Presented by: Robert Ikenberry, California Engineering Contractors

Presented by: Robert Ikenberry, California Engineering Contractors

Creating a Contractor Safety Program that Works

Introduction• This webinar has been developed to

provide guidance in developing a company safety program for contractors who apply industrial coatings. The webinar will identify the core elements and requirements for developing a company safety program that incorporates good safety practice as well as regulatory requirements, and complies with the current OSHA guidelines for a company safety program

Learning Outcomes• At the end of this webinar, you will be

able to:– Define and understand the proper steps

and components needed to create a quality company safety program

Why Develop a Contractor’s Safety Program?• A safety program is a legal

requirement• OSHA requires contractors to

develop specific safety programs– Construction Standard, Section 1926.20

requires all employers in the construction industry to regularly inspect sites for hazards, provide PPE and train workers on hazards they may encounter

Safety Program• A safety program should include the

following core elements:– Management leadership and employee

participation– Hazard identification and assessment– Information and training– Evaluation of program effectiveness

(enforcement)

Benefits of a Safety Program• Lower accident

rates• Reduced job

disruption from minor accidents and injuries

• Reduced worker compensation premiums

• More Productive workers

Steps to Create a Safety Program

• Use SSPC Guide 17, Guide to Developing a Corporate Safety Program for Industrial Painting and Coating Contractors as a template– In current version of SSPC Volume 2 –

Systems and Specifications

Steps to Take to Create a Safety Program• Step 1: Make a Management

Commitment• Step 2: Designate a Safety

Coordinator• Step 3: Develop the Basics• Step 4: Develop the Specifics• Step 5: Develop a Code of Safe

Practices• Step 6: Put it All Together

Step 1• Make a management commitment and:

– Get a copy of the applicable regulations• Federal and state

– Create a signed written policy statement endorsed by executive management

– Review any programs the company already has in place

– Review the firm’s accident history• Look for any patterns • Look for connections between type of injury

and type of work

Step 1• Federal standards from OSHA are

compiled in chapter 29 of the Code of Federal Regulations

• www.osha.gov• State OSHA plans may have

additional requirements (they must be “at least as effective as” the Federal standards)

Step 2• Designate one individual to have the

primary responsibility of acting as safety coordinator

Step 2• Some requirements for an effective

safety coordinator are:– Good communication skills– Knowledge of the business– Basic background in science and chemistry– High reading and comprehension skills– Good organizational skills– Perseverance

Step 2• The safety coordinator should assign

responsibilities for preparing specific components of the program using a checklist

Safety Program Checklist• The safety program must:

– Contain a management commitment statement

– Designate safety responsibilities– Define discipline for safety policy

violations– Provide recognition for superior safety

efforts– Define training and employee

communication

Safety Program Checklist (continued)

• The safety program must:– Provide for task-specific hazard analysis– Provide for jobsite safety inspections– Provide a procedure for correction of

unsafe conditions– Provide compliance verification– Define accident and illness reporting– Define accident investigation– Define record keeping

Management Statement• The management statement states

that the program has the full support and authority of company management

Management Statement• An example of a signed written

policy statement is:– Our company is committed to provide

facilities, equipment and management to assure a safe working environment for employees and to achieve the lowest possible personal and financial loss due to accidents and injuries

Designate Safety Responsibilities• Who is responsible for safety at:

– The management level– The project management level– The field operations level– The supervisors level– The contractor level

Define Discipline for Policy Safety Violations• Describe how violations of the safety

program will be handled• Discipline should be defined as:

– Progressive– Consistent – Fair

Recognition for Superior Safety Effort• Workers who demonstrate superior

safety attitudes, effort and thought should be rewarded

Training and Employee Communication• Explain how safety procedures and

policies should be communicated to the workers in the field

• Encourage employee feedback • Define who will act on employee

suggestions and complaints

Work Place Hazard Analysis• Tasks, equipment, procedures and

work sites must be analyzed to identify hazards or potential hazards

• Checklists for these may be helpful:– Job (task) Hazard Analysis (JHAs)– Jobsite inspections– Equipment inspections (manlift, forklift,

scaffold, vehicles, major equipment)

Correction of Unsafe Conditions

• Correct unsafe conditions by providing:(Generally in this order…)

• Revised work practices• Changes in equipment• Training• Protective equipment

Compliance Verification• Determine how you will verify that

identified unsafe practices, procedures, equipment or conditions have been corrected

Accident and Illness• Develop a process for how accidents

are to be reported to management and determine:– Who must make the report– Who receives the report– What action will be required

Accident Investigation• All accidents should be investigated

and the safety program should define:– Who will conduct the investigation– What format will be followed– Who will receive the reports and what

action will be taken

Record Keeping• The safety program should explain:

– What general safety records must be kept

– Who will maintain the records– What summary reports will be prepared– Special retention times, where

applicable • (30 years for medical records)

Record Keeping• The following checklist may be

useful for record keeping:– Are all occupational injuries and

illnesses, except for minor injuries requiring only first aid, being recorded as required in the OSHA 300 log?

– Are employee medical records and records of exposure to hazardous substances up-to-date with current OSHA requirements?

Record Keeping• Have the required OSHA training records

been kept current and are they easily accessible for review?

• Have arrangements been made to maintain records for the term of employment plus required retention? (30 years for medical)

• Are inspection tags, operating permits and other records up-to-date for such items as firefighting equipment, elevators, air pressure tanks, etc.?

Step 3• Form a safety committee

– Many states actually require or encourage a joint safety committee of employees and supervisors as part of their OSHA or worker compensation regulations

Step 3• The safety coordinator should set a

reasonable timetable for the development of a safety program and define individual responsibilities such as:– When will you have a listing of all the specific

training and procedures necessary– Who will complete them– When will they be completed– Who will inventory the hazardous materials

and develop the Hazard Communication (HAZCOM) program

Step 3• The safety coordinator should set

intermediate milestones requiring progress reports to be submitted at least once a month

Step 3• Once all the material has been

submitted from the safety committee, the safety coordinator drafts the master safety program using the checklist provided earlier in the presentation

Step 4• Use the draft program procedures to

analyze the hazards and ask:– Do workers ever use or encounter

materials containing toxic products?– Do workers enter tanks or pits?– Do workers work with lead based

paints?– Do worker work in high noise

operations?

Step 4• Do workers ever use or encounter

materials containing toxic products?– If YES, then develop a HAZCOM program

• List all hazardous materials within the organization

• Make sure all MSDSs are on hand and learn how to interrupt them

• Set up a master file and method of getting the information and copies of the MSDSs to the field

Step 4• Do workers ever spray materials

containing toxic products?• If Yes, then develop a respiratory protection

program– Cover respiratory fitness clearance (evaluation by

LHCP)– Training in proper selection, use and maintenance

of respirators– Cover fit testing– Provide for

periodic re-evaluation

Step 4• Do workers enter tanks or pits?– If YES, then the company needs a permit-

required confined space program

Step 4• Do workers work with lead based paints?– If YES, then the company should have a

comprehensive lead safety program

Step 4• Do worker work in high noise operations?

• If YES, then indicate the need for a hearing conservation program

Step 4• The following hazards require OSHA training and

may require a Competent or Qualified Person:– Blood Borne Pathogens– Confined Spaces, Permit Required– Fall Protection– First Aid– Hazard Communication Standard– Hearing Protectors– Ladders– Lead Paint Hazard

Step 4• Continued:

– Lockout and Tagging Circuits– Portable Fire Extinguishers– Powered Industrial Truck Operator Training– Respiratory Protection– Scaffolding– Power Operated Hand Tools– Personal Protective Equipment– Access to Employee Exposure and Medical

Records

Step 5• A code of safe practice should be

developed for each identified risk such as:– Fire (Materials, Storage, Use,

Emergency Response)– Health (Toxic exposures)– Physical (Falls, Struck by, Pinch-points,

Heat/Cold stressors)

Step 5• A code of safe practice is a listing of

brief standard work practices or procedures that are designed to improve safety and reduce risk

• The code summarizes general safety rules that do not fit into a specific program such as HAZCOM or Confined Space

Step 5• Weekly safety meetings should be

given by supervisors at all work sites– Include requirement and attendance at

these meetings in the code of safe practice

– Provide supervisors (or whoever instructs) with training on appropriate topics and effective safety meetings

– Relate to actual jobsite safety issues

Step 6• How will this information reach the

people who need to use it?– Provide training, which may include:

• Written materials• Video presentations• Verbal instructions from a supervisor

– Consider how you will document that training is effective

Step 6• The safety training must include

information on:– The nature of hazards and how to

recognize them – What is being done to control hazards– The protective measures the employee

must follow to prevent or minimize exposure to the hazard

– The employee’s rights and employer’s responsibilities included in OSHA or other standards relating to the hazard

Summary• With a management commitment to

safety, a dedicated safety coordinator, and some effort, a painting contractor, whether small or large, can prepare an effective safety program and reap the benefits of reduced accidents, lower insurance premiums, improved worker morale and productivity, and freedom from government citations and fines