This week a large organization was hit with over a million dollars in workplace safety fines. The US Department of Labor proposed fines of close to $1.3 million for workplace violations at multiple stores – the Assistant Secretary for OSHA said that “Dollar General continues to demonstrate a willful pattern of ignoring hazardous working conditions and a disregard for the well-being of its employees,” even after being hit with fines previously.
Facing big fines is not the only risk to ignoring the citations – companies that don’t fix hazards risk employees lives when they ignore orders to comply with investigation findings.
What can you do to avoid this happening to your organization?
Job Safety Analysis (JSA) also known as Job Hazard Analysis (JHA) is a process of looking at a work task and considering what is the safest way to complete it. The process typically involves:
1) Breaking a job down into smaller tasks and observing a worker performing it,
2) Identifying the potential hazards for each task and,
3) Determining preventive measures and controls to overcome these hazards.
Audits of work sites are conducted for the purpose of health, safety, and fire hazard identification. During these surveys, assessments are made for compliance to applicable building and fire codes and the detection of unsafe hazards.
Work site audits also provide an evaluation of compliance standards relating to ergonomics, respirator use, hearing conservation, blood-borne pathogens, and use of personal protective equipment.
Dangerous jobs benefit the most from a JSA because it can reduce or eliminate hazards that cause serious injuries or fatalities. A JSA increases job knowledge, establishes teamwork, serves as a health and safety standard and teaching aid, and supports accident investigations at work. A JSA template is used when performing a JSA procedure and is used to generate a safety and recommendation report.
What Jobs are Appropriate for a JSA?
A JSA can be conducted on many jobs in your workplace, but priority should go to the types of jobs that have:
- Highest injury or illness rates;
- Potential to cause severe or disabling injuries or illness, even if there is no history of previous accidents;
- Simple human error which could lead to a severe accident or injury;
- Undergone changes in processes and procedures; and
- Complexity enough to require written instructions
A Team Approach – If a safety audit team is used, make assignments to each person that defines their area of inspection. Ensure they have the proper program background information and documents.
Safety Audit Areas – most audits can be broken down into these areas:
Employee knowledge –standards require “effective training” – an effective program ensures that employees have the knowledge required to operate in a safe manner on a daily basis. The level of knowledge required depends on the specific activities in which the employee is involved and their specific duties and responsibilities. Generally, managers and supervisors should have a higher level of knowledge than general employees. This includes practical knowledge of program administration, management, and training. They should be able to discuss all elements of each program that affects their assigned employees. Many programs divide employees into these two groups- authorized employees and affected employees. Authorized employees must have a high level of working knowledge involving hazard identification and hazard control procedures. Determining employee level of knowledge can be achieved though written quizzes, formal interviews, or informal questions in the workplace.
Written Program Review – during the safety audit, a comprehensive review of the written program should be conducted. This review should compare the company program to requirements for hazard identification and control, required employee training and record keeping against the requirements. Additionally, if applicable, the company insurance carrier should be asked to conduct an independent written program review.
Program Administration – This part of the safety audit review checks the implementation and management of specific program requirements. This section asks these and other similar questions:
- Is there a person assigned and trained to manage the program?
- Are specific duties and responsibilities assigned?
- Are sufficient assets provided?
- Is there an effective and on-going employee training program?
Record & Document Review – Missing or incomplete documents or records is a good indication that a program that is not working as designed. Records are the company’s only means of proving that specific regulatory requirements have been met. Record review also includes a look at the results, recommendations and corrective actions from the last program audit.
Equipment and Material – This area of a safety audit inspects the material condition and applicability of the equipment for hazard control in a specific program. Examples of audit questions for this area are:
- Is the equipment in a safe condition?
- Is there adequate equipment to conduct tasks safely?
- Is personal protective equipment used and stored properly?
- Is equipment, such as exit lights, emergency lights, fire extinguishers, material storage and handling equipment designed and staged to control hazards effectively?
General Area Walk-Through – While safety audits are not designed to be comprehensive physical wall-to-wall facility inspections, a general walk-though of work areas can provide additional insight into the effectiveness of safety programs. Auditors should take written notes of unsafe conditions and unsafe acts observed during the walk-through.