One key indicator of an effective occupational health and safety (OHS) program is a relatively low workplace accident rate. How you get to that desired point takes time and effort. We can assist you with a wide range of workplace health and safety needs and requirements.
Our Occupational Health and Safety Consulting Process
Here we will explore some of the major aspects of OHS (Occupational Health & Safety) management and consulting. On this page you will find information about:
- Occupational Health and Safety
- OSHA Compliance
- MSHA Compliance
- Industrial Hygiene, Ergonomics and Material Handling
- Workers’ Compensation
We invite you to also review our information on our compliance assessment services. Because there are regulatory and practical cross-links between occupational health and safety regulations and environmental regulations, we invite you to view our Environmental Compliance information page as well.
Occupational Health and Safety Overview
Workplace occupational health and safety (OHS) is a necessity. While the regulatory requirements are important, the basis for compliance should be the prudent and correct management of employee safety by the employer. That is to say, there must be compliance regardless of the degree of enforcement.
While a safe and health workplace is an employee right, it is also a shared responsibility between the employee and employer. Best management of OHS is therefore best effective when seen as a joint mission – and a natural and mutually beneficial one at that. When effectively folded into company culture, the employer must implement a management system that is best suited to the work environment. For the system to become effective and accepted practice, it must be embraced fully by the organization. That means that all employees – from the highest ranking management member to the shop floor – must be held accountable.
There is value in linking employee performance to occupational health and safety metrics. Just as with other performance standards, desired outcome is rewarded. Likewise, if any employee, manager, or division fails to meet corporate system goals and objectives, then there should be appropriate consequences.
OSHA Compliance Consulting
Under the OSH law administered by Federal and State OSHA (Occupational Health and Safety Administration), employers have a responsibility to provide a safe workplace for their employees. The OSHA regulations cover all industries except mining where MSHA (Mine Safety and Health Administration) rules apply. OSHA rules apply to a wide range of industries with a likewise broad range of hazards. This is a general summary of some key employer responsibilities under OSHA:
- Provide a workplace free from serious recognized hazards and comply with standards, rules and regulations issued under the OSH Act.
- Ensure that workplace conditions and your administration of workplace occupational health and safety both conform to applicable OSHA standards.
- Identify, assess, mitigate and document workplace hazards and preventative and corrective measures.
- Ensure that employees have and use safe tools and equipment and properly maintain this equipment.
- Establish or update operating procedures and communicate them so that employees follow safety and health requirements.
- Provide safety training in a language and vocabulary workers can understand.
- Use visual means such as signs and labels to warn employees of potential hazards.
- Post, at a prominent location within the workplace, the OSHA poster (or the state-plan equivalent) informing employees of their rights and responsibilities.
- Keep records of work-related injuries and illnesses using the OSHA 300 form (reference: 29 CFR 1904.32) Note that employers with 10 or fewer employees and employers in certain low-hazard industries are exempt from this requirement.
There are many occupational health and safety programs required by OSHA and most all include written elements as well as, recordkeeping and employee training. Here is a list of some of the OSHA-regulated activities for general industry (with the 29 CFR Part number referenced for your convenience):
- Walking-Working Surfaces; Safety requirements for scaffolding (1910.28)
- Emergency Action Plans (1910.38);
- Fire Prevention Plans (1910.39);
- Ventilation (1910.94);
- Occupational Noise Exposure (1910.95);
- Non-ionizing Radiation (1910.97);
- Compressed Gases (general requirements); (1910.101);
- Process Safety Management of Highly Hazardous Chemicals (1910.119);
- Hazardous Waste Operations and Emergency response (1910.120);
- Personal Protective Equipment (1910.132);
- Respiratory Protection (1910.134);
- Confined Spaces (1910.146);
- The Control of Hazardous Energy (lockout/tagout); (1910.147);
- Medical Services and First Aid (1910.151);
- Portable Fire Extinguishers (1910.157);
- Powered Industrial Trucks (1910.178);
- Overhead and Gantry Cranes (1910.179);
- Machinery and Machine Guarding (1910.212);
- Hand and Portable Power Tools and Equipment (1910.242);
- Electrical Power Generation, Transmission and Distribution (1910.269);
- Electrical Safety-related Work Practices (1910.331);
- Bloodborne Pathogens (1910.1030);
- Ionizing Radiation (1910.1096);
- Hazard Communication (1910.1200);
- Occupational Exposure to Hazardous Chemicals in Laboratories (1910.1450);
- Elevated Work Platforms (1910 Subpart D);
- Means of Egress (1910 Subpart E);
- Powered Platforms, Manlifts, and Vehicle-Mounted Work Platforms (1910 Subpart F);
- Hazardous Materials (1910 Subpart H);
- Personal Protective Equipment (1910 Subpart I);
- Welding, Cutting and Brazing (1910 Subpart Q);
- Toxic and Hazardous Substances (1910 Subpart Z);
- Recordkeeping and Reporting Occupational Injuries and Illness (1904.29).
Clear Understanding of OSHA Requirements
OSHA has many similar and some different rules for the construction industry and for shipbuilding. Depending upon your location, in addition to Federal OSHA you may fall under State rules which may be more stringent that Federal OSHA. To learn more about our compliance assessment, consulting and employee training services, please click here.
OSHA’s assessment of safety and health conditions in the workplace depends on a clear understanding of the programs and management systems that an employer is using for safety and health compliance. The Agency places a high priority on safety and health programs and encourages their implementation.
OSHA may assess the effectiveness of your workplace occupational health and safety management system. When doing so, they will conduct a detailed evaluation in order to accurately determine workplace compliance conditions. In January 1989, OSHA published its voluntary Safety and Health Program Management Guidelines which have been widely used in assessing employer safety and health programs. Appendix A of this directive contains the Program Evaluation Profile (PEP), Form OSHA-195, an OSH program assessment instrument used by OSHA compliance officers in conjunction with program-specific assessments. The six main OHS program elements scored in the PEP are:
- Management Leadership and Employee Participation.
- Workplace Analysis.
- Accident and Record Analysis.
- Hazard Prevention and Control.
- Emergency Response.
- Safety and Health Training.
However, to gauge the effectiveness of your OSH management system and programs, we encourage internal and third-party assessments independent of an OSHA investigation. A gap analysis will help identify deficits and assist with the development of corrective measures. We will conduct a mock OSHA to make those assessments for you and then consult and assist with the implementation of program and procedure elements to help you meet OSHA requirements. Please ask us how we may help. Please also view our information on assessments and audits.
MSHA Compliance Consulting
Federal Mine Safety and Health Administration (MSHA) rules are related to the working conditions at surface and underground quarries and/or mines operated in the United States. While OSHA administers workplace safety rules and regulations for a wide range of workplace environments from the office environment to shipbuilding, MSHA’s purview is that of the generally high hazard mining industry.
Specific to mining, MSHA has a regular presence in the workplace and inspects with great frequency. Consequently, with a periodic and regular presence in the workplace, MSHA is more visible in that sector relative to the general presence of OSHA across a wide range of industries that those regulations cover. It is fair to say that in general, the more regular MSHA presence in the workplace inevitably leads to a higher frequency of cited violations than with their OSHA counterparts. It is recommended practice to engage third-party assessment of mining sites to preemptively identify potential occupational health and safety deficits or omissions, and consulting to correct these deficits.
Some aspects regulated by MSHA include:
- Equipment safety and maintenance
- aspects of construction; signage and warning labels
- the storage, handling and use of explosives
- mine safety protocols; medical monitoring
- employee training
- recordkeeping and more
Let us assess your operations and suggest prescriptive remedies as needed. Please ask us how we may help.
Industrial Hygiene Consulting
In many industries, there are potential health and safety risks due to possible exposure from a number of different sources. Industrial (or occupational) hygiene focuses on identifying and evaluating workplace hazards and helping to develop appropriate measures to protect employees from excessive exposure. The assessment methods are analytical and scientific. According to the National Institutes of Health (NIH):
“Industrial hygiene is generally defined as the art and science dedicated to the anticipation, recognition, evaluation, communication and control of environmental stressors in, or arising from, the work place that may result in injury, illness, impairment, or affect the wellbeing of workers and members of the community. These stressors are divided into the categories biological, chemical, physical, ergonomic and psychosocial.”
Typical exposures that are of interest include respiratory hazards from exposure to dusts, mists, fumes or aerosols with an emphasis on chemical exposure. Additionally, dermal or skin contact with chemicals is a typical avenue of exposure that can be analyzed. Besides airborne and dermal exposures chiefly to chemicals and/or bio-hazardous constituents, other aspects of exposure may include noise, temperature extremes, building ventilation (indoor air quality), lighting (too much or not enough), and other specific exposure such as heat sources (flame, heated equipment and/or materials, etc.), excessive cold sources such as refrigerated or cryogenic materials and liquids, and radiation sources such as infrared, ultraviolet, laser, radio waves, X-Rays and radioactive sources. There may be other potential hazard sources in the work environment.
While it is the duty of the employer to identify and mitigate potential health risks to the employee, many times the evaluation especially of such hazards falls to the industrial hygiene specialist. It is vital to identify and characterize risks to employee health and safety. After assessment and analysis, the implementation of proper control methods will invariably reduce the risk of injury and/or illness to the otherwise potentially exposed employee. OSHA (the Occupational Health and Safety Administration) has developed numerous rules and requirements related to workplace exposures of the types we have discussed here. Some programs may be more general such as the Hazard Communication Standard, or may be exposure or chemical specific. Knowing what exposures exist or may exist can help you develop not only control measures but business operation strategies. For example, understanding both specific chemical exposure risks as well as OSHA requirements for that chemical may lead an employer to limit the use of the material or to substitute a less harmful chemical or process. Often times IH investigations help promote beneficial changes and improvements that reach beyond OHS (occupational health and safety). It may be that a chemical substitution will also result in lower procurement and disposal costs, or a modified process will become more efficient and cost effective.
Industrial hygiene investigations may be a necessary component of your compliance with OSHA rules. They can identify and assess health & safety problems in the workplace and with analytical date, can help develop measures to properly protect your employees. This effort runs in tandem with strengthening your existing occupational and health and safety (HS) programs through program and procedure development, employee training and recommendations related to safe work practices.
Hazard control methods include administrative means such as policy and procedures, training, labeling and signage. In addition, engineering controls to isolate employees from hazards may also be recommended. Finally, when administrative and engineering controls alone or together still do not provide sufficient means to protect the employee (or if there are not practical), then the last step is to issue PPE (personal protective equipment) worn by the employee. Ask us about a safety and health analysis of your workplace. Based on our findings, we may recommend further assessment by a certified industrial hygienist. Please ask us how we may help you identify and mitigate workplace health and safety exposures.
Ergonomics and Material Handling Consulting
A notable number of workplace injuries across industries result from material handling. Ergonomics is the science and study of the relationship between the biomechanics of the human body and how it reacts to and is suited to the demands of physical tasks. A tremendous amount of information is available that helps optimize the relationship between the employee, the tasks they engage in and the tools they need to manage the job effectively and safely. In brief, the task should fit the person and not the other way around. The employee should be physically suited to their job tasks and physically fit as well. The tools and equipment (the engineering controls) that are used should be optimized to the employee and provide assistance to prevent injury or illness that would otherwise manage their tasks. Coupled with this are administrative tools such as training, and procedures to educate the employee. More than that, the use of job rotation to prevent prolonged exposure to especially repetitive and physically demanding asks can also help to reduce the incidence of injury. As noted, being suitably fit for the job at hand is another means to help reduce the likelihood of injury. To that end, a degree of physical fitness awareness and exercises have been show benefit affected employees.
In most all cases, an assessment of workplace ergonomic and material handling is recommended. Please ask us how we may help.
Workers’ Compensation Management and Consulting
Your injury and illness rate dictate your Experience Modification (or “ex mod”) rate which is used by your insurance carrier to determine the correct insurance premium rate for your worker’s compensation insurance coverage. Obviously, the higher your claim rate, so follows your premiums. However, even if workplace injury and illness rates drop, your premium may not follow as quickly.
Experience rating was created by state regulators to encourage workplace safety. The basis is purely fiscal leverage. The “experience rating” period is generally three policy years. Think of it as a trailing indicator that stakes past performance against your current insurance rate. Your ex mod is determined by comparing the actual losses your business has during the experience rating period to the average expected losses for all members of your same industry classification (Actual Losses/Expected Losses = Experience Modification). If your loss record is better than the average, then you will have an ex mod below 100%, or a credit. By improving workplace safety, you can help lower the chance of injury or illness in your workplace. Over time, this reduction in claims can lead to a lower ex mod.
By improving workplace safety, you can help lower the chance of injury or illness in your workplace. Over time, this reduction in claims can lead to a lower “ex mod”. While many insurance companies partner with you, the insured, to help you reduce injury and illnesses, a third party analysis of your workplace is an especially good idea and more than that, doing so before injuries become and issue is the best method. We recommend periodic self-assessments and third-party workplace safety and audits of your OHS (occupational health and safety) management system performance. Doing so can improve the likelihood of better insurance rates. Please ask us how we may help.