Lots of companies are confused about how to comply with OSHA’s electric arc flash standards!  Some hire high priced consultants to help them develop their arc flash policies and procedures.  

While I’m no arc flash expert, I have worked at companies where we developed our own arc flash programs in-house, without any outside assistance.  So far, each of these programs have passed OSHA’s scrutiny during multiple on-site inspections. 

I see the arc flash requirements as having some similarity to both the lockout tagout (LOTO) and the confined space requirements that many of us are already familiar with - 

• If you can disconnect and LOTO all of the electricity to the electrical equipment that is being worked on you no longer need to be concerned with arc flash.
• Each company should designate and develop their own arc flash “qualified person”.  This person will be the in-house arc flash guru (expert).  He or she should develop the written arc flash policy and procedures for the company.  There are various arc flash training seminars that the company’s qualified person can attend to further their knowledge of arc flash exposures and controls.
• Those employees, often master electricians, who will be working on or near exposed energized parts, are similar to LOTO “authorized persons”.  They should receive advanced specialized training (often provided by the qualified person) in: OSHA’s electrical safety standards, NFPA 70E, company arc flash policy and procedures, arc flash hazard analysis (AFHA), PPE requirements, arc flash labeling, special insulated tools, and other safety information.
• All other production employees are similar to LOTO “affected persons”.  They should receive general training to understand: arc flash hazards,  arc flash labels,  flash protection boundary, and the company’s arc flash policy and procedures.
• Performing electrical work on live systems over 50 volts should require the company’s arc flash qualified person to issue an energized electrical work permit (a procedure similar to confined space entry permit, although the form is totally different). 
• An arc flash hazard analysis (AFHA) should be done before the electrical work is performed to: evaluate the exposure, reduce incident energy levels, generate an arc flash label, select the proper PPE and tools, and identify safety procedures.  Software is available (see below) that can help with these calculations.  These AFHAs are sometimes done ahead of time for the entire facility.
• A job briefing should be held between the qualified person and the authorized person before the start of work.       

Many of the resources a company needs to figure out the arc flash requirements already exist on the Internet.  Below are my favorite arc flash links.  They will help you to understand the arc flash standards, and to develop your own arc flash policies and procedures.

• Understanding OSHA Arc Flash Regulations (video)
• What every owner and contractor should know about NFPA70E
• OSHA requires arc flash protection
• Arc flash compliance: What you need to know
• Arc flash handbook
• The dangers of arc flash
• OSHA and arc flash
• NFPA 70E electrical safety summary
• NFPA 70E : standard for electrical safety in the workplace
• OSHA’s electrical safety & arc flash resources
• Arc flash safety
• Arc flash products
• Arc flash videos
• Arc flash labeling
• Arc flash software
• Arc flash webinar I
• Arc flash webinar II
• Arc flash webinar III
• Arc flash webinar IV

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Lately, much has been written about how employees dislike Behavior Based Safety (BBS) programs.  For those who are not familiar with BBS, it’s basically a program where workers are regularly “observed” while they are working in order to determine if they are following the prescribed safety procedures and work rules.

The three main complaints I’ve heard from employees and unions about BBS have to do with:

• observers sneaking around and watching the employee who’s being observed from a hidden location (the worker would not be aware they were being watched)
• observers “interfering” with the worker performing their job – such a distraction could lead to an accident
• employees being disciplined for safety and work rule violations seen during the observation (like a game of “gotcha”)

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A few years ago I set up a successful BBS observation program at a company I was safety manager at.  I wanted to obtain the employee’s and the union’s support before I kicked it off, so I met with the union before implementing the program to address the above concerns.  I promised that -

• before any observation would be done, the employee would be told that they were going to be observed and that the observer would be in plain sight
• the observer would not interfere with a job and would ”debrief” the worker at the end of the work cycle (only exception would be if the worker was in immanent danger)
• there would be no disciplinary action taken for any rule infractions seen during the observation

Having addressed the union’s main concerns, we proceeded with implementing our new BBS observation program.  With the complete support of the employees and union, the new BBS program got off to a great start.  Over time, the percentage of “safe” observations improved and so did our accident record!

If you are contemplating starting a BBS program at your company, you too may want to address the above employee/union BBS concerns before implementation.

Watch for a future article on the details of my simple yet effective BBS program.

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Below is our “Safety App of the Week”.  These weekly features are published every Monday.  New apps are tested on Apple iPads and rated from ♥ to ♥♥♥♥♥ (♥♥♥♥♥ is the best).  Prior app of the week articles are archived here.

Job Safety Analysis (JSA) iPad

Official Description  

“Are you a Business Manager, Owner or Safety Personnel that sees the benefit of reducing JSA paperwork to keep your people safe? Are you looking for ways to increase efficiency throughout your business, through a JSA?

Here at Team Solutions Training (TST) our Mission is to provide “deliberately different” training and cutting edge technologies to help save more lives and increase productivity.

We have witnessed first hand the inefficiencies and negativity associated with completing a Job Safety Analysis (JSA). The Managing Director, Kym Steer, has spent years working and training top clientele in Risk Management has seen first hand the pitfalls and successes of Job Safety Analysis (JSA).

The “TST Job Safety Analysis (JSA)” App is an Innovative new way to complete JSAs and has been designed with the ability to:
- Create your own JSAs with easy to use menus.
- Use the pre-filled options to complete it faster and spend the time reviewing rather than writing.
- Use the clear Risk Matrix that’s fun to play with to enable concentration for calculating risk.
- Take photos of Hazards & Risks.
- Save time in the field.
- GPS tag your location for each and every JSA.”¹

Thumbs Up

• no registration or sign in required
• easy to follow instructions
• you can develop your own JSAs using their standard JSA form (with drop down menus)
• uses the standard JSA (aka JHA) format that we are all familiar with
• a nice addition to the standard format is a new column that “rates the risk”
• visually beautiful with easy to read words and attractive colors
• you can search your completed JSAs by: JSA, job, department, location, company, and date
• completed JSAs can be saved and emailed to others
• incorporates useful risk matrix and hierarchy of controls tables
• there is a separate iPhone version

Thumbs Down

• The app is technically free.  But the free app is worthless because you can not either save or email the JSAs you develop unless you upgrade to the $4.99 paid version.  This is deceptive.  I don’t know why they don’t just say up front that the app costs $4.99.  This excellent app is certainly worth much more than $4.99.
• Only one JSA form is available and it can not be modified.  Users should be able to modify the format of this JSA form, or at least be given a wider selection of different JSA forms to choose from.  

Overall Rating

• iPad - ♥♥♥♥

¹ Descriptions courtesy of Apple Inc.

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I hear rumors about ISO possibly working on development of a new occupational health and safety management system (OHSMS) standard to replace OHSAS 18001.  I don’t follow this very closely myself, but Thea Dunmire does.  Here’s a link to her blog article entitled An ISO OHSMS Standard?   It will tell you where this new ISO initiative is currently at.

To keep up on the latest ISO OHSMS developments, you may want to periodically check the home page on Thea’s blog.

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The Rochester Business Alliance Safety Solutions Guide (SSG) has been the high quality choice for Business Alliance members seeking single source occupational safety and health documentation of workplace safety and health procedures and training.  In the ten years since it was first published, many members have jumped at the opportunity to have a clearly written and consistently helpful binder of safety and health material.

Now, the MS Word-based package of over 44 procedures with integral training outlines for each is being offered to employers world-wide through the SafetyAwakenings web site.  In MS Word format, it’s designed for easy modification to suit unique approaches and rapid customization.  Converted to PDF format, the SSG can be made available to employees on the company intranet to ensure ready access and effective utilization.

SafetyAwakenings founder and webmaster Dave Weber, following his review of the package, said “if I was still an EHS manager, this is definitely something I’d want.  Compared to the stuff (other vendors) sell, it’s a bargain at $525!  I’d be proud to market this high quality product!”

The safety manager at an OSHA VPP site says “the (SSG) has eliminated uncertainty in meeting OSHA standards, identifies training key points and provides structure for the safety system.  The SSG was a key element of our safety improvement effort and…was instrumental in helping us pass two VPP audits.”

While written primarily for the U. S. market, the concepts and approaches covered in the manual are consistent with safety best practices worldwide.  For buyers outside the U. S., the modest changes necessary to meet country-specific requirements can be made with minimal effort.

To access a free Preview Package that includes two free procedures (a $105.00 value) and place an order, click here.

Rochester Business Alliance members can click here  to view the Preview Package and place orders.

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Thirty nine percent of on-the-job fatalities occur while driving.  If your organization has employees who drive (either as their main job or as a part-time casual driver) you need to have a comprehensive drivers safety program.

At the heart of every good drivers safety program is an MVR policy.  This policy addresses the required qualifications of all drivers, and specifies what is an acceptable MVR (Motor Vehicle Report).

The Travelers Insurance Company has an excellent, 4-page MVR policy that you can download here.  Compare your existing MVR policy to this one.  If it falls short, you may want to update it.  This model policy includes an:

• MVR policy statement
• MVR grid
• MVR flow chart
• MVR points system

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The best defense against an OSHA citation is “proper documentation”.  OSHA does not recognize that something occurred unless the employer can prove it through documentation.  The burden of proof is on the employer to prove that they were in compliance.

What safety records should you keep?  When I was a corporate safety manager the following were the documents that I archived:

• sign in sheets for training meetings
• details of the training provided (PowerPoints/videos used, test/quiz score and questions, handouts)
• equipment maintenance and repair records (e.g. inspections, preventative maintenance, safety related repairs)
• new hire training (orientation checklist, policy acknowledgement form)
• departmental safety meetings
• safety agenda items in management meetings
• completed change approval forms
• change training ( new - chemical, machine, process)
• policy training
• OSHA required training (new hire, refresher)
• at risk employee training (repeaters, near misses, post accident)
• task/job training
• ad hoc training (e.g. work floor training using an iPad)
• disciplinary action taken for safety infractions
• safety walk around inspection reports
• daily equipment tests
• period machinery safety surveys
• safety rules (past and present)
• JSA’s (aka JHA’s)
• computer based training programs
• safety committee minutes
• safety recommendation follow up
• third party inspection reports (fire department, insurance company, OSHA,  consultants)
• current and prior safety policies
• employee safety suggestions and their follow up
• industrial hygiene air testing
• noise surveys
• employee biological testing (e.g. blood lead, audiograms)
• behavioral job observations
• accident investigation reports (and follow up action taken)
• confined space entry permits
• before and after safety photographs
• risk assessments

Don’t forget that all safety documents should be “dated” and “signed”.  This is pretty basic, but you would not believe the number of safety documents I’ve seen over the years that were either not dated or not signed by the person who completed it.

Is it acceptable for a document to be “hand written”?  While hand written records are acceptable, I have found that often they are unreadable either because they were completed in a hurry, or because the writer had horrible penmanship.  If a safety document can not be typed, then make sure it’s completed by an employee with good penmanship.

Should your records be hard copies or computer documents?  OSHA will accept either.  Computer records are much easier to organize, copy and store.  Be sure to keep at least one up-to-date backup copy of all safety related records at a remote location.

How long should records be kept?  My policy is to keep all safety and OSHA compliance related documents forever.  Computer memory is cheap.  Keeping a document forever simplifies things and eliminates the chance of someone accidentally deleting an important file.

If OSHA visits your company to investigate an on the job fatality, documentation will be a key factor in determining if you get cited, the amount of the fine, and even if criminal action will be taken against your management.

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The CSA Group in Canada recently published a unique and very progressive new safety guideline (voluntary standard) entitled CAN/CSA-Z1003-13/BNQ 9700-803/2013 – Psychological Health and Safety in the Workplace – Prevention, Promotion, and Guidance to Staged Implementation.  It addresses an often overlooked aspect of workplace health and safety.

“Key topics covered in the standard include:

• Establishing commitment, leadership and participation
• Understanding the diverse needs of the organization’s population so they can be appropriately addressed
• Maintaining confidentiality
• Establishing a policy and planning process to implement the system
• Identifying the organization’s PHS hazards, assessing risks, and implementing preventive and protective measures
• Ensuring infrastructure and resources are in place to support the system
• Providing education and awareness, and ensuring key people are trained and competent
• Having processes in place to be prepared in the case of a critical event
• Collecting data, monitoring and measuring success”¹

This 76-page guide can be downloaded for free by clicking on the above blue link.

For those employers who already have a comprehensive workplace safety and health program that is getting superior results, you may want to consider employee psychological health for the next chapter in the evolution of your program.

¹  CSA Group products overview

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Below are links to dozens of examples of comprehensive written workplace safety and health programs.  They are provided as guides to help you develop, implement and maintain your own program.   They are not intended to be adopted “as is”, nor do they assure compliance with any standards.

It is recommended that all safety and health programs be adapted to each organizations’ unique needs, exposures and operations by a qualified occupational safety and health professional.

• 23-pages  ”Guidelines on Occupational Safety & Health Management Systems” by International Labour Office (ILO)
• 12-pages  ”Safety Program Guide Outline” by Hortica Insurance
• 22-pages  ”A Workplace Accident & Injury Reduction (AWAIR) Program” by Minnesota OSHA
• 20-pages  ”Your Workplace Injury & Illness Prevention Program” (IIPP) by CAL/OSHA
• 19-pages  ”The Foundation of A Safe Workplace” by Oregon OSHA
• 96-pages  ”Voluntary Protection Programs (VPP) Policies & Procedures Manual” by Federal OSHA
• 103-pages  ”Model Injury & Illness Prevention Program” by Berkshire Hathaway Homestate Companies
• 2-pages  ”Injury & Illness Prevention Plan For Small Employers” by Berhshire Hathaway Homestate Companies
• 10-pages  ”Basic safety program” by General Casualty
• 75-pages  ”Safety Industry Manual” by Ohio Bureau of Workers’ Compensation
• 16-pages  ”General Safety and Health Program” by New Mexico Mutual
• 70-pages  ”Occupational Health & Safety Manual” by University of Windsor
• 101-pages  ”Guide to Your Written Health & Safety Program” by State of Wisconsin
• 50-pages  ”AWCC 7 Point Safety and Health Plan” by State of Arkansas
• 23-pages  ”Workplace Safety Program” by State of Florida
• 30-pages  “Sample Safety & Health Program” by Oklahoma DOL
• 2-pages    “Operations Safety Plan” by Summit Loss Control Services
• 1-page      “ANSI Z10: The Blueprint for a Better Health & Safety Program” by ANSI
• 2-pages  “Sample Return To Work Policy” (PDF) by SFM Insurance
•  1-page    ”Sample Return To Work Policy” (Word) by SFM Insurance
• 9-pages  “Essential Elements Of A Safety & Health Program” by Oklahoma DOL
• 100-pages  “Policy and Promgram Templates” by IHSA
• 24-pages  “OSHA Managers Handbook” by Alaska Dept Labor
• 16-pages “Sample Safety & Health Program” by State of Hawaii

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In addition to having a comprehensive written workplace safety and health program,  OSHA also requires written safety plans for certain exposures.  For a listing of those OSHA standards that require a written plan, click here or here.

Below are links to over 200 examples of subject-specific, written, workplace, safety and health plans. Many address OSHA required plans.  They are provided as guides to help you develop, implement and maintain your own plans.   They are not intended to be adopted “as is”, nor do they assure compliance with any standards.   It is recommended that all safety and health plans be adapted to each organizations’ unique needs, exposures and operations by a qualified occupational safety and health professional.

• Sample Written Program for Respiratory Protection
• Model Plans and Programs for the OSHA Bloodborne Pathogens and Haz-Com Standards
• Bloodborne Pathogens - 1
• Bloodborne Pathogens Program – 2 (Word) (PDF)
• Bloodborne Pathogens Program - 3
• Bloodborne Pathogens Program – 4
• Bloodborne Pathogens Exposure Control Plan Checklist
• Bloodborne Pathogens Exposure Control Plan
• Bloodborne Pathogens Exposure Control Program
• Chemical Hygiene/Lab Safety Program (Word) (PDF)
• Confined Space Entry Program – 1 (Word) (PDF)
• Confined Space Entry Program - 2
• Confined Space Program
• Construction Company Safety and Health Policy (Word) (PDF)
• Electrical Safety Policy – 1 (Word) (PDF)
• Electrical Safety Policy - 2
• Emergency Action & Fire Prevention Plan – 1 (Word) (PDF)
• Emergency Action & Fire Prevention Plan - 2
• Employee Exposure and Medical Records
• Emergency Response
• Fire Prevention
• First Aid Plan – 1 (Word) (PDF)
• First Aid Plan - 2
• General Industry Safety & Health Policy (Word) (PDF)
• Hazard Communication Program – 1 (Word) (PDF)
• Hazard Communication Program - 2
• Hazard Communication Program - 3
• Hazard Communication Program – 4
• Written Hazard Communication Program
• Sample Written Hazard Communication Program
• Hazard Communication Written Program
• Hazardous Waste Operations Policy (Word) (PDF)
• Hazardous Waste Plan Guidelines (Word) (PDF)
• Hearing Conservation Program – 1  (Word) (PDF)
• Hearing Conservation Program - 2
• Hearing Conservation Program – 3
• Hearing Conservation Program – 4
• Hot Work Permit (Word) (PDF)
• Job Hazard Analysis Program (Word) (PDF)
• Lockout/Tagout Program (short version) (Word) (PDF)
• Lockout/Tagout Program (long version) (Word) (PDF)
• Lockout/Tagout  - 3
• Lockout/Tagout Program Elements
• Sample Lockout/Tagout Procedure
• Lockout/Tagout – The Control Of Hazardous Energy
• PPE Haz Analysis & Training Documents: Long Version (Word) (PDF)
• PPE Haz Analysis & Training Documents: Short Version (Word) (PDF)
• Personal Protectivee Equipment (PPE) Program
• Personal Protective Equipment (PPE) - 1
• Personal Protective Equipment (PPE) – 2
• Respiratory Program, Voluntary, Filtering Facepieces (Word) (PDF)
• Respiratory Program, Voluntary Use (Word) (PDF)
• Respiratory Protection Program
• Sample Respiratory Protection Program – 1
• Sample Respiratory Protection Program – 2
• 15  -  Written Compliance Programs
• 19 – Sample Written Programs from Georgia Tech
• 120  -  Sample Safety Programs

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