Osha small business handbook


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Osha small business handbook

  1. 1. Small Business HandbookSmall Business Safety andHealth Management SeriesOSHA 2209-02R 2005
  2. 2. Employers are responsible for providing a safe and Employers cannot be cited under the General Dutyhealthy workplace for their employees. OSHA’s role Clause in Section 5(a)(1) of the Act for failure to fol-is to promote the safety and health of America’s low recommendations in this handbook.working men and women by setting and enforcing The materials in this handbook are based uponstandards; providing training, outreach and educa- Federal OSHA standards and other requirements intion; establishing partnerships; and encouraging effect at the time of publication and upon generallycontinual improvement in workplace safety and accepted principles and activities within the jobhealth. safety and health field. They should be useful to small business owners or managers and can beAbout this Handbook adapted easily to individual establishments. It is important to point out that 24 states, Puerto This handbook is provided to owners, propri- Rico and the Virgin Islands operate their ownetors and managers of small businesses by the OSHA-approved safety and health programs underOccupational Safety and Health Administration Section 18 of the Act. While the programs in these(OSHA), an agency of the U.S. Department of State Plan States may differ in some respects fromLabor. For additional copies of this publication, Federal OSHA, this handbook can be used bywrite to the U.S. Government Printing Office, employers in any state because the standards(GPO), Superintendent of Documents, Mail Stop imposed by State Plan States must be at least asSDE, 732 N. Capitol Street, NW, Washington, DC effective as Federal OSHA standards. A list of20401, or call the OSHA Publications Office at (202) states that operate their own safety and health pro-693-1888, or fax (202) 693-2498 for ordering infor- grams can be found on OSHA’s website atmation. Please note that the entire text of the www.osha.gov.Small Business Handbook is available on OSHA’s Material in this publication is in the publicwebsite at http://www.osha.gov/Publications/ domain and may be reproduced, fully or partially,osha2209.pdf. without permission. Source credit is requested but The handbook should help small business em- not required.ployers meet the legal requirements imposed by This information will be made available to sen-the Occupational Safety and Health Act of 1970 (the sory impaired individuals upon request by voiceAct), and achieve an in-compliance status before an phone (202) 693-1999 or teletypewriter (TTY) (877)OSHA inspection. An excellent resource to accom- 889-5627.pany this information is OSHA’s Safety and HealthProgram Management Guidelines, (54 Federal Please Note: The small business employer seekingRegister 3904-3916, January 26, 1989), also avail- information on procurement or contracting with theable on OSHA’s website. Department of Labor or OSHA should contact the This handbook is not a legal interpretation of the Department of Labor’s Office of Small Businessprovisions of the Act and does not place any addi- Programs, 200 Constitution Avenue, NW, Room C-tional requirements on employers or employees. 2318, Washington, DC 20210.
  3. 3. Small Business HandbookOccupational Safety and Health AdministrationU.S. Department of LaborOSHA 2209-02R2005 U.S. Department of Labor www.osha.gov
  4. 4. ContentsPREFACE 4Office of Small Business Assistance 4Cooperative Programs 4State Plans 4Office of Training and Education 4OSHA’s Website 5Safety and Health Add Value 5INTRODUCTION: The Value of a Safety and Health Management System 6A Profit and Loss Statement 6Developing a Profitable Strategy for Handling Occupational Safety and Health 6A FOUR-POINT WORKPLACE PROGRAM: The Basis of a Plan 8Using the Four-Point Program 8MANAGEMENT COMMITMENT AND EMPLOYEE INVOLVEMENT 8WORKSITE ANALYSIS 9HAZARD PREVENTION AND CONTROL 9TRAINING FOR EMPLOYEES, SUPERVISORS AND MANAGERS 10Documenting Your Activities 11Safety and Health Recordkeeping 11INJURY/ILLNESS RECORDS 11EXPOSURE RECORDS AND OTHERS 12STARTING A SAFETY AND HEALTH MANAGEMENT SYSTEM: Creating a Plan 13Decide to Start Now 13Designating Responsibility 13Ask for Help 13Organize the Workplace 14Start Gathering Specific Facts About Your Situation 14Establish a Four-Point Safety and Health Program 15Develop and Implement Your Action Plan 15SELF-INSPECTION 17Self-Inspection Scope 17Self-Inspection Checklists 18EMPLOYER POSTING 18RECORDKEEPING 18SAFETY AND HEALTH PROGRAM 18MEDICAL SERVICES AND FIRST AID 19FIRE PROTECTION 19PERSONAL PROTECTIVE EQUIPMENT AND CLOTHING 20GENERAL WORK ENVIRONMENT 20WALKWAYS 21FLOOR AND WALL OPENINGS 21STAIRS AND STAIRWAYS 22ELEVATED SURFACES 22EXITING OR EGRESS - EVACUATION 22EXIT DOORS 23PORTABLE LADDERS 23HAND TOOLS AND EQUIPMENT 24PORTABLE (POWER OPERATED) TOOLS AND EQUIPMENT 24ABRASIVE WHEEL EQUIPMENT GRINDERS 24POWDER-ACTUATED TOOLS 25MACHINE GUARDING 25LOCKOUT/TAGOUT PROCEDURES 26WELDING, CUTTING AND BRAZING 27COMPRESSORS AND COMPRESSED AIR 28
  6. 6. 4 PREFACE American employers and workers want safe and sector and other government entities lead to healthful places in which to work. They want improved safety and health. As a result, OSHA everyone on the job to go home whole and healthy continues to expand its cooperative programs each day. Determined to make that dream possi- which currently include the free and confidential ble, OSHA is committed to assuring – so far as pos- Consultation Program, the Voluntary Protection sible – that every working man and woman in the Programs, the Strategic Partnership Program and nation has safe and healthful working conditions. OSHA’s newest addition, Alliances. For a more OSHA believes that providing workers with a safe detailed description of each of these programs, workplace is central to their ability to enjoy health, please see pages 40- 42. security and the opportunity to achieve the Small businesses are encouraged to investigate American dream. the full array of cooperative programs offered by OSHA seeks to cut unnecessary rules, regula- OSHA. Participation can be on an individual com- tions and red tape. It is eliminating thousands of pany basis or through an industry association. pages of outdated regulations and continues to Detailed information on each program is also avail- rewrite standards in plain English. OSHA is paring able on OSHA’s website at www.osha.gov, by con- down its regulatory agenda so that it more accu- tacting any OSHA office, or by calling (800) 321- rately reflects realistic goals that best serve the OSHA. needs of American employers and employees. Confronted by the realities and demands to State Plans keep pace with the workforce and problems of the future, OSHA is developing new strategies to OSHA has important partnerships with the 24 reduce occupational fatalities, injuries and illness- states, Puerto Rico and the Virgin Islands that oper- es. Coupled with strong, effective and fair enforce- ate their own OSHA-approved safety and health ment, OSHA strives to provide improved outreach, programs. State workplace safety and health pro- education and compliance assistance to America’s grams frequently lead the way in developing inno- employers and employees. vative approaches to making America’s workplaces safer and healthier. Office of Small Business Assistance States that operate their own worker safety and health plans must provide worker protection that is OSHA wants to provide quality service to our “at least as effective as” the Federal program. small business customers. In October 2002, OSHA However, because their standards and other proce- created the Office of Small Business Assistance to dures may vary, businesses should become famil- provide small business direction, to facilitate infor- iar with their state regulations and agencies. See mation sharing and to help in finding and achieving OSHA’s website for a list of State Plan States. regulatory compliance. The office also works to educate small businesses on using up-to-date tools Office of Training and Education and materials, and facilitates opportunities to com- ment on OSHA’s regulatory agenda. The Office of OSHA’s Office of Training and Education Small Business Assistance maintains OSHA’s spe- provides training and instruction in all facets of cialized small business web pages found at http:// occupational safety and health. OSHA’s Training www.osha.gov/dcsp/smallbusiness/index.html. Institute, located in Arlington Heights, IL, provides The Office of Small Business Assistance can be training for OSHA compliance safety and health contacted by telephone at (202) 693-2220 or by officers as well as for the general public and safety writing to: Director, Office of Small Business and health staff from other Federal agencies. In Assistance, 200 Constitution Avenue, N.W., Room addition to OSHA’s Training Institute, there are 32 N-3700, Washington, DC 20210. additional education sites located throughout the country. These OSHA education centers operate in Cooperative Programs conjunction with universities, colleges and learning centers to conduct OSHA courses for the private Years of experience show us that voluntary col- sector and other Federal agencies, making safety laborative relationships between OSHA, the private and health training and education more accessible OSHA HANDBOOK FOR SMALL BUSINESSES
  7. 7. 5to those who need it. There are tuition fees for pri- If you would like to receive regular updatesvate sector students. For more information about from OSHA about new programs, tools, best prac-OSHA’s Training Institute, OSHA’s education cen- tices and other useful information, subscribe to theters, or to obtain training catalogs with course agency’s e-news memo, QuickTakes. QuickTakes isschedules, write the OSHA Training Institute, 2020 issued twice monthly to subscribers and is alwaysSouth Arlington Heights Road, Arlington Heights, IL available online. You can subscribe to OSHA’s60005 or call (847) 297-4810. The information is QuickTakes at www.osha.gov.also fully accessible on the Internet atwww.osha.gov. Safety and Health Add ValueOSHA’s Website Addressing safety and health issues in the work- place saves the employer money and adds value to OSHA has made every effort to continuously the business. Recent estimates place the businessexpand and improve its website. OSHA’s extensive costs associated with occupational injuries at closewebsite provides employers and employees with to $170 billion–expenditures that come straight outpractical, easy-to-understand and up-to-date guid- of company profits.ance on regulations, compliance assistance and When workers stay whole and healthy, thelearning how to identify and control hazards. Each direct cost-savings to businesses include:OSHA cooperative program has individual web I lower workers’ compensation insurance costs;pages describing program elements and highlight- I reduced medical expenditures;ing successes of the participants. Several pages I smaller expenditures for return-to-workare devoted to small business, technical links, news programs;items, publication lists and an inventory of compli- I fewer faulty products;ance assistance tools, including expert advisors I lower costs for job accommodations forand eTools. eTools are “stand-alone” interactive, injured workers;web-based training tools on occupational safety I less money spent for overtime benefits.and health topics. Regulations, standards, direc-tives and interpretations relating to OSHA can be Safety and health also make big reductions infound as well. There is a Spanish version of the indirect costs, due to:OSHA website, and many posters and some publi- I increased productivity;cations are also available in Spanish. I higher quality products; OSHA’s web pages include MyOSHA, which I increased morale;allows users to create their own personalized I better labor/management relations;OSHA web page with customized content and I reduced turnover;links. Quick Start is another tool on OSHA’s I better use of human resources.Compliance Assistance web page that allows theuser to identify many of the major OSHA require- Employees and their families benefit fromments and guidance materials that apply to their safety and health because:individual workplaces or industry sectors. I their incomes are protected; Through its website, OSHA invites citizens to e- I their family lives are not hindered by injury;mail questions that can be routed to appropriate I their stress is not increased.agency officials for response. Any communicationconducted via the “Contact Us” link on the OSHA Simply put, protecting people on the job is inwebsite is considered an informational exchange everyone’s best interest–our economy, our commu-rather than an official communication with the nities, our fellow workers and our families. SafetyDepartment of Labor. For an official response to a and health add value to businesses, workplacesquestion or concern, inquiries should be submitted and lives.in writing. Occupational Safety and Health Administration
  8. 8. 6 INTRODUCTION: The Value of a Safety and Health Management System A Profit and Loss Statement Developing a Profitable Strategy for Handling Occupational Safety and Health As a small business owner, you are, by nature, a risk taker. You wager your business acumen Nobody wants accidents to happen in his or her against larger, perhaps more heavily financed cor- business. A serious fire, a permanent injury, or the porate groups and other free-spirited, self-employ- death of an employee or owner can cause the loss ed individuals like yourself. There is excitement of profit or even an entire business. To prevent and challenge in such a venture, but to succeed such losses, you don’t have to turn your business you need good management information, an ability upside down. You may not have to spend a lot of to be a good manager of people and the intelli- money, either. You do need to use good business gence and inner strength to make the right deci- sense and apply recognized prevention principles. sions. There are reasons why accidents happen. Thousands of workers die each year and many, Something goes wrong somewhere. It may take many more suffer injury or illness from conditions some thought, and maybe the help of friends or at work. But how often does an owner or manager other trained people, to figure out what went like you actually see or even hear about work-relat- wrong, but an accident always has a cause–a rea- ed deaths, serious injuries or illnesses in the busi- son why. Once you know why an accident hap- nesses with which you are familiar? How often has pened, it is possible to prevent future incidents. your business actually sustained this type of loss? You need some basic facts and perhaps some help In most small businesses, the answer is rarely. from others who already know some of the an- For this reason, many owners or managers do not swers. You also need a plan–a plan to prevent understand why there is controversy about the accidents. Occupational Safety and Health Administration Not all dangers at your worksite depend on an (OSHA), job safety and health standards, inspec- accident to cause harm, of course. Worker expo- tions, citations, etc. sure to toxic chemicals or harmful levels of noise But others have learned why. Unfortunately, or radiation may happen in conjunction with rou- they have experienced a loss. These owner/man- tine work as well as by accident. You may not real- agers will tell you that it is too late to do anything ize the extent of the exposure or harm that you and once a serious accident happens. They have learn- your employees face. The effect may not be imme- ed that prevention is the only real way to avoid this diate. You need a plan that includes prevention of loss. these health hazard exposures and accidents. You Reducing losses is a goal that you as an owner need a safety and health management system. or manager share with us in OSHA. While we may It is not difficult to develop such a plan. Basi- see this goal in a slightly different light, it remains cally, your plan should address the types of acci- a common bond. dents and health hazard exposures that could hap- We have learned from small employers, like pen in your workplace. Because each workplace is you, that you place a high value on the well-being different, your program should address your spe- of your employees. Like many small businesses, cific needs and requirements. you may employ family members and personal There are four basic elements to all good safety acquaintances. And, if you don’t know your em- and health programs. These are as follows: ployees before they are hired, then chances are that the very size of your workplace will promote 1. Management Commitment and Employee the closeness and concern for one another that Involvement. The manager or management team small businesses value. leads the way, by setting policy, assigning and sup- Assuming that you are committed to safe and porting responsibility, setting an example and in- healthful work practices, OSHA wants to work with volving employees. you to prevent all losses. We believe that, when you make job safety and health a real part of your every- 2.Worksite Analysis. The worksite is continually ana- day operations, you will not lose in the long run. lyzed to identify all existing and potential hazards. Investing in safety and health activity now will better enable you to avoid possible losses in the future. 3. Hazard Prevention and Control. Methods to pre- OSHA HANDBOOK FOR SMALL BUSINESSES
  9. 9. 7vent or control existing or potential hazards are put It will certainly give you a way to express and doc-in place and maintained. ument your good faith and commitment to protect- ing your workers’ health and safety.4.Training for Employees, Supervisors and This approach usually does not involve largeManagers. Managers, supervisors and employees costs. Developing a health and safety protectionare trained to understand and deal with worksite plan does not have to be expensive and generallyhazards. does not require additional employees, especially in smaller businesses. Safety and health can be Regardless of the size of your business, you integrated into your other business functions withshould use each of these elements to prevent work- modest effort on your part.place accidents and possible injuries and illnesses. The key to the success of a safety and health Developing a workplace program following plan is to see it as a part of your business opera-these four points is a key step in protecting you tion and to see it reflected in your day-to-day oper-and your workers’ safety and health. If you already ations. As you implement the plan and incorporatehave a program, reviewing it in relation to these it into your business culture, safety and healthelements should help you improve what you have. awareness will become second nature to you and Following this four-point approach to safety and your employees.health in your business may also improve efficien- The next section provides short descriptionscy. It may help you reduce insurance claims and and illustrations of each element. Since mostother costs. While having a safety and health plan employers, like you, are pressed for time, thesebased on these four elements does not guarantee descriptions will assist you in getting started oncompliance with OSHA standards, the approach your own approach.will help you toward full compliance and beyond. Occupational Safety and Health Administration
  10. 10. 8 A FOUR-POINT WORKPLACE PROGRAM: The Basis of a Plan The Four-Point Workplace Program described assets you have. Their safety, health and goodwill here is based upon the Safety and Health Program are essential to the success of your business. Hav- Management Guidelines issued by OSHA in ing them cooperate with you in protecting their January 1989. (For a free copy of the guidelines, safety and health not only helps to keep them go to OSHA’s website at www.osha.gov, write to healthy–it makes your job easier. OSHA Publications, U.S. Department of Labor, P.O. Here are some actions to consider: Box 37535, Washington, DC 200013-7535, or call (202) 693-1888.) Although voluntary, these guide- I Post your policy on worker safety and health lines represent OSHA’s policy on what every work- next to the Job Safety and Health Protection site should have in place to protect workers from Poster where all employees can see it. (See occupational hazards. The guidelines are based Appendix B, Model Policy Statements.) heavily on OSHA’s experience with its Voluntary Protection Programs (VPP), which recognize excel- I Hold a meeting with all employees to commu- lence in workplace safety and health management. nicate your safety and health policy, and dis- For more information on these guidelines and cuss your objectives for safety and health. OSHA’s cooperative programs, contact OSHA’s Office of Small Business Assistance, U.S. I Make sure that your support is visible by get- Department of Labor, 200 Constitution Avenue, ting personally involved in the activities that NW, Room N-3700, Washington, DC 20210, (202) are part of your safety and health program. 693-2220. For example, personally review all inspection and accident reports and ensure that follow- Using the Four-Point Program up occurs when needed. As you review this publication, we encourage I Ensure that you, your managers and your you to use the Action Plan Worksheet in Appendix supervisors follow all safety requirements that A to jot down the things you want to do to make apply to all employees, even if you are only in your workplace safe for your employees. Noting an area briefly. If, for instance, you require a those actions as you go along will make it easier hard hat, safety glasses and/or safety shoes in to assemble the total plan you need. an area, wear them yourself when you are in that area. MANAGEMENT COMMITMENT AND EMPLOYEE INVOLVEMENT I Take advantage of your employees’ special- As the owner or manager of a small business, ized knowledge and encourage them to buy your attitude toward job safety and health will be into the program by having them make in- reflected by your employees. If you are not inter- spections, conduct safety training, or investi- ested in preventing employee injury and illness, gate accidents. your employees will probably not give safety and health much thought either. I Make clear assignments of responsibility for Therefore, it is essential that you demonstrate at every part of your safety and health program, all times your personal concern for employee safety and make sure everyone understands them. and health, and the priority you place on them in The more people who are involved, the better. your workplace. Your policy must be clear. Only you A good rule of thumb is to assign safety and can show its importance through your own actions. health responsibilities in the same way you You can demonstrate the depth of your commit- assign production responsibilities. Make it a ment by involving your employees in planning and special part of everyone’s job to work safely. carrying out your efforts. If you seriously involve your employees in identifying and resolving safety I Give those with safety and health responsibili- and health problems, they will bring their unique ty enough people, time, training, money and insights and energy to achieving the goals and authority to get the job done. objectives of your program. The men and women who work for you are among the most valuable I Don’t forget your safety and health program OSHA HANDBOOK FOR SMALL BUSINESSES
  11. 11. 9 after you make assignments; make sure the ards. The checklists (at pages 18-39) provide a job gets done. Recognize and reward those starting point. Your state consultant can assist who do well and correct those who don’t. you in establishing an effective system. I At least once a year, review what you have I Make sure your employees feel comfortable in accomplished in meeting your objectives and alerting you or another member of manage- reevaluate whether you need new objectives ment when they see things that look danger- or program revisions. ous or out of place. I Institute an accountability system where all I Learn how to conduct a thorough investiga- personnel will be held accountable for not fol- tion when things go wrong. This will help you lowing work rules designed to promote work- develop ways to prevent recurrences. Exten- place safety and health. sive information can be found on OSHA’s website under “Accident Investigation” in the WORKSITE ANALYSIS index. It is your responsibility to know what items orsubstances you have in your workplace that could I Review several years of injury or illness rec-hurt your workers. Worksite analysis is a group of ords to identify patterns that can help youprocesses that helps you make sure that you know devise strategies to improve your safety andwhat you need to keep your workers safe. For help health program. Periodically review severalin getting started with these processes, you can call months of experience to determine if any newon your state on-site Consultation Program and patterns are developing.have an experienced health and safety professionalvisit your workplace for free and confidentially. HAZARD PREVENTION AND CONTROLLocations for each state are listed on OSHA’s web- Once you have identified your existing andsite. Also, OSHA’s booklet, Job Hazard Analysis, potential hazards, you are ready to implement themay be helpful. (See OSHA Publications at page systems that prevent or control those hazards.42 for ordering information.) Your state Consultation Program can help you do Here are some actions to consider: this. Whenever possible, hazards should be elimi- nated. Sometimes that can be done through sub- I Request a consultation visit from your state stitution of a less toxic material or engineering con- on-site Consultation Program covering both trols. When you cannot eliminate hazards, systems safety and health to get a full survey of the should be established to control them. hazards that exist in your workplace and those Here are some actions to consider: that could develop. You can also contract for such services from expert private consultants I Set up safe work procedures based on an if you prefer. analysis of the hazards in your workplace and ensure that employees understand and follow I Establish a way to get professional advice them. It is a good idea to involve employees when you make changes to procedures or in the analysis that results in those procedures. equipment, to ensure that the changes are not (See Appendix C, Codes of Safe Practices.) introducing new hazards into your workplace. Find ways to keep current on newly recog- I Be ready to enforce the rules for safe work nized hazards in your industry. procedures. Ask your employees to help you establish a disciplinary system that will be fair I Periodically review with employees each job, and understood by everyone. analyzing it step-by-step to see if there are any hidden hazards in the equipment or procedures. I Where necessary, ensure that personal protec- tive equipment (PPE) is used and that your em- I Set up a self-inspection system to check your ployees know why they need it, how to use it hazard controls and evaluate any new haz- and how to maintain it. Occupational Safety and Health Administration
  12. 12. 10 I Provide for regular equipment maintenance to first aid. First-aid supplies must be readily prevent breakdowns that can create hazards. available for emergency use. Arrangements Ensure that preventive and regular mainte- for this training can be made through your nance are tracked to completion. local Red Cross chapter, your insurance carri- er, your local safety council, and others. I Plan for emergencies, including fire and natu- ral disasters. Conduct frequent drills to en- I Check battery charging stations, maintenance sure that all employees know what to do operations, laboratories, heating and ventilat- under stressful conditions. ing operations and any corrosive materials areas to make sure the required eyewash facil- I Ask your state consultant to help develop a ities and showers are operational. medical program that fits your worksite. In- volve nearby doctors and emergency facilities I Consider retaining a local doctor or an occu- by inviting them to visit your workplace and pational health nurse on a part-time or as- help you plan the best way to avoid injuries needed basis for advice on medical and first and illness during emergency situations. aid planning. I Ensure the ready availability of medical per- TRAINING FOR EMPLOYEES, SUPERVISORS sonnel for advice and consultation on matters AND MANAGERS of employee health. This does not mean that An effective accident prevention program re- you must provide health care, but you must quires proper job performance from everyone in be prepared to deal with medical emergencies the workplace. or health problems connected to your work- As an owner or manager, you must ensure that place. all employees know about the materials and equip- ment they work with, known hazards and how to To fulfill the above requirements, consider the control the hazards. following: Each employee needs to know that: • no employee is expected to undertake a job I Develop an emergency medical procedure to until he or she has received job instructions handle injuries, transport ill or injured workers on how to do it properly and is authorized to and notify medical facilities. Posting emer- perform that job. Also, gency numbers is a good idea. • no employee should undertake a job that appears unsafe. I Survey the medical facilities near your place You may be able to combine safety and health of business and make arrangements for them training with other training, depending upon the to handle routine and emergency cases. Co- types of hazards in your workplace. operative agreements may be possible with Here are some actions to consider: nearby larger workplaces that have on-site medical personnel and/or facilities. I Ask your state consultant to recommend train- ing for your worksite. The consultant may be I Ensure that your procedure for reporting able to conduct training while he or she is injuries and illnesses is understood by all there. employees. I Make sure you have trained your employees I Perform routine walkthroughs of the worksite on every potential hazard that they could be to identify hazards and to track identified haz- exposed to and how to protect themselves. ards until they are corrected. Then verify that they really understand what you taught them. I If your business is remote from medical facili- ties, you are required to ensure that adequate- I Pay particular attention to your new employ- ly trained personnel are available to render ees and to employees who are moving to new OSHA HANDBOOK FOR SMALL BUSINESSES
  13. 13. 11 jobs. Because they are learning new opera- INJURY/ILLNESS RECORDS tions, they are more likely to get hurt. OSHA rules for recording and reporting occupa- tional injuries and illnesses affect 1.4 million estab- I Train your supervisors to understand all the lishments. Small businesses with 10 or fewer hazards faced by the employees and how to employees throughout the year are exempt from reinforce training with quick reminders and most of the requirements of the OSHA recordkeep- refreshers, or with disciplinary action if neces- ing rules, as are a number of specific industries sary. in the retail, service, finance, insurance and real estate sectors that are classified as low-hazard. I Make sure that your top management staff Detailed information about OSHA recordkeeping understand their safety and health responsibil- rules can be found at http://www.osha.gov/record- ities and how to hold subordinate supervisory keeping/index.html or refer to 29 Code of Federal employees accountable for theirs. Regulations (CFR) 1904 for the specific exceptions. OSHA recordkeeping can help the small busi-Documenting Your Activities ness employer evaluate the success of safety and health activities. Success can be measured by a Document your activities in all elements of the reduction or elimination of employee injuries andFour-Point Workplace Program. Essential records, illnesses during a calendar year.including those legally required for workers’ com- The OSHA recordkeeping system has five steps:pensation, insurance audits and government in-spections must be maintained as long as the actual 1. Obtain a report on every injury or job-related ill-need exists or as required by law. Keeping records ness requiring medical treatment (other than basicof your activities, such as policy statements, first aid).training sessions, safety and health meetings,information distributed to employees, and med- 2. Record each injury or job-related illness onical arrangements made, is greatly encouraged. OSHA Form 300 (Log of Work-Related Injuries andMaintaining essential records also will demonstrate Illnesses) using the instructions provided.sound business management as supporting prooffor credit applications, for showing “good faith” in 3. Prepare a supplementary record of occupationalreducing any proposed penalties from OSHA injuries and illnesses for recordable cases on OSHAinspections, for insurance and other audits, and aid Form 301 (Injury and Illness Incident Report).efficient review of your current safety and healthactivities for better control of your operations and 4. Every year, prepare an annual summary usingto plan improvements. OSHA Form 300A (Summary of Work-Related Injuries and Illnesses). Post it no later thanSafety and Health Recordkeeping February 1, and keep it posted until May 1. A good place to post it is next to the OSHA Workplace Records of sales, costs, profits and losses are Poster.essential to all successful businesses. They enablethe owner or manager to learn from experience 5. Retain these records for at least five years.and to make corrections for future operations.Records of accidents, related injuries, illnesses and Periodically review these records to look for anyproperty losses can serve the same purpose, if they patterns or repeat situations. These records canare used in the same way. The primary purpose of help you to identify high-risk areas that requireOSHA-required recordkeeping is to retain informa- your immediate attention.tion about accidents that have happened to helpdetermine the causes and develop procedures to Basic OSHA recordkeeping requirementsprevent a recurrence. address only injuries and illnesses, so you might consider expanding your own records to include all Occupational Safety and Health Administration
  14. 14. 12 incidents, including those where no injury or illness EXPOSURE RECORDS AND OTHERS resulted. This information may assist you in pin- In addition to injury/illness records, certain pointing unsafe conditions and/or procedures. OSHA standards require records on the exposure Safety councils, insurance carriers and others can of employees to toxic substances and hazardous assist you in instituting such a system. exposures, physical examination reports and The employer is required to report to OSHA employment records. within eight hours of the accident, all work-related As you identify hazards, you will be able to fatalities or multiple hospitalizations that involve determine whether these requirements apply to three or more employees. your workplace. Your records should be used in Even if your business is exempt from routine conjunction with your control procedures and with recordkeeping requirements, you may be selected your self-inspection activity. They should not be by the Federal Bureau of Labor Statistics (BLS) or considered merely as bookkeeping. a related state agency for inclusion in an annual sample survey. You will receive a letter directly from the agency with instructions, if you are selected. OSHA HANDBOOK FOR SMALL BUSINESSES
  15. 15. STARTING A SAFETY AND HEALTH MANAGEMENT SYSTEM: Creating a Plan 13 You can use this handbook to create a basic Designating Responsibilityplan of action for starting a safety and healthmanagement system at your business. The action You must decide who in your company is theplan described in this section provides the most most appropriate person to manage your safetydirect route to getting yourself organized to com- and health system. Who can ensure that the pro-plete the Four-Point Program outlined in the previ- gram will become an integral part of your busi-ous section. ness? In many cases it will be you, the owner. Sometimes it will be a plant manager or key super-Decide to Start Now visor. It could even be an engineer, personnel spe- cialist, or other staff member. The time to start your safety and health man- Whoever you choose should be committed toagement system is now. You have a better picture workplace safety and health, have the time to de-of what constitutes a good safety and health pro- velop and manage the program, and be willing togram. Now you can address the practical concerns take on the responsibility and accountability thatof putting these elements together and coming up goes with operating an effective program. Thewith a program to suit your workplace. individual will need your full cooperation and sup- Hopefully, you have been taking notes for your port, but the ultimate responsibility for safety andaction plan as you reviewed the preceding de- health in your workplace rests on you.scription of the Four-Point Program. You shouldnow be ready to decide what you want to accom- Ask for Helpplish and to determine what steps are necessaryto achieve your goals. Next you need to deter- Federal occupational safety and health lawmine how and when each step will be done and allows a state to develop and operate its own occu-who will do it. pational safety and health program in place of the Your plan should consider your company’s Federal OSHA program. It is possible that the reg-immediate needs and provide for ongoing, long- ulatory aspect of the law (setting of mandatorylasting worker protection. Once your plan is minimum standards and conducting inspections ofdesigned, it is important to follow through and workplaces) is being operated by your state gov-use it in the workplace. You will then have a pro- ernment as opposed to Federal OSHA.gram to anticipate, identify and eliminate condi- One of the first things to learn is which branchtions or practices that could result in injuries and of government, Federal or state, has current juris-illnesses. diction over your business. If you are not sure If you have difficulty deciding where to begin, a what agency is responsible for administering work-phone call to your state Consultation Program will place safety and health in your state, contact thehelp get you started. A state consultant will survey nearest OSHA Area Office to find out. (Seeyour workplace for existing or potential hazards. www.osha.gov). You will need certain FederalThen, if you request it, he or she will determine OSHA publications (or comparable state publica-what you need to make your safety and health pro- tions) for use in your safety and health activities,gram effective. The consultant will work with you such as:to develop a plan for making these improvementsand to keep your program effective. I Job Safety and Health Protection - OSHA Whether you choose to work with a consultant 3165. You must display the Federal or stateor to develop your program yourself, many publi- OSHA poster in your workplace. This postercations are available from your state on-site Con- is also available in Spanish (Job Safety andsultation Program or from OSHA that spell out in Health Protection OSHA 3167).greater detail the steps you can take to create aneffective safety and health program for your work- I OSHA standards that apply to your business.place. The rewards for your efforts will be an effi- You need to have a copy of all OSHA stan-cient and productive workplace with a low level of dards that apply to your type of businessloss and injury. available for reference. (See Appendix D.) Occupational Safety and Health Administration
  16. 16. 14 Standards are the regulations that OSHA uses vey should focus on evaluating workplace condi- to inspect for compliance and should be the tions with respect to safety and health regulations baseline for your inspections in determining and generally recognized safe and healthful work what to do when hazards are identified. Most practices. It should include checking on the use of businesses fall under OSHA’s General Industry any hazardous materials, observing employee work Standards. If you are involved with construc- habits and practices, and discussing safety and tion or maritime operations, you will need the health problems with employees. See the Self- standards that apply to these classifications. Inspection Checklists (at pages 18-39), to help you (In states with state-run occupational safety get a good start on creating this initial survey. and health programs, use the appropriate state standards.) 2. The second major activity is to assess your existing safety and health program and identify I Recordkeeping requirements and the neces- areas that work well and those that need improve- sary forms. ment. You should gather as much information as you can that relates to safety and health manage- I Occupational Safety and Health Act of 1970. ment in your workplace. You should include the You may want a copy of this legislation for following in this review: reference. I Safety and health activities. Examine ongoing Organize the Workplace activities as well as those tried previously, company policy statements, rules (both work Poor housekeeping can contribute to low and safety), guidelines for proper work prac- morale and sloppy work. Most safety action pro- tices and procedures, and records of training grams start with an intensive cleanup campaign in programs. all areas of the workplace. Get rid of unecessary items; provide proper I Equipment. List your major equipment, what waste containers; store flammables properly; make it is used for and where it is located. Special sure exits are not blocked; mark aisles and pas- attention should be given to inspection sched- sageways; provide adequate lighting, etc. ules, maintenance activities, and plant and Get everyone involved and impress upon em- office layouts. ployees that you want to make your workplace safer, more healthful and more efficient. I Employee capabilities. Make an alphabetical list of all employees, showing the date hired, Start Gathering Specific Facts their job descriptions, and experience and About Your Situation training. Before making changes in your safety and I Accident and injury/illness history. Review health operations, you should gather information first-aid cases and workers’ compensation about the current conditions and business practices insurance payments and awards, and review that comprise your safety and health program. your losses. Compare your insurance rate This information can help you identify problems with others in your group. Give special atten- and determine what is needed to solve them. tion to recurring accidents, types of injuries, Your workplace assessment should be conduct- etc. ed by the person responsible for your safety and health management system and/or a professional After gathering facts, see if any major problem safety and health consultant. The assessment con- areas emerge such as interruptions in your normal sists of two major activities: operations, too many employees taking too much time off due to illness or injury, too many damaged 1. A comprehensive safety and health survey of products, etc. General help with this kind of prob- your entire facility will identify any existing or lem identification can often be obtained from com- potential safety and health hazards. This initial sur- pensation carriers, local safety councils, trade asso- OSHA HANDBOOK FOR SMALL BUSINESSES
  17. 17. 15ciations, state agencies, major suppliers or similar- Establish and regularly conduct a worksitely situated businesses in the same industry. analysis. A successful safety and health program If you discover a major problem, see what can depends on an accurate identification of all the haz-be done to solve it. Once a problem is identified, ards and potential hazards in your workplace. Thisyou can work on the corrective action or a plan to is an ongoing process that includes routine self-control the problem. Take immediate action and inspections.make a record of what you have done. Even if you Create systems and procedures to prevent andfind no major problems, don’t stop there. Now it is control hazards identified through your worksitetime to develop a comprehensive safety and health analysis. OSHA standards can be helpful becauseprogram to avoid any major problems in the future. they address controls in order of effectiveness and preference. The hierarchy of controls is engineer-Establish a Four-Point Safety and ing, administrative, work practice and PPE. When-Health Program ever feasible, engineering, administrative or work practice controls should be instituted even if they The success of any workplace safety and health do not eliminate the hazard or reduce exposure.program depends on careful planning. This means Use of such controls in conjunction with PPE willthat you must take the time to analyze what you help reduce the hazard or exposure to the lowestwant to accomplish and develop an action plan in practical level. Where no standard exists, creativeorder to attain your goals. From this standpoint, problem-solving and consultant resources mayyou can design a step-by-step process to take you help you create effective controls. The basic for-from the idea stage to an effective safety and mula for controlling workplace hazards, in order ofhealth management system. preference, includes: The best way to create a safe and healthfulworkplace is to institute the Four-Point Program I Eliminating the hazard from the machine, thediscussed at page 8 of this handbook. method, the material or the facility. Establish your management commitment andinvolve your employees. No safety and health I Abating the hazard by limiting exposure orprogram will work without this commitment and controlling it at its source.involvement. The first step is to designate a person tobe responsible for your safety and health program. I Training personnel to be aware of the hazard Involve your employees as widely as possible and to follow safe work procedures to avoid it.from the beginning. They are most in contact withthe potential and actual safety and health hazards I Prescribing PPE for protecting employeesat your worksite and will have constructive input against the hazard and ensuring that they noton the development of your program. The ultimate only use it, but that they know how to use itsuccess of your safety and health program will correctly.depend on their support. Make sure your program assigns responsibility Establish and provide ongoing training forand accountability to all employees in your organi- employees, supervisors and managers to ensurezation. A good safety and health program makes it that everyone at your worksite can recognize haz-clear that each and every employee, from you ards and how to control them.through the supervisory levels to the line worker, These points are crucial to a safe and healthfulcarries responsibility for his or her part of the pro- workplace for you and your employees, making itgram. Make safety and health duties clear and more difficult for accidents to occur and for work-hold every individual accountable for his or her related health problems to develop.safety- and health-related duties. Refer to the recommended actions to take in the Develop and Implement Your Action PlanWorksite Analysis paragraph at page 9. These willhelp start your program off on the right track. You Developing an action plan to build a safety andwill be building the foundation for a successful health program around the four points can serve assafety and health program. a “road map” to take your program to where you Occupational Safety and Health Administration
  18. 18. 16 want it to be. An action plan tells you what has to Remember, a safety and health program is a plan be done, the logical order in which to do it, who is put into practice. Keep your program on track by responsible and where you want to be when you periodically checking its progress and by calling on finish. It describes problems and solutions, but is a state consultant when you need assistance. not ironclad. An action plan can and should be Any good management system requires period- changed to correspond with changes in the work- ic review. Take a careful look at each component of place. your safety and health program to determine what A good action plan has two parts: is working well and what changes are needed. Once again, a state consultant can assist you in this 1. A list of major changes or improvements to area. Any necessary improvements can be turned make your safety and health program effective. into new safety and health objectives for the com- Each item should be prioritized, have a target date ing year. Developing new action plans to imple- for completion and identify who is responsible for ment these improvements will continue progress implementation. toward an effective safety and health program, reduce your safety and health risks, and increase 2. A specific plan to implement each major change efficiency and profit. or improvement, including what you want to Remember that it is important to document accomplish, the steps required, who will be your activities. The best way to evaluate the suc- assigned to do what and a schedule for comple- cess of your safety and health program is to have tion. documentation of what you have done, which pro- vides guidance on how you can make it work even A worksheet to help you design an overall better. action plan and describe specific action steps Technical assistance may be available to you as appears in Appendix A. a small business owner or manager through your Once a plan is established, put it into action, insurance carrier; your fellow businesspeople; sup- beginning with the highest priority item. Ensure pliers of your durable equipment and raw materi- that it is realistic, manageable and addresses the als; the local safety council; and many local, state steps you have planned for that item. A detailed and Federal agencies, including the state on-site description of the steps required will help you keep Consultation Programs and closest OSHA Area track of your progress. Keep in mind that you can Office. work on more than one item at a time and that pri- Establishing a quality safety and health man- orities may change as other needs are identified or agement system will take time and involve some as your company’s resources change. resources, but you should be pleased with the Open communication with your employees is results. Employees will feel reassured because of crucial to the success of your efforts. Their cooper- your commitment to their safety and health on the ation depends on them understanding what the job. You may save money through increased pro- safety and health program is all about, why it is ductivity and reduced workers’ compensation in- important to them and how it affects their work. surance costs. You may gain increased respect in The more you do to involve them in the changes you your community. The tangible and intangible re- are making, the smoother your transition will be. wards for a solid safety and health program far Putting your action plan into operation at your outweigh the cost of an accident, injury or work- workplace will be a major step toward implement- place fatality. ing an effective safety and health program. OSHA HANDBOOK FOR SMALL BUSINESSES
  19. 19. SELF-INSPECTION 17 The most widely accepted way to identify haz- I Building and Grounds Conditions – floors,ards is to conduct safety and health inspections walls, ceilings, exits, stairs, walkways, ramps,because the only way to be certain of an actual sit- platforms, driveways, aisles.uation is to look at it directly from time to time. Begin a program of self-inspection in your own I Housekeeping Program – waste disposal,workplace. Self-inspection is essential if you are to tools, objects, materials, leakage and spillage,know where probable hazards exist and whether cleaning methods, schedules, work areas,they are under control. remote areas, storage areas. This section includes checklists designed toassist you in self-inspection fact-finding. The I Electricity – equipment, switches, breakers,checklists can give you some indication of where to fuses, switch-boxes, junctions, special fixtures,begin taking action to make your business safer circuits, insulation, extensions, tools, motors,and more healthful for all of your employees. grounding, national electric code compliance. These checklists are by no means all-inclusiveand not all of the checklists will apply to your busi- I Lighting – type, intensity, controls, conditions,ness. You might want to start by selecting the diffusion, location, glare and shadow control.areas that are most critical to your business, thenexpanding your self-inspection checklists over time I Heating and Ventilation – type, effectiveness,to fully cover all areas that pertain to your busi- temperature, humidity, controls, natural andness. Remember that a checklist is a tool to help, artificial ventilation and exhausting.not a definitive statement of what is mandatory.Use checklists only for guidance. I Machinery – points of operation, flywheels, Don’t spend time with items that have no appli- gears, shafts, pulleys, key ways, belts, cou-cation to your business. Make sure that each item plings, sprockets, chains, frames, controls,is seen by you or your designee and leave nothing lighting for tools and equipment, brakes, ex-to memory or chance. Write down what you see or hausting, feeding, oiling, adjusting, mainte-don’t see and what you think you should do about it. nance, lockout/tagout, grounding, work space, Add information from your completed checklists location, purchasing standards.to injury information, employee information, andprocess and equipment information to build a I Personnel – training, including hazard identifi-foundation to help you determine what problems cation training; experience; methods of check-exist. Then, as you use the OSHA standards in ing machines before use; type of clothing;your problem-solving process, it will be easier for PPE; use of guards; tool storage; work prac-you to determine the actions needed to solve these tices; methods for cleaning, oiling, or adjust-problems. ing machinery. Once the hazards have been identified, insti-tute the control procedures described at page 9 I Hand and Power Tools – purchasing stan-and establish your four-point safety and health dards, inspection, storage, repair, types, main-program. tenance, grounding, use and handling.Self-Inspection Scope I Chemicals – storage, handling, transportation, spills, disposals, amounts used, labeling, toxi-Your self-inspections should cover safety and city or other harmful effects, warning signs,health issues in the following areas: supervision, training, protective clothing and equipment, hazard communication require- I Processing, Receiving, Shipping and Storage – ments. equipment, job planning, layout, heights, floor loads, projection of materials, material han- I Fire Prevention – extinguishers, alarms, sprin- dling and storage methods, training for mate- klers, smoking rules, exits, personnel assign- rial handling equipment. ed, separation of flammable materials and dangerous operations, explosion-proof fix- Occupational Safety and Health Administration
  20. 20. 18 tures in hazardous locations, waste disposal appropriate information concerning employee and training of personnel. access to medical and exposure records and Material Safety Data Sheets (MSDSs) been I Maintenance – provide regular and preventive posted or otherwise made readily available to maintenance on all equipment used at the affected employees? worksite, recording all work performed on the machinery and by training personnel on the proper care and servicing of the equipment. J Are signs loading, biohazards, exposures to x- ties, floor concerning exit routes, room capaci- ray, microwave, or other harmful radiation or I PPE – type, size, maintenance, repair, age, stor- substances posted where appropriate? age, assignment of responsibility, purchasing methods, standards observed, training in care J Is the Summary of Work-Related Injuries and Illnesses (OSHA Form 300A) posted during the and use, rules of use, method of assignment. months of February, March and April? I Transportation – motor vehicle safety, seat belts, vehicle maintenance, safe driver programs. RECORDKEEPING I First-Aid Program/Supplies – medical care J Are occupational injuriesonlyillnesses, except minor injuries requiring or first aid, recorded facilities locations, posted emergency phone as required on the OSHA 300 log? numbers, accessible first-aid kits. I Evacuation Plan – establish and practice pro- J Are employee medical hazardous substances employee exposure to records and records of cedures for an emergency evacuation, e.g., or harmful physical agents up-to-date and in fire, chemical/biological incidents, bomb compliance with current OSHA standards? threat; include escape procedures and routes, critical plant operations, employee accounting following an evacuation, rescue and medical J Are employee training records kept and acces- sible for review by employees, as required by duties and ways to report emergencies. OSHA standards? Self-Inspection Checklists J Have arrangements been made to retaineach records for the time period required for specific type of record? (Some records must These checklists are by no means all-inclusive. be maintained for at least 40 years.) You should add to them or delete items that do not apply to your business; however, carefully consider each item and then make your decision. You J Areitems suchpermits and records up-to-date for operating as elevators, air pressure tanks, should refer to OSHA standards for specific guid- liquefied petroleum gas tanks, etc.? ance that may apply to your work situation. (Note: These checklists are typical for general industry but SAFETY AND HEALTH PROGRAM not for construction or maritime industries.) EMPLOYER POSTING J Do you have an active safety and health safety gram in operation that includes general pro- J Is the required OSHA Job Safety and Health Protection Poster displayed in a prominent loca- and health program elements as well as the management of hazards specific to your work- tion where all employees are likely to see it? site? J Are emergency telephone found in case of where they can be readily numbers posted J Is one person clearly responsible for the safety and health program? emergency? J Do youup of management and laborgroup made have a safety committee or represen- J Where employees mayphysical agents,toxic substances or harmful be exposed to has tatives that meets regularly and reports in writing on its activities? OSHA HANDBOOK FOR SMALL BUSINESSES
  21. 21. 19J Do you have a working procedure to handle in-house employee complaints regarding safe- J If employees have hadpathogens, was an im- involving bloodborne an exposure incident ty and health? mediate post-exposure medical evaluation and follow-up provided?J Are your employees the safety and health pro- advised of efforts and accomplishments of gram made to ensure they will have a work- J Are medicalconsultationreadily availableemploy- advice and personnel on matters of for place that is safe and healthful? ees’ health?J Have you consideredexcel in reducing work- or workgroups who incentives for employees J Are emergency phone numbers posted? place injury/illnesses? J Areeach work area,first aid kits easily accessible to fully supplied periodically inspected and replenished as needed? MEDICAL SERVICES AND FIRST AID J Havephysician, indicating that they are ade- first aid kits and supplies been approvedJ Is there a hospital, clinic, or infirmary for med- ical care near your workplace or is at least one by a quate for a particular area or operation? employee on each shift currently qualified to render first aid? J Is there an eye-washorstation or sink available for quick drenching flushing of the eyes andJ Have all employees emergencies as part of respond to medical who are expected to body in areas where corrosive liquids or mate- rials are handled? their job responsibilities received first aid training; had hepatitis B vaccination made FIRE PROTECTION available to them; had appropriate training on procedures to protect them from bloodborne J Is your local fire department familiar with your facility, its location and specific hazards? pathogens, including universal precautions; and have available and understand how to use appropriate PPE to protect against exposure to J If you have aand tested annually?is it certified as required fire alarm system, bloodborne diseases?* *Pursuant to an OSHA memorandum of July 1, J If youinspected regularly? and valves, are they have interior standpipes1992, employees who render first aid only as a col-lateral duty do not have to be offered pre-exposure J If youflushedoutside privateafire hydrants,aare they have at least once year and on rou-hepatitis B vaccine only if the employer includes tine preventive maintenance schedule?and implements the following requirements inhis/her exposure control plan: (1) the employermust record all first aid incidents involving the J Are fire doors and shutters in good operating condition?presence of blood or other potentially infectiousmaterials before the end of the work shift during J Are fire doors andobstructions, including and protected against shutters unobstructed theirwhich the first aid incident occurred; (2) the em- counterweights?ployer must comply with post-exposure evaluation,prophylaxis and follow-up requirements of the J Are fire door and shutter fusible links in place?Bloodborne Pathogens standard with respect to“exposure incidents, ” as defined by the standard; J Are automatic sprinkler systemcheckedcontrol valves, air and water pressure water period-(3) the employer must train designated first aid ically as required?providers about the reporting procedure; (4) theemployer must offer to initiate the hepatitis B vac-cination series within 24 hours to all unvaccinated J Is the assigned to responsible persons or to a tems maintenance of automatic sprinkler sys-first aid providers who have rendered assistance in sprinkler contractor?any situation involving the presence of blood orother potentially infectious materials. J Are sprinkler heads protected bydamage? if exposed to potential physical metal guards Occupational Safety and Health Administration