CTB Inc. Annual Safety Audit

• Site conducted

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• Conducted on

  Date

• Prepared by

• Overview of auditing procedures and scoring methodologies

New Hire Orientation: These criteria evaluate the compliance level to certain CTB Corporate Safety Guidelines and the general safety culture of the operation. Rating management involvement or pro-action toward safety activities is more subjective than other performance issues but is an extremely important aspect to evaluate.

• No new hire orientation, or new hires are given a brief and undocumented safety orientation.

• New hires are given a formal safety orientation and documentation is kept.

• New hires are given a formal safety orientation and documentation exists. The safety expectations are communicated to the employees and hazard training is given for the tasks they are expected to perform.

• New hires are given a formal safety orientation and documentation exists. The safety expectations are communicated to the employees and hazard training is given for the tasks they are expected to perform. Follow-up is made several times after the initial orientation to ensure training was understood. The safety program is presented as a positive activity.

• New hires are given a formal orientation and documentation exists. The safety expectations are communicated to the employees and hazard training is given for the tasks they are expected to perform. An individual sign off form is kept for the task specific training presented. Follow-up is made several times after the initial orientation to ensure training was understood. First follow-up is made within 30 days of initial training and is documented. The safety program is presented as a positive activity.

• Subsection Rating

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Safety Program Location: These criteria evaluate the compliance level to certain CTB Corporate Safety Guidelines and the general safety culture of the operation. Rating management involvement or pro-action toward safety activities is more subjective than other performance issues but is an extremely important aspect to evaluate.

• No copy of the Location or Corporate Safety Programs are available on-site.

• Safety Programs are on-site but are not used.

• Safety Programs are on-site and are used; but have not been updated for two years.

• A current copy of the Safety Program is on-site and used as the safety program guidelines. The guidelines are updated to the most recently released programs.

• A fully updated current copy/copies of the Safety Programs are on-site and are clearly used as the safety program guidelines. File organization for safety related items is particularly good and management has a high level of understanding about the guidelines' contents. No written safety programs, files, or documentation is missing.

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Safety Policy: These criteria evaluate the compliance level to certain CTB Corporate Safety Guidelines and the general safety culture of the operation. Rating management involvement or pro-action toward safety activities is more subjective than other performance issues but is an extremely important aspect to evaluate.

• No Safety Policy has been developed.

• Safety Policy has been developed but is not posted for visitors and employees.

• Both the CTB Corporate and the Location safety policies are posted.

• Both the CTB Corporate and the Location safety policies are posted in areas visible to the employees and visitors. They are signed by the plant manager and Business Unit Manager. The Department of Labor Job Safety and Health poster is displayed.

• The safety policies are posted in highly visible areas for employees and guests. The safety policy is given to all employees during their orientation. Visitors are given a safety orientation prior to touring the facility. The Department of labor Job Safety and Health poster is displayed.

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Management Involvement: These criteria evaluate the compliance level to certain CTB Corporate Safety Guidelines and the general safety culture of the operation. Rating management involvement or pro-action toward safety activities is more subjective than other performance issues but is an extremely important aspect to evaluate.

• Plant management demonstrates no involvement in the safety process.

• Most of the safety activities are delegated to others in the organization and management does little to follow-up on the safety activities.

• Plant management is aware of major safety related problems. Daily safety activities are delegated to others and management is kept abreast of those activities.

• Plant manager/location manager participates in most of the meetings. All incident investigations are either performed or reviewed and signed by the plant manager. Management takes a genuine interest and participates in the daily safety related activities.

• Plant manager/location manager participates and attends most safety meetings. All incident investigations are either performed or reviewed and signed by the plant manager/location manager and reviewed with the Business Unit Manger. Annual safety goals and objectives are set, and supervisors are held accountable for safety performance. Management is involved with all safety related activities, promote safety in a variety of ways, and reinforce safety expectations to the workforce.

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Goals and Objectives: These criteria evaluate the compliance level to certain CTB Corporate Safety Guidelines and the general safety culture of the operation. Rating management involvement or pro-action toward safety activities is more subjective than other performance issues but is an extremely important aspect to evaluate.

• Management sets no measurable safety goals or objectives.

• Some safety goals and objectives are set, but they are not measurable nor designed to reduce accidents.

• Safety goals and objectives are set. They indicate a reduction in losses, but do not specify safety activities or responsibilities that will allow such losses to be achieved.

• Management directs the safety effort by setting annual safety goals and by planning, organizing, and controlling to achieve them. Goals and objectives are measurable, achievable, and justifiable, and are designed to reduce accidents and the costs associated with them. Goals and objectives are review with all affected employees.

• Management directs the safety effort by setting annual safety goals and by planning, organizing, and controlling to achieve them. Goals and objectives are measurable, achievable, and justifiable, and are designed to reduce accidents and the costs associated with them. Goals and Objectives are reviewed with all affected employees. Management is held accountable for achieving the stated goals and objectives.

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General Guidelines Scoring

• Total Rating: 5 Points Possible

Housekeeping: Applicable OSHA Standard: 1910.22 Good housekeeping is perhaps the single most important aspect to maintaining a safe and healthful work environment. The term housekeeping is used in a broad and comprehensive sense to include: • Tidiness and order (5S) • Waste control • Storage of goods • Aisleway arrangement • Exterior maintenance and landscaping • Equipment and operations arrangement A good housekeeping program has many benefits including: reduced operating costs, material conservation, better use of floor space, reduced fire hazards, and improved morale. The overall impression of your facility is influenced by the housekeeping more than any other single factor. The performance issues to consider are trash removal, aisles, smoking, and general appearance

Waste Removal: Housekeeping

• There is an excessive amount of trash and waste in most work areas. The dumpster is overfull. There is no program for regular cleanup.

• There is an excessive amount of trash in some work areas. The dumpster is full and in need of emptying. Trash removal is done on an "as needed" basis.

• Trash and waste accumulation interfering with work process in some areas. Trash removal is done as needed.

• Trash or waste (paper, material scraps, etc.) was noted in some areas but does not interfere with the work process.

• Frequent waste removal from production areas keeps waste to an absolute minimum. Shops, storage rooms, and equipment rooms are kept impeccably clean and orderly. A recycling program is in place.

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Aisles: Houskeeping

• Aisleways are crowded and not marked.

• Aisleways are crowded in most areas and generally are not marked.

• Crowded conditions exist in some areas. Aisleway markings are incomplete and/or improper.

• Aisleways are uncrowded with limited exceptions. Most designated aisleways are marked.

• No aisleway crowding exists. All designated aisleways are marked properly.

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General Appearance: Houskeeping

• Overall housekeeping, exterior building condition, rest rooms, and parking lot are poorly maintained. General impression of facility is unacceptable.

• There are deficiencies in the way of cleanliness, maintenance, or arrangement in any three of the following areas: overall housekeeping, exterior building condition, rest rooms, or parking lot.

• There are deficiencies in the way of cleanliness, maintenance, or arrangement in any two of the following areas: overall housekeeping, exterior building condition, rest rooms, or parking lot.

• There are only limited deficiencies in the way of cleanliness, maintenance, or arrangement in any of the following areas: overall housekeeping, exterior building condition, rest rooms, parking lot, or exterior grounds.

• Management shows an extra concern for all areas of housekeeping mentioned above. A rating of four (4) or higher in all the other performance issues for housekeeping was achieved.

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Housekeeping Scoring

• Total Rating: 5 points possible

SAFETY COMMITTEE Description: This section will be used to evaluate the Safety Committee activities and how those activities compare with the CTB Corporate Safety Guidelines concerning Safety and Health Committee organization. The performance issues to consider are: Safety Committee organization, documentation of the activities, and meeting content.

Safety Committee: Organization

• There is no organized Safety Committee structure.

• A Safety Committee has been organized and meets sporadically. Minutes of the committee meetings are maintained

• A Safety Committee has been organized and meets monthly. Minutes of the committee meetings are maintained. The membership of the Safety Committee, including all chairpersons, has been identified.

• A Safety Committee has been organized and meets monthly. The membership of the committee has been identified and the plant manager attends most meetings. The minutes of the Safety Committee activities are posted for the workforce to review.

• A Safety Committee has been organized for at least one year. The membership of the committee has been identified, the plant manager attends most meetings, and an organizational chart is posted. The Safety Committee activities have been identified for twelve months in advance, and the plan is being followed. The minutes of the Safety Committee activities are posted and there is high degree of awareness about the Safety Committee efforts among the workforce.

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Safety Committee: Documentation

• There is no documentation (minutes) supporting the Safety Committee activities.

• There is documentation supporting the Safety Committee efforts. There is at least six months of documentation in file.

• Documentation supports the Safety Committee efforts. There is at least twelve months of documentation in file.

• Documentation supports the committee's efforts and there are minutes in file for the past twelve months. The minutes of the Safety Committee meetings are posted for the workforce to review. The Safety Committee file is well organized, and no minutes are missing.

• The most recent minutes of the Safety Committee activities are posted and there is a high degree of awareness about the Safety Committee efforts among the work-force. Documentation supports the Safety Committee activities for the past year and no minutes are missing. A log of outstanding issues is maintained to document action, responsible parties, and completion dates. The Safety Committee file is organized such that the program could continue with the absence of any member.

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Safety Committee: Meetings

• Safety meetings are not being held

• Safety meetings are held periodically and meeting content centers around facility inspections.

• Safety meetings are held monthly with each member reporting their activities.

• Safety meetings are held monthly with each member reporting their activities. The minutes reflect a pro-active approach to accident prevention. Committee establishes written goals and objectives for itself and monitors status until completion.

• Safety meetings are held monthly with each member reporting their activities. There is good coordination of the efforts and there is pro-active approach to accident prevention. A schedule for future meetings has been established. Participation in the safety effort of the facility is plant-wide with the involvement of much of the workforce. Committee establishes written goals and objectives for itself and monitors status until completion.

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Safety Committee Scoring

• Total Rating: 5 points possible

Incident Investigation: Incident investigation is an important aspect of the loss control efforts. The CTB Corporate Safety Guidelines are specific in the procedures to be followed. The performance issues to evaluate are use of guidelines and recommendations

Incident Investigation: Guideline Use

• CTB Corporate incident investigation procedures and paperwork are not used.

• There is an inconsistent approach to the incident investigation procedure. There is not a designated person completing the investigation paperwork.

• The required incident investigation paperwork is used. There are several people which may be completing the investigation paperwork but not necessarily the employee's immediate supervisor. Safety Alerts are being developed and sent to CTB EHS Corporate in a timely manner.

• There is a written policy requiring all incidents and near misses to be thoroughly investigated. Incident investigation training has been completed and the proper paperwork is used. The employee's immediate supervisor completes the investigation and paperwork within 48 hours. Safety Alerts are being developed and sent to CTB EHS Corporate in a timely manner.

• There is a written policy requiring ail accidents and near misses to be thoroughly investigated. Accident investigation training has been completed and the proper paperwork is used. The employee's immediate supervisor completes the investigation and paperwork immediately after each accident. All accident investigation documentation is reviewed by the plant manager/location manager who signs off on the report. Safety Alerts are being developed and sent to CTB EHS Corporate in a timely manner.

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Incident Investigation: Recommendations

• Recommendations are not made in the incident investigation process.

• Recommendations are sometimes made to prevent a recurrence of the accident. Of a minimum of five random files reviewed, two would contain appropriate recommendations reviewed by management.

• Recommendations are generally made to prevent a recurrence of the accident. Of a minimum of five random files reviewed, three would contain appropriate recommendations reviewed by management.

• Recommendations are always made to prevent a recurrence of the accident. Of a minimum of five random files reviewed, four accident investigations would contain appropriate recommendations reviewed by management and the Safety Committee.

• Recommendations are always made to prevent a recurrence of the incident. Of a minimum of five random files reviewed, all incident investigations would contain appropriate recommendations reviewed by management and the Safety Committee. Recommendations are written as action plans with person responsible and date for correction given. Similar situations or tasks are changed, and retraining accomplished for affected employees.

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Incident Investigation: Total Scoring

• Total Rating: 5 Points Possible

Ergonomics: The study of the man/machine relationship with the goal of matching the workplace to the worker. CTB’s goal is the development of an ergonomic program designed to prevent repetitive motion disorders or cumulative trauma disorders. The expectations in this area are to have all workers trained in ergonomic principles and for engineering to evaluate jobs on an ongoing basis for work design improvements. The performance issues to evaluate are training, medical management, workstation analyses, documentation, and employee inquiries

Ergonomics: Training

• No ergonomic training program is in place.

• Training has been completed for management and supervisors.

• Initial ergonomic training completed for entire workforce consisting of video presentation and supervised instruction. New employees receive orientation concerning ergonomics.

• Initial ergonomic training completed for entire workforce as above. New employees receive orientation concerning ergonomics. Injured employees are retrained as needed prior to returning to their regular job.

• Annual training is accomplished for all employees and documentation exists which supports this annual training. All employees questioned about ergonomics had a working knowledge of the ergonomics program. There is a high degree of awareness generated in the plant with ergonomic related safety posters, etc

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Ergonomics: Medical Management

• The local medical care provider is not involved in any degree with the ergonomic program on a prevention basis.

• The local medical provider is available for consultation. There is a focus on prevention rather than treatment and conservative return to work is practiced following a repetitive motion disorder.

• The local medical provider is available for consultation. There is post-injury analysis done to investigate job modification or retraining remedies. Retraining of the injured employee is done prior to returning them to work. The focus is toward prevention of claims rather than treatment.

• The local medical provider has visited the plant. There is post-injury analysis done to investigate job modification or retraining remedies. Job Hazard Analyses (JHA's) are used when appropriate. Retraining of the injured and other potentially affected employees is done. Medical management focus is prevention rather than treatment.

• Medical management focus is prevention rather than treatment. The local medical provider has visited the plant. There are established exam procedures for employees who present symptoms of repetitive trauma and a protocol for referring employees to medical experts as a means of prevention. There is post-injury analysis done to investigate job modification or retraining remedies. JHA's are used when appropriate. Retraining of the injured and other potentially affected employees is done. Modified or alternative work is established to allow the injured employee back into the workforce as soon as possible.

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Ergonomics: Workstation Analysis

• No ergonomic Job Hazard Analyses (JHA's) have been completed.

• A minimum of two (2) ergonomic Job Hazard Analyses (JHA's) have been completed.

• A minimum of three (3) ergonomic Job Hazard Analyses (JHA's) have been completed. Ergonomic baseline surveys were completed for those jobs and proper documentation exists.

• A minimum of four (4) ergonomic Job Hazard Analyses (JHA's) have been completed. Ergonomic baseline surveys were completed for those jobs and proper documentation exists. Video tapes supporting the evaluations are kept in file. Improvements were accomplished in the jobs studied, and these improvements have been shared with other facilities.

• At least five (5) ergonomic Job Hazard Analyses (JHA's) have been completed as stated above. There are additional jobs which have been identified and there is a schedule for those evaluations to be completed. Cost/benefit analysis is done for the evaluations completed and long-range planning has been set for ergonomic improvements. Outside resources are consulted for special assistance with problems beyond the expertise of plant personnel.

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Ergonomics: Employee Inquiry Five employees should be selected at random to answer the following questions: A) Are you aware there is an ergonomic program in effect in the plant? B) Have you received any ergonomic training? C) What is management's response to your suggestions concerning job design or work modifications?

• Of the five employees questioned, none had any awareness of the ergonomic program in the plant.

• Of the five employees questioned, one had knowledge of the ergonomic program.

• Of the five employees questioned, two or three had knowledge of the ergonomic program.

• Of the five employees questioned, four had knowledge of the ergonomic program and were aware that ergonomic safety suggestions or concerns could be reported to management.

• Of the five employees questioned, all employees were aware of the ergonomic program, had received some form of training within the past year, and were aware that ergonomic safety suggestions or concerns could be brought to management.

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Ergonomics: Total Scoring

• Total Rating: 5 Points Possible

Lockout/Tagout: Is an OSHA mandated safety program which is designed to protect workers against unexpected start-up of equipment and machinery which is being serviced or repaired. The standard requires that all potential sources of energy, such as electricity and compressed air, be de-energized and locked out to prevent the equipment from starting while it is being repaired or serviced. The performance issues to consider are documentation, training, procedures, equipment, and employee inquiry. Two (2) is the max score if Lockout Procedures are not on equipment and the equipment lockout points are not identified. This is based on CTB’s Updated Standard. Applicable OSHA Standard: 1910.147

Lockout/Tagout: Documentation

• No documentation exists supporting the lockout/tagout program.

• Documentation is in file supporting the training that has been accomplished. Two (2) is the max score if Lockout Procedures are not on equipment and the equipment lockout points are not identified.

• Documentation is in file supporting the training that has been accomplished. There is a written Lockout/Tagout program.

• Documentation is in file supporting the training that has been accomplished. There is a written Lockout/Tagout program. Specific procedures for the equipment are in written form listing the sequential steps to follow for proper lockout/tagout of equipment with multiple sources of energy.

• All the above listed criteria for Documentation have been met. Records are maintained documenting Lockout/Tagout activities. Documentation concerning the annual audit of the Lockout/Tagout program is available and includes the names of each Authorized person audited. There are safety-related posters, warning stickers, or other awareness type literature posted to reinforce proper lockout/tagout procedures.

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Lockout/Tagout: Training

• There has been no formalized and documented training.

• "Authorized employees" have been trained.

• Authorized employees have been trained and "affected employees" have been given training to recognize lockout/tagout of equipment so as not to compromise the lockout safety procedure.

• Affected and Authorized employees have received the initial training and an annual follow-up has been done or is planned. Periodic training is scheduled, and new hire orientation contains training. Training materials such as videos or handouts are available and distributed for training purposes.

• All the above and all employees questioned about lockout/tagout had a working knowledge of the program.

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Lockout/Tagout: Procedures

• There are no formalized procedures for lockout/tagout.

• Authorized employees are practicing lockout/tagout procedures but are not supported by documented directives or training.

• Procedures are written concerning how each machine is to be locked and tagged out. However, OSHA's six step procedure is not used.

• Procedures are written concerning how each machine is to be locked and tagged out. OSHA's six step procedure is used. There is an annual inspection/review of procedures and an audit of authorized employee practices to ensure the program is effective and used properly.

• All the above-listed criteria for Procedures have been met. Authorized employees are practicing lockout/tagout procedures with specific directives which are documented. There is evidence that the proper procedures and equipment are being used.

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Lockout/Tagout: Equipment

• There is no equipment provided to lock or tag out machinery.

• Padlocks are available for the authorized employees to lockout machinery.

• Padlocks and tags are available to specific Authorized employees. The lockout/tagout equipment is neatly arranged on a lockout board or cabinet.

• Lockout equipment has been provided for all potential sources of energy (electric, hydraulic, pneumatic, compressed air). Padlocks and tags have been assigned to specific authorized employees. The lockout/tagout equipment is neatly arranged on a lockout board or cabinet. Padlocks and tags are standardized by size, shape and/or color, and format.

• All the above, plus Authorized personnel have been assigned multiple padlocks for locking out all sources of energy on one piece of equipment. There is evidence that the proper procedures and equipment are being used.

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Employee Inquiry: Two authorized and three additional employees, selected at random, should be asked the following questions. A) Have you received training in lockout/tagout procedures? B) Where is the written lockout/tagout policy/program for the plant? C) Do you have lockout equipment specifically assigned to you? (If authorized) D) Do you believe the lockout program to be effective?

• Of the five employees questioned, none had any awareness of the lockout/tagout program in the plant.

• Of the five employees questioned, only one was able to answer the listed questions and had a working knowledge of the lockout/tagout program.

• Of the five employees questioned, two or three were able to answer the listed questions and had a working knowledge of the lockout/tagout program.

• Of the five employees questioned, four were able to answer the listed questions and had a working knowledge of the lockout/tagout program.

• Of the five employees questioned, all were able to answer the listed questions and had a working knowledge of the lockout/tagout program. Training of the employees has been within the last year and lockout equipment was assigned to authorized employees.

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Lockout/Tagout: Total Scoring

• Total Rating: 5 Points Possible

HAZARD COMMUNICATION: Haz-com, or Right-To-Know is an OSHA mandated safety program whose purpose is to ensure that information concerning the hazards of chemicals is transmitted to the employees working with or around those chemicals. This standard requires a high degree of employee training, labeling of hazardous chemicals, and availability of Safety Data Sheets (SDS) for each hazardous chemical. The performance issues to consider are documentation, training, labeling, SDS organization, and employee inquiry. Applicable OSHA Standard: 1910.1200

Hazard Communication: Documentation

• No documentation exists supporting the Hazard Communication program.

• Documentation is in file supporting the training that has been accomplished.

• Documentation is in file supporting the training that has been accomplished. There is a written Hazard Communication program.

• Documentation is in file supporting the training that has been accomplished. There is a written Hazard Communication program. SDS's and chemical inventory are readily available to all employees.

• All the above-listed criteria for Documentation have been met and the documentation concerning the Hazard Communication program is organized in a neat fashion and readily available. There are no labels, SDS's, training files, or chemical inventories missing. There are safety-related posters, warning stickers, or other awareness type literature posted to reinforce hazard communication compliance, safe use of chemicals, etc.

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Hazard Communication: Training

• There has been no formalized and documented training.

• Select employees who deal with most of the chemicals have received training.

• Initial training has been completed for all employees.

• All employees have received the initial training and an annual follow-up has been done or is planned. Periodic training is scheduled, and new hire orientation contains training in these regards. Training materials such as videos or handouts are available and distributed for training purposes. Supervisors have a working knowledge on how to secure an SDS from the electronic data system.

• All the above and all employees questioned about hazard communication had a working knowledge of the program. They understand chemical labeling, know where SDS's and written programs are kept, and use safe work practices when handling chemicals.

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Hazard Communication: Labeling

• There is no labeling system for chemicals. More than fifteen (10) containers were noted without labels.

• There is no formalized system to ensure all chemicals are properly labeled in a standardized fashion. There were at least ten (8) incidents where hazard labels were missing or incomplete.

• A standardized system has been developed to ensure chemicals are properly labeled, but there were at least five (5) incidents where a hazard label were missing or incomplete.

• A standardized system has been developed to ensure chemicals are properly labeled, but there were at least three (3) incidents where hazard labels were missing or incomplete. All original labels are in the GHS format.

• A standardized system has been developed to ensure chemicals are properly labeled and there were no incidents where hazard labels were missing. All original chemical containers were labeled with the GHS format and plant labels were in the GHS and/or HMIS format. There are safety posters, awareness bulletins or signs reinforcing the labeling system and the meaning of the various labeling terminology.

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Hazard Communication: SDS Organization

• There is no organization of the SDS's.

• There is a collection of SDS’s, but they are not organized in a fashion making them readily available and are out-of date or incomplete.

• There is an inventory of chemicals in the E Binder and it is up to date.

• There is an inventory list of all chemicals. The SDS's are organized in the E Binder and made available to the workforce. Chemicals no longer in use have been archived.

• All criteria listed above, and there are no SDS's missing. Contractors provide SDS's for chemicals they bring to the facility.

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Hazard Communication Inquiry: Five employees should be selected at random and asked the following questions. A) Have you received training in Hazard Communication? B) Where is the written Hazard Communication policy/program for the plant? C) Where are the SDS's and do you have access to them? D) What chemicals do you use in your job? E) What is the meaning of the pictograms on labels, if any, on the chemicals you use?

• Of the five employees questioned, none were able to answer any of the questions listed above and had no awareness of the Hazard Communication in the plant.

• Of the five employees questioned, only one was able to answer most of the listed questions and had basic knowledge of the Hazard Communication program.

• Of the five employees questioned, two or three had basic knowledge of the Hazard Communication program and could answer the listed questions.

• Of the five employees questioned, four had knowledge of the Hazard Communication program and were able to answer the listed questions and they knew how to access the SDS’s from the electronic data base.

• Of the five employees questioned, all employees were knowledgeable of the Hazard Communication program and answered the listed questions. All employees have received some form of Hazard Communication training within the past year and were aware that health related, or chemical use concerns could be brought to management.

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Hazard Communication: Total Scoring

• Total Rating: 5 Points Possible

Bloodborne Pathogens: is an OSHA mandated safety program whose purpose is to ensure that necessary precautions are taken when handling potentially infectious body fluids. This standard requires a high degree of employee training, medical waste disposal, personal protective equipment, and employee inquiry. The performance issues to consider are documentation, training, medical waste disposal, and personal protective equipment, and employee inquiry.

Bloodborne Pathogens: Documentation

• No bloodborne pathogens program documentation exists.

• There is a written Exposure Control Plan. There is limited or no documentation of training, Hepatitis B vaccinations, annual review, or waste manifests.

• There is a written Exposure Control Plan. Some documentation exists of training, Hepatitis B vaccinations, annual review, and waste manifests.

• There is a written Exposure Control Plan. Initial bloodborne pathogens training has been completed and documented. Hepatitis B vaccination has been made available to occupationally exposed employees and is properly documented as to who has received or declined the shots.

• There is a written Exposure Control Plan. Initial bloodborne pathogens training has been completed and properly documented with the name and job title of the employee, name and job title of the trainer, contents of training, and date. Hepatitis B vaccination has been made available to occupationally exposed employees and is properly documented as to who has received or declined the shots. Manifests from the medical waste disposal are maintained in file. There is documentation of the annual written Exposure Control Plan review.

• Subsection Rating

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Bloodborne Pathogens: Training

• No bloodborne pathogens training is done.

• Initial training done for occupationally exposed employees.

• Initial training done for occupationally exposed employees. All other employees received initial awareness training.

• Annual training is done for occupationally exposed employees, and this is properly documented. Training materials such as videos or handouts are available and distributed for training purposes. All other employees receive annual awareness training.

• All the above and all employees questioned about bloodborne pathogens had a working knowledge of the program.

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Bloodborne Pathogens: Medical Waste Disposal

• There is no plan for disposing of medical waste. it is discarded as regular trash.

• Red biohazard bags or sharps containers are available, but medical waste is discarded as regular trash.

• Provisions for proper disposal of biohazard waste have been arranged with a licensed hauler. Red biohazard bags or sharps containers are used, and extra supplies are available.

• Provisions for proper disposal of biohazard waste have been arranged with a licensed hauler. Red biohazard bags and sharps containers are used, and extra supplies are available. Manifests from the licensed hauler are maintained in file.

• Provisions for proper disposal of biohazard waste have been arranged with a licensed hauler. Red biohazard bags and sharps containers are used, and extra supplies are available. Manifests from the licensed hauler are maintained in file.

• * Subsection Rating

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Bloodborne Pathogens: PPE

• No bloodborne pathogens program personal protective equipment or clean-up kit is available.

• Either a clean-up kit or latex gloves are available.

• A clean-up kit and disinfectant are available. Latex gloves are available to first responders.

• A clean-up kit and disinfectant are available. Latex gloves, aprons, goggles, face masks, and booties are available and used by first responders.

• A clean-up kit and disinfectant are available. Latex gloves, aprons, goggles, face masks, and booties are available and used by first responders. Utility gloves are available and used to scrub work surfaces. Employees have been trained how to don and doff personal protective equipment.

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Bloodborne Pathogens: Employee Inquiry Five employees should be selected at random and asked the following questions. A) Do you know what Bloodborne Pathogens are? B) Have you received training in the Bloodborne Pathogens Program' C) What do you do if you see an injured employee who is bleeding?

• Of the five employees questioned, none were able to answer any of the questions listed above and had no awareness of the Bloodborne Pathogens Program in the plant.

• Of the five employees questioned, only one was able to answer most of the listed questions and had basic knowledge of the Bloodborne Pathogens Program.

• Of the five employees questioned, two or three had basic knowledge of the Bloodborne Pathogens Program and could answer the listed questions.

• Of the five employees questioned, four had knowledge of the Bloodborne Pathogens Program and were able to answer the listed questions.

• Of the five employees questioned, all employees were knowledgeable of the Bloodborne Pathogens Program and answered the listed questions. All employees have received some form of bloodborne pathogens training within the past year.

• Subsection Rating

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Bloodborne Pathogens: Total Scoring

• Total Rating: 5 Points Possible

Hearing Conservation: is a program whose purpose is to ensure that employees are protected from noise overexposure. A hearing conservation program is necessary when an employees eight-hour time-weighted-average exceeds 85 dBA. The performance issues to consider are sound level measurements, documentation, employee training, and hearing protection. Applicable OSHA Standard: 1910.95

Hearing Conservation: Sound Level Management

• The noise exposure in the plant has not been evaluated in the last three years.

• The noise exposure has been evaluated in the last three years, but there is no documentation supporting the results.

• The noise testing has been completed within the past two years using sound level meters. Documentation supports the noise exposure evaluation of the entire plant.

• The noise testing has been completed within the past two years using sound level meters and noise dosimeters and high noise areas are identified based on 8-hour time-weighted average. Documentation supports the noise exposure evaluation of the entire plant.

• Noise measurements have been taken within the year with calibrate sound level meters and noise dosimeters. There is a detailed noise survey to indicate the eight-hour time-weighted average noise levels, minimum and maximum noise levels, percent dosage, sampling time, instrument calibration, and other related information. Engineering controls are used where feasible to reduce noise levels. If there is no documented noise exposure, and monitoring is done when there are changes in machinery or production processes that may result in increased noise levels, a five (5) rating can be given.

• Subsection Rating

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Hearing Conservation: Documentation

• There is no documentation regarding noise testing or hearing conservation.

• There is documentation of either noise testing or a hearing conservation program

• There is documentation of noise testing and a hearing conservation program. The noise testing has been completed within the past two years using sound level meters or noise dosimeters.

• There is documentation of noise testing and a hearing conservation program. The noise testing has been completed within the past two years using sound level meters or noise dosimeters. Annual audiograms are performed for affected employees and documented. There is documentation of annual training. Hearing protection signs are posted.

• There is a detailed noise survey to indicate the eight-hour time-weighted average noise levels, minimum and maximum noise levels, percent dosage, sampling time, instrument calibration, and other related information. A comprehensive written Hearing Conservation program including annual training, audiograms of affected employees, periodic monitoring, and use of personal protective equipment is in place. Annual audiograms are performed for affected employees and documented. Audiograms are kept for 30 years. There is documentation of annual training. The Hearing Conservation Standard and hearing protection signs are posted. If there is no noise exposure, and monitoring is done when there are changes in machinery or production processes that may result in increased noise levels, a five (5) rating can be given.

• * Subsection Rating

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Hearing Conservation: Employee Training

• A hearing conservation program is necessary, but no formal training is done.

• There was informal hearing conservation training in the past, but nothing documented. At least three employees who need hearing protection were noted without it.

• There was initial training for affected employees in the effects of noise, use and limitations of hearing protection, and the purpose of audiograms. Documentation of training is maintained. In at least one case, an employee in a hearing conservation area was noted without hearing protection.

• In the past two years, there was training for affected employees in the effects of noise, use and limitations of hearing protection, and the purpose of audiograms. Documentation of training is maintained. In at least one case, an employee in a hearing conservation area was noted without hearing protection.

• There is annual training for affected employees in the effects of noise, use and limitations of hearing protection, and the purpose of audiograms. Documentation of training is maintained. All employees in hearing conservation areas were noted with hearing protection. If there is no noise documented exposure, and monitoring is done when there are changes in machinery or production processes that may result in increased noise levels, a five (5) rating can be given.

• Subsection Rating

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Hearing Conservation: Hearing Protection

• A hearing conservation program is necessary, but no hearing protection is available, or at least five employees were noted without it. There are no signs posted in areas requiring hearing protection.

• Only one type of hearing protection is available. At least three employees who need hearing protection were noted without it. There are no signs posted in areas requiring hearing protection.

• Only one type of hearing protection is available. At least one employee who needs hearing protection was noted without it. There are no signs posted in areas requiring hearing protection.

• Several different types of hearing protection are available, but in at least one case, an employee was noted without it. There are signs posted in areas requiring hearing protection.

• Hearing protection is offered to employees exposed to over 85 dBA and is required for employees exposed to over 90 dBA. At least three different types of hearing protection are available. All employees in hearing conservation areas were noted with hearing protection. There are signs posted in areas requiring hearing protection. If there is no noise exposure, and monitoring is done when there are changes in machinery or production processes that may result in increased noise levels, a five (5) rating can be given.

• Subsection Rating

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Hearing Conservation: Total Scoring

• Total Rating: 5 Points Possible

Toxic Material Control: Toxic materials and air contaminants vary from plant to plant. The Safety Performance Audit is not intended to evaluate the health issues or judge if the exposures are controlled, but rather to determine if plant management has evaluated and implemented controls as necessary to deal with the health issues. The performance issues to consider are: SDS review/air sampling, ventilation, respirators, and other. Applicable OSHA Standard: 1910.1000

Toxic Material Control: SDS Review/Air Sampling

• There has been no SDS review or air sampling to determine if employees are over exposed to air contaminants.

• In the past three years, there was an SDS review and personal air sampling. Documentation of results were not maintained in file.

• In the past two years, there was an SDS review and personal air sampling. Documentation of results were maintained in file, but there was no employee notification.

• There are periodic reviews of SDS's. Personal air sampling has been done in the past two years of known air contaminants with calibrated air pumps or badges. The results are documented on-site and there is employee notification of the results in writing or posting in a common area. Documentation is maintained for 30 years.

• There are periodic reviews of SDS's. Annual personal air sampling is done of known air contaminants with calibrated air pumps or badges. The results are documented on-site and there is employee notification of the results in writing or posting in a common area. Documentation is maintained for 30 years. Engineering controls have been investigated to proactively reduce the levels. If there is no documented air contaminant overexposure, and a periodic review is made of Safety Data Sheets, processes, etc. to ensure that no air contaminants are being introduced into the plant, a five (5) rating should be given.

• Subsection Rating

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Toxic Material Control: Ventilation

• Air sampling and SDS reviews show that ventilation is necessary, but none is provided.

• Only general ventilation is provided to remove air contaminants. There have been no tests to ensure that ventilation is enough to reduce or eliminate air contaminants.

• Local and general ventilation is provided, where necessary, to reduce or eliminate air contaminants. There have been no tests to ensure that ventilation is enough to reduce or eliminate air contaminants.

• Local and general ventilation is provided, where necessary, to reduce or eliminate air contaminants. The ventilation has been tested to ensure the needed air velocities, but there is no supporting documentation.

• Local and general ventilation is provided, where necessary, to reduce or eliminate air contaminants. The ventilation has been tested to ensure the needed air velocities. Documentation of results is maintained in file. Filters, if required, are replaced according to the manufacturer's instructions. Ventilation conforms to American Conference of Governmental Industrial Hygienist's requirements. If there is no documented air contaminant overexposure, and a periodic review is made of Safety Data Sheets, processes, etc, to ensure that no air contaminants are being introduced into the plant, a five (5) rating should be given.

• Subsection Rating

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Toxic Material Control: Respirators

• Air sampling and SDS reviews show that engineering controls, administrative controls, or respirators are necessary.

• Respirators or dust masks are worn by some employees, but a formal written respirator program is not in place.

• Respirators are required if engineering and administrative controls cannot bring the exposure levels down to permissible levels. A written respirator program has been implemented, but some elements written in the program are not being done. Employees wearing dust masks have not been trained or have not received permission from their doctor to wear masks.

• Respirators are required if engineering and administrative controls cannot bring the exposure levels down to permissible levels. A full written respirator program has been implemented including training, cartridge selection, fit testing, maintenance/cleaning, storage, and medical surveillance. No elements of the program are missing, and employees are noted in full compliance. Employees wearing dust masks have not been trained or have not received permission from their doctor to wear masks.

• All the above are in place. Signs are posted where respirators are required. Employees wearing dust masks have been trained and have received permission from their doctor to wear masks. Documentation of doctor's permission is maintained in file. If there is no document air contaminant overexposure, and a periodic review is made of Safety Data Sheets, processes, etc. to ensure that no air contaminants are being introduced into the plant, a five (5) rating should be given.

• Subsection Rating

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Toxic Material Controls: Total Scoring

• Total Rating: 5 Points Possible

Plant Safety Hazard Controls: Safety hazards in each plant do vary widely, but there are common issues which need to be addressed. It is not the intent of this survey to evaluate all safety hazards which may occur in a specific plant or operation but rather to determine if the management of the plant has evaluated and implemented controls as necessary to deal with the safety issues. The performance issues to consider are machine guarding, electrical service, forklift truck operation, storage of hazardous materials, and other hazards.

Plant Safety Hazard Controls: Machine Guarding-APPLICABLE OSHA STANDARD: 1910.212

• More than six (6) deficiencies in guarding are noted. This includes unguarded pinch points, gears, point of operation, chain and sprocket, or machinery.

• No more than five (5) deficiencies are noted.

• No more than four (4) deficiencies are noted.

• No more than three (3) deficiencies are noted. All power tools are approved by a recognized testing agency. The facility inspection document monthly inspection of the premises and guarding is an inspection item.

• No deficiencies are noted. All power tools are approved by a recognized testing agency. The facility inspection documents monthly inspection of the premises and guarding is an inspection item. Employees are trained not to remove or tamper with machine guards. There are purchasing specifications for machine guarding.

• * Subsection Rating

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Machine Guarding: Total Scoring

• Total Rating: 5 Points Possible

Plant Safety Hazard Controls: Electrical Service

• More than six (6) electrical service deficiencies are noted. This includes use of electrical extension cords, missing grounding prong, frayed or broken wiring, unmarked circuit breaker panel or electrical disconnects, wet conditions around electrical service, and uncovered junction boxes or circuit breaker panels. There is no written Electrical Safety-Related Work Practice program or training.

• No more than five (5) electrical deficiencies are noted. There is no written Electrical Safety-Related Work Practice program. Electrical Safety-Related Work Practice training has been done for qualified employees, but no documentation exists.

• No more than four (4) electrical deficiencies are noted. There is no written Electrical Safety-Related Work Practice program. Qualified people have been trained and documentation exists. Unqualified persons have not been trained.

• No more than three (3) electrical deficiencies are noted. There is a written Electrical Safety Program. The facility inspection documents monthly inspection of the premises and electrical service is an inspection item. Initial Electrical Safety-Related Work Practice training has been done for qualified and unqualified persons and documentation exists.

• No electrical deficiencies are noted. There is a written Electrical Safety Program. The facility inspection documents monthly inspection of the premises and electrical service is an inspection item. Deficiencies are corrected within one week. Qualified and unqualified people have been identified and trained appropriately and documentation exists. Annual retraining is scheduled, and new hires receive an orientation of the plant's Electrical Safety-Related Work Practice Program. Electrical equipment such as insulated gloves, voltmeters, tic tracers, and circuit testers are available and used. Arc Flash Evaluation has been completed and updated in the last 5 years

• Subsection Rating

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Electrical Service: Total Scoring

• Total Rating: 5 Points Possible

Plant Safety Hazard Controls: Forklift Trucks-APPLICABLE OSHA STANDARD: 1910.178

• There is no formal training of Powered Industrial Vehicle (PIV) operators. All PIV’s must have blue-lights, or some means of warning mounted on the vehicle. If no warning means are on the vehicle, then the max score will not be higher than a two (2)

• Only designated employees may drive the forklift trucks but there is no formal training done.

• Forklift operators are trained. Forklift truck operation is safe with no "hot rod" activities noted.

• There is a formal training program for the forklift operators and safe operation is observed. The inspection checklist is completed after or before each shift and maintained in file. Wheel chocks are used when loading or unloading trucks. Battery charging areas are equipped with flushing and neutralizing facilities to protect employees. Flushing equipment has a minimum capacity of 15 minutes of continuous water flow. Personal protective equipment including goggles, apron and gloves are provided at the battery charging area.

• There is a formal training program for the forklift operators and safe operation is observed. The inspection checklist is completed after or before each shift and maintained in file. Wheel chocks are used when loading or unloading trucks. Battery charging areas are equipped with flushing and neutralizing facilities to protect employees. Flushing equipment has a minimum capacity of 15 minutes of continuous water flow. Personal protective equipment including goggles, apron and gloves are provided at the battery charging area. Training has occurred within the past year and periodic retaining is scheduled at least annually.

• Subsection Rating

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Forklift Trucks: Total Scoring

• Total Rating: 5 Points Possible

Plant Safety Hazard Controls: Storage of Hazardous Materials-APPLICABLE OSHA STANDARD: 1910.101

• Hazardous materials stored improperly and in no special containers.

• Most hazardous materials stored improperly.

• Some hazardous materials stored improperly.

• There are proper containers provided and used in most situations.

• Most hazardous materials are stored properly, proper containers provided and used in most cases and properly labeled. Compatibility of chemicals stored together is evaluated and documented. All hazardous materials are stored in proper containers and properly labeled. Designated areas for storage is provided. Compatibility of chemicals stored together is evaluated and documented.

• Subsection Rating

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Storage of Hazardous Materials: Total Scoring

• Total Rating: 5 Points Possible

Plant Safety Hazard Controls-Other potential safety issues: A) Cutting hazards B) Trip/slip/falls C) Fall Protection D) Confined space entry E) Power tool use F) Laser Safety G) Vehicle operation other than PIV H) Welding, cutting and Hot Work I) Conveyors or other mechanical equipment J) Elevated work surfaces, ladders.

• At least five of the above hazards exist and there has been no recognition, evaluation, or controls investigated.

• Less than five of the above hazards exist and no evaluation of the hazard has been done.

• Some degree of control, e.g. personal protective equipment, is used to protect against the hazards in the plant.

• Evaluations of most potential safety hazards have been done. Personal protective equipment, administrative controls, and engineering controls are required to protect against the hazards in the plant.

• All identified safety hazards have controls to prevent overexposure. Mandated safety programs are in place where applicable. Engineering controls are in place or are being investigated to eliminate or reduce the potential health hazards on a pro-active basis If there are no other safety hazards and proper documentation exists where needed, a four (5) rating should be given.

• Subsection Rating

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Other Potential Safety Issues: Total Scoring

• Total Rating: 5 Points Possible

Personal Protective Equipment (PPE): The use of PPE is an alternative only if engineering and administrative controls are not possible. The criteria evaluate compliance with OSHA's PPE standard which is a performance standard based on hazard assessment. The performance issues to consider are assessment/equipment selection, training, and utilization APPLICABLE OSHA STANDARD: 1910.132

PPE: Assessment/Equipment Selection

• No assessment of workplace hazards has been done.

• There is written certification identifying the workplace evaluated; the person completing the evaluation; and date(s) of the assessment

• Assessment has been completed and verified with written documentation and the selection of proper personal protective equipment has been done.

• There is a written Personal Protective Equipment Program. All operations were evaluated to determine hazards to the head, eyes/face, hands, and feet. The hazard assessment is maintained in file.

• There is a written Personal Protective Equipment Program. All operations were evaluated to determine hazards to the head, eyes/face, hands, and feet. The hazard assessment is maintained in the file. Equipment is inspected periodically. If significant defective equipment is noted by the auditor, a score no greater than 3 can be awarded.

• Subsection Rating-One (1) point will be deducted from score if Arc Flash Analysis has not been conducted or if 5-year review of Arc Flash Analysis has not been performed.

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PPE: Training

• There has been no formalized and documented training.

• Personal protective equipment training is informal and not documented. At least five employees whose job requires PPE is noted without it.

• All employees have been given initial PPE training including when PPE is necessary, what PPE is necessary, how to wear the PPE, limitations of the PPE, and proper care and maintenance of the PPE. At least three employees whose job requires PPE is noted without it.

• All employees have been given initial PPE training, including when PPE is necessary, what PPE is necessary, how to wear the PPE, limitations of the PPE, and proper care and maintenance of the PPE. There is written certification of training showing the employee’s name, date of training, and the subject of certification. At least one employee whose job requires PPE is noted without it

• All employees are trained annually in the PPE Program including when PPE is necessary, what PPE is necessary, how to wear the PPE, limitations of the PPE, and proper care and maintenance of the PPE. There is written certification of training showing the employee's name, date of training, and the subject (personal protective equipment) of certification. All employees whose job requires PPE is noted wearing it.

• Subsection Rating

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PPE: Utilization

• Management does not require employees to wear necessary personal protective equipment.

• At least three (3) employees whose job requires PPE is noted without it.

• At least two (2) employees whose job requires PPE is noted without it.

• At least one employee whose job requires PPE is noted without it. There is a written disciplinary policy for handling affected employees who fail to wear proper personal protective equipment.

• All employees whose job requires PPE is noted wearing it. There is a written disciplinary policy for handling affected employees who fail to wear proper personal protective equipment.

• Subsection Rating

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PPE: Total Soring

• Total Rating: 5 Points Possible

Emergency Procedures: There are numerous emergencies which need to be planned for from a safety perspective, to reduce the impact of that emergency to personnel in the organization. Disasters such as fire, flood, tornado, earthquake, etc. are potential threats to personnel. Properly maintained exits are of paramount importance to maintaining a safe environment. Emergency planning for property conservation measures are covered under the Property Conservation performance criteria. The performance issues to consider are plan, drills, exits, and first aid. APPLICABLE OSHA STANDARD: 1910.38

Emergency Procedures: Plan

• There is no formalized and written emergency plan.

• A written plan for the expected emergencies is available. No formal training is done

• A written plan for the expected emergencies is available and the evacuation plan for the building is posted in numerous sites. No formal training is done.

• There is a written emergency action plan to indicate escape procedures, procedures for employees who must remain to shut down critical operations, head counting procedures, rescue and medical duties, and names of personnel who can explain the plan. The evacuation plan for the building is posted in numerous sites. The plan is reviewed at least annually to ensure it is up to date. There was initial training for all employees.

• All the above conditions have been met. Employees are trained annually in procedures for each type of emergency particular to the individual plant. This may include tornadoes, bomb threats, chemical spills, floods, severe winter storms, workplace violence, etc. Emergency phone numbers are conspicuously posted. Alarm systems with backups are available and operable. A separate, distinct alarm system is used for emergencies where employees are not to evacuate.

• Subsection Rating

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Emergency Procedures: Drills

• No drills have been held for the past two years

• A relevant emergency drill has been held during the past two years

• A relevant emergency drill is held on at least an annual basis. The time for evacuation is recorded.

• A relevant emergency drill is held on at least a semi-annual basis. The time for evacuation is recorded. There are provisions to account for all persons such as a roll call or other means.

• All the above conditions have been met. Any deficiencies that were noted are reviewed with all employees prior to the next drill. Local authorities have participated or reviewed the emergency plans.

• Subsection Rating

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Emergency Procedures: Exits

• One or more exits are blocked, locked, or obstructed in some way. This can be inside the building or outside the exit doors. [Situation must be corrected immediately.

• No exits are blocked or locked. There are adequate signs to indicate the exitways.

• No exits are blocked or locked. There are adequate signs to indicate the exitways. Emergency exit lighting is present in facilities which have people on-duty after dark. There are no locking devices on exit doors or exit access doors.

• No exits are blocked. There are adequate signs to indicate the exit ways. Marked aisles lead the way to the exits. Emergency exit lighting is present and working in facilities which have people on duty after dark. Management gives a very strong message that exits are not to be blocked in any way. There are no locking devices on exit doors or exit access doors.

• All the above-listed criteria have been met. From any part of the facility, there are at least two exits and exit directional signs visible. All exits lead to open yards, courts, lots, or other open spaces. No exit access is less than 28 inches wide.

• Subsection Rating

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Emergency Procedures: First-Aid-APPLICABLE OSHA STANDARD: 1910.151

• There is no control of the first aid supplies. First aid cases are not reported, and anyone may be doing first aid treatment.

• There are several people who are trained as first aid responders. First aid supplies are kept in kits at supervisor desks or located throughout the plant. Reporting of cases is not complete.

• There are several certified first aid responders with current training. A list of responders is posted. First aid supplies are kept in kits located in several areas of the plant. Reporting of cases in not formalized.

• There are several certified first aid responders with current training. A list of responders is posted. First aid supplies are kept centralized so that first aid cases can be monitored. There is a first aid log and all cases are reported.

• There are several certified first aid responders one each shift with current training. A list of responders is posted. First aid supplies are kept centralized so that first aid cases can be monitored. No expired first aid supplies were noted. An inventory list of approved supplies is in the kit. There is a first aid log and all cases are reported. First aid cases are taken seriously as a potential avenue for prevention of more disabling accidents. Adequate eye washing and shower facilities are available where corrosive materials are used.

• Subsection Rating

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Emergency Procedures: Total Scoring

• Total Rating: 5 Points Possible

PROPERTY CONSERVATION: These criteria evaluate the effectiveness of the facilities fire protection self-inspection program and responsiveness to fire emergencies by a designated team. Performance issues to consider are: adequacy of fire self- inspections to assure valves remain in the open position and fire pumps are maintained operational; use of formal procedures to follow in the event that a fire protection system must be taken out of service; the adequacy of the site's fire emergency response team; fire extinguishers; and fire prevention plan. APPLICABLE OSHA STANDARD: 1910.155

Property Conservation: Self-Inspection of Fire Protection Systems-APPLICABLE OSHA STANDARD: 1910.159

• There is no self-inspection program of the building fire protection system or occupancy hazards.

• There is an informal self-inspection program, but the inspections are not extensive and are not documented.

• There is a formal self-inspection program which focuses on the periodic check of sprinkler control valves for the open position and the periodic running of any fire pumps. Inspections are made every two months (bi-monthly) or less frequently. Records of the inspections are kept on file for review by management.

• There is a formal self-inspection program which focuses on the periodic check of sprinkler control valves for the open position and the periodic running of any fire pumps. Inspections are completed monthly. Records of the inspections are kept on file for review by management.

• There is a formal self-inspection program which focuses on the periodic check of sprinkler control valves for the open position, running fire pumps, and conducting drain tests. Inspections items also include checking fire doors, fire extinguishers, and occupancy hazards. Records of the inspections are kept on file for review by management.

• Subsection Rating

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Property Conservation: Fire Protection Impairments

• No procedure to deal with fire protection impairments (valves not tagged out; no precautions taken).

• Informal procedures during impairment in which valves are tagged out.

• Formal procedures during impairment in which valves are tagged out and property insurance carrier is notified.

• Formal procedures during impairment in which valves are tagged out, property insurance carrier and the fire department is notified, and special fire protection is offered.

• All the above and documentation of valve closures exists. If no impairments have occurred but procedures are in place, a 5 rating may be given.

• Subsection Rating

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Property Conservations: Emergency Service Team-APPLICABLE OSHA STANDARD: 1910.38

• No formal emergency service team exits.

• An emergency service team exists and consists of the positions of someone in charge, someone to notify the fire department, someone to check the sprinkler control valve for the open position, and a fire pump operator, however it is not in writing and personnel do not receive training.

• An emergency service team exists and consists of the positions of someone in charge, someone to notify the fire department, someone to check the sprinkler control valve for the open position, and a fire pump operator. It is in writing, however there is no annual training.

• An emergency service team exists for all shifts and consists of the positions of someone in charge and someone to notify the fire department or other emergency services provider. It is in writing with alternates assigned to each position; there is at least annual training to assure all members understand their responsibilities.

• All the above plus the local fire department has reviewed the written emergency service team plan to ensure all elements are covered.

• Subsection Rating

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  5

Property Conservation: Fire Extinguishers-APPLICABLE OSHA STANDARD: 1910.157

• Inadequate number (sparsely distributed) of fire extinguishers in the plant. No training in proper use of extinguishers, yet some employees may fight fires with extinguishers. No inspection program exists

• Extinguishers properly distributed throughout the plant, yet some may be blocked. No inspection program exists or inspections inconsistent. No formal training program on extinguisher use.

• Extinguishers properly distributed throughout the plant, yet some may be blocked. Extinguisher inspection is completed monthly. Some training has been done within the last two years.

• Extinguishers are properly distributed throughout the plant and are easily accessible. Extinguisher inspection is completed monthly. The Emergency Service Team has been trained and will respond to incipient stage fires only. Hands-on and classroom training is completed annually and documented. All other employees will evacuate premises in the event of fire.

• Extinguishers are properly distributed throughout the plant and are easily accessible. Extinguisher inspection is completed monthly. Hands-on and classroom training is completed annually and documented. All other employees will evacuate premises in the event of fire. A service contract has been arranged with a fire extinguisher vendor for yearly inspections. Documentation is complete.

• Subsection Rating

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Property Conservation: Fire Prevention Plan-APPLICABLE OSHA STANDARD: 1910.38

• No written fire prevention plan exists. Employees are not aware of fire hazards

• No written fire prevention plan exists; however, employees are aware of fire hazards and ignition sources.

• A written fire prevention plan exists which includes some but not all the required elements. No formal training is done.

• A written fire prevention plan exists and includes a list of hazards and ignition sources, a list of employees with assigned responsibilities to control equipment and fuel source hazards, housekeeping rules, training, and maintenance procedures for heat producing equipment. Initial training has been conducted and documented.

• All the above and annual training is conducted and documented. The local fire department has reviewed the written fire prevention plan to ensure all elements are covered. The written plan is available in the workplace for review.

• Subsection Rating

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Property Conservation: Total Scoring

• Total Rating: 5 Points Possible

MATERIAL HANDLING AND STORAGE RACKS/SYSTEMS: Description: These criteria evaluate compliance with CTB’s Standard for the storage of materials to include the following: Capacity and Marking, Proper Anchoring/Backing/Column Protection, Compatibility of Rack Components, Repair/Replace and Rack Inspections. Performance issues to consider are: is the capacity for the rack marked on the cross beams and the uprights, are the racks damaged, are the racks overloaded, are protective barriers on the back of racks where work is being preform or where people can be behind the racks, are rack systems compatible, are racks anchored, are safety clips/devices in place, do racks have protection on their legs, are racks being inspected and replaced or repaired when damaged. APPLICABLE OSHA STANDARD: 1910.176.

Material Handling and Storage Racks/Systems: Storage Racks

• Are racks in good working conditions and are the racks being inspected and repairs or replacement done when needed.

• Is the capacity marked on the upright and the cross arms and are the racks not being overloaded? Are the racks anchored and are legs protected?

• Are all the racks compatible and where needed does the racking system have the backs enclosed to prevent materials from falling onto people or equipment.

• Are the shelves secured and all components secured with safety clips and/or safety devices

• All the above and inspections are documented.

• Subsection Rating

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Material Handling and Storage Racks/Systems: Total Scoring

• Total Rating: 5 Points Possible

RESPONSE TO RECOMMENDATIONS FROM OUTSIDE RESOURCES Description: These criteria evaluate plant management's response to recommendations generated from outside resources. Such outside resources include: OSHA, EPA, the local or state fire marshal, insurance provider and CTB Corporate EHS Department. The responsiveness by the plant management to outside generated recommendations is a strong indicator of the depth of the safety culture within an organization. The performance issues to consider are procedures and documentation. LOSS REVIEW Description: Claims management requires proper documentation and detail work to ensure claims are controlled and administered properly. Effective management of claims requires that documentation be complete, accurate, and organized. The performance issues to consider are: OSHA log, files, and Early Return to Work.

Uninvited Inspection Procedures:

• Procedures for dealing with uninvited inspections (e.g. OSHA) are not known by the management staff.

• Management has a rough idea of how to handle uninvited inspections or inquiries from agencies outside the CTB family, but these procedures are not formalized, nor are they communicated to others in the organization.

• Plant or general manager knows the corporate or division policy on dealing with uninvited inspections or inquiries from agencies outside the CTB family, but the procedures have not been communicated to others in the management/supervisory staff. No written policy exists.

• The corporate or division policy on dealing with uninvited inspections or inquiries from agencies outside the CTB family is known by the entire management/supervisory staff. A written policy exists.

• All the above plus management has taken a proactive approach to contacting agencies inside and outside the CTB family for help and advice in complying with safety and health related issues.

• Subsection Rating

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  5

Documentation/Recommendation Compliance:

• There are outstanding recommendations which plant management had no knowledge or documentation of. There is no documentation on file regarding any previous inspections, audits and/or assessments.

• There has been no response to existing recommendations. Some documentation exists but is poorly organized and does not show management's response to previous inspections, audits and/or assessments.

• In response to previous recommendations, some have been complied with and there is no response to other recommendations. Documentation is incomplete, but generally shows the response to recommendations from inspections, audits, and/or assessments.

• All existing recommendations have been complied with or have been responded to appropriately. Location management has been contacted concerning any recommendations so that the information can be relayed to other division locations. Documentation exists in file and is completed, organized, and clearly shows management's response to inspections, audits, and/or assessments.

• All the above plus procedures are in place to ensure that the completed recommendations are not generated as a repeat violation or citation. Follow-up procedures are in place to audit this process and ensure there are no loose ends in dealing with the agencies.

• Subsection Rating

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  5

Loss Review: OSHA Log-APPLICABLE OSHA STANDARD: 1904

• OSHA 300 log is not current.

• OSHA 300 log is not current within six (6) working days for reporting of OSHA recordable cases. Recording errors or missing information was noted on the log.

• OSHA 300 log is current but cases which are not OSHA recordable are entered. Injuries and illnesses are not being classified separately. Recording errors or missing information was noted on the log. All required electronic submittals have been sent to OSHA or State OSHA.

• OSHA 300 log is current within six (6) working days and posted from February 1 – April 30. Only OSHA recordable cases are recorded, and injuries and illnesses are classified properly. No recording errors or missing information was noted on the log. All required electronic submittals have been sent to OSHA or State OSHA.

• OSHA log is current within six (6) working days and posted from February 1 – April 30. Only OSHA recordable cases are recorded, and injuries and illnesses are classified properly. All required electronic submittals have been sent to OSHA or State OSHA. No recording errors or missing information was noted on the log. Current and past OSHA logs are neat, well organized, and maintained for five (5) years.

• Subsection Rating

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Response to recommendations from outside resources and loss review: Total Scoring

• Total Rating: 5 Points Possible