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Supervisor Safety Training
Why do you need this? An effective safety program starts with the first line supervisor. Supervisors have tremendous responsibilities for training their employees and ensuring the safety of their employees.
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Supervisor Safety Training
References: 29 CFR 1960 Basic Program Elements For Federal Employee Occupational Safety And Health (OSH) NAVMCDIR Marine Corps Occupational Safety and Health (OSH) Program Manual MCO Marine Corps Safety Program ASO MCAS Beaufort Occupational Safety & Health (OSH) Program MCO P Navy/Marine Corps Mishap & Safety Investigation, Reporting, and Record Keeping Manual MCO Operational Risk Management
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What’s required? Installation Safety Managers (ISM’s) and safety officers shall ensure Occupational Safety & Health (OSH) training is provided to all supervisory personnel. Document Supervisor Safety Training. (maintain for 5 years) Minimum 4 hours of training. New supervisors, trained within 90 days of appointment.
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Marine Corps OSH Program NAVMCDIR 5100.8
Chapter 1 paragraph 1003 All Marine Corps commands are required to provide a safe and healthful operational, training, and working environment for all Marine Corps personnel. These conditions shall be ensured through a comprehensive OSH Program that includes: Applicable OSHA regulations and other non-DoD standards wherever and whenever possible. When not possible to apply non-DoD regulations and standards, SOPs will be developed and published prescribing OSH measures.
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Marine Corps OSH Program cont’d NAVMCDIR 5100.8
Qualified OSH Inspectors will inspect all facilities, training areas, recreational areas, and work centers at least annually. Prompt abatement of identified hazards. Procedures for all personnel to report suspected hazards through their chain of command without fear of reprisal. Appropriate OSH training provided for safety and health officials, all supervisory personnel, and all other Marine Corps personnel. Establish procedures to review new construction projects and renovations to ensure OSH hazards are eliminated. Pre-construction meetings.
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Marine Corps OSH Program cont’d NAVMCDIR 5100.8
Mishap investigations performed and completed. Comprehensive management system maintained that provides OSH data to higher authority. OSH surveillance programs such as medical and industrial hygiene, implemented by qualified personnel. Procedures to recognize superior or deficient OSH performance. Provide hobby shops with the same level of OSH requirements. Specifically addresses requirements to be provided to patrons.
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Occupational Safety & Health Program ASO 5100.24C
Chapter 1 para.1 b: (excerpt) An effective safety program requires a combination of training, active participation and leadership from all levels. Chapter 1 para.2, b, (1): Department Heads, Officers-In-Charge and Supervisors at every echelon are responsible for establishing and conducting an effective safety program within their department by incorporating and enforcing safe practices, establishing and maintaining safe physical standards in all operations, maintenance and training under their cognizance.
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OSH Responsibilities & Training ASO P5100.24C
Chapter 3 para.1, a: Commanding Officers, Directors, Officers- In-Charge, Department Heads, and Supervisors shall ensure their personnel receive indoctrinated and continuous instructions in applicable OSH regulations and procedures. Chapter 3 para.2, a: Management personnel shall receive sufficient Occupational Safety and Health (OSH) training to enable them to actively support programs in their specific areas of responsibility. At a minimum, this training shall include but is not limited to the 4 hour Supervisor’s OSH Course.
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29 CFR 1960 & Executive Order 12196 Basic Program Elements for Federal Employees OSH
1960.1 Administered by the Secretary of Labor. Required to issue basic program elements to operate OSH programs. Sec. of Labor required to perform consultations, training, recordkeeping, inspections, and evaluations. Elements apply to all agencies, all Federal employees, and working conditions of Federal employees. (Except military unique equipment, systems, and operations.) Does not relieve private employers, Federal contractors, or their employees of any rights or responsibilities under the Act.
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Section 19 of the OSH Act Federal Agency Safety Programs and Responsibilities
(a) It shall be the responsibility of the head of each Federal agency (not including the United States Postal Service) to establish and maintain an effective and comprehensive occupational safety and health program which is consistent with the standards … (1) provide safe and healthful places and conditions of employment… (2) acquire, maintain, and require the use of safety equipment, personal protective equipment, and devices reasonably necessary to protect employees (3) keep adequate records of all occupational accidents and illnesses for proper evaluation and necessary corrective action (4) consult with the Secretary with regard to the adequacy as to form and content of records kept… (5) make an annual report to the Secretary with respect to occupational accidents and injuries and the agency's program…
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Questions?
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Reporting Hazards & Unsafe/Unhealthful Report NAVMC 11401
Any military or civilian personnel, or employee representative, observing unsafe or unhealthful work practices, conditions or violations of established OSH standards, shall advise the work center supervisor of the condition noted, either orally or in writing. NOTE: Initial oral reports are required for imminent danger situations. Reprisals against personnel for submitting hazard reports are prohibited.
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Reporting Hazards cont’d
Upon receipt of an oral or written report, the supervisor responsible for the area in question shall investigate and initiate appropriate corrective action. NOTE: When a condition cannot be corrected at the supervisory level, the supervisor shall notify the ISM or unit safety officer within 5 working days. Any employee desiring anonymity may submit a NAVMC 11401, "Unsafe or Unhealthful Working Conditions" form. Blank copies of this form and procedures shall be posted in or near all Marine Corps work centers (e.g., safety boards, official bulletin boards, time clocks)
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Reporting Hazards cont’d
If anonymity is requested, the ISM or unit safety officer shall delete the originator's name and any individual named in the report, and advise the responsible supervisor that a hazardous condition has been reported. WHY? ISM or Unit Safety Office will retain copies of reports and records for 5 years following the end of the calendar year to which they relate. (5 + the current year)
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Cont’d on next slide UNSAFE OR UNHEALTHFUL WORKING CONDITION
NAVMC REV I believe a condition exists which is a safety or health hazard to Marine Corps personnel or property. (Check one) Civilian: _____ Military: _____ Employee Representative: _____ Other: _____ 2. Does this hazard immediately threaten life or health? Yes ____ No ____ 3. Building, worksite, or other location where you believe the unsafe or unhealthful condition exists. 4. Supervisor (if known) at this location is:___________________________________________ Phone number is:__________________________________ 5. Briefly describe hazard:_________________________________________________________ ________________________________________________________________________________ 6. Number of employees exposed to or threatened by hazard:___________________________ 7. If known, list any safety or health standard which you believe may apply to this condition: Cont’d on next slide
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8. To your knowledge, has this condition been reported to, discussed with, or brought to the
attention of a supervisor? Yes____ No____ If yes, please give the results, including any efforts by management to correct condition. ________________________________________________________________________________ Name (optional):______________________________________________________________ Phone number (optional):______________________________________________________ If you are a representative of employees, provide name of your organization. Case number:_________________(Filled in by Installation or Unit Safety Office)
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Reporting/Investigating allegations of Reprisal
Reporting: Use your chain of command! Request Mast Grievance (MLA) Human Resources HRO Inspector General IG Hotline OSHA Investigation: IG, HRO, Union.
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Questions?
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Employee Training Who conducts it?
NAVMCDIR 5001. TRAINING REQUIREMENTS 1. Job Safety Training. Marine Corps personnel will be given job safety training before their assigned work begins. This training will normally be provided and documented by the person's work center supervisor.
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Employee Training cont’d What’s Required?
As a minimum, the training will consist of: General safety matters related to (YOUR) work environment Hazards associated with assigned tasks Applicable safety and health standards (HAZCOM, LOTO, etc) PPE required for each task An overview of the local safety and health program with emphasis on individual rights and responsibilities Prompt reporting to management (YOU) of unsafe conditions
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Employee Training cont’d What’s Required?
Potential exposure to hazardous materials, or occupational injury or illness (Hazard Communication) Additional specialized safety and health training the person is required to attend and a date and time schedule of applicable training. Such as: MCAS Beaufort Commanding Officers Policy Letter which addresses Required Safety Training For Civilian Employees Which states:
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Employee Training cont’d CO’s Policy Letter 01-10
All employees must attend: (both AF and NAF employees aboard MCAS Beaufort) OSHA 10 Hour General Industry (2 day class) Operational Risk Management (annual requirement) All supervisors and managers must attend: Four hour Supervisors Safety class. All unit safety representatives: OSHA 30 hour General Industry. (GSM supersedes this requirement.)
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Employee Training cont’d Specialized Training?
Supervisors are responsible to: Provide or obtain job unique safety training. Determine the safety training each person will receive based on a job hazard analysis, safety inspections, or industrial hygiene survey. Training may be available from local safety, occupational health, or preventive medicine personnel. Document and maintain all training at the work center. Provide the ISM or safety officer with a summary of the training conducted and roster of all personnel trained.
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Supervisor Training Specifics Required within 90 days of your assignment per NAVMCDIR 5100.8
The use of Job Hazard Analysis (JHA) Operational Risk Management (ORM) Implementing, documenting & tracking hazard abatements Mishap investigation, recording & reporting procedures How to train & motivate subordinates on safe and healthful work practices Hazard control principles
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Questions?
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Job Hazard Analysis (JHA)
What is it? (similar to ORM) An evaluation of the hazards associated with an employee’s work activity focusing on identifying and correcting root causes that brought about the hazardous condition or unsafe practice. An organized approach to evaluate a work process. Identifies hazards, root causes and corrective actions. Provides documentation of employee’s knowledge of the job requirements.
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Job Hazard Analysis (JHA) cont’d
What does a JHA do for you? Involves your employees in the process of hazard recognition and awareness (A sense of ownership) Standardizes work procedures based on safety Identifies appropriate Personal Protective Equipment (PPE) Allows formal documentation of employee’s knowledge of the job requirements.
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Job Hazard Analysis (JHA) cont’d
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Job Hazard Analysis (JHA) cont’d Types of Workplace Hazards
Slips, trips & falls Electrical Harmful dust Smoke and noxious or poisonous gases Biological Ergonomic Radiation Penetration Chemical Flying particles Noise Fire Heat/Cold Stored Energy Work place violence Other… BOLD TYPE…MOST FREQUENTLY FOUND AT MCAS WORKPLACES.
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Job Hazard Analysis (JHA) cont’d
(Possible) Root Causes Lack of knowledge or training Lack of physical ability Prior training that included unsafe practices Previously unidentified hazard Newly introduced hazard resulting from process or equipment change. Inadequate leadership or communication
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Job Hazard Analysis (JHA) cont’d Hazard Mitigation
Hierarchy of controls to mitigate risk (Often combined) Engineering Administrative Work Practice Personal Protective Equipment Let’s look at some examples…
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Job Hazard Analysis (JHA) cont’d
Engineering controls: Eliminate or reduce exposure to the hazard by: Isolating the employee from the hazard Improving (redesign) work area layout Substituting less hazardous products (Green Products) Modifying equipment (Per the manufacturer)
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Job Hazard Analysis (JHA) cont’d
Administrative controls: Reduces employee exposure to a hazard by: Reducing the frequency of performing the hazardous task Rotating employees to reduce exposure time Training employees to recognize hazards and employ safety practices Typically written procedures: Standard Operating Procedures (SOP’s) Preventive Maintenance inspections (PM’s) Technical Manuals (TM’s)
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Job Hazard Analysis (JHA) cont’d
Work practice controls include: Workplace rules Safe & healthful work practices Personal hygiene Housekeeping and maintenance Procedures for specific operations Hopefully these don’t require an explanation. As with any controls, they are only effective if they are ENFORCED.
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Job Hazard Analysis (JHA) cont’d
Personal Protective Equipment (PPE): Least preferred method of hazard control. (Used as a Last Resort) Why? PPE may reduce productivity while affording less effective protection against the recognized hazard than previously mentioned methods of control. However, there are instances where adequate levels of risk reduction cannot be achieved through other methods, and PPE must be used, alone or in conjunction with other protective measures.
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Job Hazard Analysis (JHA) cont’d
Evaluate Effectiveness Assess how well the JHA process is mitigating hazardous conditions by: Updating JHAs for routine and non-routine task Ensuring JHAs were developed for all new processes Conducting routine self-inspections (monthly) Examining Industrial Hygiene reports and safety inspections Review investigation findings for injuries and near misses Following up on employee reports/concerns. NOTE: JHA’s are inspected for during Facilities Annual OSH Inspections.
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Job Hazard Analysis (JHA) cont’d
Organization: MCAS Division: S-4 Section/Shop: Supply, Property Control Task: Operate Fork Lift, Provide equipment for the Air Show Conducted By: Worker/Safety Rep/Supervisor Reviewed By: Supply Officer/MCCS Safety Approved By: Supply Officer/S-4 Director
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Job Hazard Analysis (JHA) cont’d
Step Sequence of Job Task: (A-Z) Include equipment used. Keep steps in order of job process. Hazards: All real & potential hazards identified Preventative Measures: Eliminate or reduce all hazards identified using engineering, administrative, or PPE controls Original in JHA Binder and copy to MCAS Safety Office Review annually with workers and with new hires. (Refresher Training)
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JOB HAZARD ANALYSIS WORKSHEET
JOB DESCRIPTION JOB LOCATION KEY JOB STEPS TOOLS, EQUIPMENT, OR MATERIALS POTENTIAL HEALTH/INJ HAZARD TO WORKER POTENTIAL HAZARD TO SYSTEM RECOMMENDATIONS FOR WORKER PROTECTION SYSTEM COUNTERMEASURES EXAMPLE
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Questions?
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Implementing, conducting & documenting safety inspections
Safety Inspections. Why ? To provide all personnel with a safe and healthful workplace by identifying hazardous conditions and unsafe acts before a mishap occurs. How? By detecting hazards and unsafe acts Indentifying safeguards and precautions Promoting the OSH Program (Offering assistance & knowledge) Increase hazard awareness for personnel Strengthen working relationships (We are not OUT TO GET YOU)
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Implementing, conducting & documenting safety inspections cont’d
Two areas of concentration are: Operational—commands can correct (Includes programs such as HAZCOMM, HAZMAT, PPE, Training & Documentation, Fire Safety, etc.) Infrastructure (your building)—typically requires outside assistance (e.g., Public Works, etc.) for corrections.
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Implementing, conducting & documenting safety inspections cont’d
Responsibilities. Department of Safety and Standardization (DSS) Conduct annual inspections of (low risk hazard) areas Conduct semiannual inspections of (high risk hazards) areas Assist tenant commands in tracking infrastructure hazards Post NAVMC OSH Deficiency Notices (RACs 1, 2, 3)
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Implementing, conducting & documenting safety inspections cont’d
Responsibilities. Cont’d Supervisors shall: At a minimum, ensure work center and program inspections are conducted and documented monthly. (NAVMCDIR ) Inspections will include a review of the SOPs, TMs, and all other directives that govern the operations, processes and facility management. Ensure new processes or equipment are identified to the DSS so a JHA evaluation can be conducted. Ensure personnel are trained on the hazards associated with work being performed and follow procedures described in SOPs, PMs, TMs, and NAVMCDIR
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Implementing, conducting & documenting safety inspections cont’d
Supervisors shall: cont’d Ensure an emergency action plan (EAP) is available and posted. Ensure abatement of all identified work center OSH deficiencies within 30 days of the Inspection Report date. Post the OSH Deficiency Notice as directed by the OSH inspector. Initiate interim control measures at work areas as directed by the inspecting safety office for those hazards awaiting permanent abatement.
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Implementing, conducting & documenting safety inspections cont’d
Qualified safety and health personnel conduct the inspections. Inspections will not disrupt the operations of the workplace. Safety Representative and/or the Supervisor should accompany the inspector, or if you are the inspector, have someone from the unit being inspected walk with you and take notes.
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Implementing, conducting & documenting safety inspections cont’d
“Imminent danger” situations shall be brought to the immediate attention of supervisory personnel for corrective action.
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Implementing, conducting & documenting safety inspections cont’d
The first portion of the safety inspection should be looking at training records to ensure individuals have received required training. Training records provide a valuable tool to the inspector. (NOTE: By-name rosters are required. If your training isn’t documented by-name, it is impossible for you to prove your employees were trained.)
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Implementing, conducting & documenting safety inspections cont’d
Most Frequent Violations Electrical Eye wash stations in need of servicing HAZMAT (improper storage, MSDS) Housekeeping (slips, trips, falls) PPE Training Warning signs
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Areas of Focus Housekeeping PPE Tools Ergonomics Vehicles Practices
Chemicals PPE Tools Vehicles Practices Ergonomics Machine Guarding Electrical
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Let’s look at some HAZARDS.
Supervisors should be able to identify and describe these HAZARDS.
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What’s the HAZARD? Loose wires Ungrounded Not Insulated Unmarked boxes
Electrical Hazards Loose wires Ungrounded Not Insulated Unmarked boxes
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Walking & working surfaces
Housekeeping Control clutter Walking & working surfaces
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Chemical Exposures PPE
Labeling Written Program MSDS’s Training PPE Assessment Respirators Hardhats Gloves Footwear Eye protection
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Point of operation clearance
Machine Guarding Point of operation clearance Nip points Tools & Equipment Hand Power Ladders
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Vehicles Work Practices
Brakes Steering Glass Wipers Work Practices Follow Procedure SOPs Training Supervision
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Are all work areas clean, sanitary, orderly, and adequately illuminated?
Is the floor free from potential trip or fall hazards?
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Are aisles clear and width maintained?
Are floor openings and holes protected?
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Are elevated open-sided floors, platforms and runways 4 feet or more above adjacent floors or ground level guarded by a standard railing on all open sides except at the entrance to a ramp or stairway or fixed ladder?
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TWO HAND RAILS REQUIRED INTERMEDIATE RAILS REQUIRED AT HALF-WAY MARK
Are stairs having four or more risers provided with compliant hand rails? Do all stairs or stairways have a slip-resistant surface? TWO HAND RAILS REQUIRED INTERMEDIATE RAILS REQUIRED AT HALF-WAY MARK
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Are fire evacuation procedures posted?
EXIT YOU ARE HERE EXIT
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Are panic and door hardware working properly?
Are means of egress continuously maintained free of obstructions or impediments for full instant use in the case of fire or other emergency?
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Are fire exits marked clearly and properly?
Are emergency lights working properly? Are EXIT signs working properly?
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Is proper storage of flammable/
combustible material practiced to minimize the risk of fire? Are hazardous materials stored in a dedicated storage locker, storage room, or warehouse?
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Are hazardous materials stored with other compatible hazardous
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Are fire suppression systems on dip tanks in working order?
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Are all personnel provided PPE
when and where necessary? Are all personnel trained in the use, care, maintenance, and storage of their PPE?
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“No employee shall be allowed to
consume food or beverages in a toilet room nor in any area exposed to a toxic material?” Are all toilets and washing facilities clean and sanitary?
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Are portable fire extinguishers provided in adequate number and type?
mounted in accessible, unobstructed areas? Are portable fire extinguishers inspected monthly and marked on the monthly inspection tag? Are Fire Alarm Pull Stations clear of obstructions & easily accessible?
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Are areas involving storage and use of flammable/hazardous
materials identified with appropriate warning signage?
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Are all circuit breakers identified/ labeled as to what they serve?
Are all unused openings in panel boxes effectively closed?
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Are all electrical appliances/ machinery grounded properly?
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Are unused openings in switch boxes, junction boxes, receptacles, panel boxes, effectively closed, providing complete enclosure? Are conductors entering boxes, cabinets, or fittings protected from abrasion?
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Do all panel boxes, switch boxes,
junction boxes, and receptacles have covers that provide complete enclosure?
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Are extension cords NOT being
used as permanent wiring? Are flexible cords or cables NOT run through holes in walls, ceilings, floors, doorways, windows, or similar openings?
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Are GFCI receptacles or GFCI
circuit breakers installed where wet processes occur, i.e., bathrooms, kitchens, laundry rooms, wash racks? Are frayed, damaged, or deteriorated cords taken out of service and replaced? 29 CFR (a)(2)
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Are all containers properly labeled with mandatory identifiers:
contents, associated hazards, affected bodily organs and personal protective equipment (PPE) required for wear?
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Are there Material Safety Data Sheets (MSDS) for all hazardous
materials on the premises located in a binder (or electronically) and readily available and accessible? Are all personnel in your section/ activity/facility trained in the purpose and use of the MSDS?
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Are plumbed emergency eyewash
stations and drenching showers maintained and tested on a weekly basis? ANSI Z Are emergency eyewash stations and drenching showers completely accessible and unobstructed? ANSI Z Are self-contained eyewash stations maintained in accordance with the manufacturer’s instructions? ANSI Z
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Are all vending machines over 700 pounds and all beverage vending machines firmly anchored to the deck or the bulkhead? NAVMC DIR , d
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Written Deficiency Reports Inspection Report Info
I.D. # for tracking Organization Location of hazard Description of violation Standard violated Risk Assessment Code Suggested corrective action Inspector’s name Date of inspection Abatement status includes: Interim control measures Project description to include estimated cost/date of completion Corrections made to include date/cost Signature/phone of person verifying corrective action Comments for follow-up
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Let’s take a closer look at a Report.
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Hazardous Communications (HazCom)
Hazardous Communications (HazCom). Although the HazCom labels for secondary containers meets the standard, the information on the label does not. The secondary container pictured at right has the label with the contents identified as “bleach.” Crucial information missing for employees’ Right To Know are hazards related to the contents and the personal protective equipment (PPE) required for wear when using this product. Ref: 29 CFR RAC 4 Recommendation: Ensure this container and all containers of hazardous materials (HazMat) are labeled with identifiers as to the manufacterurer or distributor and the contact number, contents, the hazards associated with the contents, and the PPE required for wear when using the HazMat. Ensure containers for water are identified as such to avoid confusion. 83
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Incorporate a product inventory sheet in the binder.
The Material Safety Data Sheet (MSDS) Binder was incomplete and all personnel in this Activity have not received training on the purpose, use, and location of the binder. Ref: 29 CFR RAC 3 Recommendation: Inventory all hazardous materials (HazMat) within this Section and obtain MSDS for each. Include a Table of Contents to correspond with each tabbed MSDS. Incorporate a product inventory sheet in the binder. Ensure all personnel assigned to this Activity are instructed on the purpose and use of the MSDS and that this instruction is documented. Mount completed MSDS binder in a conspicuous location. Ensure all employees are aware of its location. Before personnel use any HazMat ensure the relevant MSDS is read and its recommendations are employed. 84
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Implementing, conducting & documenting safety inspections
SUMMARY To provide all personnel with a safe and healthful workplace. By detecting hazards and unsafe acts and taking action. Inspections concentrate on your buildings and programs. DSS and Supervisors responsibilities. Documentation.
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Questions?
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Implementing, documenting & tracking hazard abatements
Implementation. Supervisors work with safety inspectors to establish interim controls of hazards that cannot immediately be abated. Supervisors should request assistance from DSS for hazards that cannot be abated within 30 days of the Inspection Report.
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Implementing, documenting & tracking hazard abatements
Implementation. Unit Safety Reps & Supervisors should keep their commander informed. Maintain an active role in your safety program. Ensure abatement of all OSH deficiencies.
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Implementing, documenting & tracking hazard abatements
Documentation. Inspection Reports NAVMC 11400, OSH Deficiency Notice Copies of Work Requests Hazard Abatement Log (Electronic is ok.) unit/monthly Copies of other correspondence. ( s, etc.)
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Implementing, documenting & tracking hazard abatements
ESAMS Safety Rep Logbooks, Database Other
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Implementing, documenting & tracking hazard abatements
Let’s look at an OSH Deficiency Notice NAVMC 11400 Full page slide Section A slide Section B-C slide
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Implementing, documenting & tracking hazard abatements
SUMMARY Establish interim controls of hazards. Command informed, stay active, track all deficiencies until abated. Documentation and tracking.
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Questions?
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MISHAP INVESTIGATION AND REPORTING
MCO B
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What Is a MISHAP? Injury to USMC military personnel on or off duty.
Injury to USMC civilian personnel on-duty. Injury as a result of Marine Corps operations to non-USMC personnel. Occupational illness to USMC Personnel military or civilian
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Injury vs. Illness Injury-
Traumatic bodily harm caused by a specific event or a sequence of events within a single day or work-shift. Illness- Any abnormal bodily condition or disorder, other than an injury, caused by repeated and continued exposure to toxins, poisons, fumes, or other hazardous materials or agents associated with employment.
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LOST TIME CASE A nonfatal injury that causes any loss of time from work after the day or shift on which it occurred; or a nonfatal occupational illness that causes loss of time from work or disability at any time.
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NO LOST TIME CASE An injury or occupational illness that does not meet the definition of a lost time case. These are cases usually created by a compensation claim for payment of medical services.
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LOST WORKDAYS Total number of full days, consecutive or not, that a person was unable to work as a result of an injury or occupational illness. Applies to: Civilian Personnel Military Personnel
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Disability Permanent Total Disability
A non-fatal injury or occupational illness, which in the opinion of competent medical authority permanently incapacitates someone. Includes: Both hands, both feet, both eyes, or A combination of any two of these body parts
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Disability Permanent Partial Disability
An injury or occupational illness, that results in permanent impairment or loss of any part of the body (e.g., loss of the great toe, thumb, or a non-repairable inguinal hernia, traumatic acute hearing loss of 10 dB or greater documented by MD). EXCEPTIONS: Loss of teeth, fingernails, or toenails Loss of tips of fingers or toes, without bone loss. Inguinal hernia, if it can be repaired. Disfigurement. Sprains or strains which do not cause PERMANENT limitation of motion.
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Mishap Cost Total Cost of damage, injury, and illness from a Marine Corps mishap. Determining mishap costs = the total cost of a mishap by adding costs for all injury, occupational illness, and reportable damage. COMNAVSAFECEN will determine & calculate cost based on data received in the mishap report.
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DUTY STATUS (For reporting mishaps)
ON DUTY Performing Official military duties Transported by DOD or commercial vehicles for performing official duties Taking part in directed compulsory sports activities OFF DUTY Departed their official duty station or TAD site at COB Leave or liberty Traveling before and after official duties Participating in voluntary unit/base team sports Engaged in personal activities
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Vs REPORTABLE You need to Know! RECORDABLE
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ALL MISHAPS ARE RECORDABLE!!!
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Reportable Mishaps All Class A and Class B mishaps.
All Class C Mishaps (beyond first aid, loss of consciousness, and/or days away from work, as well as light duty or limited. All Chemical related mishaps. All Ordnance related mishaps. To include everything from an M16A2, paintball, trip flares, pyro...etc First Aid: Any one time treatment, with follow up treatment if required, to clean, bandage, or observe a scratch, cut, burn, splinter, sprained ankle, etc., not necessarily provided by competent medical authority.
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Mishap & Injury Classes
Class A - Fatality, Permanent Total Disability, or total damage costs exceeds $2 million or more. Class B - Permanent Partial Disability, hospitalization of 3 or more in 1 mishap, or total damage costs of $500,000 or more, but less than $2 mil. Class C - A Lost Time case or total damage costs of $50,000 or more, but less than $500,000
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Mishap - Damage Damage to Marine Corps property or equipment.
Damage to non-Marine Corps property as a result of Marine Corps operations.
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Damage Costs Marine Corps Property Non-Marine Corps Property
acquisition costs replacement costs repair costs Non-Marine Corps Property claims officer (when available) police reports (official estimates) mishap investigator (estimate $ damage)
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Damage Costs cont’d Calculating Damage Costs.
Repair costs include both the cost to replace all parts and repair all repairable component. Damage to USMC property as a result of non-governmental activities - only report USMC damage.
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Mishap Investigation Responsibilities
Commander - Ensure that all mishaps are investigated appropriately per the instructions in MCO P Investigative personnel include: Immediate Supervisor Safety Representative Other supporting personnel…OSH Specialist, ESO, IH…
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INDEPENDENCE SAFETY JAG
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Responsibilities Unit Safety Officer/Representative:
Investigate mishaps to determine classification and reporting requirements. Assist safety investigation boards, as required. Investigate mishaps or assist/review mishap investigations conducted by unit/department/facility/activity supervisors or shop/section safety monitors per MCO, higher headquarters, MCAS Beaufort, etc. Maintain unit mishap action plan, logs, records and reports. Initiate safety investigation reports and hazard reports as required or requested.
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Responsibilities cont’d
Unit Safety Officer/Representative: Submit monthly mishap reports to higher headquarters and MCAS Beaufort. Submit Annual Mishap Summary Report per the current issuance of MCO P to higher headquarters and MCAS Beaufort. Promulgate correction actions. Conduct follow-ups. MCO A, Enclosure (2), 3
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MISHAP INVESTIGATION AND REPORTING
Summary BLAH BLAH BLAH
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Questions?
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Do your job or you’re FIRED!
How to train & motivate subordinates on safe and healthful work practices Do your job or you’re FIRED!
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How to train & motivate subordinates on safe and healthful work practices
Set the example. Be the example. LEAD, FOLLOW, or GET THE HELL OUT OF THE WAY! Safety Training & Knowledge= Safe workers.
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Questions?
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Hazard control principles
Works in conjunction with previously discussed topics. However, safety professionals are specialists who, through training and experience, develop proficiency in risk assessment and hazard abatement. Their training includes the recognition, evaluation, and control of work center hazards and in operational training environments. NAVMCDIR5100.8 Let’s look at some specific control principles…
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Hazard control principles cont’d
Engineering Controls Substitution: Airless painting vice spray painting. Reduces atomization (air borne particles.) Electric fork lifts vice internal combustion engines. Reduces carbon monoxide exposures.
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Hazard control principles cont’d
Engineering Controls cont’d Isolation: Machine guards, to prevent exposure to points of operation and/or danger areas. Acoustical enclosures for a load air compressor. Remote controlled equipment.
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Hazard control principles cont’d
Engineering Controls cont’d Ventilation: General or dilution ventilation, is done by mixing hazardous concentrations with uncontaminated air. Local exhaust ventilation, by capturing the hazardous concentrations at the point of generation.
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Hazard control principles cont’d
Administrative Controls Standard Operating Procedures (SOPs) Technical Manuals (TM’s) Preventive Maintenance (PM’s) Adjusted work schedules Limited access to hazardous work areas Must be in writing!
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Hazard control principles cont’d
Personal Protective Equipment (PPE) Least preferred because it may reduce productivity and affords less protection than engineering or administrative controls. However, there are instances where adequate levels of risk reduction cannot be achieved through other methods, and PPE must be used, alone or in conjunction with other protective measures. (Painting aircraft in the CCF)
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Hazard control principles cont’d
Works with everything we’ve talked about. Safety professionals are always available to assist you. Controls: Engineering Administrative and/or Work Practice PPE (Last resort.)
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Questions?
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Reporting Mishaps & Near Misses
Responsibilities. MCAS Beaufort Department Heads, OICs, and/or Supervisors shall conduct internal investigations and report all ground mishaps within 48 working hours to the DSS. All mishap notifications are to be sent via to DSS.
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Reporting Mishaps & Near Misses
Military and Federal Civilian Personnel Mishap Report. All military on-duty and off-duty mishaps that result in a Class A, B, or C mishap. All federal civilian personnel on-duty mishaps that result in a Class A, B, or C mishap. Report by telephone to the DSS office during normal working hours. If the mishap occurs after the normal duty hours, weekends, or holidays, then the Staff Duty Officer is notified. Department Heads, OIC's, and/or Supervisors shall complete MCAS Mishap Report Form and submit the form to the DSS office within 48 hours working days from the date of the mishap. The Mishap Report form may be retrieved from the Beaufort intranet website at default.aspx
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Reporting Mishaps & Near Misses
Reporting Near-Misses. A near miss is an unplanned event that did not result in injury, illness, or damage but had the potential to do so. MCAS Beaufort Department Heads, OICs, and/or Supervisors shall conduct internal investigations and report all ground near-misses within 48 working hours to the DSS. All near-miss notifications are to be sent via to the DSS. The same form shall be used. Other means of reporting a near miss.
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Reporting Mishaps & Near Misses
Remember If not identified and corrected, Near Misses become Mishaps.
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Questions?
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OPERATIONAL Risk MANAGEMENT
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WHAT IS ORM? A process to assist you in performing everyday task safely and efficiently! Let’s you modify the process to fit the situation while still identifying and assessing risks and developing controls to reduce the hazards.
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WHAT ORM IS NOT A program; it IS a process
Something to prove a specific point The magical solution to all your problems
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WHY DO WE NEED ORM?
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MISHAPS The greatest risk, the person in the machine. Of all USN/USMC aviation Class A FM in FY-96, 81%(29 of 36) involved Human Error. Every Hand that flies, fixes or supports aircraft has the opportunity to introduce human error. This is very difficult to investigate. Supervisory error is human also. Here is what we are trying to do about it... The unplanned result of a behavior that is likely part of an organization’s culture
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MISHAP COSTS MILLIONS OF DOLLARS ANNUALLY AND
HUNDREDS OF DEATHS AND INJURIES
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CAUSES OF DEATH AND INJURY TO CIVILIAN PERSONNEL
DEATH AND INJURY (ON DUTY) SLIPS, TRIPS AND FALLS BACK INJURIES ARE THE MOST COMMON AND THE MOST COSTLY OFF-DUTY MOTOR VEHICLE MISHAPS
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ORM vs. Traditional Approach
Systematic Random, Individual-Dependent Proactive Reactive Integrates All Types of Risk Into Plan Safety As After-thought Once Plan is Done Common Non-standard Process/Terms Although the five steps of ORM are a lot like the decision-making process that good leaders have always used, applying a standard process is different in some important ways. - ORM is more systematic. Frequently, hazard identification and assessment is random, and highly dependent upon an individual’s past experience and organizational skills. ORM requires the operator(s) to focus on one piece of the puzzle at a time, completing each step before moving on to the next. - ORM is more proactive. It requires an attempt to identify ALL hazards, not just the things that have happened in the past. - ORM addresses all types of risk which could threaten our ability to accomplish the mission during the planning process (security, readiness, communications, enemy threats, fiscal limitations, credibility, health, personal safety, equipment failures, etc..). This allows effective prioritization of risks, which helps focus limited time/assets on the most important issues, rather than addressing safety threats as an after-thought, once the plan has been formulated. - ORM enhances communication about risk by providing a common process and set of terms. Provides a means to articulate concerns/justify decisions. - ORM calls for a conscious decision to accept or reject the assessed risk, based on the potential cost and benefit to the overall mission. It also requires a leader to communicate with the COC when risk > benefit. Conscious Decision “Can Do” Regardless of Risk Based on Risk vs. Benefit 18 8
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ORM TERMS
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HAZARD A Condition with the potential to cause personal injury, death, property damage, or mission degradation
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Expression of possible loss in terms of severity and probability
RISK Expression of possible loss in terms of severity and probability
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Feeling of Invincibility Speed, Tempo of Operations
CAUSES OF RISK Personal Work Ethic Complex Evolutions Environmental Influences Stress Human Nature High Energy Levels CHANGE!! This slide could also be titled: “The Challenges of Naval Culture” We’ve got young kids with can do attitudes, who want to do well, are afraid to say no and feel they are invincible. Couple that with sophisticated equipment, complex evolutions, arduous conditions and the infinite risk multiplier -- change -- the mother of all risk and you have the ingredients for the disasters we read about in our daily message traffic. New Technology Feeling of Invincibility Resource Constraints Complacency Speed, Tempo of Operations
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Likelihood that a hazard will result in a
PROBABILITY Likelihood that a hazard will result in a mishap or loss
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The worst credible consequence which can occur as a result of a hazard
SEVERITY The worst credible consequence which can occur as a result of a hazard
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The process of detecting hazards and assessing associated risks
RISK ASSESSMENT The process of detecting hazards and assessing associated risks
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CONTROL A method for reducing risk for an identified hazard by lowering the probability of occurrence, decreasing potential severity, or both
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ORM CONCEPTS All are responsible for using ORM
Risk is inherent in all operations Risk can be controlled
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ELEMENTS OF ORM 3 Levels of Application 4 Principles 5 Steps
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FOR SITUATIONS THAT ALLOW MORE PLANNING
3 LEVELS OF APPLICATION TIME CRITICAL(HEADWORK) 90% of ORM processes are “On the run” DELIBERATE(PRE-MISSION BRIEFING) FOR SITUATIONS THAT ALLOW MORE PLANNING 3 levels: Time Critical: The actions we take almost automatically when posed with a routine hazard: Entering intersection in your car, traffic light turns yellow, you’re going to assess the situation and make split second decisions that can impact the rest of your life. Rain, slick roads: use wipers, slow down, increase distance behind vehicle ahead of you. Deliberate: The planning that goes into making a long trip over a weekend. Using the 5 step process we’ll talk about in a couple of slides. In Depth: The planning and coordination that goes into an overseas or cross-country PCS move, where much of what happens is outside our control. IN DEPTH(LOI’S – POAM’S) LONG TERM PROCESS WITH EXTENSIVE RESEARCH AND PLANNING
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4 PRINCIPLES Accept risk when benefits outweigh cost
Accept no unnecessary risk Anticipate and manage risk by planning Make risk decisions at correct level Does the benefit outweigh the risk? If so, mitigate and accept, if not, a decision is required. Take only those risks necessary to execute mission, and remember, they are generally more easily controlled when they are identified early in the planning process. In the conduct of an evolution, if you feel the risk is too high, or goes beyond the commander’s stated intent, additional guidance from the COC needs to be sought.
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5 STEPS Identify hazards Assess hazards Make risk decisions
Implement controls Supervise That’s the 3 and 4, the 5 is a simple five step process developed to provide answers to those three questions. It provides a means to identify what can go wrong, how to prevent it from going wrong, and how to mitigate and minimize the extent of damage and injury if it goes wrong.
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IDENTIFY HAZARDS Step #1: Analyze manageable pieces of an event
Use experience as a guide “Experience is the name everyone gives to their mistakes” Oscar Wilde, 1892 Ask what if, use brainstorming, think cause and effect Step #1: What can go wrong? Take a look at an impending event and list the associated hazards that could lead to damage or injury. Ask what if.
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ASSESS HAZARDS Step #2: Prioritize identified hazards based on: Severity & Probability For each hazard identified in the previous step, determine the associated risk in terms of severity and probability. This can be pretty subjective and open for interpretation, but the most dangerous hazards and those most likely to occur should be pretty obvious. We’ll try it in a while.
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Severity + Probability
ASSESS HAZARDS Step #2: To aid in this assessment, various tools can be devised and used. This one, you can find on one of the two plastic cards I’ve given you. It lists 4 categories of varying severity. CLICK: 4 hazard probability categories, CLICK: and puts them in a matrix. For any given hazard, you can assign severity and probability categories, read the corresponding matrix box to determine the RAC. CLICK CLICK: This is an tool that makes it easier to assess the hazards. Severity + Probability of Occurrence = RAC
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MAKE RISK DECISIONS Step #3:
Consider risk control options, most serious risks first Risk versus benefit Accept when benefits outweigh the costs Reject when costs outweigh the benefits Communicate as required Consider risk control options, prioritizing, starting with the most serious risk first, or the lowest RAC, if you’re using that method. Determine from your perspective whether the benefit outweighs the risk. When in doubt, or you feel the decision should be made at a higher level, don’t be afraid to kick it up the chain of command.
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IMPLEMENT CONTROLS 1- Engineering Controls 2- Administrative Controls
Step #4: 1- Engineering Controls Barriers, ventilation 2- Administrative Controls Reject, avoid, delay, reduce Transfer, spread, compensate 3- Personal Protective Equipment A control is a method for reducing risk by lowering the probability of occurrence and/or decreasing potential severity. These are the three categories: Engineering - modification or redesigning of pertinent or appropriate hardware Administrative - developing, revising or implementing procedures germane to the process And use of appropriate PPE
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SUPERVISE Step #5: Assure controls are effective and in place
Same as any other supervisory process: Assure controls are effective and in place Maintain implementation schedules Correct ineffective risk controls Watch for change Final step, supervise, be vigilant, check use and effectiveness of controls, and look for changes in situation or conditions because, and I reiterate: change is the mother of all risk. Leadership’s personal interest in an evolution will cause additional focus by the troops. Let’s look at a scenario and try to apply this common sense approach.
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SUMMARY ORM is a process ... NOT a program Decision making tool to:
Increase ability to make informed choices Reduce risks to acceptable level ORM must become the way we do business daily. ORM is a systematic way of thinking. The process can and should be used by personnel at all levels in the COC to increase awareness of the hazards and risks involved in an operation. It enhances the ability to make informed decisions. But it’s not a program. You can equate it to leadership, which is not a program either, yet is essential and fundamental to our success. Leadership is folded into our training and doctrine from our first days in the service. ORM will be most effective if we can integrate it into our culture as completely and effectively as leadership.
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COMMON SENSE It’s just Common Sense!
Common sense is the ability to apply sound and consistent judgment regardless of formal education. More and more personnel lack the experience or suffer from a sudden loss of judgment that result in mishaps. 80% of our mishaps are a result of human factors/error 100 deaths a year, 2000 Marines separated
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ORM WORKSHEET Let’s look at one.
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EXAMPLE OPERATIONAL RISK MANAGEMENT WORKSHEET 1. MISSION/TASK:
PAGE:_____OF____ 1. MISSION/TASK: 2. DATE/TIME BEGIN: 3. DATE PREPARED: 4. HAZARDS 5. RISK LEVEL 6. CONTROL 7. HOW TO IMPLEMENT 8. HOW TO SUPERVISE 9. ARE CONTROLS EFFECTIVE (Y / N) OVERALL RISK LEVEL AFTER CONTROLS ARE IMPLEMENTED (Circle One) LOW / MODERATE / HIGH / EXTREMELY HIGH 11. PREPARED BY: (Rank, Name, Duty Title) 12. RISK DECISION AUTHORITY EXAMPLE
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5-Steps 1 2 3 4 5 1. MISSION/TASK: 2. DATE/TIME BEGIN:
3. DATE PREPARED: 4. MISSION OR TASK STEPS 5. HAZARDS 6. RISK LEVEL 7. CONTROL(s) 8. RESIDUAL RISK LEVEL 9. HOW TO IMPLEMENT 10. HOW TO SUPERVISE 11. ARE CONTROLS EFFECTIVE (Y / N) 1 2 3 4 5 5-Steps OVERALL RISK LEVEL AFTER CONTROLS ARE IMPLEMENTED (Circle One) LOW / MODERATE / HIGH / EXTREMELY HIGH 13. PREPARED BY: (Rank, Name, Duty Title) 14. RISK DECISION AUTHORITY
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“Life is tough, but it’s tougher if you’re stupid”
Sergeant John M. Stryker, USMC, in “The Sands of Iwo Jima”
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Questions?
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Questions?
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Voluntary Protection Programs (VPP) Fundamentals
Development, Validation, Implementation and Enhancement of a Voluntary Protection Programs Center of Excellence (VPP CX) Capability for Department of Defense (DoD) Voluntary Protection Programs (VPP) Fundamentals Department of Defense Voluntary Protection Programs Center of Excellence Operated by: DoD Lead Agent: Office of the Assistant Secretary of the Army (Installations and Environment)
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Objectives After this training you will be able to:
State why VPP is important to DoD and this workplace Describe two levels of VPP recognition (Star and Merit) State the benefits of VPP State the four elements of VPP and an effective Safety and Health Management System Describe your role in VPP.
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Could you find these in your Organization?
Discuss with participants what is wrong with these images.
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VPP Background In 1982, the Occupational Safety and Health Administration (OSHA) developed VPP to recognize and promote effective worksite-based safety and health management systems. The Occupational Safety and Health Administration (OSHA) on July 2, 1982, announced establishment of the Voluntary Protection Programs (VPP) to recognize and promote effective worksite-based safety and health management systems. In the VPP, management, labor, and OSHA establish cooperative relationships at workplaces that have implemented comprehensive safety and health management systems. Approval into VPP is OSHA's official recognition of the outstanding efforts of employers and employees who have created exemplary worksite safety and health management systems. OSHA offers assistance to sites committed to achieving the VPP level of excellence. The enabling legislation for VPP is Section (2)(b)(1) of the OSH Act, which declares the Congress's intent "to assure so far as possible every working man and woman in the Nation safe and healthful working conditions and to preserve our human resources B (1) by encouraging employers and employees in their efforts to reduce the number of occupational safety and health hazards at their places of employment, and to stimulate employers and employees to institute new and to perfect existing programs for providing safe and healthful working conditions. . ."
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Why VPP in DoD? Preventable injuries and illnesses cost the DoD an estimated $10 to $21 billion annually, according to the National Safety Council. “Our goal is zero preventable accidents, and I remain fully committed to achieving the 75% accident reduction target in 2008 “- Secretary of Defense 2007
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OSHA VPP Programs VPP compares YOUR Safety and Health management system to key elements found in the BEST S+H management systems. Program Levels: – Star – Highest level of recognition All VPP Elements/Sub-elements in Place Injury and illness rates below the national average. – Merit – Working toward Star Some Elements/Sub-elements may not be in place Rates may be above national average Sets time limit for achieving Star. Merit status is a temporary state. A site cannot enter into the VPP with the expectation that they will maintain Merit status; the intent is to continuously improve and ultimately achieve Star status.
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VPP Benefits Improved safety and health for workers Cost savings
Average injury/illness rates of VPP Star sites are 52% below those of their industry peers. Cost savings Lost time and property Disruption and lost productivity Medical treatment Workers compensation. Improved morale and productivity. Benefits of VPP attainment at military installations can include: Increases in available end strength, which positively affects force readiness Improvements in employee morale & worksite productivity Increased understanding of safety & health requirements, providing supervisors & employees with focus & direction Improved lines of communication, which provide better opportunities for feedback Increased knowledge sharing within & between military services, agencies & private sector Please be sure to acknowledge that it is very common for sites to experience an initial SPIKE in their injury rates as they begin working toward VPP. Correlated to increased communication and awareness about the importance of injury (and near miss) reporting. It isn’t the injuries that are increasing, but the reporting of those injuries.
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Keys to VPP Success Look at Safety and Health in a different way
It’s not a program, it’s a core value It’s not just meeting requirements - it’s eliminating hazards “We don’t do it until we can do it safely.” Managers are committed to worker safety. Other items to possibly touch upon is the culture being the key and creating a supportive atmosphere to foster safety as a core value.
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Keys to VPP Success Involve workers in finding hazards and making decisions: They know where the hazards are They know what works for them, and what doesn’t. Union support Empower everyone to see, report, act Pursue systematic continuous improvement. Other items to possibly touch upon is the culture being the key and creating a supportive atmosphere to foster safety as a core value.
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VPP Elements VPP is a process, a culture, not an inspection.
There are four main elements to this process: – Management Leadership and Employee Involvement – Work Site Analysis – Hazard Prevention and Control – Safety and Health Training.
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Management Leadership
Managers lead the way by: Making safety expectations clear to all (policies, goals, objectives, responsibilities, assignments) Creating ways for workers to be heard on safety and health issues (committees, self inspections, reporting systems, etc.) Allowing time for safety activities Setting an example Ensuring workers and contractors are provided high quality safety and health protection. Critical concept: Assigned accountability is essential in triggering a culture change. Having responsibilities identified is only part of the equation. Leadership and employees must be able to recognize what it means to fulfill those responsibilities… and having defined measurable goals and objectives is necessary to establish clear accountability.
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Employee Involvement Employee involvement in at least three meaningful ways: Participating in safety and health committees, events, reviews, inspections, investigations, etc. Learning about the safety and health management system, and sharing that knowledge with others Reporting hazards and submitting ideas for improvement Participating in the development or review of Job Hazard Analyses Awareness of the installation’s VPP participation Understanding the basic principles of VPP.
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Work Site Analysis Analyze safety and health hazards such as:
Safety Office inspections Industrial Hygiene Surveys Job Hazard Analysis Prior review of new processes Investigate mishaps and near misses Routine self inspections. May want to emphasize that this is clearly NOT a regulatory requirement, but it is a MINIMUM requirement of VPP. The employer must use a JSA or any equally effective method for conducting a hazard analysis. The employer may use ANY system for hazard analysis as long as it: adequately identifies the hazards of the job, documents the hazards, and ensures tracking of identified hazards to correction in a timely manner.
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Work Site Analysis Report and record hazards Analyze data and trends
Track until completed. Analyze data and trends Mishaps Near misses Hazards found in inspections, self- inspections Hazards reported by employees. May want to emphasize that this is clearly NOT a regulatory requirement, but it is a MINIMUM requirement of VPP. The employer must use a JSA or any equally effective method for conducting a hazard analysis. The employer may use ANY system for hazard analysis as long as it: adequately identifies the hazards of the job, documents the hazards, and ensures tracking of identified hazards to correction in a timely manner.
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Hazard Prevention and Control
Hazard Prevention and Control includes: Access to qualified safety and health professionals Access to qualified medical/health professionals Utilizing control measures, such as: Preventive maintenance of facilities and equipment Emergency systems (drills, training, response). Hazard controls are understood, followed and enforced. Improved process design Hazmat substitution or elimination Confined space access controls Lockout/tagout Machine guards Personal protective equipment.
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Safety and Health Training
Safety and Health Training includes: – Hazard recognition – Worksite hazards – Signs and symptoms of workplace related illnesses – Job specific hazards – Protective measures – Personal protective equipment – Emergency evacuation – Employee rights under OSHA – VPP fundamentals. Example for Hazards at the site: Job Safety Analyses, Job Hazard Analyses, etc. Example of Protective Measures: PPE, process specific hazard controls, etc. Example for Emergency evacuation: Evacuation route, where to assemble after evacuation, etc. Example for Employee Rights under OSHA: OSHA Hazard Communication Act (Worker Right to Know), injury/illness reporting, etc. Example for VPP: Fundamental Principles of VPP, and the right to file a complaint Some other General Training Program Requirements include: – Attendance must be documented – Frequency must meet OSHA standards – Additional training is required for changes in processes, new equipment, new procedures, etc. – Curricula must be up-to-date and specific to worksite – Curricula must be modified for changes in worksite, hazards, controls, etc.
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Summary In this session you learned about: Why VPP is significant
Two levels of VPP recognition (Star and Merit) The benefits of VPP The four elements VPP and an effective Safety and Health Management System. The employee’s role in VPP.
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Questions?
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Any Saved Questions?
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Congratulations! This training has met the requirements of:
4 Hour Minimum Supervisor safety training. Operational Risk Management annual/refresher training. Job Hazard Analysis initial/refresher training. Voluntary Protection Program (VPP) one-time requirement.
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