OSHA's Program Evaluation Guide

To further assist the employer in evaluating or implementing their safety and health program and to assist the CSHO in a evaluating a workplace safety and health program, the following program evaluation guide is provided.

The use of the program evaluation guide is not required, but rather is provided as a tool for use and assistance in evaluation of ones program or as a guide in using the 1989 safety and health guidelines. Each of the elements and factors of the program evaluation may be scored from 1 to 5, indicating the level of the safety and health program, as follows:

Overall Score Level of Safety and Health Program

5 Outstanding program

4 Superior program

3 Program implemented

2 Developmental program

1 No program implemented

MANAGEMENT LEADERSHIP and EMPLOYEE PARTICIPATION

Management Leadership

Visible management leadership provides the motivating force for an effective safety and health program. [1989 Voluntary Safety and Health Program Management Guidelines, (b)(1) and (c)(1)]

1 Management demonstrates no policy, goals, objectives, or interest in safety and health issues at this worksite.

2 Management sets and communicates safety and health policy and goals, but remains detached from all other safety and health efforts.

3 Management follows all safety and health rules, and gives visible support to the safety and health efforts of others.

4 Management participates in significant aspects of the site's safety and health program, such as site inspections, incident reviews, and program reviews. Incentive programs that discourage reporting of accidents, symptoms, injuries, or hazards are absent. Other incentive programs may be present.

5 Site safety and health issues are regularly included on agendas of management operations meetings. Management clearly demonstrates—by involvement, support, and example--the primary importance of safety and health for everyone on the worksite. Performance is consistent and sustained or has improved over time.

MANAGEMENT LEADERSHIP and EMPLOYEE PARTICIPATION

Employee Participation

Employee participation provides the means through which workers identify hazards, recommend and monitor abatement, and otherwise participate in their own protection. [Guidelines, (b)(1) and (c)(1).]

1 Worker participation in workplace safety and health concerns is not encouraged. Incentive programs are present which have the effect of discouraging reporting of incidents, injuries, potential hazards or symptoms. Employees/employee representatives are not involved in the safety and health program.

2 Workers and their representatives can participate freely in safety and health activities at the worksite without fear of reprisal. Procedures are in place for communication between employer and workers on safety and health matters. Worker rights under the Occupational Safety and Health Act to refuse or stop work that they reasonably believe involves imminent danger are understood by workers and honored by management. Workers are paid while performing safety activities.

3 Workers and their representatives are involved in the safety and health program, involved in inspection of work area, and are permitted to observe monitoring and receive results. Workers' and representatives' right of access to information is understood by workers and recognized by management. A documented procedure is in place for raising complaints of hazards or discrimination and receiving timely employer responses.

4 Workers and their representatives participate in workplace analysis, inspections and investigations, and development of control strategies throughout facility, and have necessary training and education to participate in such activities. Workers and their representatives have access to all pertinent health and safety information, including safety reports and audits. Workers are informed of their right to refuse job assignments that pose serious hazards to themselves pending management response.

5 Workers and their representatives participate fully in development of the safety and health program and conduct of training and education. Workers participate in audits, program reviews conducted by management or third parties, and collection of samples for monitoring purposes, and have necessary training and education to participate in such activities. Employer encourages and authorizes employees to stop activities that present potentially serious safety and health hazards.

 

MANAGEMENT LEADERSHIP and EMPLOYEE PARTICIPATION

Implementation

Implementation means tools, provided by management, that include:

-- budget

-- information

-- personnel

-- assigned responsibility

-- adequate expertise and authority

-- means to hold responsible persons accountable (line accountability)

-- program review procedures.

[Guidelines, (b)(1) and (c)(1)]

1 Tools to implement a safety and health program are inadequate or missing.

2 Some tools to implement a safety and health program are adequate and effectively used; others are ineffective or inadequate. Management assigns responsibility for implementing a site safety and health program to identified person(s). Management's designated representative has authority to direct abatement of hazards that can be corrected without major capital expenditure.

3 Tools to implement a safety and health program are adequate, but are not all effectively used. Management representative has some expertise in hazard recognition and applicable OSHA requirements. Management keeps or has access to applicable OSHA standards at the facility, and seeks appropriate guidance information for interpretation of OSHA standards. Management representative has authority to order/purchase safety and health equipment.

4 All tools to implement a safety and health program are more than adequate and effectively used. Written safety procedures, policies, and interpretations are updated based on reviews of the safety and health program. Safety and health expenditures, including training costs and personnel, are identified in the facility budget. Hazard abatement is an element in management performance evaluation.

5 All tools necessary to implement a good safety and health program are more than adequate and effectively used. Management safety and health representative has expertise appropriate to facility size and process, and has access to professional advice when needed. Safety and health budgets and funding procedures are reviewed periodically for adequacy.

MANAGEMENT LEADERSHIP and EMPLOYEE PARTICIPATION

Contractor Safety

Contractor safety: An effective safety and health program protects all personnel on the worksite, including the employees of contractors and subcontractors. It is the responsibility of management to address contractor safety. [Guidelines, (b)(1) and (c)(1)]

1 Management makes no provision to include contractors within the scope of the worksite's safety and health program.

2 Management policy requires contractor to conform to OSHA regulations and other legal requirements.

3 Management designates a representative to monitor contractor safety and health practices, and that individual has authority to stop contractor practices that expose host or contractor employees to hazards. Management informs contractor and employees of hazards present at the facility.

4 Management investigates a contractor's safety and health record as one of the bidding criteria.

5 The site's safety and health program ensures protection of everyone employed at the worksite, i.e., regular full-time employees, contractors, temporary and part-time employees.

WORKPLACE ANALYSIS

Survey and Hazard Analysis

Survey and hazard analysis: An effective, proactive safety and health program will seek to identify and analyze all hazards. In large or complex workplaces, components of such analysis are the comprehensive survey and analyzes of job hazards and changes in conditions. [Guidelines, (c)(2)(I)]

1 No system or requirement exists for hazard review of planned/changed/new operations. There is no evidence of a comprehensive survey for safety or health hazards or for routine job hazard analysis.

2 Surveys for violations of standards are conducted by knowledgeable person(s), but only in response to accidents or complaints. The employer has identified principle OSHA standards which apply to the worksite.

3 Process, task, and environmental surveys are conducted by knowledgeable person(s) and updated as needed. Current hazard analyzes are written (where appropriate) for all high-hazard jobs and processes; analyzes are communicated to and understood by affected workers. Hazard analyzes are conducted for jobs, tasks,, workstations, where injury or illnesses have been recorded.

4 Methodical surveys are conducted periodically and drive appropriate corrective action. Initial surveys are conducted by a qualified professional. Current hazard analyzes are documented for all work areas and are communicated and available to all the workforce; knowledgeable persons review all planned/changed/new facilities, processes, materials, or equipment.

5 Regular surveys including documented comprehensive workplace hazard evaluations are conducted by certified safety and health professional. Corrective action is documented and hazard inventories are updated. Hazard analysis is integrated into the design, development, implementation, and changing of all processes and work practices.

WORKPLACE ANALYSIS

Inspection

Inspection: To identify new or previously missed hazards and failures in hazard controls, an effective safety and health program will include regular site inspections. [Guidelines, (c)(2)(ii)]

1 No routine physical inspection of the workplace and equipment is conducted.

2 Supervisors dedicate time to observing work practices and other safety and health conditions in work areas where they have responsibility.

3 Competent personnel conduct inspections with appropriate involvement of workers. Items in need of correction are documented. Inspections include compliance with relevant OSHA standards. Time periods for correction are set.

4 Trained workers conduct inspections, and all items are corrected promptly and appropriately. Workplace inspections are planned, with key observations or check points defined and results documented. Persons conducting inspections have specific training in hazard identification applicable to the facility. Corrections are documented through follow-up inspections. Results are available to workers.

5 Inspections are planned and overseen by certified safety or health professionals. Statistically valid random audits of compliance with all elements of the safety and health program are conducted. Observations are analyzed to evaluate progress.

WORKPLACE ANALYSIS

Hazard Reporting

A reliable hazard reporting system enables workers, without fear of reprisal, to notify management of conditions that appear hazardous and to receive timely and appropriate responses. [Guidelines, (c)(2)(iii)]

1 No formal hazard reporting system exists, or workers are reluctant to report hazards.

2 Workers are instructed to report hazards to management. Supervisors are instructed and are aware of a procedure for evaluating and responding to such reports. Workers use the system with no risk of reprisals.

3 A formal system for hazard reporting exists. Worker reports of hazards are documented, corrective action is scheduled, and records maintained.

4 Workers are periodically instructed in hazard identification and reporting procedures. Management conducts surveys of worker observations of hazards to ensure that the system is working. Results are documented.

5 Management responds to reports of hazards in writing within specified time frames. The workforce readily identifies and self-corrects hazards; they are supported by management when they do so.

ACCIDENT and RECORD ANALYSIS

Accident Investigation

Accident investigation: An effective program will provide for investigation of accidents and Near miss incidents, so that their causes, and the means for their prevention, are identified. [Guidelines, (c)(2)(iv)]

1 No investigation of accidents, injuries, near misses, or other incidents is conducted.

2 Some investigations of incidents takes place, but root cause may not be identified, and correction may be inconsistent. Supervisors prepare injury reports for lost time cases.

3 OSHA-101 is completed for all recordable incidents. Reports are generally prepared with cause identification and corrective measures prescribed.

4 OSHA-recordable incidents are always investigated, and effective prevention is implemented. Reports and recommendations are available to workers. Quality and completeness of investigations are systematically reviewed by trained safety personnel.

5 All loss-producing accidents and "near-misses" are investigated for root causes by teams or individuals that include trained safety personnel and workers.

ACCIDENT and RECORD ANALYSIS

Data Analysis

Data analysis: An effective program will analyze injury and illness records for indications of sources and locations of hazards, and jobs that experience higher numbers of injuries. By analyzing injury and illness trends over time, patterns with common causes can be identified and prevented. [Guidelines, (c)(2)(v)]

1 Little or no analysis of injury/illness records; records (OSHA 200/101, exposure monitoring) are kept or conducted.

2 Data is collected and analyzed, but not widely used for prevention. OSHA -101 is completed for all recordable cases. Exposure records and analyzes are organized and are available to safety personnel.

3 Injury/illness logs and exposure records are kept correctly, are audited by facility personnel, and are essentially accurate and complete. Rates are calculated so as to identify high risk areas and jobs. Workers compensation claim records are analyzed and the results used in the program. Significant analytical findings are used for prevention.

4 Employer can identify the frequent and most severe problem areas, the high risk areas and job classifications, and any exposures responsible for OSHA recordable cases. Data are fully analyzed and effectively communicated to workers. Illness/injury data are audited and certified by a responsible person.

5 All levels of management and the workforce are aware of results of data analyzes and resulting preventive activity. External audits of accuracy of injury and illness data, including review of all available data sources are conducted. Scientific analysis of health information, including non-occupational data bases is included where appropriate in the program.

HAZARD PREVENTION and CONTROL

Hazard Control and Maintenance

Hazard Control: Workforce exposure to all current and potential hazards should be prevented or controlled by using engineering controls wherever feasible and appropriate, work practices and administrative controls, and personal protective equipment (PPE). An effective safety and health program will provide for facility and equipment maintenance, so that hazardous breakdown is prevented. [Guidelines, (c)(3)(I) and (ii)]

1 Hazard control is seriously lacking or absent from the facility. No preventive maintenance program is in place; break-down maintenance is the rule.

2 Hazard controls are generally in place, but effectiveness and completeness vary. Serious hazards may still exist. Employer has achieved general compliance with applicable OSHA standards regarding hazards with a significant probability of causing serious physical harm. Hazards that have caused past injuries in the facility have been corrected. There is a preventive maintenance schedule, but it does not cover everything and may be allowed to slide or performance is not documented. Safety devices on machinery and equipment are generally checked before each production shift.

3 Appropriate controls (engineering, work practice, and administrative controls, and PPE) are in place for significant hazards. Some serious hazards may exist. Employer is generally in compliance with voluntary standards, industry practices, and suppliers' safety recommendations. Documented reviews of needs in machine guarding, energy lockout, ergonomics, materials handling, bloodborne pathogens, confined space, hazard communication, and other generally applicable standards have been conducted. The overall program tolerates occasional deviations. A preventive maintenance schedule is implemented for areas where it is most needed; it is followed under normal circumstances. Manufacturers' and industry recommendations for maintenance frequency are complied with. Breakdown repairs for safety related items are expedited. Safety device checks are documented. Ventilation system function is observed periodically.

4 Hazard controls are fully in place, and are known and supported by the workforce. Few serious hazards exist. The employer requires strict and complete compliance with all OSHA, consensus, and industry standards and recommendations. All deviations are identified and cause determined. The employer has effectively implemented a preventive maintenance schedule that applies to all equipment. Facility experience is used to improve safety-related preventative maintenance scheduling.

5 Hazard controls are fully in place and continually improved upon based upon workplace experience and general knowledge. Documented reviews of needs are conducted by certified health and safety professionals. There is a comprehensive safety and preventative maintenance program that maximizes equipment reliability.

HAZARD PREVENTION and CONTROL

Medical Program

An effective safety and health program will include a suitable medical program where it is appropriate for the size and nature of the workplace and its hazards. [Guidelines, (c)(3)(iv)]

1 Employer is unaware of, or unresponsive to medical needs. Required medical surveillance, monitoring, and reporting are absent or inadequate.

2 Required medical surveillance, monitoring, removal, and reporting responsibilities for applicable standards are assigned and carried out, but results may be incomplete or inadequate.

3 Medical surveillance, removal, monitoring, and reporting comply with applicable standards. Workers report early signs/symptoms of job-related injury or illness and receive appropriate treatment.

4 Health care providers provide follow-up on worker treatment protocols and are involved in hazard identification and control in the workplace. Medical surveillance addresses conditions not covered by specific standards. Worker concerns about medical treatment are documented and responded to.

5 Health care providers are on-site for all production shifts and are fully involved in hazard identification and training. Health care providers periodically observe the work areas and activities and are fully involved in hazard identification and training.

EMERGENCY RESPONSE

Emergency Preparedness and First Aid

Emergency preparedness: There should be appropriate planning, training/drills, and equipment for response to emergencies. Note: In some facilities the employer plan is to evacuate and call the fire department. In such cases, only applicable items listed below should be considered. First aid/emergency care should be readily available to minimize harm if an injury or illness occurs. [Guidelines, (c)(3)(iii) and (iv)]

1 Little or no effective effort to prepare for emergencies. Neither on-site nor nearby community aid (e.g., emergency room) can be ensured.

2 Emergency response plans for fire, chemical, and weather emergencies as required by 1910.38, 1910.120 are present. Training is conducted as required by the standard. Some deficiencies may exist. Either on-site or nearby community aid is available on every shift.

3 Emergency response plans have been prepared by persons with specific training. Appropriate alarm systems are present. Workers are trained in emergency procedures. The emergency response extends to spills and incidents in routine production. Adequate supply of spill control and PPE appropriate to hazards on site are available. Personnel with appropriate first aid skills commensurate with likely hazards in the workplace and as required by OSHA standards (e.g., 1910.151) are available. Management documents and evaluates response time on a continuing basis.

4 Evacuation drills are conducted no less than annually. The plan is reviewed by a qualified safety and health professional. Personnel with certified first aid skills are always available on-site; their level of training is appropriate to the hazards of the work being done. Adequacy of first aid is formally reviewed after significant incidents.

5 Designated emergency response team with adequate training are on-site. All potential emergencies have been identified. Plan is reviewed by the local fire department. Plan and performance are reevaluated at least annually and after each significant incident. Procedures for terminating an emergency are clearly defined. Personnel trained in advanced first aid and/or emergency medical care are always available on-site. In larger facilities a health care provider is on-site for each production shift.

SAFETY and HEALTH TRAINING

Safety and health training should cover the safety and health responsibilities of all personnel who work at the site or affect its operations. It is most effective when incorporated into other training about performance requirements and job practices. It should include all subjects and areas necessary to address the hazards at the site. [Guidelines, (b)(4) and (c)(4)]

1 Facility depends on experience and peer training to meet needs. Managers/supervisors demonstrate little or no involvement in safety and health training responsibilities.

2 Some orientation training is given to new hires. Some safety training materials (e.g., pamphlets, posters, videotapes) are available or are used periodically at safety meetings, but there is little or no documentation of training or assessment of worker knowledge in this area. Managers generally demonstrate awareness of safety and health responsibilities, but have limited training themselves or involvement in the site's training program.

3 Training includes OSHA rights and access to information. Training required by applicable standards is provided to all site workers. Supervisors and managers attend training in all subjects provided to workers under their direction. Workers can generally demonstrate the skills/knowledge necessary to perform their jobs safety. Records of training are kept and training is evaluated to ensure that it is effective.

4 Knowledgeable persons conduct safety and health training that is scheduled, assessed, and documented, and addresses all necessary technical topics. Workers are trained to recognize hazards, violations of OSHA standards, and facility practices. Workers are trained to report violations to management. All site workers--including supervisors and managers--can generally demonstrate preparedness for participation in the overall safety and health program. There are easily retrievable scheduling and record keeping systems.

5 Knowledgeable persons conduct safety and health training that is scheduled, assessed, and documented. Training covers all necessary topics, situations, and that includes all persons working at the site (hourly workers, supervisors, managers, contractors, part-time and temporary workers). Workers participate in creating site-specific training methods and materials. Workers are trained to recognize inadequate responses to reported program violations. Retrievable recordkeeping system provides for appropriate retraining, makeup training, and modifications to training as the result of evaluations.

 

Reference: http://www.osha-slc.gov/OshDoc/Directive_data/CPL_2-0_119.html