Occupational Health - Injury & Illness Prevention

Occupational Health relies on a progressive injury & illness prevention plan. 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 occupational health illness and injury 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 IIP 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 occupational health illness and injury prevention plan must document everything, in language that everyone can understand. Over the months and years ahead, the occupational health illness and injury 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 occupational health illness and injury prevention plan. 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 occupational health illness and injury 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 IIP 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 occupational health illness and injury 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 occupational health illness and injury 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 occupational health illness and injury prevention plan 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.

Ok, there's much more, but let's stop here and summarize an occupational health illness and injury 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 occupational health illness and injury prevention plan and other written plans on computer disk, to help you make this job a bit easier.
 

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  and forms concerning occupational health
 and illness and injury plans are available in the Members area