Health and Safety Gap Analysis

Site Information

Site conducted
Conducted on
Prepared by
Location

Management Involvement and Support

Health and Safety Policy

Management has implemented a written health and safety policy and it is reviewed with all employees, at least annually.
Employees understand the basic policy requirements.
Copies of the policy are visible and readily available to employees, visitors, and contractors.

Goals and Objectives for Accident Prevention

Goals have been established based on key performance indicators, e.g., TRI, and LTI, in support of business and corporate goals and objectives.
Goals for leading indicators (Near Misses, # of Behavior Based Safety (BBS) Observations, Safety Contact Cards, etc.) have been established and are tracked.
Objectives for accident prevention specify safety and health programs improvements.
Specific goals and objectives have been established for various levels of the organization appropriate to the size of the site, e.g., at the department, work group or crew, and supervisor levels.
Goals and objectives are both measurable and achievable.
Goals and objectives are communicated to all employees.

Performance Measurement Systems

An Internal Health and Safety assessment is conducted every year.
Internal Health and Safety Assessment corrective action plan developed and maintained for the facility (and departments as required by policy).
Corrective action plans also developed and maintained for other health & safety programs, e.g., hazard reporting system, industrial hygiene surveys, behavior-based safety, etc.
The corrective action plans specify individuals responsible and target dates for completion.
Corrective action plans reviewed and updated, at least quarterly.
Corrective actions prioritized and completed within designated target dates and in a reasonable and timely fashion.
Safety-related work orders tracked to ensure prompt completion and to minimize backlog.
Other safety performance measures have been established and are used to monitor improvement. Examples include attendance at H&S training, percent participation in BBS observations, etc.
Feedback on safety performance provided to employees at regular intervals.

Accounntability for Health and Safety

Health and safety is a key component of one-on-one discussions conducted with all managers, supervisors, and salaried individual contributors.
All employees receive at a minimum an annual safety performance review.
Site has a documented, site-specific Health and Safety Accountability Procedure in accordance with the corporate guidelines to ensure that discipline for health and safety violations is administered on a fair and consistent basis.
The Health and Safety Accountability Procedure is communicated to all employees.
Facility disciplinary log consistent with the Health and Safety Accountability Procedure.
Safety and health rules, policies, and procedures reinforced/enforced fairly and consistently.
Management periodically audits crew safety meetings for quality and content and to reinforce accountability.
Safety and health objectives are included in the annual performance goals process.
Safety and health activities such as training, safety meetings, audits, observations, incident investigations, etc., have a meaningful impact in the annual performance goals for managers, supervisors, and salaried individual contributors.
Individual safety improvement plans developed for unsatisfactory performance such as accident repeaters.

Contractor Management

Facility has a written contractor safety management program meeting the requirements of the corporate safety policy.
HSE coordinators and facility contractor coordinators identified for projects.
Contractors qualified in accordance with policy requirements prior to being awarded work.
Adequate safety information provided to contractor management on the following:
a. ZES/Lockout Tagout
b. Emergency Preparedness
c. Confined Space Entry
d. Fall Protection
e. Personal Protective Equipment (PPE) Requirements
f. Fire Prevention and Hot Work
g. Process Safety Management (if applicable)
h. Chemical Management (including Hazcom), Asbestos, Lead and Hazardous Waste Requirements (as applicable)
i. Other permitted procedures (i.e., roof, line breaking or trenching)
Contractor management is conducting required training, inspections, safety meetings, and audits.
Special work permits are established as necessary.
Contractor personnel and worksites are in compliance with rules and procedures.
Quarterly audits conducted of the contractor OSHA 300 Logs or its equivalent (e.g., 300A).
Contractor personnel have completed the required site safety orientation.
Facility contractor coordinators are conducting periodic inspections of the worksite and recommending improvements and documenting the inspections.

Safety and Health Support

Person(s) designated to effectively coordinate safety and health programs/ responsibilities.
Individuals assigned to coordinate H&S are appropriately qualified and trained.
These individuals participate in regular development to maintain or improve their skills.
Individuals (departments) assigned to coordinate H&S have established goals, objectives, and activities to support continuous health and safety programs improvement.

Other Activities

Management has established and participates in a site safety committee that has membership from various stakeholders, including hourly employees, supervisors and management.
Management is supportive of the safety committee to assure it is viable and integral to the site's safety program.
Site/Department managers hold annual or semi-annual update meetings with employees on progress towards meeting safety goals and objectives.
Site lead team routinely interacts with individual employees or small groups to have informal conversations on safety performance.
Site lead team and/or department managers participate in workplace assessment or audits of employee activities and workplace conditions.
Management uses past trends or data analysis to initiate special focus for employee observations, supervisor audits or general awareness initiatives (i.e., pre-summer heat discussion/handouts, holiday safety discussion).
Management participates in identifying innovative ways to keep employee awareness, enthusiasm, and participation high (e.g. safety slogan, billboard, or calendar contest).

Employee Involvement

Safety Meetings

All employees including supervisors, attend a safety meeting at least monthly.
Safety meeting topics are established, follow an agenda, and utilize instructional material.
Employees who conduct safety meetings are adequately trained and effectively present the material.
Employees actively participate in the meetings.
Meeting attendance, agenda, and follow-up issues documented.
Safety suggestions/issues brought up by crew members at the previous meetings tracked and followed up.
Site has a process for conducting periodic "toolbox" meetings to communicate safety-critical information outside of the regularly scheduled safety meetings.
Site has process to track meeting attendance and provide employees who missed the meetings with the covered information.
Quality and contents of crew meetings monitored periodically to improve the effectiveness of communication.

Safety Committees

Facility has an active safety committee(s).
Committee(s) meet at least monthly.
Department and/or function-specific committees or subcommittees established based upon the needs and size of site (i.e., incident investigation, ergonomics, or behavior-based safety).
Membership of committee(s) includes representation from various stakeholders, including hourly employees, and each committee has a designated leader/chairperson.
Written guidelines established specifying goals and responsibilities of various committees, their authority, and procedures.
Safety committees assigned projects to support the safety program.
Permanent safety committees develop annual written goals and objectives, consistent with those of the facility.
Safety committee(s) provide progress reports on activities to employees and management at regular intervals.
Meetings follow an agenda and meeting minutes are documented and communicated.
Issues and recommendations made by the committee(s) tracked to completion.

Other Activities

Employees participate in reviews and revisions of safety rules and procedures.
Employees participate in developing behavior-based operating procedures.
Employees involved in developing safety goals and objectives for work groups.
Employees participate in the evaluation and selection of PPE.
Employees participate on safety reviews of new processes or equipment.
Employees participate on facility/department H&S Assessments.
Employee hazard notification and suggestion system(s) has been established.
Employees assist in prioritizing safety work performed by maintenance crews.
Employees participate in site walk-thru inspections, such as housekeeping audits.

Safe Behavior Process

The facility's behavior-based safety (BBS) process is an employee-directed process.
A process steering committee, or equivalent, is organized and empowered to manage the BBS process, with hourly employees representing a majority of the committee membership.
The roles and responsibilities of the steering committee established and documented.
Employees conduct and document peer observations of co-workers that focus on behaviors.
Observations represent a cross-section of jobs and/or tasks.
Observations use job/task specific checklists, hazard specific checklists, or use the job BJA (or equivalent) Behavioral Job Analysis.
Behavioral Job Analysis (BJAs) (or equivalent) have been completed for all routine and non-routine, high-hazard tasks.
Observations are conducted during routine and non-routine tasks involving high-hazard activities, and during upset conditions.
Observers provide reinforcement and correction during the observation process.
Observations tracked to identify trends and analyzed to identify barriers to safe behaviors.
Corrective actions implemented to address the identified barriers to safe behavior.
Process reports provided to management/employees on a regular basis.
Management utilizes data provided in process reports to provide support and additional reinforcement for critical safe behaviors.

Safety Policies and Procedures

Hoses used for dispensing flammable/combustible liquids shall be equipped with self-closing nozzles. (NFPA 30 - 7.5.2.1)

Facility Safety Rules and Procedures

Conditions posing "Imminent Danger" must be addressed immediately. "Imminent Danger" is an OSHA defined term.
Facility has written general safety rules, which are written in clear, concise language and cover at a minimum, the following topics: clothing, jewelry, hair, PPE, emergency procedures, access restrictions and smoking control.
Facility safety rules adequately protect employees, visitors and contractors from workplace hazards.
Rules and procedures readily accessible to employees via a handbook, manual, electronic, or similar means.
All rules, policies, and procedures are current with revision or review dates indicated.
Facility has a written OSHA inspection/reception procedure that is reviewed periodically with affected employees.
Visitors policy established to communicate safety requirements to visitors, vendors, etc.
An annually signed Cellular/Mobile Data Device Use Agreement on file for all employees required to use a cellular/mobile data device that is either company issued or personal, in the performance of their job duties, or an annual LMS training module completed by each affected employee.

ZES / Lockout Control of Hazardous Energies

Facility written program meets or exceeds the requirements of the corporate policy.
Employees are assigned locks that are individually identified and legible.
Procedures established for multiple lockout (group lockout).
Procedure for removal of locks established.
Approved disconnects and energy isolating devices used and clearly identified for isolating energy sources.
Written ZES procedures are established for all applicable equipment and processes.
Written ZES procedures are readily available to employees.
Periodic inspections (of ZES procedures) conducted and documented annually.
Audible warnings with a delay feature provided to warn of start-up of equipment.
Documented annual audits of proficiency are conducted for each affected employee.

Moving (Energized) Equipment

Boundaries have been established around applicable moving equipment.
Tasks within boundaries have been identified.
Risk assessment completed for all tasks performed within boundaries of moving equipment.
Written procedures for working on energized equipment have been developed. The procedures state how the task will be safely performed.
Guards are secured from movement and are in good condition.
Equipment is operated with guards or protective devices in place. (29 CFR 1910.212(a)(3)(ii))
Interlocks are provided where fixed point of operation guards are not practical. OSHA 29 CFR 1910.212(a)(1).
Emergency stops are provided at sufficient locations, easily identifiable, and readily accessible. (29 CFR 1910.261(k)(1);(I)
Lubrication fittings extended or openings provided to reduce exposure to rotating equipment.

Confined Space Entry (CSE)

Facility CSE written program meets the requirements of the corporate policy.
CSE entry written program describes how contractors and IP employees will share the responsibilities of CSE, for example, who will conduct the required air monitoring and who can sign and authorize confined space entry permits.
All confined spaces and their associated hazards are documented on a master inventory.
All confined spaces appropriately labeled.
An effective CSE permit system has been established and is enforced.
The atmosphere inside the confined space tested prior to entry and periodically thereafter based on risk. Personnel are trained in the use of the monitoring equipment.
Industrial hygiene personal exposure monitoring conducted for employees who enter a permitted space where the atmosphere exceeds (or may likely exceed) established exposure limits (OSHA PEL or ACGIH TLV).
A documented CSE program evaluation conducted annually based on audits, incidents, and a 12-month permit review.
Cancelled permits retained for 12 months.
Entry procedures address requirements including isolation, ZES, PPE, and air monitoring.
Entry attendants and persons entering permit-required confined spaces provided with required PPE and emergency equipment.
Blanking, separation, or double block-and-bleed required for isolation of all highly hazardous systems.
Entry operations reviewed when there is reason to believe that the program may no longer be effective. The program revised to correct deficiencies.
Electrical equipment used in confined spaces is low voltage or connected to a GFCI.
Explosion-proof or non-sparking tools or equipment used in potentially explosive atmospheres.
Mechanical forced-air ventilation required for permit-required confined spaces where there is the potential for a hazardous atmosphere.

Cutting/Welding/Hotwork

Facility written Hot Work program meets or exceeds the requirements of the Property Conservation Manual.
An effective permit system established and fully implemented.
Area safeguards are specified on the permit.
Permits are signed by authorized production and maintenance employees.
Fire protection equipment is verified to be in service and required fire fighting equipment provided.
Areas inspected before hot work performed to ensure area is made safe, e.g., combustibles are protected and required safeguards are in place.
Monitor for explosive gases in affected tanks and piping before hot work is performed. The head space within tanks should be evaluated by extending the sampling device into the tank from a safe access.
Fire watch provided and area rechecked by appropriately trained individuals, e.g., guards, supervisors, etc.
Permit compliance verified daily by those authorizing the hot work permit. A paper audit is conducted at least every 6 months.
Completed hot work permits are kept on file for a minimum of one year.
Proper eye protection, other PPE, and welding screens used in accordance with 29 CFR 1910.2529(b)(2).
Mechanical ventilation during welding or cutting provided when the space is less than 10,000 cubic feet/welder OR the ceiling height is less than 16 feet OR the space contains partitions, balconies, or other structural barriers that significantly obstruct cross ventilation. (29 CFR 1910.252(c)(2))
Local exhaust ventilation (LEV) provided for indoor welding or cutting on zinc, lead, cadmium and stainless steel (hexavalent chromium). (29 CFR 1910.252); (29 CFR 1910.1026)
Mechanical ventilation provided during gas-shielded arc cutting of stainless steel. (29 CFR 1910.252(c)(12))
Welding rod containers, carts, ovens, or welding areas labeled with the ANSI (Z49.1-1967) caution sign. (29 CFR 1910.252(c)(1)(iv)(A))
Fuel gas and oxygen cylinders separated by a distance of 20 feet, or a 5 foot high noncombustible barrier with a 30 minute fire rating. (29 CFR 1910.253(b)(4)(iii))
Compressed gas cylinders stored with caps in place and secured from movement. (29 CFR 1910.253(b)(2)(iv))
Arc welding equipment (machines, leads, electrode holders, etc.) checked prior to use and in good condition. (29 CFR 1910.254 (c)(2)(v))
Welding operations are not performed in locations where chlorinated solvent vapors are present (recommend 50 ft separation). (29 CFR 1910.252(c)(11)(ii))
Fuel gas equipment (cylinders, hoses, regulators, etc.) checked prior to use and in good condition. (29 CFR 1910.254(d)(2))

Personal Protective Equipment (PPE)

Hazard assessment to verify the proper selection, use and application of PPE, including chemical and electrical protective clothing, conducted, documented, and "certified."
Safety glasses with side shields, including prescription safety glasses worn in all manufacturing or work areas.
Protective headgear worn in all manufacturing environments where there is a hazard of head injury.
Protective footwear worn in all manufacturing and warehouse environments.
PPE requirements specified in written operating procedures.
Signs specifying special PPE requirements posted in areas where the PPE is required (e.g., chemical handling areas, pedestal grinders, etc.).
Facility has work rules regarding appropriate clothing, jewelry, hair styles, etc., on or near moving equipment.
Special PPE worn when required by the risk assessment (e.g., chemical protective clothing, electrical protective clothing, face shields, goggles, life vests).
PPE, including chemical and electrical protective clothing, inspected before each use, kept clean, properly maintained, and disposed when damaged or defective.
Seat belts worn by the operator and passenger(s) when operating a company owned/leased/rented vehicle or personal vehicle used for company business.
Areas above 4 feet where employees are required to work that have unprotected sides and edges are identified and appropriate controls and/or procedures are implemented and communicated to employees (e.g., roofs, top of tanks, temporary work platforms, manlifts).
Approved fall protection (e.g. aerial lift, fall arrest, scaffolding) systems are used when employees are exposed to falls greater than 4 feet unless guarded by a standard handrail.
Fall protection equipment inspected prior to each use and is discarded when damaged or defective.
Fall arrest equipment is secured to anchorage capable of supporting at least 5,000 pounds dead weight.

Walkways/Stairs/Ladders

Walkways, stairs, work platforms, floor openings, and scaffolds greater than 4 feet high with unprotected sides or edges, protected by standard handrails and toeboards. (1910.23)
Floor load limits posted in areas where materials are stored. (1910.22(d))
Stairs, steps, or ladders provided where necessary to prevent climbing on or over equipment. (1910.24)
Fixed ladders meet applicable OSHA standards for clearances and dimensions, cages and landings where required. (1910.27)
Crossovers provided for conveyors where necessary. (1910.24)
Portable metal ladders prohibited.
Area lighting levels acceptable for required tasks. (ANSI/IES RP-7-1991)
Written housekeeping standards established in accordance with the company property conservation manual.
Housekeeping maintained in the facility. ((1910.141(a)(3)), (1910.22(a)))

Electrical

The facility has a written electrical safety program. (1910.269 (d)(2)(iii), NFPA 70E 110.7)
Written work practices/rules/JSAs established for tasks requiring employees to work on or near energized electrical equipment. (1910.333(a), NFPA 70E 110)
The site has a policy that after a circuit is de-energized by a protective device, the circuit may not be manually reenergized until it has been determined that the equipment and circuit can be safely energized. (1910.334 (b)(2))
Jewelry/conductive articles are not allowed when working on or near energized electrical circuits. (1910.333(c)(8))
An Energized Electrical Permit system is used where required to work on energized electrical equipment. (NFPA 70E 130)
Electrical Job Safety Briefings are conducted prior to starting energized electrical work. (NFPA 70E 110.7)
A means is provided to prevent exposure of "Unqualified" persons to energized electrical hazards (e.g., barricades) (1910.145, 1910.335, NFPA 70E 130.7)
Appropriate shock and arc flash protective clothing and PPE (as well as insulating tools) are provided to qualified persons based on the NFPA 70E Tables, or by arc flash hazard analysis (1910.137, 1910.335, NFPA 70E 130.7)
Emergency response procedures for electrical incidents are implemented.
Portable GFCIs used in outdoor or wet locations are tested before each use using the GFCI's built-in testing circuitry.
Appropriate clearance and illumination is provided for electrical equipment. (1910.303(g))
Permanent wiring installed in conduit or cable tray (or other means) protected and free from damage. (1910.305(a))
Flexible cable use restricted to temporary or approved services only. (1910.305(g))
Strain reliefs provided on flexible cords. (1910.305)
Ground fault circuit interrupters (GFCI) are provided, used and maintained for use with portable equipment and extension cords. (1910.304(b))
Electrical equipment is properly guarded or access restricted to prevent unqualified and accidental contact. All covers and openings are effectively closed on all cabinets, boxes, and fittings. (1910.303(g)(2), 1910.305 (b)(1)(ii))
Portable equipment, power tools, and appliances are equipped with grounding conductor or double insulated. (1910.334(a))
All designated Motor Control Centers (MCC) and/or power distribution centers are locked, or otherwise prohibited to unauthorized personnel and energized equipment appropriately guarded.
Electrical equipment is the correct type for the environment and has been approved for use where flammable vapor/gases or combustible dust/fibers are present.
Electrical equipment is properly marked with identification of manufacturer and ratings (e.g., voltage). (1910.303(e))
All circuits, equipment or controls properly labeled as to its purpose.(1910.303(f))
A single line diagram for the electrical system shall be maintained. The facility has a system to ensure the drawing(s) are correct and updated as necessary (NFPA 70E 205.2)

Emergency Planning and Preparedness

Facility has an updated written fire prevention plan. (1910.39(a))
Plant has a written procedure/system for managing fire protection impairments.
Pre-Emergency Planning conducted for possible hazardous substance release scenarios.
Facility has a current written Emergency Action Plan for foreseeable emergencies, that includes how to report emergencies, escape procedures and routes, personnel accounting procedures, rescue/medical duties, when to operate/shut down equipment, persons responsible for the plan, employee roles and responsibilities, and employee access to the plan. (1910.38)
Adequate type and amount of emergency response equipment available as specified in Emergency Action Plan.
Emergency responses and drills critiqued and Emergency Action Plan revised to reflect identified improvements.
Facility has an incipient fire response team with a current organizational statement identifying responsibilities and limitations or written plan describing reliance on local responding agencies and employee responsibilities. (1910.156(b)(1))
Hose stations equipped with lined hose and shut-off nozzles. (1910.158(c))
Sprinkler systems equipped with water flow alarms are provided where required by corporate risk management. ( 1910.159(c)(9))
Fire extinguishers provided and accessible within specified travel distances. (1910.157(d))
Plant enforces a smoking control policy.
Facility use of fire water regulated by a permit system.
Local fire department visits the facility to conduct pre-planning at a frequency based upon the site's hazards.
Alarm/notification systems designed to be heard or seen by all employees in affected areas and operable at all times. (1910.165(b), 1910.37(e))
Emergency reporting numbers posted and manually-operated devices accessible.
Employees understand their roles and responsibilities during an emergency.

Materials Handling Equipment

Powered industrial trucks are being operated and maintained in accordance with the IP Powered Industrial Truck Safety Policy.
Traffic flow risk assessment conducted, documented, and revised when new equipment is installed, building layout changes, or process changes occur.
Controls established to protect pedestrians from the hazards of powered industrial truck operations based upon findings of traffic flow risk assessment(s).
Periodic observations conducted in areas of industrial truck operations.
Lift trucks equipped with appropriate capacity data plate(s), rotating or flashing beacon, horns and restraint devices.
Industrial truck operators wear restraint devices approved by the equipment manufacturer.
Site has a written procedure to prevent premature trailer departure that meets or exceeds the latest version of the Dock Safety Guidance Document.
Jack stands are available and correctly positioned at the nose of trailer when tractor not attached, and positioned at rear of trailer to add stability when the tandems cannot be moved to the rearward most position.
Trailer door straps or an effective safe operating procedure, are in place to prevent loads from falling onto personnel when opening trailer doors.
Trailer tandems are moved to the rearward most position prior to loading and unloading.
Each dock at the site is equipped with either wheel chocks (enough for 2 per trailer) OR a trailer restraint system (such as Dok-Lok).
Use of Glad hand locks, key controls, or driver controls are in place in addition to a chocking or dock restraint device for loading and unloading.
Cranes load tested for the rated capacity prior to initial use, or when extensively repaired or altered. (1910.179(k)(1))
Written safety rules established and followed for operation of hoisting equipment per manufacturers instructions. (1910.179)
Cranes and hoists provided with safety equipment (limit switches, stop blocks, guards, audible or visual warning signals). (1910.179)
Slings and rigging used correctly and stored in designated areas. (1910.184)
A safety spotter is used to monitor all movements of an aerial lift when the operator can not see the wheels of the aerial lift.
A pre-job safety hazard assessment is conducted for each aerial lift use and is reviewed by all affected personnel.

Medical Programs

Management has ensured medical personnel are readily available for advice or consultation on matters of occupational health. (1910.151 (a))
CPR and First Aid trained personnel are immediately accessible on all shifts. (1910.151(b))
There is timely and appropriate transportation to off-site medical assistance. (1910.151b)
Emergency medical care is provided within scope of documented training, certification, licensing, and State regulations.
First Aid and emergency response equipment and supplies maintained and routinely inspected. (at least monthly) (1910.151b)
Medical first responders hold regular drills (i.e., quarterly) to test their ability to respond to medical emergencies. (1910.151(b))
All emergency medical care and first aid treatment logged and documented in a confidential manner. (1910.1020)
There is a designated Employee Medical Record (EMR) custodian for the location responsible for the security and integrity of all site-related EMR's. (1910.1020)
Employees are annually informed of their rights regarding access to medical and exposure monitoring records. (1910.1020(g)(1)(2))
Inspection of or a copy of the EMR provided on the written request of employee within 15 days of the request. (1910.1020(e)(1)(i))
EMRs do not include drug screening, personnel, safety, disability or workers' compensation records.
Only the employee, H-E Parts International affiliated Physicians and Nurses, location EMR custodian, and regulatory agency representatives have access to the current or archived Employee Medical Record. (1910.1020)
There is a program to manifest and index all current and archived EMRs.
All current and archived EMRs are secured under lock and key at all times and are in an area protected from heat or water damage.
All EMRs and original X-rays are retained for 30 years after the last date of employment. (1910.1020(d)(1)(i))
Restrictions to work activity or job accommodations due to a health condition are clearly documented and confidentially communicated to managers.
New employees receive post-offer pre-placement health assessments and initial medical testing before assignment.
Members of the hazmat team are medically evaluated prior to assignment, annually, and after any exposure to hazardous substances above the permissible exposure limits with signs or symptoms of an exposure (1910.120(d)(1)(i))
The facility has a documented heat stress control program.
The facility has a written Bloodborne Pathogen Exposure Control Plan that is location-specific and includes all applicable components as listed in the Bloodborne Pathogen Policy and 29 CFR 1910.1030 (c)(1)(i).
Copies of the Bloodborne Pathogens Exposure Control Plan available to employees. (1910.1030 (c)(1)(iii))
Hepatitis B Vaccine is offered to covered employees pre-exposure and post-exposure to all employees who have had an exposure incident.
Any covered employee who declines the offer of Hepatitis B vaccination has signed the OSHA Declination Form (1910.1030(f)(2)(iii)
Regular inspection of Bloodborne Pathogen engineering controls documented, i.e., medical waste containers, needles/sharps containers, PPE accessibility. (1910.1030(d)(2)(ii))
Regulated medical waste disposal system meets all state and federal regulatory requirements including waste handling techniques, waste containers, labeling and manifesting (documentation) of waste disposal. (1910.1030(d)(4)(iii)(C))

Means of Egress

Exits and the means of egress identified by signs. (1910.37(b)(2))
Exits and the means of egress are unobstructed. (1910.37(a)(3))
Number and arrangement of exits are in accordance with applicable standards. (1910.36)
Building features that could be mistaken as exits are appropriately labeled. (1910.37(b)(5))
Adequate emergency lighting provided along the exit route, including stairways and aisle ways, and in first aid and medical treatment areas. (1910.261 (b)(2),1910.37(b)(1)))

Ergonomics

Management has designated a site ergonomics coordinator.
The site has a written ergonomics program that meets the requirements of the corporate policy. The program is up to date and reflects current practices at the site.
The site coordinator or ergonomics team(s) identify potential ergonomic hazards at the site using information such as injury data, ergonomic risk assessments, and employee input on a regular basis.
The identified potential ergonomic hazards are prioritized for resolution.
Ergonomic job analyses are performed on the potential ergonomic hazards with the highest priority.
Employee inputs are incorporated in solutions development for the identified potential ergonomic hazards.
Solutions addressing the most critical contributing factors, as determined by the job analysis, are implemented, with engineering controls utilized whenever feasible.
Solutions are communicated to all affected employees and incorporated into relevant work practices documentation, i.e., BJAs and SOPs.
Follow-up and documentation of ergonomic activities are completed for each implemented solution.
The site has an injury and illness management system including processes to encourage early reporting of signs and symptoms of Musculoskeletal injury and illness and to supervise the care of injured employees for maximum recovery and reintegration into the workplace.
A system established to ensure the consideration of ergonomics in the modification, design, purchase, and installation of equipment, processes, and workstations.
An evaluation of the program effectiveness, as determined by one or more results measures, is periodically performed.

Flammable/Combustible Liquids

Flammable/combustible liquids stored in approved storage rooms or cabinets. (NFPA 30 6.2-6.6)
Flammable/combustible liquid storage rooms equipped with fixed fire protection, ventilation and self-closing fire doors. (NFPA 30-6.8-4.4.2.7 & 30-4.4.2.2)
Flammable/combustible liquids located outside storage rooms are stored in safety cans or approved, covered containers. (NFPA 30- 6.7)
Safety cans and storage cabinets are labeled with flammable/combustible designation. (NFPA 30 - 6.3.5)
Drums and equipment for dispensing Class I and II liquids must be grounded and bonded, with self closing faucets or an approved pump and bung vent. (NFPA 30 - 6.4 and 6.5)
Rags soiled with flammable/combustible liquids and flammable/combustible liquid waste must be kept to a minimum in covered metal containers and disposed of daily. (1910.106(e)(9)(iii))
Hoses used for dispensing flammable/combustible liquids shall be equipped with self-closing nozzles. (NFPA 30 - 7.5.2.1)

Hearing Loss Prevention

Management has designated a HLPP Coordinator that has completed IP Coordinator training.
The site has a written site-specific hearing loss prevention program (HLPP).
Personal noise dosimetry conducted to characterizes time-weighted average (TWA) noise exposures for all employee job classifications.
TWA noise exposure data formally summarized for all employee job classifications including, at a minimum, employees job classification, department, and TWA levels.
When changes in production, process, equipment or controls may increase noise levels, a sound level survey and/or personal dosimetry conducted within 90 days.
Every 2 years noise levels are reassessed either by plant wide dosimetry or conducting a sound level survey. Where sound levels have significantly increased (e.g., greater than 3 dBA), personal dosimetry conducted for the affected employee job classifications.
Facilities that conduct their own sound level surveys and personal noise dosimetry, calibrate the equipment before and after use. The calibrator is factory calibrated annually. The monitoring data documented on H-E Parts International or equivalent monitoring forms.
Employees notified of exposure monitoring results within 15 days of the site receiving the results. Employees who wore a dosimeter are notified in writing.
Dosimetry studies are filed in the employee's medical record.
Engineering/administrative controls evaluated and documented where employee TWAs exceed 90 dBA and feasible controls implemented where TWA exceed 100 dBA (a 90 dBA threshold is used for these determinations). Some States (e.g., NC and CA) may enforce implementation of feasible controls at 90 dBA TWA.
Hearing protection worn in areas at or above 85 dBA (regardless of exposure duration) which Includes employees who operate equipment that produces noise at or above 85 dBA.
A variety of types/styles of hearing protection are provided for employees (e.g. plugs and muff).
Site has determined that the attenuation (noise reduction rating) of hearing protection is adequate. Except for custom molded PPE, measured TWA exposure (dBA) - [(NRR-7)/2] <85 dBA is the formula. Employees working extended shifts will substitute the 85 dBA value with either 83 dBA for a 10-hour shift or 82 dBA for a 12 hour shift.
Entrances to all areas at or above 85 dBA posted with a sign that requires the use of hearing protection. Includes signs for equipment that produce noise at or above 85 dBA when operated.
Annual audiometric tests provided to all employees who may be exposed at or above an 8-hour TWA of 85 dBA. For employees working extended 10-hour or 12 hour work shifts annual audiograms are required for TWAs at or above 83 and 82 dBA, respectively.
New employees receive a baseline audiogram within 30 days of hire (employees are informed that they should avoid excessive noise for 14 hours prior to this baseline test).
Employee audiograms sent to the company hearing program vendor for analysis on approved forms (or entered into the HLPP vendors web program which include: employee name, department code, job classification code, test date, examiner's name, equipment calibration date, test results and TWA exposure.
Employees identified with an potential recordable OSHA STS retested within 30 days of that audiogram.
Employees notified in writing if analysis recommends medical referral.
Employees identified with an OSHA 10 STS notified in writing within 21 days of that audiogram.
Potential and confirmed OSHA Recordable hearing shifts entered on the site's OSHA 300 Log within 7 days of notice; unless a retest within 30 days or the results of a Work Relationship Determination questionnaire determine the shift was not persistent or related to workplace noise exposure.
A copy of OSHA noise standard 29 CFR 1910.95 posted in a prominent location in the workplace.
The following records maintained indefinitely: Exposure monitoring records , area sound level surveys, audiometric test records (employment plus 30 years), audiometer biological and annual exhaustive calibration records (, noise reduction documentation, technician training certificates, and Audiobooth ambient noise monitoring records.

Chemical Management

The site has implemented a Hazardous Chemical Review and Approval Process for all hazardous chemical products purchased, prior to these products being brought onsite, including any chemicals brought onsite by contractors.
The site has a system in place to ban the purchase of Restricted Chemicals: asbestos (> 1%), cadmium (>= 0.1%), lead-based paint (>0.06%), and Polychlorinated Biphenyls (PCBs).
The site has a written Hazard Communication Program that includes a chemical inventory, MSDSs, container labeling, training, and contractor Hazard Communication Programs.
If the site has a laboratory that meets the criteria for "laboratory scale" and "laboratory use" per 29 CFR 1910.1450, the facility has also developed and implemented a written Chemical Hygiene Plan.
The written Hazard Communication Program and/or Chemical Hygiene Plan is made available to H-E Parts International employees and contractors.
The site maintains a chemical inventory and has implemented procedures to ensure the list is current and up-to-date. At the minimum, an annual update of the inventory is required but facilities may choose to conduct more frequent updates (e.g., quarterly).
The site has a system(s) to review and maintain current copies of MSDSs (e.g., MSDS shall not be older than 5 years; (3 years for Canadian sites) MSDSs are accessible to employees and has properly archived (for 30 years) obsolete MSDSs, or the hazardous chemical lists, as allowed in 29 CFR 1910.1020(d)(ii)(B)).
Containers have a complete manufacturer's label, or, at a minimum, a label identifying the material and the appropriate hazard warning(s). There is a system to identify and correct deficient labels, as well as a system to ensure containers shipped off-site are properly labeled.
The site has conducted an initial or baseline Chemical Exposure Risk Assessment (e.g., industrial hygiene survey) of all work areas or operations to identify and assess worker chemical exposure risks.
The site conducts periodic chemical exposure risk assessments at least annually.
Records of employee exposure monitoring and Material Safety Data Sheets or the hazardous substance identity are maintained for 30 years (29 CFR 1910.1020)(d)(1)(ii)).

Respiratory Protection

Site has a written program covering applicable information from policy and site-specific respirator usage information.
A workplace chemical exposure assessment determines respirator selection.
Respirators only used where feasible engineering or administrative controls are not available.
All respirator wearers (except voluntary wearers of filtering facepieces) medically approved to wear a specific respirator before it is assigned and thereafter as directed by H-E Parts International policy protocol or , as directed by healthcare provider. , if more frequently or there is a significant change in employee's health.
Voluntary users of filtering facepieces provided with a medical evaluation if signs or symptoms of distress occur during respirator use.
Breathing air quality is verified to be Grade D or better by written certification, or other reliable means.
Fit-tests performed upon initial assignment and annually thereafter for all wearers of tight fitting respirators.
Conditions such as facial hair, head bands, or the arms of eye glasses that may interfere with the face-to-facepiece seal or valve function are not allowed.
Respirators are properly stored and kept clean and sanitary.
Respirators inspected before and after each use and during cleaning, and maintained according to manufacturer's instructions.
A change-out schedule for chemical cartridges has been established based upon manufacturer's data, or other reliable means.
Single use disposable filtering facepiece respirators ("dust masks") discarded after each day's use.

Training

New/Transferred Employees

Site has a structured health and safety new employee orientation program that meets the requirements of the corporate policy.
General health and safety rules, incident reporting procedures and the site health and safety policy reviewed in the new employee orientation.
New employee orientation program includes ergonomics awareness training.
New employee orientation program includes workers' compensation awareness training.
Specific safety procedures such as ZES/Lockout, hazard communication, noise, PPE, and confined space entry reviewed during the department orientation and consequences for violations of safety rules are discussed.
Hazard assessments/work instructions reviewed with new or transferred employees during the department health and safety orientation.
Objective health and safety performance criteria included in the evaluation during the probationary period.

General (Overview) Training

Annual training provided to all employees which reviews general health & safety rules, incident reporting procedures, and the site health & safety policy.
Annual training provided to all employees on how to access employee medical and exposure records. (29 CFR 1910.1020 (q)(1))
All employees receive annual ergonomics awareness training.
All employees receive Workers' Compensation awareness training at least every two years.
All Employees exposed to noise at or above 85 dBA (regardless of exposure duration) receive annual training. Training includes site-specific requirements.
All employees receive training on the site's Emergency Action Plan and their role during emergencies, when an employee is initially assigned, when employee responsibilities change, and when the plan is changed. (OSHA 29 CFR 1910.38)
All employees receive Hazard Communication (Hazcom) training provided upon initial assignment, when hazards change, and refresher training at a minimum of every 3 years.
Employees received training in the safe behavior process which includes how to conduct a behavior-based safety observation.
All employees and contractors informed of the presence and location of asbestos-containing materials (ACM) and presumed asbestos-containing materials (PACM), where these materials are present.
All employees have received initial training on selection, maintenance, storage and use of PPE appropriate for their jobs. Training includes a method for employees to demonstrate an understanding of the material covered.
Employees receive refresher PPE training when there are changes in the workplace, types of PPE used, or when observations indicate PPE is not being used correctly.
All employees receive annual Bloodborne Pathogen Awareness Training
All employees have received General Awareness Electrical Safety Training at least once every 3 years. (1910.332, NFPA 70E 110.6)

Functional Health & Safety Training

Fire extinguisher training provided annually for designated individuals. (OSHA 29 CFR 1910.157(g)(2))
Employees required to respond to hazardous material emergencies receive training corresponding to their responsibilities (OSHA 29 CFR 1910.120 - Hazwoper).
All emergency response personnel meet minimum training requirements and have current certifications according to emergency response assignment.
Employees designated to respond to medical emergencies annually trained in infection control procedures, the location's Exposure Control Plan with pre and post testing. (OSHA 29 CFR 1910.1030)
If an Automated External Defibrillators (AED) is used on site, certified training has been provided to those expected to use the device.
The site's designated Hearing Loss Prevention Program Coordinator has received formal hearing program management training (e.g. EHS University, Council for Accreditation in Occupational Hearing Conservation (CAOHC) or equivalent).
Employees who experience a confirmed OSHA 10 dB Standard Threshold Shift are retrained, fitted/refitted with hearing protection, and instructed in its use.
All site WC Coordinators have completed claims management training.
Designated Ergonomic Coordinator has received formal ergonomics training.
Engineers, purchasers, site healthcare professionals and others with a significant role in the site’s ergonomics program provided with the ergonomics skills and knowledge appropriate for their involvement.
Supervisors and incident investigation team members receive training in incident investigation techniques.
Employee proficiency in using ZES procedures demonstrated and verified annually.
Electrical Qualified Persons have received training to perform assigned tasks safely. (19110.269(a)(2)(i), 1910.332, NFPA 70E 110.6))
Training provided for all employees affected by the moving equipment risk assessment. This training includes their responsibilities around moving equipment.
Initial certification required for powered industrial truck operators prior to operating the vehicle.
Powered industrial truck (PIT) training program has been customized to make it both site and equipment-specific. (OSHA 29 CFR 1910.178(I)(3))
Operators of Class 1,4, and 5 PITs complete annual recertification (demonstration of skills) in accordance with the IP Lift Truck Safety and Certification Course.
PIT operators receive refresher training as required by OSHA 29 CFR 1910.178(I)(4).
Employees who train operators of Class 1, 4, and 5 PITs certified in the IP Lift Truck Safety and Certification Course.
Employees who operate aerial lifts will be trained by a qualified trainer initially before use and every three years as a refresher.
Employees exposed to potential fall hazards receive initial training. Training includes a method for employees to demonstrate an understanding of the material covered.
Confined Space Entry training conducted for affected employees initially and refresher training at least every 3 years.
Employees designated to conduct atmospheric testing of confined spaces appropriately trained.
If gas monitor maintenance and calibration is done on-site, site has trained employees to perform these duties.
Respiratory Protection training conducted annually, including training for those who voluntarily use only the filtering face-piece respirator (dust masks). (Respiratory Protection - HSPG 11: 3.9.1 and 3.9.6 and OSHA 29 CFR 1910.134 - Appendix D)
Facilities with OSHA specifically regulated chemicals (i.e., asbestos, arsenic, lead, cadmium, formaldehyde, methylene chloride and hexavalent chromium) provide detailed training as specified in these standards.
Safety Officer (LSO) trained on the hazards of misuse, control measures, and medical surveillance requirements.
Welders and supervisors of welders trained to correctly select lens shades and welding screens to protect from UV light and trained to understand the hazard UV light poses in close proximity to chlorinated solvents.

Supervisory (Management) Training Programs

All Supervisors and Managers attend all training as required.
Upon assignment, supervisors receive ergonomics training which includes education on their role in the site's ergonomics program.
New supervisors and work group leaders, including hourly employees used as temporary supervisors, receive basic Health & Safety management training (e.g., managing the safety process and hazard recognition) within six months of assignment.
Employees who directly supervise powered industrial truck operators have completed the formal instruction portion (classroom or computer-based training) of the powered industrial truck certification process.
Persons supervising users of UV-producing equipment, for example, arc welding equipment, are aware of the reaction of UV with chlorinated solvents.

Training Program Administration and Management

A training needs assessment, which considers site health & safety exposures to help determine who should receive training and frequency of training, used when developing the site safety training plan.
Site safety trainers have adequate knowledge and skill in both subject matter and training methodologies (e.g., adult learning techniques) to effectively conduct safety training.
Site uses qualified operating personnel (hourly employees) wherever possible to conduct safety training.
All safety training (including on-line and computer-based training) provides a mechanism to address trainees questions and concerns.
All safety training comprehension verified with a test of understanding (e.g., quiz, exam or supervised demonstration).
Make-up sessions held for those individuals who missed required training sessions.
System in place to evaluate training programs and drive continuous training improvements.
Training attendance documented and tracked to ensure each individual employee receives the required training.
Training records retained per the requirements of the Records Retention Model Schedule.

Maintenance and Inspection Programs

Fire Protection Inspections

Fire extinguishers, fire hoses, fire doors, and sprinkler system visually inspected at least monthly.
Fire extinguisher maintenance inspections conducted annually. (1910.157(e)(3))
Fire extinguishers and hoses hydrostatically tested at required intervals. (1910.157(f) Table L-1)
Fire water control valves visually checked monthly to ensure they are fully open and sealed or locked. Valves exercised on a quarterly basis to assure effective operation. Valves operated annually to their fully closed position and immediately reopened to assure correct operation.
Fire pumps (electric or diesel) checked and started weekly.
Sprinkler system main drain and water flow alarm tests conducted quarterly.
Dry pipe system trip tests conducted annually.
Fixed gaseous systems (e.g., halon, CO2) inspected monthly and tested semiannually. Dry/Wet chemical systems inspected monthly. Foam systems inspected monthly and tested annually.
Fire equipment and systems inspections documented and deficiencies tracked to completion.
Alarm/notification systems tested periodically and equipped with back-up power. (1910.165(d))

New Installation

System in place to ensure new designs and modifications of facilities, equipment, and processes receive appropriate safety, health, and ergonomic reviews.
Global Risk Management reviews plans of fire protection systems, site modifications and new installations.
New equipment and facilities inspected and approved prior to start-up.
ZES/Energy-control procedures developed and reviewed before start-up.
Behavioral job analysis developed and reviewed with applicable employees prior to start up of new or modified equipment.

Emergency Equipment Inspections

Eyewashes provided at battery charging stations.
Eyewashes and safety showers visible, unobstructed, and located within 10' of acid or caustic handling areas.
Eyewashes and safety showers located within 50 to 100 feet or 10 seconds of other chemical handling areas. (ANSI Z358.1 Appendix B - B.5 & 9.4)
Showers/eyewashes connected to a potable water supply with at least a 15 minute supply of water. (ANSI Z358.1 (a)(1), (a)(2), (5.15))
Eyewashes and safety showers inspected monthly and flushed weekly. (ANSI Z358.1 7.5.2)
Portable eyewash stations inspected and refilled according to manufacturers instructions.
Temperature protection provided on eyewashes and shower, where applicable.
Emergency rescue equipment readily identified, operational, and unobstructed.
Emergency-use respirators inspected monthly and in accordance with the manufacturer's recommendations.
Emergency lighting systems inspected monthly.
Automated External Defibrillators (AEDs) inspected according to manufacturer's instructions.

Materials Handling Equipment Inspections

Powered industrial trucks inspected before each shift. Truck removed from service if safety critical deficiencies are identified during inspection.
Trailers are inspected (interior/exterior) prior to loading or unloading.
Pre-delivery, pre-use, and annual equipment inspections are conducted on aerial lift equipment in accordance to the Aerial Lift Safety Guidance Document (March 2008).
Cranes and hoisting equipment visually inspected prior to use. (1910.179(j)(2)(i))
Cranes inspected periodically based on frequency of use and severity of service. (1910.179(j))
Crane and hoist inspections conducted by qualified individuals. (1910.179(l))
Slings checked visually before each use. (1910.184(d))
Alloy steel chain slings shall be thoroughly inspected once every 12 months (1910.184 (e)(3))
Visual inspection performed on hooks. Non-destructive testing performed if visually indicated.
Elevators and manlifts inspected periodically with current certifications maintained. (1910.68(e))
Repairs or modifications to powered industrial trucks, cranes, hoisting equipment, and elevators made in accordance with manufacturer's requirements.
Procedure established for identifying and removing defective equipment from service.

Gas Monitoring Equipment Inspections

Confined space survey monitor(s) are appropriate for the contaminant(s) of concern.
Confined space survey monitor(s) maintained and calibrated (at least monthly) in accordance with manufacturer's instructions.
Calibration/repair log maintained for confined space survey monitor(s).
When required, confined space survey monitor(s) used with sampling pumps and extension probes to sample remote areas of the confined space.
Confined space survey monitor(s) are "go/no-go or bump" checked before use.
Personal use monitor(s) are appropriate for the contaminant(s) of concern.
Personal use monitor(s) maintained and calibrated (at least monthly) in accordance with manufacturer's instructions, unless designed not to be calibrated.
Calibration/repair log maintained for personal use monitor(s).
Personal use monitor(s) are "go/no-go or bump" checked before each use.
Personal use monitors set at an appropriate alarm level to indicate evacuation (e.g., 5 ppm H2S and 0.3 ppm Cl02).
Area and fixed monitor(s) are appropriate for the contaminant(s) of concern.
Area and fixed monitor(s) maintained and calibrated (at least monthly) in accordance with manufacturer's instructions.
Calibration/repair log maintained for area and fixed monitor(s).
Number and placement of fixed monitor(s) are appropriate to effectively warn employees of a gas/vapor release, identify system upsets and help maintain employee exposures at or below the occupational exposure limit.
Site has implemented a plan to provide an equivalent level of protection when area and fixed monitor(s) are out of service due to repair/calibration.
Area and fixed monitors are set at an appropriate alarm level to indicate evacuation (e.g., 5 ppm H2S and 0.3 ppm ClO2 and 0.5 or 1.0 ppm Cl2).

Pressure Vessel Inspections

Fired pressure vessels are built, identified, inspected and tested according to section 1 of the ASME code.
All unfired pressure vessels (UPV) shall be periodically inspected to ensure their integrity.
Operational walkdown in-service inspections conducted by qualified persons.
A progressive record maintained for each inspection and repair including the test of set pressure and blowdown (if applicable).
Deficiencies identified on inspections are tracked and corrected.
Pressure relief valves inspected and tested according to UPV policy.
Pressure relief valves and pressure relief devices discharge in locations where employees will not be exposed to hazards of pressure, burns or chemical exposure.
All UPV repairs made in accordance with the National Board Inspection Code (NBIC).

Equipment and Site Inspections

Interlocks tested periodically where fixed point of operation guards are not practical.
Emergency stops are tested periodically.
Portable ladders inspected periodically (recommend quarterly), stored, and used correctly. (1910.25)
Portable power tools inspected quarterly. (1926.404(b)(1)(iii)(E)(4))
Housekeeping inspections conducted at least weekly.

Failure Analysis and Feedback

Incident Investigation and Reporting

Records of injuries and illnesses are maintained in accordance with the OSHA Recordkeeping Guidelines ("OSHA 300 Log"). 29 CFR 1904
All recordable injuries and illnesses, process-related incidents, and motor vehicle accidents investigated and documented using the company Incident Investigation Reporting process.
All first aid injuries and near misses investigated and documented.
The supervisor/work group leader of the affected employee coordinates the investigation and ensures the investigation is appropriately documented.
Operating procedures reviewed as part of the investigation process.
Basic or root causes, in addition to immediate causes, identified in the investigation report.
Corrective actions which address the identified basic causes are established and tracked to completion.
Process established to communicate the results of incident investigations to employees.
A process is in place to verify the quality of each incident report.
Regular incident analyses conducted to identify trends or problem areas.
System established to ensure compliance with company Crisis Communication Notification Process for both employee and contractor incidents meeting the severity threshold for notification.

Workers Compensation Management

All claims, including incidents only and first aids entered into the Incident Investigation Reporting System.
For all serious injuries, lost time claims, and contested/denied claims the Site provides all investigative materials to the Insurance Carrier within 5 business days of accident or within 24 hours of completion of the investigation if investigation is finalized after 5 days.
Site has designated a WC Coordinator and established an alternate coordinator or protocol for situations where the WC Coordinator is unavailable.
The contact information of the Insurance Carrier (State Workers Comp Information) is posted in a location visible to all employees.
The panel of preferred medical providers is posted in a location visible to all employees.
State-specific WC guidelines posted in a location visible to all employees.
Site has a documented return to work policy (RTW). This policy is compliant with the corporate return to work policy.
All modified duty or transitional work positions are reviewed every 30 days to ensure RTW position availability. Work restrictions or employee capabilities are received from the treating physician following each medical appointment.
WC Coordinator remains in contact with the injured employee throughout the period of recovery, regardless of the severity of the injury.
Site has a designated primary medical provider.
Designated primary medical providers have been educated on the site's operations and have visited the location.
Designated primary medical providers have been advised of availability of return to work options.
Designated primary medical providers are given job descriptions and/or job analysis for all injuries involving restricted duty and/or lost time.
All medical management is managed through the Insurance Carrier or State Representative. Site does not receive medical reports direct from the medical provider unless an occupational health nurse is on-site.
Site has a prescription drug program for workers comp claims and instructs the injured employee to use the prescription drug authorization form for all prescriptions that may be required.
Site maintains regular communications with the Insurance Carrier on all pending workers comp claims and is current on claim status and activities.
Assignment of defense counsel is made by and managed thru the TPA.
All litigation and communications with defense attorney is managed through and coordinated by the Insurance Carrier.
Site forwards all workers comp lawsuits to the Legal Dept, Workers Comp Dept, and/or TPA upon receipt within 24 hours.
Site receives copies of the monthly Worker's Comp Allocation Report and understands the charges made thru the Allocation program.
Site maintains separate employee medical records and workers comp files. No personal medical information unrelated to the specific workers comp injury is maintained in the workers comp claim file., unless there is an occupational health nurse on site.
Site provides workers comp training to all supervisors and all appropriate employees or members of the management team.

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Health and Safety Policy

Goals and Objectives for Accident Prevention

Performance Measurement Systems

Accounntability for Health and Safety

Contractor Management

Safety and Health Support

Other Activities

Safety Meetings

Safety Committees

Other Activities

Safe Behavior Process

Facility Safety Rules and Procedures

ZES / Lockout Control of Hazardous Energies

Moving (Energized) Equipment

Confined Space Entry (CSE)

Cutting/Welding/Hotwork

Personal Protective Equipment (PPE)

Walkways/Stairs/Ladders

Electrical

Emergency Planning and Preparedness

Materials Handling Equipment

Medical Programs

Means of Egress

Ergonomics

Flammable/Combustible Liquids

Hearing Loss Prevention

Chemical Management

Respiratory Protection

New/Transferred Employees

General (Overview) Training

Functional Health & Safety Training

Supervisory (Management) Training Programs

Training Program Administration and Management

Fire Protection Inspections

New Installation

Emergency Equipment Inspections

Materials Handling Equipment Inspections

Gas Monitoring Equipment Inspections

Pressure Vessel Inspections

Equipment and Site Inspections

Incident Investigation and Reporting

Workers Compensation Management

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