NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only. |
Program Evaluation Profile (PEP)
CAUTION: The following excerpts are from
the OSHA Notice CPL 2, distributed on August 1, 1996, by the Directorate of Compliance Programs.
This Program Evaluation Profile (PEP) notice was cancelled on November 15,
1996. This document is provided as an EXAMPLE of an auditing tool to assist in the
evaluation of a Safety and Health Program.
This notice establishes policies and procedures for the Program Evaluation
Profile (PEP), Form OSHA-195, which is to be used in assessing employer safety and
health programs in general industry workplaces.
- OSHA Instruction CPL 2.103, September 26, 1994,
Field Inspection Reference Manual (FIRM).
- OSHA Instruction
CPL
2.111 [CPL 02-00-111], November 27, 1995, Citation Policy for Paperwork and Written Program
Requirement Violations.
- Safety and Health Program Management Guidelines, Federal Register,
January
26, 1989, Vol. 54, No. 16, pp. 3904-3916.
OSHA's assessment of safety and health conditions in the workplace depends
on a clear understanding of the programs and management systems that an employer is using for
safety and health compliance. The Agency places a high priority on safety and health programs
and wishes to encourage their implementation.
- Evaluation of Workplace Safety and Health Programs. In the
past, compliance officers have evaluated employers' safety and health programs, but
those evaluations have not always required thorough documentation in case files. More
detailed evaluation and documentation is now required to meet the Agency's need to
assess such programs accurately and to respond to workplace compliance conditions
accordingly.
- Safety and Health Program Management Guidelines. In January
1989, OSHA published its voluntary Safety and Health Program Management Guidelines (Federal
Register,
Vol.
54, No. 16, pp. 3904-3916; hereinafter referred to as the 1989
Guidelines), which have been widely used in assessing employer safety and health
programs.
- The PEP.
Appendix A of
this directive contains the Program Evaluation Profile (PEP),
Form
OSHA-195, a new program assessment instrument.
- The PEP was developed by representatives of OSHA's National Office and field
staff in a cooperative effort with the National Council of Field Labor Locals (NCFLL).
- The PEP is presented in a format that will enable the compliance officer to
present information about the employer's program graphically. While the PEP is
compatible with other evaluation tools based on the 1989 Guidelines, it is not
the only such tool that will be used. It is not a substitute for any other kinds
of program evaluations conducted by OSHA, such as those that are required by
OSHA standards. Program evaluations, such as those required by the
Process
Safety Management Standard, the
Lockout/Tagout
Standard, the
Bloodborne
Pathogens Standard, and others, are considered to be an integral part of a
good safety and health program if the workplace is covered by those standards,
and therefore must be included in the PEP review.
- Instructions for use of the PEP are found in
"Using the PEP" section of this
notice.
- The PEP shall be completed for general industry inspections and compliance-related
activities that include an evaluation of an employer's workplace safety and health
programs.
- The PEP is an educational document for workers and employers, as well as a
source of information for OSHA's use in the inspection process.
- A new PEP need not be completed when a PEP has recently been done for a specific
workplace and the compliance officer judges that no substantive changes in the
employer's safety and health program have occurred.
- In multi-employer workplaces, a PEP shall be completed for the safety and health
program of the host employer. This PEP will normally apply to all subordinate
employers onsite, and individual PEPs need not be completed for them. The
compliance officer may, however, complete a PEP for any other employers onsite
for which he/she believes it is appropriate; e.g., where a subcontractor's
program is markedly better or worse than that of the host employer.
- The PEP shall be used in experimental programs and cooperative compliance
programs (e.g., Maine 200) that require evaluation of an employer's safety and
health program, except where other program evaluation methods/tools are
specifically approved.
- The compliance officer's evaluation of the safety and health program contained in the
PEP shall be shared with the employer and with employee representatives, if any, no
later than the date of issuance of citations (if any).
- The preliminary assessment from the PEP shall be discussed with the employer in
the closing conference; the employer shall be advised that this assessment may
be modified based on further inspection results or additional information
supplied by the employer.
- The compliance officer's evaluation of the safety and health program may be
shared with the employer and with employee representatives in the following
ways:
- Giving a copy of the completed PEP to the employer and employee
representatives.
- Giving a blank PEP to the employer and employee representatives, who may
complete it themselves based on compliance officer comments and their
own knowledge.
- Providing only verbal comments and recommendations to the employer and
employee representatives.
- Providing written comments and recommendations (e.g., in a letter from
the Area Director) to the employer and employee representatives.
- Because the PEP represents the compliance officer's evaluation of an employer's
worksite safety and health program at the time an inspection was conducted, the
scoring shall normally be modified only by the inspecting compliance officer,
except in the case of clear errors (e.g., computation).
The PEP will be used as a source of safety and health program evaluation
for the employer, employees, and OSHA.
- Gathering Information for the PEP begins during the opening
conference and continues through the inspection process.
- The compliance officer shall explain the purpose of the PEP and obtain
information about the employer's safety and health program in order to make an
initial assessment about the program.
- This initial assessment shall be verified--or modified--based on information
obtained in interviews of an appropriately representative number of employees
and by observation of actual safety and health conditions during the inspection
process.
- If the employer does not wish to volunteer the information needed for the PEP,
the compliance officer shall note this in the case file but shall not press the
issue. The benefits of a PEP evaluation shall, however, be explained.
- Recording the Score. The program elements in the PEP
correspond generally to the major elements of the 1989 Guidelines.
- Elements. The six elements
to be scored in the PEP are:
-
Management
Leadership and Employee Participation
-
Workplace Analysis
-
Accident and Record
Analysis
-
Hazard Prevention
and Control
-
Emergency Response
-
Safety and Health
Training
- Factors. These elements [except for (6), Training] are
divided into factors, which will also be scored. The score for an element will
be determined by the factor scores. The factors are:
- Management Leadership and Employee Participation.
- Management leadership.
- Employee participation.
- Implementation [tools provided by
management, including budget, information, personnel, assigned
responsibility, adequate expertise and authority, line
accountability, and program review procedures].
- Contractor safety.
- Workplace Analysis.
- Survey and hazard analysis.
- Inspection.
- Reporting.
- Accident and Record Analysis.
- Investigation of accidents and near-miss incidents.
- Data analysis.
- Hazard Prevention and Control.
- Hazard control.
- Maintenance.
- Medical program.
- Emergency Response.
- Emergency preparedness.
- First aid.
- Safety and Health Training (as a whole).
- Scoring. The compliance officer shall objectively
score the establishment on each of the individual factors and elements after
obtaining the necessary information to do so. (See 'Using the PEP' 5., below.)
These shall be given a score of 1, 2, 3, 4, or 5.
-
Appendix B of this notice
contains the PEP Tables, which provide verbal
descriptors of workplace characteristics for each factor for each of the
five levels. Compliance officers shall refer to these tables as
appropriate to ensure that the score they assign to a factor corresponds
to the descriptor that best fits the worksite.
NOTE: The descriptors are intended as brief
illustrations of a workplace at a particular level. In exercising their
professional judgment, compliance officers should proceed with the
understanding that the descriptor that "best fits" will not
necessarily match the workplace exactly or in literal detail.
- Determine scores for each of the six elements as follows:
- The score for the "Management Leadership and Employee
Participation" element shall be whichever is the lowest of
the following:
- The score for the "Management Leadership"
factor.
- The score for the "Employee Participation"
factor.
- The average score for all four factors.
NOTE: The factors of
"Management Leadership" and "Employee
Participation" are given greater weight because
they are considered the foundation of a safety and
health program.
- For the sixth element, Training,
just determine the level 1-5 that best fits the worksite and
note it in the appropriate box on the PEP.
- For each of the other four elements, average
the scores for the factors.
- In averaging factor scores, round to
the nearest whole number (1, 2, 3, 4, or 5). Round up from
one-half (.5) or greater; round down from less than one-half
(.5).
- If the employer declines to provide pertinent information regarding one
or more factors or elements, a score of 1 shall be recorded for the
factor or element.
- If the element or factor does not apply to the worksite being inspected,
a notation of "Not Applicable" shall
be made in the space provided. This shall be represented by "N/A"
or, in IMIS applications, "0." This
shall not affect the score.
- Overall Score. An "Overall Score" for the
worksite will be recorded on the score summary. This will be the average
of the six individual scores for elements, rounded to the nearest whole number
(1, 2, 3, 4, or 5). Round up from one-half (.5 )or greater; round
down from less than one-half (.5).
EXAMPLE: A PEP's element scores are:
2 |
2 |
13 |
= |
2.16 |
= |
2 |
1 |
6 |
3 |
2 |
+3 |
13 |
- Rating and Tracking. The six individual element
scores, in sequence (e.g., "2-2-1-2-3-1") will constitute a
"rating" for purposes of tracking improvements in an establishment's
safety and health program, and shall be recorded.
- Program Levels. The Overall Score on the PEP constitutes the
"level" at which the establishment's safety and health program is scored. Remember:
this level is a relatively informal assessment of the program, and it does not represent
a compliance judgment by OSHA--that is, it does not determine whether an employer
is in compliance with OSHA standards. The following chart summarizes the levels:
Score |
Level of Safety and Health Program |
5 |
Outstanding program |
4 |
Superior program |
3 |
Basic program |
2 |
Developmental program |
1 |
No program or ineffective program |
- Specific Scoring Guidance. The following shall be taken into
account in assessing specific factors:
- Written Programs. Employer safety and health programs
should be in writing in order to be effectively implemented and communicated.
- Nevertheless, a program's effectiveness is
more important than whether it is in writing. A small worksite may well
have an effective program that is not written, but which is well
understood and followed by employees.
- In assessing the effectiveness of a safety and health program that is
not in written form, compliance officers should follow the general
principles laid out in OSHA Instruction
CPL
2.111 [CPL 02-00-111], "Citation Policy for Paperwork and Written Program
Requirement Violations." That is:
- An employer's failure to comply with a paperwork requirement is
normally penalized only when there is a serious hazard related
to this requirement.
- An employer's failure to comply with a written program
requirement is normally not penalized if the employer is
actually taking the actions that are the subject of the
requirement.
- Thus, compliance officers should follow the general principle that
"performance counts more than paperwork." Neither the 1989
Guidelines nor the PEP is a standard; neither can be enforced through
the issuance of citations. In using the PEP, the compliance officer is
responsible for evaluating the employer's actual management of safety
and health in the workplace, not just the employer's documentation of a
safety and health program.
- Employee Participation.
- Employee involvement in an establishment's safety and health program is
essential to its effectiveness. Thus, evaluation of safety and health
programs must include objective assessment of the ways in which workers'
rights under the OSH Act are addressed in form and practice. The PEP
Tables include helpful information in this regard.
- Employee involvement should also include participation in the OSHA
enforcement process; e.g., walkaround inspections, interviews, informal
conferences, and formal settlement discussions, as may be appropriate.
Many methods of employee involvement may be encountered in individual
workplaces.
- Comprehensiveness. The importance of a safety and
health program's comprehensiveness is implicitly addressed in Workplace Analysis
under both "Survey and hazard analysis" and "Data analysis."
An effective safety and health program shall address all known and potential
sources of workplace injuries and illnesses, whether or not they are covered by
a specific OSHA standard. For example, lifting hazards and workplace violence
problems should be addressed if they pertain to the specific conditions in the
establishment.
- Consistency with Violations/Hazards Found. The PEP
evaluation and the scores assigned to the individual elements and factors should
be consistent with the types and numbers of violations or hazards found during
the inspection and with any citations issued in the case. As a general rule,
high scores will be inconsistent with numerous or grave violations or a high
injury/illness rate. The following are examples for general guidance:
- If applicable OSHA standards require training, but the employer does not
provide it, the PEP score for "Training" should not normally
exceed "2."
- If hazard analyses (e.g., for permit-required confined spaces or process
safety management) are required but not performed by the employer, the
PEP score for "Workplace analysis" should not normally exceed
"2."
- If the inspection finds numerous serious violations--in particular,
high-gravity serious violations--relative to the size and type of
workplace, the PEP score for "Hazard prevention and Control"
should not normally exceed "2."
- Scope of the PEP Review. The duration of the PEP review will
vary depending on the circumstances of the workplace and the inspection. In all cases,
however, this review shall include:
- A review of any appropriate employer documentation relating to the safety and
health program.
- A walkaround inspection of pertinent areas of the workplace.
- Interviews with an appropriate number of employer and employee representatives.
Each of the elements and factors of the PEP may be scored from 1 to 5,
indicating the level of the safety and health program, as follows:
Overall Score |
Level of Safety and Health Program |
5 |
Outstanding program |
4 |
Superior program |
3 |
Basic program |
2 |
Developmental program |
1 |
No program or ineffective program |
Scoring. Score the establishment on each
of the factors and elements after obtaining the necessary information to do so. These shall be
given a score of 1, 2, 3, 4, or 5.
- Refer to the PEP Tables, Appendix B of this notice, as
appropriate, to ensure that the score given to a factor corresponds to the descriptor
that best fits the worksite. Determine scores for each of the six elements as follows:
- The score for the Management Leadership and Employee Participation
element shall be whichever is the lowest of the following:
- The score for the "Management Leadership" factor, or
- The score for the "Employee Participation" factor, or
- The average score for all four factors.
- For the sixth element, Training, just determine the level
1-5 that best fits the worksite and note it in the appropriate box on the PEP.
- For each of the other four elements, average the scores for
the factors.
- If the employer declines to provide pertinent information regarding one or more factors
or elements, a score of 1 shall be recorded for the factor or element.
- If the element or factor does not apply to the worksite being inspected, a notation of "Not
Applicable" shall be made in the space provided. This shall be represented
by "N/A" or, in IMIS applications, "0."
This shall not affect the score.
Overall Score. An "Overall
Score" for the worksite will be recorded on the PEP. This will be the average
of the six individual scores for elements, rounded to the nearest whole number (1, 2, 3, 4, or
5). Round up from one-half (.5 )or greater; round down from less than one-half
(.5).
EXAMPLE: A PEP's element scores are:
2.5 |
2.7 |
14.8 |
= |
2.467 |
= |
2 PEP Score |
2.3 |
6 |
3.0 |
2.3 |
+2.0 |
14.8 |
- The text in each block provides a description of
the program element or factor that corresponds to
the level of program that the employer has
implemented in the workplace.
- To avoid duplicative language, each level should
be understood as containing all positive factors
included in the level below it. Similarly, each
element score should be understood as containing all
positive factors of the element scores below it.
That is, a 3 is at least as good as a 2; a 4 is at
least as good as a 3, and so on.
- The descriptors are intended as brief
illustrations of a workplace at a particular level.
In exercising their professional judgement,
compliance officers should proceed with the
understanding that the descriptor that "best fits"
will not necessarily match the workplace exactly or
in literal detail.
1 |
Management demonstrates no policy, goals,
objectives, or interest in safety and health
issues at this worksite. |
2 |
Management sets and communicates safety and
health policy and goals, but remains detached
from all other safety and health efforts. |
3 |
Management follows all safety and health rules,
and gives visible support to the safety and
health efforts of others. |
4 |
Management participates in significant aspects
of the site's safety and health program, such as
site inspections, incident reviews, and program
reviews. Incentive programs that discourage
reporting of accidents, symptoms, injuries, or
hazards are absent. Other incentive programs may
be present. |
5 |
Site safety and health issues are regularly
included on agendas of management operations
meetings. Management clearly demonstrates--by
involvement, support, and example--the primary
importance of safety and health for everyone on
the worksite. Performance is consistent and
sustained or has improved over time. |
MANAGEMENT LEADERSHIP and EMPLOYEE PARTICIPATION |
Employee Participation |
Employee participation provides the means
through which workers identify hazards,
recommend and monitor abatement, and otherwise
participate in their own protection. [Guidelines,
(b)(1) and (c)(1)] |
1 |
Worker participation in workplace safety and
health concerns is not encouraged. Incentive
programs are present which have the effect of
discouraging reporting of incidents, injuries,
potential hazards or symptoms.
Employees/employee representatives are not
involved in the safety and health program. |
2 |
Workers and their representatives can
participate freely in safety and health
activities at the worksite without fear of
reprisal. Procedures are in place for
communication between employer and workers on
safety and health matters. Worker rights under
the Occupational Safety and Health Act to refuse
or stop work that they reasonably believe
involves imminent danger are understood by
workers and honored by management. Workers are
paid while performing safety activities. |
3 |
Workers and their representatives are involved
in the safety and health program, involved in
inspection of work area, and are permitted to
observe monitoring and receive results. Workers'
and representatives' right of access to
information is understood by workers and
recognized by management. A documented procedure
is in place for raising complaints of hazards or
discrimination and receiving timely employer
responses. |
4 |
Workers and their representatives participate in
workplace analysis, inspections and
investigations, and development of control
strategies throughout facility, and have
necessary training and education to participate
in such activities. Workers and their
representatives have access to all pertinent
health and safety information, including safety
reports and audits. Workers are informed of
their right to refuse job assignments that pose
serious hazards to themselves pending management
response. |
5 |
Workers and their representatives participate
fully in development of the safety and health
program and conduct of training and education.
Workers participate in audits, program reviews
conducted by management or third parties, and
collection of samples for monitoring purposes,
and have necessary training and education to
participate in such activities. Employer
encourages and authorizes employees to stop
activities that present potentially serious
safety and health hazards. |
MANAGEMENT LEADERSHIP and EMPLOYEE PARTICIPATION |
Implementation |
Implementation means tools, provided by
management, that include:
-- budget
-- information
-- personnel
-- assigned responsibility
-- adequate expertise and authority
-- means to hold responsible persons
accountable (line accountability)
-- program review procedures.
[Guidelines, (b)(1) and
(c)(1)] |
1 |
Tools to implement a safety and health program
are inadequate or missing. |
2 |
Some tools to implement a safety and health
program are adequate and effectively used;
others are ineffective or inadequate. Management
assigns responsibility for implementing a site
safety and health program to identified person(s).
Management's designated representative has
authority to direct abatement of hazards that
can be corrected without major capital
expenditure. |
3 |
Tools to implement a safety and health program
are adequate, but are not all effectively used.
Management representative has some expertise in
hazard recognition and applicable OSHA
requirements. Management keeps or has access to
applicable OSHA standards at the facility, and
seeks appropriate guidance information for
interpretation of OSHA standards. Management
representative has authority to order/purchase
safety and health equipment. |
4 |
All tools to implement a safety and health
program are more than adequate and effectively
used. Written safety procedures, policies, and
interpretations are updated based on reviews of
the safety and health program. Safety and health
expenditures, including training costs and
personnel, are identified in the facility
budget. Hazard abatement is an element in
management performance evaluation. |
5 |
All tools necessary to implement a good safety
and health program are more than adequate and
effectively used. Management safety and health
representative has expertise appropriate to
facility size and process, and has access to
professional advice when needed. Safety and
health budgets and funding procedures are
reviewed periodically for adequacy. |
MANAGEMENT LEADERSHIP and EMPLOYEE PARTICIPATION |
Contractor Safety |
Contractor safety: An effective safety
and health program protects all personnel on the
worksite, including the employees of contractors
and subcontractors. It is the responsibility of
management to address contractor safety. [Guidelines,
(b)(1) and (c)(1)] |
1 |
Management makes no provision to include
contractors within the scope of the worksite's
safety and health program. |
2 |
Management policy requires contractor to conform
to OSHA regulations and other legal
requirements. |
3 |
Management designates a representative to
monitor contractor safety and health practices,
and that individual has authority to stop
contractor practices that expose host or
contractor employees to hazards. Management
informs contractor and employees of hazards
present at the facility. |
4 |
Management investigates a contractor's safety
and health record as one of the bidding
criteria. |
5 |
The site's safety and health program ensures
protection of everyone employed at the worksite,
i.e., regular full-time employees, contractors,
temporary and part-time employees. |
WORKPLACE ANALYSIS |
Survey and Hazard Analysis |
Survey and hazard analysis: An effective,
proactive safety and health program will seek to
identify and analyze all hazards. In large or
complex workplaces, components of such analysis
are the comprehensive survey
and analyses of job hazards
and changes in conditions. [Guidelines,
(c)(2)(i)] |
1 |
No system or requirement exists for hazard
review of planned/changed/new operations. There
is no evidence of a comprehensive survey for
safety or health hazards or for routine job
hazard analysis. |
2 |
Surveys for violations of standards are
conducted by knowledgeable person(s), but only
in response to accidents or complaints. The
employer has identified principal OSHA standards
which apply to the worksite. |
3 |
Process, task, and environmental surveys are
conducted by knowledgeable person(s) and updated
as needed and as required by applicable
standards. Current hazard analyses are written
(where appropriate) for all high-hazard jobs and
processes; analyses are communicated to and
understood by affected employees. Hazard
analyses are conducted for jobs/
tasks/workstations where injury or illnesses
have been recorded. |
4 |
Methodical surveys are conducted periodically
and drive appropriate corrective action. Initial
surveys are conducted by a qualified
professional. Current hazard analyses are
documented for all work areas and are
communicated and available to all the workforce;
knowledgeable persons review all
planned/changed/new facilities, processes,
materials, or equipment. |
5 |
Regular surveys including documented
comprehensive workplace hazard evaluations are
conducted by certified safety and health
professional or professional engineer, etc.
Corrective action is documented and hazard
inventories are updated. Hazard analysis is
integrated into the design, development,
implementation, and changing of all processes
and work practices. |
WORKPLACE ANALYSIS |
Inspection |
Inspection: To identify new or previously
missed hazards and failures in hazard controls,
an effective safety and health program will
include regular site
inspections. [Guidelines,
(c)(2)(ii)] |
1 |
No routine physical inspection of the workplace
and equipment is conducted. |
2 |
Supervisors dedicate time to observing work
practices and other safety and health conditions
in work areas where they have responsibility. |
3 |
Competent personnel conduct inspections with
appropriate involvement of employees. Items in
need of correction are documented. Inspections
include compliance with relevant OSHA standards.
Time periods for correction are set. |
4 |
Inspections are conducted by specifically
trained employees, and all items are corrected
promptly and appropriately. Workplace
inspections are planned, with key observations
or check points defined and results documented.
Persons conducting inspections have specific
training in hazard identification applicable to
the facility. Corrections are documented through
follow-up inspections. Results are available to
workers. |
5 |
Inspections are planned and overseen by
certified safety or health professionals.
Statistically valid random audits of compliance
with all elements of the safety and health
program are conducted. Observations are analyzed
to evaluate progress. |
WORKPLACE ANALYSIS |
Hazard Reporting |
A
reliable hazard reporting
system enables employees, without fear of
reprisal, to notify management of conditions
that appear hazardous and to receive timely and
appropriate responses. [Guidelines,
(c)(2)(iii)] |
1 |
No formal hazard reporting system exists, or
employees are reluctant to report hazards. |
2 |
Employees are instructed to report hazards to
management. Supervisors are instructed and are
aware of a procedure for evaluating and
responding to such reports. Employees use the
system with no risk of reprisals. |
3 |
A
formal system for hazard reporting exists.
Employee reports of hazards are documented,
corrective action is scheduled, and records
maintained. |
4 |
Employees are periodically instructed in hazard
identification and reporting procedures.
Management conducts surveys of employee
observations of hazards to ensure that the
system is working. Results are documented. |
5 |
Management responds to reports of hazards in
writing within specified time frames. The
workforce readily identifies and self-corrects
hazards; they are supported by management when
they do so. |
ACCIDENT and RECORD ANALYSIS |
Accident Investigation |
Accident investigation: An effective
program will provide for
investigation of accidents and "near miss"
incidents, so that their causes, and the
means for their prevention, are identified. [Guidelines,
(c)(2)(iv)] |
1 |
No investigation of accidents, injuries, near
misses, or other incidents is conducted. |
2 |
Some investigation of incidents takes place, but
root cause may not be identified, and correction
may be inconsistent. Supervisors prepare injury
reports for lost time cases. |
3 |
OSHA-101 is completed for all recordable
incidents. Reports are generally prepared with
cause identification and corrective measures
prescribed. |
4 |
OSHA-recordable incidents are always
investigated, and effective prevention is
implemented. Reports and recommendations are
available to employees. Quality and completeness
of investigations are systematically reviewed by
trained safety personnel. |
5 |
All loss-producing accidents and "near-misses"
are investigated for root causes by teams or
individuals that include trained safety
personnel and employees. |
ACCIDENT and RECORD ANALYSIS |
Data Analysis |
Data analysis: An effective program will
analyze injury and illness records for
indications of sources and locations of hazards,
and jobs that experience higher numbers of
injuries. By analyzing injury and illness trends
over time, patterns with common causes can be
identified and prevented. [Guidelines,
(c)(2)(v)] |
1 |
Little or no analysis of injury/illness records;
records (OSHA 200/101, exposure monitoring) are
kept or conducted. |
2 |
Data
is collected and analyzed, but not widely used for
prevention. OSHA - 101 is completed for all
recordable cases. Exposure records and analyses are
organized and are available to safety personnel. |
3 |
Injury/illness logs and exposure records are kept
correctly, are audited by facility personnel, and
are essentially accurate and complete. Rates are
calculated so as to identify high risk areas and
jobs. Workers compensation claim records are
analyzed and the results used in the program.
Significant analytical findings are used for
prevention. |
4 |
Employer can identify the frequent and most severe
problem areas, the high risk areas and job
classifications, and any exposures responsible for
OSHA recordable cases. Data are fully analyzed and
effectively communicated to employees.
Illness/injury data are audited and certified by a
responsible person. |
5 |
All
levels of management and the workforce are aware of
results of data analyses and resulting preventive
activity. External audits of accuracy of injury and
illness data, including review of all available data
sources are conducted. Scientific analysis of health
information, including non-occupational data bases
is included where appropriate in the program. |
HAZARD PREVENTION and CONTROL |
Hazard Control |
Hazard Control: Workforce exposure to all
current and potential hazards should be
prevented or controlled by using
engineering controls wherever feasible
and appropriate, work
practices and
administrative controls, and
personal protective equipment (PPE). [Guidelines,
(c)(3)(i)] |
1 |
Hazard control is seriously lacking or absent
from the facility. |
2 |
Hazard controls are generally in place, but
effectiveness and completeness vary. Serious
hazards may still exist. Employer has achieved
general compliance with applicable OSHA
standards regarding hazards with a significant
probability of causing serious physical harm.
Hazards that have caused past injuries in the
facility have been corrected. |
3 |
Appropriate controls (engineering, work
practice, and administrative controls, and PPE)
are in place for significant hazards. Some
serious hazards may exist. Employer is generally
in compliance with voluntary standards, industry
practices, and manufacturers' and suppliers'
safety recommendations. Documented reviews of
needs for machine guarding, energy lockout,
ergonomics, materials handling, bloodborne
pathogens, confined space, hazard communication,
and other generally applicable standards have
been conducted. The overall program tolerates
occasional deviations. |
4 |
Hazard controls are fully in place, and are
known and supported by the workforce. Few
serious hazards exist. The employer requires
strict and complete compliance with all OSHA,
consensus, and industry standards and
recommendations. All deviations are identified
and causes determined. |
5 |
Hazard controls are fully in place and
continually improved upon based on workplace
experience and general knowledge. Documented
reviews of needs are conducted by certified
health and safety professionals or professional
engineers, etc. |
HAZARD PREVENTION and CONTROL |
Maintenance |
Maintenance: An effective safety and
health program will provide for
facility and equipment maintenance, so
that hazardous breakdowns are prevented. [Guidelines,
(c)(3)(ii)] |
1 |
No preventive maintenance program is in place;
break-down maintenance is the rule. |
2 |
There is a preventive maintenance schedule, but
it does not cover everything and may be allowed
to slide or performance is not documented.
Safety devices on machinery and equipment are
generally checked before each production shift. |
3 |
A
preventive maintenance schedule is implemented
for areas where it is most needed; it is
followed under normal circumstances.
Manufacturers' and industry recommendations and
consensus standards for maintenance frequency
are complied with. Breakdown repairs for safety
related items are expedited. Safety device
checks are documented. Ventilation system
function is observed periodically. |
4 |
The employer has effectively implemented a
preventive maintenance schedule that applies to
all equipment. Facility experience is used to
improve safety-related preventative maintenance
scheduling. |
5 |
There is a comprehensive safety and preventive
maintenance program that maximizes equipment
reliability. |
HAZARD PREVENTION and CONTROL |
Medical Program |
An
effective safety and health program will include
a suitable medical program
where it is appropriate for the size and nature
of the workplace and its hazards. [Guidelines,
(c)(3)(iv)] |
1 |
Employer is unaware of, or unresponsive to
medical needs. Required medical surveillance,
monitoring, and reporting are absent or
inadequate. |
2 |
Required medical surveillance, monitoring,
removal, and reporting responsibilities for
applicable standards are assigned and carried
out, but results may be incomplete or
inadequate. |
3 |
Medical surveillance, removal, monitoring, and
reporting comply with applicable standards.
Employees report early signs/symptoms of
job-related injury or illness and receive
appropriate treatment. |
4 |
Health care providers provide follow-up on
employee treatment protocols and are involved in
hazard identification and control in the
workplace. Medical surveillance addresses
conditions not covered by specific standards.
Employee concerns about medical treatment are
documented and responded to. |
5 |
Health care providers are on-site for all
production shifts and are involved in hazard
identification and training. Health care
providers periodically observe the work areas
and activities and are fully involved in hazard
identification and training. |
EMERGENCY RESPONSE |
Emergency Preparedness |
Emergency preparedness: There should be
appropriate planning,
training/drills, and equipment for
response to emergencies.
Note: In some facilities the employer
plan is to evacuate and call the fire
department. In such cases, only applicable items
listed below should be considered. [Guidelines,
(c)(3)(iii) and (iv)] |
1 |
Little or no effective effort to prepare for
emergencies. |
2 |
Emergency response plans for fire, chemical, and
weather emergencies as required by 29 CFR
1910.38, 1910.120, or 1926.35 are present.
Training is conducted as required by the
applicable standard. Some deficiencies may
exist. |
3 |
Emergency response plans have been prepared by
persons with specific training. Appropriate
alarm systems are present. Employees are trained
in emergency procedures. The emergency response
extends to spills and incidents in routine
production. Adequate supply of spill control and
PPE appropriate to hazards on site is available. |
4 |
Evacuation drills are conducted no less than
annually. The plan is reviewed by a qualified
safety and health professional. |
5 |
Designated emergency response team with adequate
training is on-site. All potential emergencies
have been identified. Plan is reviewed by the
local fire department. Plan and performance are
reevaluated at least annually and after each
significant incident. Procedures for terminating
an emergency response condition are clearly
defined. |
EMERGENCY RESPONSE |
First Aid |
First aid/emergency care should be
readily available to minimize harm if an injury
or illness occurs. [Guidelines,
(c)(3)(iii) and (iv)] |
1 |
Neither on-site nor nearby community aid (e.g.,
emergency room) can be ensured. |
2 |
Either on-site or nearby community aid is
available on every shift. |
3 |
Personnel with appropriate first aid skills
commensurate with likely hazards in the
workplace and as required by OSHA standards
(e.g., 1910.151, 1926.23) are available.
Management documents and evaluates response time
on a continuing basis. |
4 |
Personnel with
certified first aid skills are always
available on-site; their level of training is
appropriate to the hazards of the work being
done. Adequacy of first aid is formally reviewed
after significant incidents. |
5 |
Personnel trained in advanced first aid and/or
emergency medical care are always available
on-site. In larger facilities a health care
provider is on-site for each production shift. |
SAFETY and HEALTH TRAINING |
Safety and health training should cover
the safety and health responsibilities of all
personnel who work at the site or affect its
operations. It is most effective when
incorporated into other training about
performance requirements and job practices. It
should include all subjects and areas necessary
to address the hazards at the site. [Guidelines,
(b)(4) and (c)(4)] |
1 |
Facility depends on experience and peer training
to meet needs. Managers/supervisors demonstrate
little or no involvement in safety and health
training responsibilities. |
2 |
Some orientation training is given to new hires.
Some safety training materials (e.g., pamphlets,
posters, videotapes) are available or are used
periodically at safety meetings, but there is
little or no documentation of training or
assessment of worker knowledge in this area.
Managers generally demonstrate awareness of
safety and health responsibilities, but have
limited training themselves or involvement in
the site's training program. |
3 |
Training includes OSHA rights and access to
information. Training required by applicable
standards is provided to all site employees.
Supervisors and managers attend training in all
subjects provided to employees under their
direction. Employees can generally demonstrate
the skills/knowledge necessary to perform their
jobs safely. Records of training are kept and
training is evaluated to ensure that it is
effective. |
4 |
Knowledgeable persons conduct safety and health
training that is scheduled, assessed, and
documented, and addresses all necessary
technical topics. Employees are trained to
recognize hazards, violations of OSHA standards,
and facility practices. Employees are trained to
report violations to management. All site
employees--including supervisors and
managers--can generally demonstrate preparedness
for participation in the overall safety and
health program. There are easily retrievable
scheduling and record keeping systems. |
5 |
Knowledgeable persons conduct safety and health
training that is scheduled, assessed, and
documented. Training covers all necessary topics
and situations, and includes all persons working
at the site (hourly employees, supervisors,
managers, contractors, part-time and temporary
employees). Employees participate in creating
site-specific training methods and materials.
Employees are trained to recognize inadequate
responses to reported program violations.
Retrievable record keeping system provides for
appropriate retraining, makeup training, and
modifications to training as the result of
evaluations. |
|