OSHA Field Safety and Health Manual (SHMS)

CHAPTER 2. SAFETY AND HEALTH MANAGEMENT SYSTEM

The basic tenets of an effective SHMS are Management Commitment and Leadership, Employee Participation, Worksite Analysis, Hazard Prevention and Control and Safety and Health Training.

  1. Management Commitment and Leadership
    1. Policy Statement

      It is the policy of the Agency to provide a safe and healthful work environment for all permanent, temporary, and contract employees. It is also our policy to provide the same safe and healthful environment for our visitors. OSHA is not only committed to ensuring a safe and healthful work environment for others, but is equally committed to the safety and health of its employees. The development, implementation, and evaluation of this Safety and Health Management System (SHMS) shall be a cooperative effort between labor and management in order to prevent injuries, illnesses, and death from work-related causes and minimize losses of material resources. The information contained in this SHMS shall be used to assist employees and supervisors in carrying out their responsibilities of ensuring a safe and healthful working environment.

      This SHMS establishes the framework of a continuing process for providing occupational safety and health guidelines and information to all personnel. OSHA’s commitment is to ensure continuous improvement by establishing procedures for annual self-evaluation and follow-up. The safety, health, and wellbeing of OSHA’s Federal employees, contractors, and members of the visiting public are a shared responsibility. Management will provide training and the time necessary for successful implementation of all aspects of this program.

    2. Roles and Responsibilities

      1. National Office

        1. The Assistant Secretary bears responsibility for the health and safety of OSHA employees as well as temporary, contract and visiting employees and will demonstrate leadership and commitment for employee safety and health. The Assistant Secretary will hold Regional Administrators accountable for the SHMS and programs within their respective offices.

        2. The National Field Safety and Health Steering Committee consists of three executive field management representatives and three NCFLL representatives.

      2. DTSEM will be organizationally responsible for the implementation and management of the program. DTSEM will:

        1. Support the Regions in the implementation of the SHMS, e.g. provide guidance and assistance.

        2. Maintain oversight of SHMS.

        3. Review and submit, to National Field Safety and Health Steering Committee, all changes to the SHMS submitted by the Regions other than those that describe site specific roles and responsibilities.

        4. Review Annual SHMS Self-Evaluations submitted by the Regions and provide guidance as needed.

        5. Compile and maintain injury/illness/incident reports and analyze trends and share recommendations and success stories as appropriate

        6. Provide safety and health performance updates on a semi-annual basis to the National Field Safety & Health Steering Committee which includes the status of:

          1. Regional progress towards safety and health goals;

          2. Regional percent completion of mandatory training;

          3. Regional percent completion of annual physicals;

          4. Regional percent completion of respirator fit tests;

          5. Regional percent completion of required annual exercises (e.g. Continuity Of Operations Plan, Shelter In Place Plan, Occupant Emergency Plan, Local Contingency Plan);

          6. Regional percent completion of required inspections (e.g. office inspections, vehicle inspections, SCBA inspections)

          7. Regional number of incidents investigated and percentage of timely reporting (within 5 days);

      3. Regional Offices

        The Regional Administrators bear responsibility for the health and safety of all Regional employees as well as temporary, contract and visiting employees. The Regional Administrator will demonstrate leadership and commitment to employee safety and health. See Chapter 4 for roles and responsibilities specific to the Regions.

      4. Area and District Offices

        The Area Directors bear responsibility for the health and safety of the staff as well as temporary, contract and visiting employees within the Area and District Offices. The Area Director will demonstrate leadership and commitment to employee safety and health. See Chapter 5 for roles and responsibilities specific to the Area and District Offices.

  2. Employee Participation
    1. Each employee covered by this instruction is responsible for:

      1. Following all of the safety and health rules and practices of the SHMS and safety and health programs;

      2. Monitoring and reporting to their supervisor (or designee) any unsafe conditions for prompt correction;

      3. Correcting any hazard that they have the ability to correct and report that event to the applicable supervisor (or designee), e.g. their Regional Administrator/Area Director/Unit Manager and/or Assistant Area Director (AAD)/appropriate OSHA manager;

      4. Providing feedback to their applicable supervisor (or designee) regarding the need for additional controls to ensure safety and health standards are met;

      5. Setting the example as a leader in occupational safety and health to others in the course of their professional duties;

      6. Avoiding exposure to any recognized uncontrolled hazard; and

      7. Participating meaningfully in SHMS activities, for example; preparing Job Hazard Analyses (JHA), conducting accident investigations, and serving on safety and health committees

    2. All employees shall be provided access to: training materials; safety data sheets; results of inspections; evaluations of their own SHMS; results of accident investigations except for portions deemed confidential for personnel or medical reasons; hazard assessments and such other materials produced by the SHMS that may be helpful to employees in improving safety and health in their workplace.

    3. Union and employee participation in the field are to be undertaken consistent with the National Council of Field Labor Locals (NCFLL) bargaining agreement.

    4. Each Region shall establish a joint labor management committee referred to as the Regional Safety and Health Committee (RSHC) to promote occupational safety and health benefits to all employees, including temporary, contract, and visiting employees. The requirements for formation and election of the RSHC and chairperson will be consistent with 29 CFR 1960.37. The size of the RSHC will be determined jointly by the local labor-management representatives.

      1. The RSHC will consist of at least as many bargaining unit representatives as management representatives. The NCFLL will appoint the union representatives and the Regional Administrator will appoint the management representatives.

      2. Each committee member will serve terms of one to three years. The terms should be staggered so that no more than half of the management or union members will be rotated off the committee's membership during the year.

      3. A Regional Safety and Health Manager (RSHM), identified by the Regional Administrator, serves as facilitator and technical advisor and is a permanent support position in the committee. This position is in addition to the members of the RSHC.

      4. The RSHC may designate ad hoc work groups as appropriate (with up to four members) to address specific safety and health issues and work assignments.

  3. Worksite Analysis
    1. Inspections

      Safety and health inspections will be conducted at each OSHA office quarterly at a minimum with at least one union and one management representative participating. Corrective actions will be documented on the Corrective Action List (Appendix A) communicated to all affected employees, and retained at the office where the inspection was conducted for at least two years. Consideration should be given to conducting limited scope monthly inspections (e.g. fire extinguisher, eyewash, or emergency lighting inspections).

    2. Hazard Analysis of Routine Tasks

      1. Hazards and risks to employees' safety and health should be identified and assessed on an ongoing basis at both the office and field locations, such as at enforcement inspection and VPP onsite evaluation locations. Implementation of preventive and protective measures should: eliminate the hazard/risk; control the hazard/risk at the source through the use of engineering controls or organizational measures; minimize the hazard/risk by the design of safe work systems or use of administrative control measures; or where residual hazards/risks cannot be controlled by collective measures, effected by the use of appropriate personal protective equipment

      2. Hazard Analyses are effective in uncovering hazards to employees and shall be done to the fullest extent possible for all tasks assigned to employees. Based on a general assessment of work sites, at a minimum, employees are required to utilize safety glasses, safety shoes, and hard hats on construction sites and safety glasses and safety shoes on all general industry, maritime and long shoring sites. All employees shall abide by the requirements of the employer under inspection, if more protective than the general assessment.

      3. The SHMS program serves as the basic hazard analysis and control for routine tasks.

      4. To evaluate potential health hazards, employees will abide by OSHA’s Policies and Procedures in Chapter 27 entitled, Policies and Procedures for Field Staff Exposure Monitoring.

    3. Hazard Analysis of Non Routine Tasks

      1. When known special hazards are identified prior to the OSHA inspection and or evaluation, safe job instructions will be given by the unit manager in these cases.

      2. When OSHA employees discover hazards that limit their ability to access an area for inspection and or evaluation, they will contact their unit manager immediately.

      3. When OSHA employees encounters a hazard that is not addressed in the SHMS program they will notify their supervisor who will discuss with the local safety and health committee whether a JSA should be developed.

      4. When it is determined by the safety and health committee that a JSA be developed Appendix C will be utilized. Any JSAs developed will be forwarded to the Regional Safety and Health Committee for review and upon approval forwarded to DTSEM for posting.

    4. Employee Reporting of Hazards

      1. The recognition and control of all types of hazards encountered in the performance of official duties is critical to the safety and health of employees.

      2. Employees including temporary, contract and visiting employees have the right, and are encouraged, to report all working conditions perceived to be potential safety or health hazards to their supervisor (or designee) without fear of reprisal.

      3. In order to capture such incidents as chemical overexposures, near misses, vehicle accidents, and office hazards, employees shall report workplace hazards and provide the information necessary to complete the Incident Investigation and Hazard Reporting Worksheet (Reporting Worksheet) as soon as possible to his or her supervisor (or designee). Once submitted, investigations of these incidents are initiated as soon as possible, but within three working days.

      4. Reported hazard(s) are documented on the Incident Investigation and Hazard Reporting Worksheet (Reporting Worksheet) and submitted to the RSHM and union official within 24 hours. Corrective action(s) dates shall be tracked on the Corrective Action List (Corrective Action List). The supervisor (or designee) shall ensure that employees and the union official are notified in writing within 15 work days of the corrective actions taken or are pending and the reason why.

      5. Reports of unsafe conditions may also be submitted to any local management or the Department of Labor on line using DL 1-1097 Form, Reporting Unsafe and Unhealthful Conditions located at https://shimshosting.dol.gov/login/ShimsLogin.aspx). Reports may be submitted anonymously. The Office of the Assistant Secretary for Administration and Management (OASAM) Safety and Health Manager will investigate and respond appropriately to the hazard(s) identified, within required timeframes.

  4. Incident Reporting/Investigation Procedures
    1. Prompt and accurate reporting and investigation of work-related “incidents,” which include all work-related injuries, illnesses and near misses, or accidents that could have caused serious injuries, is a necessary component of effective accident prevention programs. This information can be used in evaluating and preventing hazards, fulfilling mandatory recordkeeping requirements and filing for workers’ compensation benefits. Incidents resulting in personal injury and/or illness require that the appropriate Office of Worker’s Compensation Programs (OWCP) and DOL procedures are followed and forms completed.

    2. The supervisor (or designee) will notify the Regional Administrator within one workday of all incidents involving recordable injuries and illnesses. The Incident Investigation and Hazard Reporting Worksheet (Reporting Worksheet) will be completed by the manager or designated coordinator.

    3. The supervisor (or designee) will notify the Regional Administrator within one workday of all incidents involving recordable injuries and illnesses. The Incident Investigation and Hazard Reporting Worksheet (Reporting Worksheet) will be completed by the manager or designated coordinator.

      • For Regions, the Worksheet is sent to the RSHM within five days of the incident correction due date. The Worksheet shall include the action plan to correct the incident. Copies are kept at the office for employees to review.

    4. Incidents involving property damage shall be reported as soon as possible to the manager (or designee). The manager (or designee) will complete the Incident Investigation and Hazard Reporting Worksheet (Reporting Worksheet) and will be involved in the investigation process.

      1. In the Regions, all incidents involving property damage must be reported to the RSHM within one workday. An Incident Investigation and Hazard Reporting Worksheet (Reporting Worksheet) and supporting information shall be sent immediately to the RSHM.

      2. In addition to the reporting requirements outlined in this directive and in the Department of Labor Management Series (DLMS) 4, Chapter 800, DOL Safety and Health Program, employees and supervisors must fully adhere to DOL accident reporting requirements in DLMS 2, Chapter 1500, Motor Vehicle Management. These requirements are in addition to the Motor Vehicle Accident Report (SF 91) that must be completed and submitted to DTSEM in the National Office and the RSHM in the Regions.

    5. Each office must maintain their own recordkeeping forms in accordance with 29 CFR Part 1904 for injuries/illnesses occurring at their facilities or work areas. In addition, each office will follow DOL requirements in regards to the use of SHIMS.

      • The RSHM will maintain the recordkeeping forms in accordance with 1904 for the Regional Office. Completed Incident Investigation and Hazard Reporting Worksheet (Reporting Worksheet) are sent to the RSHM within five days of the incident correction due date. Copies are kept at the office for employees to review.

  5. Hazard Prevention and Control
    1. Hazard prevention and control procedures must be reviewed and modified as necessary on a regular basis to follow the most current laws and regulations and to ensure that the fullest level of protection is provided.

    2. Supervisors (or designees) are responsible for ensuring that employees comply with all safety and health rules, policies, and programs and are required to take appropriate action to prevent injury or illness to employees. Specific actions to be taken will be in accordance with existing personnel practices and regulations.

    3. Employees including temporary, contract and visiting employees are required to wear required Personal Protective Equipment (PPE) as outlined below and in the PPE Program.

      1. At the start of any inspection/audit or other field activity, the employees will assess the need for PPE, which will include the employer’s PPE assessment.

      2. Employees including temporary, contract and visiting employees will abide by OSHA’s PPE Program (Chapter 8) or the program of the employer under inspection or other field activity, whichever requires greater protection.
      3. If during the course of an inspection/audit or other field activity the employee encounters a hazardous condition requiring the use of PPE not addressed by the employer’s PPE hazard assessment, the employee will promptly address the hazardous condition with the employer. The employee will also don the appropriate PPE before proceeding, unless other appropriate action eliminates the hazard.

      4. Supervisors will periodically evaluate the employee use of PPE to ensure that employees are adequately protected.

  6. Safety and Health Training

    The following procedures apply to supervisors (or designees) in the Regions:

    1. The supervisor (or designee) will ensure that all employees are trained initially and given refresher training as appropriate on an annual basis thereafter.

      1. Employee training will include all relevant Chapters of the SHMS and specific safety and health programs.

      2. Specialized technical training will be provided for employees who may encounter unique hazards associated with a particular industry or hazard.

      3. Supervisors and employees who are engaged in safety and health activities for the agency will be trained to conduct those duties.

    2. The supervisor (or designee) will ensure that new employees are provided training on this Instruction as part of a DOL new employee orientation process.

    3. Training will be accomplished within 30 days after a new or updated chapter is released. Employees will be trained on the emergency action plan when first hired, and notified, and trained as necessary, whenever the plan has changed or whenever any person's responsibilities under the plan have changed.

    4. Records of training will be maintained for three years at the Regional or Office level to ensure that all employees have been appropriately trained.

    5. Supervisors (or designees) will make available records of the training conducted to the Regional Administrator, and DTSEM when requested.

    6. Supervisors (or designees) will ensure that appropriate training is provided to temporary, contract, and visiting employees to ensure their safety.

  7. Specific Safety and Health Programs
    1. Safety and health programs for the specific topics identified in the subsequent chapters must be adopted and implemented. These may be supplemented or augmented to enhance employee safety and health. Safety and health on additional topics may also be adopted and implemented to address unique safety and health topics. All safety and health programs shall ensure the highest level of protection for employees, temporary employees, contractors, and the visiting public consistent with existing rules, standards and guidance.

    2. All changes to the SHMS or programs other than those that describe site specific roles and responsibilities must be submitted to the DTSEM for review and approval using the following procedures.

      DTSEM in conjunction with the joint Labor-Management Committee is to review and respond to the Region within 60 days of receipt of changes to policies and procedures.

    3. The SHMS and programs provide baseline guidance to OSHA in order to implement an effective SHMS to prevent employee injuries, illnesses and fatalities. Within established guidelines, Regional Administrators may supplement or augment the SHMS and programs to address the unique needs within the National Office or their respective Regions and ensure the health and safety of their employees. Changes to the SHMS or programs to make them site specific, (e.g. identify areas of responsibility), may be made without National Office approval. Changes to the SHMS or programs that alter the SHMS or program policies require National Office approval.

APPENDIX A: CORRECTIVE ACTIONS LIST
APPENDIX B: HAZARD REPORTING AND INCIDENT INVESTIGATION
WORKSHEET

Hazard Reporting and Incident Investigation Worksheet

(Attach summary of investigation - optional)

Suggested Possible Corrective Actions (explain):

Planned Corrective Action Items/Corrective Action(s) including actions (explain):