Accident & Injury Prevention Plan
Despite a natural tendency of self protection, people have
also demonstrated a willingness to take chances in exchange
for certain gains. In the safety field, it might be a
forklift operator operating his or her vehicle in a fast
manner, so as to gain a little more productivity. This does
not always produce the desired effect because of accidents,
injuries and damaged property. All too often, physical
hazards are blamed for accidents, such as the brakes on the
forklift didn't work or the floor was slippery. Another
important causal factor of the accident can be viewed as
operator error, inattention, disregarding of rules and human
behavior. Perhaps all of these contributed to the accident,
but let's not lay blame.... let's correct the problem. One
of the most important documents a company can have is a
safety guidebook. It's a plan that's developed to prevent
injuries and illnesses and it's called an
Injury/Illness
Prevention Plan (IIP). Some states have made these IIP's mandatory
and even Congress is debating whether to make these IIP's
mandatory for all businesses through the Occupational Safety
and Health Act or OSHA. Before we go much further, let's
make some things clear. Whether it's mandatory or not, a
written safety plan is worth the time and effort. If you
don't have a map, you don't know where you're going. Many of
the elements of an IIP has nothing to do with OSHA. OSHA
regulations are aimed primarily at physical hazards, whereas
an effective injury/illness prevention plan also targets the
human behavior of employees. Keep this in mind as we develop
the program for you.
First, the company
should state their basic safety policy. One such statement
could go like this: "We have no job or task to perform
that would endanger the health or safety of any employee and
each employee has the responsibility to work and act safely
at all times. If any task is unhealthy or unsafe to perform,
no one shall perform that task". That's a fair
statement. It establishes that your company is committed to
safety and will do their part and you, as an employee, must
do your part by working and acting in a safe manner.
The next step is to
assign a Safety Coordinator. In smaller companies, this may
be an employee, supervisor or manager, but this person will
be assigned the responsibility for coordinating safety and
safety projects. Make no mistake, this person is a
coordinator and an advisor. Supervisors and managers are
still responsible for safety, but the coordinator helps by
providing advice, assisting in training coordination and
helping everyone improve safety. In no case, however, are
Safety Managers or Coordinators responsible for safety. That
responsibility remains with supervisors and managers.
One of the first
things to do is develop a set of general safety duties of
employees. These written rules give the employee information
they need for basic safety for their jobs and company
policies and procedures. If they don't know of the rules,
how can they be expected to follow them, so written safety
rules of the company are required. Quite often, employees
can provide a wealth of knowledge and experience in
developing these rules, so include them when developing
these safety guidelines. These guidelines can include
personal hygiene, job responsibilities, proper clothing,
personal protective equipment, housekeeping, machine
guarding and a variety of other safety standards.
Companies should
have their own inspection system for identifying hazards, so
it's advisable to develop a self inspection checklist for
each department. This gives supervisors and employees a
guide by which to inspect themselves, to make sure any
identified hazards are corrected before they turn into
accidents.
Your written accident prevention plan
should also include proper posting requirements. These are
the required posters, such as OSHA, emergency telephone
numbers, signs, and other federal and state posting
requirements. The next part of the accident prevention plan should be policies
regarding Labor-Management Safety Committees and medical
services and first aid.
Do you have first
aid/CPR trained personnel? If so, what are they allowed to
do, do they have training in Bloodborne Pathogens and all
the things necessary for a person to perform these job
duties in an emergency. Keep in mind, the IIP must document
everything, in language that everyone can understand. Over
the months and years ahead, the accident prevention plan must be revised,
changed, added to, deleted from, as things change. This is a
working guide, so make sure you have everything in it and
that it's changed as necessary. You just can't write it,
then leave it on the shelf. It's a guide that should be used
regularly as a reference, by employees, supervisors and
managers.
The next thing to
address is fire protection. You need a specific plan for
emergencies.... what to do in case of an earthquake,
tornado, flood or other emergency. Do you have all emergency
telephone numbers listed and up to date. Fire, police,
electrical, plumbing and so on. Fire protection is much more
than making sure all your extinguishers are serviceable.
Depending upon the size of your facilities, there may be
sprinkler systems, fire doors, proper clearance below
sprinkler heads, and many other items that affect fire
prevention. Monthly inspections are required for all fire
extinguishers and they must also be serviced at least
annually. You should have forms available for these
inspections and all documentation maintained in your files.
Personal Protective
Equipment. If PPE is required, do you have specific rules
regarding the proper use of the equipment and what jobs
require PPE? In case you have respirators, a written
Respiratory Protection Plan is mandatory, as well as
effective training for all employees who use respirators. Do
you use ladders? You need specific safety rules and training
relating to the use and maintenance of these ladders. The
same thing applies to hand and power tools, abrasive
wheel/grinders, machine guarding, lockout/tagout of
equipment, electrical safety, welding/cutting, forklift
operations, safe lifting, compressors and compressed air.
The list goes on and on, but keep in mind.... if no one has
been trained in these rules, how can they be expected to
obey them? Take each specific area and develop basic safety
guidelines for each job. All this information goes in the
IIP. If you use chemicals in the workplace, you must have a
written HAZARD COMMUNICATIONS PLAN. Have all employees been
trained in the potential hazards of chemicals they use? Are
material safety data sheets available and has everyone been
trained in proper labeling procedures for chemicals? It has
to be written, everyone must be properly trained and that
all training must be properly documented.
It has to be written down and people trained, so everyone
will be dancing to the same tune.
The next part of
the accident prevention plan is very important. It's important for the company
and the employee. It's called ENFORCEMENT OF SAFETY RULES.
All too often,
companies will have a safety plan, they'll have written
rules and employees will be trained. However, when the time
comes and the Judge asks the question: "Do you enforce
your safety rules?" Your answer will be yes and the
Judge will say prove it! How do you do that? One of the most
effective methods of proving that you enforce safety rules
is to show the proper documentation. We like to recommend
that "Safety Counseling's" be provided to
employees who cause or contribute to an accident. A
"Safety Counseling" is simply a form of training.
It the accident investigation revealed that an employee
contributed to an accident due to an unsafe act, then a
"Safety Counseling" should be provided to that
particular employee. Basically, the "Safety
Counseling" simply informs the employee what he or she
did wrong or what unsafe behavior caused the accident. The
employee is show the proper procedure and then a time frame
is given to the employee for correcting this unsafe
behavior. It's not disciplinary action, but it should be
viewed as training and teaching the employee, more than
disciplinary action. After all, the employee may have
thought they were performing in an approved manner and
didn't understand why this particular act could have caused
an accident. The employee may have learned a bad technique
or wasn't told or whatever reason..... so it's the company's
responsibility to point out the wrong way and head them in
the proper direction. This "Safety Counseling" is
put in the employee's record, in case documentation is
required to prove you do enforce safety rules. If one
employee keeps having a series of "Safety
Counseling's", disciplinary action may be the next
choice. This part of the accident prevention plan is extremely important for a
variety of reasons, the most important of which is accident
prevention.
Of equal importance is safety training. More paperwork, more
documentation, but it's necessary. Let's take a quick look
at some typical training that should be conducted:
GENERAL HAZARDS
TRAINING
General hazards to
which exposed is the terminology, but it could include an
Employee Safety Orientation Program for all employees, which
explains basic safety rules of the company. General hazards
training could include fire prevention, basic chemical
safety, emergency preparedness and so on.
SPECIFIC HAZARDS
TRAINING
We could make
specific hazards training real easy by saying everything
else not covered in General Hazards Training. In reality, it
may mean HAZARD COMMUNICATIONS, ladder safety, respiratory
protection, office safety, lockout/tagout, forklift
operator, bonding and grounding of flammable liquids,
welding or other specific job hazard training.
One important reminder in developing an
accident prevention plan is training
requirements. What training is required for each job and if
a person isn't properly trained and authorized by the
company, that person should not use any equipment until they
have been properly trained and authorized.
While we're on the
subject of training, let's discuss proper training
documentation.
Of course, there must be written materials as to what
information is taught during the training session.
Generally, we call it a lesson plan, developed by the
company or the instructor and this information should be
maintained in your files, in case documentation is required
to prove what information was taught. If you use a video
program for part of your training, that too must be
maintained as documentation of what information was taught.
The instructor's name and qualifications should also be
documented. Naturally, the date of the training and who
attended the training. It's also recommended that any quiz
or tests that are given during training, be retained in
company files as documentation. That's a lot of time and
effort, but it's necessary. It's very necessary.
The next part of
your Injury/Illness Prevention Plan should include
ACCIDENT
INVESTIGATION. You have to have written procedures, so
supervisors, as well as employees, will have a guide by
which to properly conduct an accident investigation. This
part of the accident prevention plan should be very specific. The reason for this
is accidents don't occur everyday, hopefully. The person
conducting the investigation should have a reference, or
guide to conduct a proper investigation. Accident
investigation seeks to determine facts.... nothing else.
Gather the facts, so a determination can be made as to what
caused the accident. Preventative measures can then be taken
to prevent a similar accident in the future. A statement
should be made in the IIP and General Safety Rules that
"All accidents and injuries must be reported when they
occur". The prompt reporting of accidents and injuries
allows proper investigation and proper medical treatment, if
required. Anyone not promptly reporting an accident or
injury is in violation of safety rules, therefore should be
given a "Safety Counseling". It's an important
part of your overall safety program.
Summary of Accident Prevention Plan
1. Written safety
rules, policies and procedures.
2. Assignment of someone to
coordinate safety within the company.
3. Develop a set of job duties
with general and specific safety rules for each job.
4. Self inspection of your
facilities, equipment and make sure you maintain proper
documentation of all hazards identified and corrected. There
are some requirements for equipment that they be inspected
on a daily or shift basis.
5. Posting and OSHA
recordkeeping.
6. Fire protection and
Emergency Preparedness Plan.
7. Personal Protective
Equipment use and training program, as well as Hazard
Communications Plan, Respiratory Protection Plan and others,
as required.
8. Enforcement of safety
rules and documentation.
9. Training. General Hazards
and Specific Hazards Training.
10. Accident Investigation
guidelines.
You can add more,
or develop a different list of your own, depending upon your
operations, personnel and facilities. You may think this is
too much work and will take too much time and effort to
complete. In the long run, it will be the most important
investment you can make in safety. Whether you are a very
small company or a large corporation, an Injury/Illness
Prevention Plan will help guide you through a more effective
and productive workforce. That's guaranteed. We also have
the basics of the accident prevention plan and other written plans on computer
disk, to help you make this job a bit easier.
More information on accident
prevention, accident investigation along with written programs, employee
training and forms can be found in the members area.
