This document discusses developing effective safety standards and procedures. It covers reviewing various safety programs and principles, developing rules and procedures to guide the safety process, and the importance of management commitment to safety. It also summarizes a presentation on the federal and state rulemaking process for safety standards and tips for developing plant-specific standards and procedures.

1. Safety Standards & Procedures January 2008 Standards / Procedures Policy & Procedures Corporate Standards Communications Off-the-Job Safety Change Management

2. Review of What We Have Covered Various types of safety programs Looked at Scott Geller’s 10 Principles of Safety Management The role that management commitment and involvement plays in the process The role planning plays in the safety process

3. During Decembers Meeting The role that a Gap Analysis plays in the safety process How to conduct a Gap Analysis How effective safety processes do this annually to keep improving

4. Quote of the Session Opportunity is missed by most people because it is dressed in overalls and looks like work. Thomas A. Edison (1847 - 1931)

5. Safety Rules and Procedures Developing safety rules and procedures is an opportunity to shape our safety process Provides guidance for the process Sets the checks and balances Determines the route for our education.

6. First Quest Speaker Stefanie Corbitt Former VaOSHA Compliance Officer Masters in Industrial Hygiene - West Virginia University Worked as a safety manager in Texas Owns her own consulting firm – SSIOSHA in Brunswick, Georgia - email - ssiosha@aol.com

7. The Rulemaking Process Federal Three Kinds 6(a) Adoption of Consensus Standard 6(b) Permanent Standards 6(c) Emergency Temporary Standards

8. 6(b) Standards Development 6(b)(1)-(4) Procedures for Rulemaking 6(b)(5) Health Standards 6(b)(6) Temporary Variances 6(b)(7) Content of Standards 6(b)(8) National Consensus Standards

9. Standards Development 29 C.F.R. 1911 Request for Information Advanced Notice of Proposal Rulemaking (ANPR) Notice of Proposed Rulemaking (NPRM) Public Comment

10. Standards Development Public Hearings Post-hearing Comment Analysis Final Rule

11. Components of a Proposed Rule Justification for Standard Significant Risk Material Impairment of Health Economic Impact Analysis Technical Feasibility Analysis Proposed Rule

12. Components of a Final Rule Findings Significant risk Technical feasibility Economic Impact Final Rule Justification for Decision Implementation Schedule

13. Challenges to a Final Rule Administrative Appeal Judicial Review Standard for Review 60 days from date of publication Court of Appeals

14. Emergency Temporary Standards Imminent Danger Serious Effects Standard is necessary to prevent effects

15. Thanks Stef; Are there any questions before Stef goes to pick up Ike?

16. OR-OSHA Rule Making Process Anyone can have a bill introduced to state legislation If passed OR-OSHA will adopt the rule OR-OSHA has to adopt a new federal rule within 90 days Can make changes to enhance the application for Oregon

17. OR - OSHA Rule Making Process Can Develop rules they feel are necessary to promote safety within the state Must prove: Significant risk Technical feasibility Economic Impact Follows the same type of procedure as the federal process only on a state level

18. Standards That Require Written Programs Emergency Response H2 & O2 HAZWOPER PPE Respiratory PRCS LOTO Fire Brigades Fire Extinguishers O2 Welding Vertical Standards Most of Subpart Z: Asbestos, Pb, VC, Cd, Benzene, coke oven emissions, cotton dust, Acrylonitrile, Formaldehyde, MC* BBP Access to Medical Records HCS & Lab Standard *List not exhaustive

19. Additional OR-OSHA Requirements Safety Committee Written Health and Safety Plans

20. Things to Remember? All plant standards should be developed under the care and direction of a safety professional If the site does not have a safety professional then use insurance company Loss Control engineers, private consultants, or the OR-OSHA consultation service Care must be taken to understand the standard being adopted Must reflect the way the plant does the activity Must be specific

21. What Should You Do Read the Standards Consult References OROSHA Guidebooks, OSHA CPL, LOI, STD Magazines and Trade Publications ASSE, AIHA Publication DOD/DOE Directives and Procedures Adapting "canned" programs to your facility

22. Who Should Develop a Plant Standard? Standards should be developed by individuals who will be required to follow them: Safety Committee Members Supervisors Safety Managers (technical assistance only)

23. Our Second Speaker Bob Riley Former plant Safety Manager for Mars, Incorporated at the Burr Ridge and Chicago, IL plants (over 20 years experience in the plant) Bob is a Haz Mat Expert Bob has his own consulting firm – Riley Associates – email – bob@rileysafety.com

24. Standards and Procedures from A Safety Manager’s Perspective Are they really necessary? Are they simple and concise? Are they enforceable and enforced? Must not demand unreasonable effort? Was employee input used? Are they consistent?

25. Manager’s Responsibility Development of proper and co-operative attitudes toward safety in employees. Personal example: The manager must set an example by his/her personal behavior. Enforcement Knowledge of safe work procedures and accident prevention techniques Standards, SOP’s, Policy documents

26. Types of Standards and Procedures Technical Engineering specifications Machine Specific Lock out procedures Confined space entry Behavioral PPE compliance “How To” SOP’s Expectations

27. Safety Managers Role Provide technical input Ensure that the standard or Procedure follows current OSHA/OR-OSHA regulations Ensure that the procedure is feasible Ensure that the procedure is kept up to date Develop appropriate communication and training for the standard or procedure

28. The Managers’ Areas of Focus Do you reallyknow the Rules? Educate yourselves Educate your teams Take and delegate responsibility for safety standard development, implementation and enforcement Share the knowledge and get input ! “Walk the Talk”

29. Thanks Bob; Are there any Questions for Bob?

30. Standard Development Process Obtain a copy of the OR-OSHA and or Federal OSHA standard Read and gain an understanding of the standard Determine the application to the plant Assemble a team of employees and managers to assist in the writing of the plant procedure Educate the team Draft the procedure Have management review the procedure Implement the procedure (communicate it to the plant and provide training)

31. Corporate – vs – OR-OSHA Procedures Many corporations require things that are not part of a OR-OSHA or Federal OSHA standard If this is the case, during an inspection the inspector will hold you accountable for compliance to your standard, not the OSHA standard

32. Things You Should NOT Do Provide copies of plant standards or procedures to a compliance officer to which that the officer is not entitled Give entire company safety manual to the compliance officer Provide the compliance officer access to a network computer containing the safety procedures

33. Safety Procedures Format Develop a standard format for safety standards and procedures Common sections Scope/Purpose Responsibilities Technical Section Implementation Appendix Section with forms and support information Review and Update section

34. Plant Format Be consistent Title Block Printer on date good for one day on the bottom

35. Communication of Standards and Procedures Establish a formal safety communication process Use: safety committee members Bulletin boards Emails Shift Meetings

36. Training Generic Training programs are good for communicating the basic standard information Each standard has specific training requirements

37. Change Management System Establish a formal Change Management system Document all updates and changes Provide information about changes to all affected employees

38. Policies & Procedures from a CSHO Perspective Is the document technically correct? Has it been reviewed/documented? Does it correlate to the process? Is it followed? Has communication & training been implemented on the floor?

39. Policies & Procedures from a CSHO Perspective Corporate Standards exceed OSHA requirements Use of CPL and LOI Training CSHO (at your expense)

40. Next Month Checking the Safety Management System Self Assessments Corporate Audits Safety Work Order Systems Inspections & Audits Incident Investigation Performance Management Open Item Tracking / Info Mgmt

41. Thanks for coming and have a safe month!