA's?Ergonomics?page),

Implementing an effective?hearing conservation program, when applicable - when noise exposure is at or above 85 decibels over an 8-hour time-weighted average.

Implementing design and maintenance of electrical systems and an effective?lockout/tagout program?to prevent injury from accidental start-up of machinery during pre-operational inspection with USDA, maintenance activities, sanitation and 3rd party contractors when applicable.

Providing required?personal protective equipment (PPE).

Guarding?dangerous equipment.

Following OSHA's?process safety management?standard to protect workers from accidental leaks of anhydrous?ammonia,

Incorporating engineering controls, such as improving sanitation and?ventilation?measures, to protect workers from chemical - and - biological hazards.

Maintaining?walking/working surfaces?to prevent slips, trips and falls.

Implementing OSHA's?Hazard Communication Standard?requirements and ensuring?workers are not exposed to unsafe levels of hazardous chemicals,

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Following?OSHA standards?that require that exit doors are not blocked and not locked while employees are in the building. Employees must be able to open an exit route door from the inside at all times without keys, tools or special knowledge.

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Having in place a drug testing policy program before employees are hired and whenever an injury occurs.

A must.

It's 2023.

Involve a proven labor attorney to ensure state and federal laws are in-line to your drug testing policies in the state or states your company resides in.

An updated Company Policy Manual.

A Company Policy Manual is your company's Foundation for ALL of your operations / programs - and then some.

In addition, a Company Policy Manual must be in a language that everyone can understand.

Selected food and beverage companies do not have in place Company Policy Manuals - while selected others fail to incorporate updates into their Company Policy Manuals.

Those that do have Company Policy Manuals should include individual sub-chapters covering / governing industrial safety, food safety - and - customer driven GFSI.

Why?

Why do GFSI accredited food and beverage companies have updated Employee Policy Manuals?

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Whenever a safety program has been established, it must be evaluated initially to validate that its been implemented and is working as authored and intended.

Just like USDA themed HACCP systems, establishments should at the very least - annually reassess what is and isn’t working and determine whether their OSHA programs are collectively on track to achieve planned, documented / dated / and signed company industrial safety goals.

If companies are truly safety orientated there should be multiple documented reviews / amendments of safety programs each calendar year.

Similar to GFSI - as well.

Whenever such assessments identifies 'opportunities' to improve programs, company's must make adjustments, monitor, and then document how the program performs.

"If you said you did it - you didn't do it. However, if you said you did it, and you documented it, signed it, and dated it - with always at least one (1) witness - then indeed - you did it."

Sharing the results of monitoring and evaluation with ALL employees shall help drive - 'Continuous - Improvements' - resulting unequivocally with a safer and healthier workplace - and - a more cohesive safety culture that employees have already bought into.

Documented program evaluations and improvements must include:

• Establishing, reporting and tracking targets that indicate whether programs are making progress.
• Evaluating the program initially and periodically eschewing shortcomings and opportunities for improvements.
• Providing the ways and means for workers to participate in program evaluations and improvements.
• Investigations of each "near miss" as if they really were bona fide injuries.

Monitoring performance and progress

The first step in monitoring is to define indicators that will help track performance and progress.

Next, employers, managers, supervisors, and workers need to establish and follow procedures to collect, analyze, and review performance data.

Both -?lagging?and leading?indicators - are key tools for monitoring progress.

Lagging indicators generally track worker exposures and injuries that have already occurred.

Leading indicators track how well various aspects of the program have been implemented and reflect steps taken to preclude injuries or illnesses before they occur.

Carbon copy with your HACCP system - and GFSI.

Develop and track lagging safety and health indicators, such as:

• Number and severity of injuries and illnesses by reviewing past OSHA 300 Logs.
• Results of worker exposure monitoring that show that exposures are hazardous.
• Workers compensation data, including claim counts, rates, and associated cost.

Develop and track leading indicators, such as:

• Level of worker participation in program activities.
• Number of employee safety suggestions proffered each month. Incentives for offering safety suggestions - is - well - a suggestion to contemplate.
• Number of hazards, near misses and first aid cases reported.
• Amount of time taken to respond to reports.
• Number and frequency of management walkthroughs.
• Number and severity of hazards identified during inspections.
• Number of workers who have fully completed required safety and health training.
• Timely completion of corrective actions after a workplace hazard is identified or an incident occurs.
• Timely completion of planned preventive maintenance activities involving equipment and logging it.
• Worker opinions about program effectiveness obtained from a safety climate or safety opinion survey.
• ?Analyzing performance indicators and evaluate progress over time.

The frequency of program evaluations varies depending on changes in OSHA standards - including too - new UL approved equipment, etc., that can bring new hazards; the scope, complexity, and maturity of the program - and - the types of hazards it must control, must be in place.

• Verify that the core elements of each safety program have been fully implemented.
• ?Again - involve workers in all aspects of program evaluations, including: reviewing information such as incident reports and exposure monitoring; establishing and tracking performance indicators; and 'opportunities' to improve the program.
• ?Review the results of any compliance audits to confirm that any program shortcomings are being identified. Validate that actions are being taken that will prevent recurrence - if germane.

Correct program shortcomings and identify opportunities towards continuous improvements

Whenever 'opportunities' are identified - employers in coordination with supervisors, managers and workers must take prompt action to correct the problem and prevent future occurrences.

If program shortcomings are identified - then corrective actions are needed to correct them:

Collect input from managers, workers, supervisors on how the program(s) can be improved.

• Determine whether changes in equipment, new equipment, infrastructure, materials, key personnel or work practices trigger any need for changes in the program.
• Determine whether performance indicators and goals are still relevant and, if not, how updating them to be more effectively - all with the purpose of driving continuous - improvements in workplace safety.

NAICS Code: 3116?Animal Slaughtering and Processing

Establishment Size: ALL sizes

Listed below are OSHA standards which were cited by?OSHA?for the 3116 NAICS Code regarding Animal Harvesting (slaughtering) establishments that covers the time period of Oct. 2021 through Sept. 2022.

Such a list, as cited below, clearly reflects the common safety hazards of your specific assigned NAICS code operations.

For more information, see?definitions.

As the NAICS Code for Animal Harvesting Establishments clearly indicates that lockout / tagout / blockout (LOTOBL) was Number #1 - again - with 61 citations cited during 29 inspections.

However, these 61 company citations does not truly represent the true failure of implementing LOTOBO - despite the industry at hand.

The 61 violations cited during 29 inspections are the ones that got caught with their hand in OSHAs cookie jar.

Trust me.

The sheer lack of Top Management commitment on down the management chain regarding industrial safety is a large contributor and a common denominator of why LOTOBL and other industrial safety programs fail.

SPECIAL NOTE: Since the last century, FSIS Directive 4791.11 dated 06/02/1997 - has mandated that LOTOBO is in place by the USDA prior to the inspectors performing pre-operational inspection every production day.

I liked and applauded that FSIS LOTOBO Directive. Others bitched and complained back then - as the Directive made its way through the usual Federal Register bows and arrows process and became law.

Without any doubt - the 1997 USDA / FSIS LOTOBO Directive has avoided / truncated many injuries, amputations, and deaths at meat / poultry establishments.

Industrial safety programs are easy to scribble up - but their proper implementation and monitoring thereafter with top management 100% behind it - is where the attention is needed most - and unfortunately is not always present.

The www has generic templates for any OSHA safety program you may be lacking.

Same with HACCP and GFSI.

You can't have a clean plant unless it's a safe plant - and you can't have a safe plant unless it's a clean plant.

XTRA XTRA XTRA !

To change a culture, says Petersen, you have to start by carefully assessing what things are like at the time.

That means asking employees how management actions and decisions define the work environment. Then, management needs to decide where it wants to go and the steps that will take it there.

Management needs to set up "accountability systems for activities and actions at each level of management," he said. When managers have demonstrated to employees that they are serious about safety, they can then go to the employees and ask "Will you help us?"

He notes: "It"s not them versus us anymore. It's a team. We're doing this together."

"Interest in behavioral safety has paled and some are discovering the importance of management and culture," Petersen asserted during a 2003 presentation.

"But even in an environment with good management and a good culture, people are still being injured due to human error, their own or someone else's. We in safety need to be able to explain why human error happens and what it is. That knowledge will open up the next frontier in safety management."