how do you get buy in for supervisors to complete their paperwork

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# APPENDIX C COMPLIANCE GUIDELINES AND RECOMMENDATIONS FOR PROCESS SAFETY MANAGEMENT (NON-MANDATORY) (cont.) ## 9. Mechanical Integrity. (cont.) A quality assurance system is needed to help ensure that the proper materials of construction are used, that fabrication and inspection procedures are proper, and that installation procedures recognize field installation concerns. The quality assurance program is an essential part of the mechanical integrity program and will help to maintain the primary and secondary lines of defense that have been designed into the process to prevent unwanted chemical releases or those which control or mitigate a release. "As built" drawings, together with certifications of coded vessels and other equipment, and materials of construction need to be verified and retained in the quality assurance documentation. Equipment installation jobs need to be properly inspected in the field for use of proper materials and procedures and to assure that qualified craftsmen are used to do the job. The use of appropriate gaskets, packing, bolts, valves, lubricants and welding rods need to be verified in the field. Also, procedures for installation of safety devices need to be verified, such as the torque on the bolts on ruptured disc installations, uniform torque on flange bolts, proper installation of pump seals, etc. If the quality of parts is a problem, it may be appropriate to conduct audits of the equipment supplier's facilities to better assure proper purchases of required equipment which is suitable for its intended service. Any changes in equipment that may become necessary will need to go through the management of change procedures. ## 10. Non-routine Work Authorizations. Non-routine work which is conducted in process areas needs to be controlled by the employer in a consistent manner. The hazards identified involving the work that is to be accomplished must be communicated to those doing the work, but also to those operating personnel whose …

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# APPENDIX C COMPLIANCE GUIDELINES AND RECOMMENDATIONS FOR PROCESS SAFETY MANAGEMENT (NON-MANDATORY) (cont.) ## 11. Managing Change. (cont.) Copies of process changes need to be kept in an accessible location to ensure that design changes are available to operating personnel as well as to PHA team members when a PHA is being done or one is being updated. ## 12. Investigation of Incidents. Incident investigation is the process of identifying the underlying causes of incidents and implementing steps to prevent similar events from occurring. The intent of an incident investigation is for employers to learn from past experiences and thus avoid repeating past mistakes. The incidents for which OSHA expects employers to become aware and to investigate are the types of events which result in or could reasonably have resulted in a catastrophic release. Some of the events are sometimes referred to as "near misses," meaning that a serious consequence did not occur, but could have. Employers need to develop in-house capability to investigate incidents that occur in their facilities. A team needs to be assembled by the employer and trained in the techniques of investigation including how to conduct interviews of witnesses, needed documentation and report writing. A multi-disciplinary team is better able to gather the facts of the event and to analyze them and develop plausible scenarios as to what happened, and why. Team members should be selected on the basis of their training, knowledge and ability to contribute to a team effort to fully investigate the incident. Employees in the process area where the incident occurred should be consulted, interviewed or made a member of the team. Their knowledge of the events form a significant set of facts about the incident which occurred. The report, its findings and recommendations are to be shared with those who can benefit from the information. The cooperation of employees is essential to an effective incident investigation. The f…

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$12-60-50 (3) Periodic inspections. The employer shall conduct periodic in-house safety and health inspections so that new or previously missed hazards or failures in engineering, work practice, and administrative controls are identified. The in- house inspections will be conducted by individuals who are trained to recognize hazardous conditions, as members of the safety and health committee or a person designated and trained by the employer for the facility's safety and health program. (4) Safety and health training. (A) The employer shall develop and institute a safety and health training program for all employees so they have an understanding of the hazards to which they may be exposed, and the procedures or practices needed to protect them from these hazards. (B) In addition, supervisors and managers shall be trained in the elements of the employer's safety and health program and in the specific responsibilities assigned to them under the program. (C) The employer shall ensure that the supervisors and managers understand their responsibilities under the safety and health program and their importance to the safety and health of the workplace. In particular, the training for managers and supervisors shall enable them to: (i) Recognize potential hazards; (ii) Maintain safety and health protection in the work area; and (iii) Reinforce employee training on the nature of the potential hazards and required protective measures. (c) The use of any machinery, tool, material, or equipment which is not in compliance with any applicable requirement of these standards is 60-7

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# VIOLATIONS (cont.) such circumstances, no citation should be issued in relation to the condition. c. Documenting Employee Exposure. - CSHOs shall thoroughly document exposure, both observed and unobserved, for each potential violation. This includes: - Statements by the exposed employees, the employer (particularly the immediate supervisor of the exposed employee), other witnesses (other employees who have observed exposure to the hazardous condition), union representatives, engineering personnel, management, or members of the exposed employee's family; - Recorded statements or signed written statements; - Photographs, video recordings, and/or measurements; and - All relevant documents (e.g., autopsy reports, police reports, job specifications, site plans, OSHA-300/301, equipment manuals, employer work rules, employer sampling results, employer safety and health programs, and employer disciplinary policies). C. Regulatory Requirements. - Violations of 29 CFR Part 1903 and Part 1904 shall be documented and cited when an employer does not comply with posting, recordkeeping and reporting requirements contained in these Parts as provided by OSHA policy. See CPL 02-00-135, Recordkeeping Policies and Procedures Manual (December 30, 2004). See also CPL 02-00-111, Citation Policy for Paperwork and Written Program Requirement Violations, dated November 27, 1995. - NOTE: If prior to the lapse of the 8 hour or 24 hour reporting periods, the Area Director becomes aware of an incident required to be reported under §1904.39 through means other than an employer report, then there is no violation for failure to report. - NOTE: 29 CFR Part 1904 has requirements for reporting work-related fatalities, hospitalizations, amputations or losses of an eye. The rule updates the list of employers partially exempt from OSHA record-keeping requirements, went into effect on January 1, 2015, for workplaces under federal OSHA jurisdiction. (See 79 FR [redacted…

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# Occupational Safety and Health Administration (cont.) training required in paragraphs (p)(7) and (p)(8) as parts of the employers comprehensive overall safety and health program. This program is to be in writing. Each site or workplace safety and health program will need to include the following: (1) Policy statements of the line of authority and accountability for implementing the program, the objectives of the program and the role of the site safety and health supervisor or manager and staff; (2) means or methods for the development of procedures for identifying and controlling workplace hazards at the site; (3) means or methods for the development and communication to employees of the various plans, work rules, standard operating procedures and practices that pertain to individual employees and supervisors; (4) means for the training of supervisors and employees to develop the needed skills and knowledge to perform their work in a safe and healthful manner; (5) means to anticipate and prepare for emergency situations; and (6) means for obtaining information feedback to aid in evaluating the program and for improving the effectiveness of the program. The management and employees should be trying continually to improve the effectiveness of the program thereby enhancing the protection being afforded those working on the site. - Accidents on the site or workplace should be investigated to provide information on how such occurrences can be avoided in the future. When injuries or illnesses occur on the site or workplace, they will need to be investigated to determine what needs to be done to prevent this incident from occurring again. Such information will need to be used as feedback on the effectiveness of the program and the information turned into positive steps to prevent any reoccurrence. Receipt of employee suggestions or complaints relating to safety and health issues involved with site or workplace activities is also a feedback mechanism that can be used e…

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# Effective Workplace Inspections (cont.) ## Are there other types of reports that may be useful? (cont.) Ongoing inspections: Supervisors and workers should conduct ongoing inspections as part of their job responsibilities. Such inspections identify hazardous or unusual operating conditions as they occur during the course of work. A hazard report may be generated to either correct the issue immediately or to request further corrective action. Hazard Reports about unsafe working conditions and hazards may be submitted directly or anonymously by workers, and by the health and safety committee or representative. Reports may include corrective action recommendations from the committee. Incident and investigation reports include a detailed inspection of the work area where the incident occurred and a root cause analysis. Being aware of how and why an incident occurred can help inspectors to identify the same hazard elsewhere. Incident trends can help to prioritize specific hazards, for example, if there have been several slip-trip-fall incidents or musculoskeletal (MSD) injuries in recent months. Inspection compliance orders and tickets (fines) may be given by inspection officers from the jurisdictional health and safety regulator, fire department, electrical authority, and other regulatory bodies. Inspection may occur at any time, for a targeted blitz, or in response to a reportable incident, fatality, or complaint. These legal orders must be complied with and receive immediate priority. Pre-operation checks are performed by workers at the beginning of their shift, before they begin to use the machine, vehicle, equipment, or process. Daily checks by users assure that the equipment meets minimum acceptable safety requirements. The frequency of these inspections varies with the amount and conditions of equipment use. Several pre-operation checklists may be completed each day by different workers. These checks are also done after workplace shutdowns, provided no mod…

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# APPENDIX C COMPLIANCE GUIDELINES AND RECOMMENDATIONS FOR PROCESS SAFETY MANAGEMENT (NON-MANDATORY) (cont.) ## 14. Compliance Audits. (cont.) An effective audit includes a review of the relevant documentation and process safety information, inspection of the physical facilities, and interviews with all levels of plant personnel. Utilizing the audit procedure and checklist developed in the preplanning stage, the audit team can systematically analyze compliance with the provisions of the standard and any other corporate policies that are relevant. For example, the audit team will review all aspects of the training program as part of the overall audit. The team will review the written training program for adequacy of content, frequency of training, effectiveness of training in terms of its goals and objectives as well as to how it fits into meeting the standard's requirements, documentation, etc. Through interviews, the team can determine the employee's knowledge and awareness of the safety procedures, duties, rules, emergency response assignments, etc. During the inspection, the team can observe actual practices such as safety and health policies, procedures, and work authorization practices. This approach enables the team to identify deficiencies and determine where corrective actions or improvements are necessary. An audit is a technique used to gather sufficient facts and information, including statistical information, to verify compliance with standards. Auditors should select as part of their preplanning a sample size sufficient to give a degree of confidence that the audit reflects the level of compliance with the standard. The audit team, through this systematic analysis, should document areas which require corrective action as well as those areas where the process safety management system is effective and working in an effective manner. This provides a record of the audit procedures and findings, and serves as a baseline of operation data for future audits…

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# Effective Workplace Inspections (cont.) ## Are there other types of reports that may be useful? (cont.) Internal audits are performed throughout the year by qualified workers, generally to support a health and safety management system, and to verify that the overall workplace inspection program is effective. External audits are performed by accredited auditors, hired by the employer to perform scheduled health and safety management system audits. Corporate insurance providers may also request an audit. These reports are useful as the auditor may have identified new areas of concern or existing issues that should be prioritized. A periodic summary of key items and trends from all of these reports may be prepared by the employer's health and safety specialist for presentation to the health and safety committee and operations team on a monthly, quarterly, or annual basis. They may be called "executive summaries' or 'management reviews'. Using an existing summary report can save time during the inspection preparation phase. ## Who should be on the inspection team? Health and safety committee members and representatives are obvious choices of personnel to carry out formal inspections, especially if they have received training or certification. Other criteria for selecting the inspection team are: - knowledge of regulations and procedures - knowledge of potential hazards - experience with work procedures involved Engineers, maintenance personnel, occupational hygienists, health and safety professionals, supervisors or managers may be a part of the inspection team or they may be called upon to help with certain aspects of the inspection, or to help explain equipment or processes. Large workplaces may have more than one inspection team. The various teams can have separate areas to inspect or use a rotation schedule. ## Should supervisors be on the inspection team? It depends. Supervisors are responsible for taking action to prevent incident, illness and inju…

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# APPENDIX C COMPLIANCE GUIDELINES AND RECOMMENDATIONS FOR PROCESS SAFETY MANAGEMENT (NON-MANDATORY) (cont.) ## 6. Employee Training. (cont.) Hands-on-training where employees are able to use their senses beyond listening, will enhance learning. For example, operating personnel, who will work in a control room or at control panels, would benefit by being trained at a simulated control panel or panels. Upset conditions of various types could be displayed on the simulator, and then the employee could go through the proper operating procedures to bring the simulator panel back to the normal operating parameters. A training environment could be created to help the trainee feel the full reality of the situation but, of course, under controlled conditions. This realistic type of training can be very effective in teaching employees correct procedures while allowing them to also see the consequences of what might happens if they do not follow established operating procedures. Other training techniques using videos or on-the-job training can also be very effective for teaching other job tasks, duties, or other important information. An effective training program will allow the employee to fully participate in the training process and to practice their skill or knowledge. Employers need to periodically evaluate their training programs to see if the necessary skills, knowledge, and routines are being properly understood and implemented by their trained employees. The means or methods for evaluating the training should be developed along with the training program goals and objectives. Training program evaluation will help employers to determine the amount of training their employees understood, and whether the desired results were obtained. If, after the evaluation, it appears that the trained employees are not at the level of knowledge and skill that was expected, the employer will need to revise the training program, provide retraining, or provide more frequent refresher tr…