Mastering Health and Safety Risk Assessments in Industrial Environments
Ensuring health and safety in an industrial setting is paramount for the well-being of employees and the overall success of the business. This requires more than just a familiarity with compliance regulations; there must be an understanding of the risk associated with exposure to workplace hazards. I have visited many workplaces and observed many industrial processes and their associated hazards. I have had opportunities to conduct both compliance assessments and risk assessments. Through my experiences, I’ve noticed a gap in many safety professionals’ understanding of risk assessments and how to conduct them. This article will explain a simple approach to mastering health and safety risk assessments in industrial environments.
Understanding the Importance of Health and Safety Risk Assessments:
Risk assessment involves calculating the severity of potential outcomes from hazard exposure and the probability of their occurrence. Developing a risk matrix based on these factors helps visualize the level of risk, emphasizing the importance of not overlooking high risks. Regular risk assessments are key to preventing accidents, reducing liabilities, and boosting productivity. Here is an example of a risk matrix:
Key Components of a Health and Safety Risk Assessment:
The key components of a health and safety risk assessment involve hazard identification, risk evaluation, and risk control. When identifying hazards, various factors such as machinery, materials, processes, and human factors must be considered. When assessing risk, it is crucial to determine the type of injury or illness resulting from exposure to the hazard and evaluate the effectiveness of existing controls in mitigating the risk.
To illustrate, let's perform a hypothetical risk assessment on a table saw with an unguarded saw blade. The unguarded blade is identified as the hazard, with the severity of potential injury being finger amputation (i.e., Catastrophic [4]). The probability of contacting the blade is high due to its unguarded nature and frequent use (i.e., Probable [3]). Calculating the risk as 4 x 3 = 12 places it in the red portion of the risk matrix, indicating an unacceptable level of risk.
To address this, we must implement risk controls. Following the NIOSH hierarchy of controls, we prioritize engineering controls over elimination and substitution controls, as they are not feasible for our workplace. Implementing an engineering control such as a self-adjusting guard reduces the probability of injury. Upon reassessing the risk with the guard installed, the severity remains unchanged, but the probability is reduced (i.e., Improbable [1]). The calculated risk is 4 x 1 = 4, placing it in the tan portion of the risk matrix, signifying an acceptable level of risk.
Steps to Conducting Effective Risk Assessments
Preparation: Gather necessary information and resources.
Hazard Identification: Identify potential hazards in the workplace.
Risk Assessment: Evaluate the likelihood and severity of identified hazards.
Risk Control: Implement measures to eliminate or mitigate identified risks.
Review and Monitoring: Regularly review and update risk assessments to ensure ongoing effectiveness.
Common Challenges and Solutions:
Implementing workplace changes can face obstacles such as limited resources, expertise gaps, and resistance. Overcoming these challenges involves leaning on the NIOSH Hierarchy of Controls, emphasizing employee training, and nurturing a safety culture. Sharing success stories from real-world risk assessments can illustrate the approach's effectiveness and encourage its adoption.
Summary
Mastering health and safety risk assessments in industrial environments is vital for protecting workers and ensuring the sustainability of the company. Companies that are proactive in terms of risk management ensure workplace safety and compliance. I encourage you to prioritize regular risk assessments as an integral part of your health and safety management practices.
References
Department of Labor, Occupational Health and Safety Administration “Recommended Practices for Safety and Health Programs” https://www.osha.gov/safety-management/hazard-Identification
ANSI B11.0 / ANSI B11.19 / B11.TR3 Risk Assessment and Safeguarding of Machinery Package
OSHA Injury and Illness Recordkeeping and Reporting Requirements
Preventing workplace injuries and illnesses is always the focus of any company’s health and safety program; however, despite best efforts to eliminate workplace hazards and reduce risk, workplace injuries and illnesses still happen.
In my current position in the private sector and as a former OSHA Compliance Officer, I have provided safety and health consultation to employers in a wide range of industries. In both roles, I have noticed that many employers are not aware of their worker safety compliance obligations. Typical requirements that may be overlooked include injury and illness recordkeeping and reporting, documenting those records with sufficient detail, or submitting required records in a timely manner.
OSHA’s Recording and Reporting Occupational Injuries and Illnesses regulation, 29 CFR 1904, provides the compliance obligations for employers for recordable workplace injuries and illnesses. Many employers with more than ten employees are required to keep a record of serious work-related injuries and illnesses. (Certain low-risk industries are exempted). Minor injuries requiring first aid only do not need to be recorded. Visit the following links for more information on these topics:
During my career, I have found that some employers do not record occupational injuries and illnesses altogether. The basic requirement for recording listed in 29 CFR 1904.7(a) states: The employer must record any work-related injury or illness meeting the general recording criteria. That is, if it results in any of the following: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness. Also, if it involves a significant injury or illness diagnosed by a physician or other licensed health care professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness.
OSHA Injury and Illness Recordkeeping Forms
Employers must use the required forms (or forms soliciting equivalent information). OSHA provides the following forms for injury and illness recordkeeping purposes:
Forms 300, 300A, 301 and Instructions PDF Fillable Format
Forms 300, 300A, 301 Excel format (Forms ONLY) Requires Microsoft Excel or equivalent
Recording Details and Following Instructions Required by the Form
In my experience, when an employer has kept injury and illness records, the records lack the detail required and the instructions were not followed. There are numerous examples of this: not classifying the case correctly; entering the wrong information on number of days away from work or days of restricted work; incorrect tallying of injury and illness case totals; or lack of employer representative signature are a few examples commonly mentioned.
Maintaining and Posting Records
The records must be maintained at the worksite for at least five years. Each February through April, employers must post a summary of the injuries and illnesses recorded the previous year. Also, if requested, copies of the records must be provided to current and former employees, or their representatives.
Severe Injury Reporting
Employers must report any worker fatality within 8 hours and any amputation, loss of an eye, or hospitalization of a worker within 24 hours.
Electronic Submission of Records
On many occasions, I’ve noted that an employer has failed to submit injury and illness records to OSHA in a timely manner or not at all. OSHA’s Injury Tracking Application (ITA) provides a secure website that offers three options for injury and illness data submissions. You can manually enter your data, upload a CSV file to add multiple establishments at the same time, or transmit data electronically via an API (application programming interface).
Who is covered by this reporting requirement?
Only a small fraction of establishments are required to electronically submit their Form 300A data to OSHA. Establishments that meet any of the following criteria DO NOT have to electronically report their information to OSHA. Remember, these criteria apply at the establishment level, not to the firm as a whole.
The establishment's peak employment during the previous calendar year was 19 or fewer, regardless of the establishment's industry.
The establishment's industry is on Appendix A to Subpart B of OSHA’s recordkeeping regulation, regardless of the size of the establishment.
The establishment had a peak employment between 20 and 249 employees during the previous calendar year AND the establishment's industry is NOT on Appendix A to Subpart E of OSHA’s recordkeeping regulation.
What must covered establishments submit?
Covered establishments must electronically submit information from their OSHA Form 300A.
When must covered establishments submit their completed Form 300A?
Establishments must submit the required information by March 2 of the year after the calendar year covered by the forms (for example, by March 2, 2022 for the forms covering calendar year 2021).
If the submission due date of March 2 has passed, establishments that meet the reporting requirements and failed to do so must still report their Form 300A data through the ITA and can do so until December 31.
Does OSHA provide training for the general public on recordkeeping requirements?
Yes. Through its national network of OSHA Training Institute (OTI) Education Centers, OSHA offers the OSHA #7845 Recordkeeping Rule Seminar course. This half-day course covers the OSHA requirements for maintaining and posting records of occupational injuries and illnesses, and reporting specific cases to OSHA. Included in the course are hands-on activities associated with completing the OSHA Form 300 Log of Work-Related Injuries and Illnesses, OSHA Form 300A Summary of Work-Related Injuries and Illnesses, and the OSHA Form 301 Injury and Illness Incident Report. To search for specific course locations and dates, please visit the OTI Education Centers searchable schedule.
Recent Posts
Incident Investigation and Injury/Illness Reporting Requires a Systematic Approach
No one wants to have workplace accidents, but when they happen it’s important to have an Incident Investigation and Injury/Illness Reporting Program in place. The program must include the procedures necessary to properly investigate the incident and determine the cause as well as how to prevent a recurrence. The following is a summary of the steps necessary to properly respond, investigate and record an incident to meet OSHA compliance.
Reporting the Incident
First and foremost, employees must immediately report all incidents and near misses to their supervisor who will then notify the person responsible for incident investigation and injury/illness reporting. Depending upon the type and severity of the incident, notification to OSHA may also be required.
Investigate the Scene
All incidents, regardless of severity or impact, need to be thoroughly investigated. The process must look beyond what happened to discover why it happened. This will allow for the identification and correction of shortcomings in the safety and health management programs. The principal incident investigators must go to the site of the incident to conduct the investigation. It is critical that the scene is preserved to prevent material evidence from being removed or altered. Using cones, tape, and/or other guards may be required. Facts must be carefully documented.
Collect Information
The principal incident investigators must collect information through interviews, review of documents, and other means. Using a checklist may help ensure that all information pertinent to the incident is collected. In addition, other sources of useful information may be sought out such as equipment manuals and training records.
Determining Root Cause of the Incident
The principal incident investigators must determine and document the underlying reasons the incident occurred and the corrective actions required to prevent future incidents. At a minimum, a determination must be made whether there are deficiencies in any area, and in doing so persistently ask the question “Why?” at least 5 times to probe the area in depth.
Corrective Actions
The investigation is not complete until corrective actions are implemented that address the root causes of the incident. Implementation entails program-level improvements and must be supported by senior management. It is important for the person(s) responsible for incident investigation and injury/illness reporting to review the root cause factors and corrective actions and forward the information to appropriate management personnel for follow-up and implementation. It is recommended for management personnel to(s be responsible for ensuring corrective actions are implemented.
Training
The person(s) responsible for incident investigation and injury/illness reporting must also provide training to management employees who are assigned duties under the program. The training must cover a review of the Incident Investigation and Injury/Illness Reporting Program, including all the information needed and steps involved in the process.
Records Required by OSHA
The person(s) responsible for incident investigation and injury/illness reporting must ensure all injury/illness records required by OSHA are completed and maintained. The company must record information about every work-related injury or illness that involves loss of consciousness, restricted work activity or job transfer, days away from work, or medical treatment beyond first aid. Significant work-related injuries and illnesses diagnosed by a physician or licensed health care professional must also be recorded. In addition, the company must record work-related injuries and illnesses that meet any of the specific recording criteria listed in 29 CFR 1904.8 through 1904.12.
OSHA recordkeeping and reporting requirements are extensive and necessitate a robust system for reporting and retaining records related to incident investigations. To ensure all the necessary information is investigated and reported properly, ask an expert for help when implementing an Incident Investigation and Injury/Illness Reporting Program.
Further Information
Cornerstone offers a structured software application for Incident Management which can be an invaluable tool to support incident prevention programs and facilitate the process of investigating and recording incidents. We also offer safety management programs and training to help prevent injuries and illnesses in the workplace. Learn more about Incident Management Systems.
David Blane is a Senior Health and Safety Specialist. He is a Certified Safety Professional by the Board of Safety Professionals. He currently provides health and safety compliance auditing, program development, training, and industrial hygiene monitoring to Cornerstone’s industrial and construction sector clients. Blane formerly served as an OSHA compliance inspector.