By Phil Molé, MPH

A growing number of safety professionals now agree that addressing psychosocial risks is essential for safeguarding employees’ mental health and overall well-being. Our recent webinar provided some background on psychosocial risks and the ways you can use the time-tested risk management tool of job safety analysis (JSA) to address them and build employee engagement.

For the benefit of those of you who couldn’t attend live, here’s a quick recap of the webinar.

Background on Psychosocial Risks

Psychosocial risks are sources of anxiety workers experience that are rooted in the work environment itself, and therefore, are under the employer’s control or influence.

Recent studies highlight the significant impact of psychosocial risks on employee well-being and productivity. Nearly one-in-three EU workers report experiencing stress at work, with stress-related diseases contributing to the loss of millions of workdays annually.

It’s important to understand that the same workplace hazards that create what we think of as ‘traditional’ safety risks (e.g., falls, “struck by” incidents, chemical exposures) also create psychosocial risks because employee exposure to those risks causes anxiety. These risks are exacerbated by poor communication, lack of employee involvement in safety programs, and inadequate visibility of safety data. That’s why ‘traditional’ safety management and psychological/psychosocial safety management work like interconnected pieces of a puzzle.

When employees are aware of potential hazards but feel excluded from decision-making processes, their anxiety levels can understandably increase. This anxiety is intensified when safety programs do not sufficiently represent the entire workforce, easily leading to feelings of neglect and further stress. One example of this would be employees with disabilities who are not given an opportunity to participate in planning key safety program policies such as emergency response procedures such as fire drills and evacuation procedures. If emergency response plans do not account for the needs of workers with disabilities, employees with mobility issues may not be able to evacuate the building as quickly and hearing-impaired employees may not hear alarms. These examples, in addition to the growing prevalence of workplace anxiety mentioned earlier, underscores the critical need for proactive psychosocial risk management. Doing so starts with identifying and controlling those risks with the active participation of frontline workers.

Psychosocial risks, which include organizational, physical, and human factors, have a profound impact on workplace safety and productivity, and these factors often interact synergistically. For example, rigorous production targets (organizational factors) can lead to greater employee fatigue (human factors), thereby increasing the risk for injuries such as slips, trips, and falls (physical factors).

The Interaction Between Psychosocial and Traditional Safety Risks

Understanding workplace safety involves examining the interplay between the physical and psychosocial risks. Physical hazards, such as exposure to noise or chemicals, can directly harm employees. The stress resulting from potential exposure to these hazards can also lead to indirect harm, such as anxiety that can lead to high blood pressure or muscle tension that can cause musculoskeletal disorders (MSDs).

This dynamic relationship underscores the need for a more holistic approach to risk management that considers both direct and indirect pathways to harm and addresses both traditional and psychosocial risk management strategies. By addressing the root causes of stress and anxiety, businesses can create a safer and more supportive work environment.

The Importance of a Safety Management System (SMS) Approach

Adopting a safety management system (SMS) approach to identifying hazards and risks can provide the framework for the holistic approach companies need to adopt to manage both physical and psychosocial risks. A prime example of an SMS approach is alignment with ISO 45001, the internationally recognized “gold standard” for safety management.

There are several key reasons why ISO 45001 is an ideal framework for managing both physical and psychosocial risks. One reason is that ISO 45001emphasizes the need for a proactive approach to safety management focused on identification of hazards, risks, and opportunities. Another reason is that it specifically emphasizes the need for “consultation and participation” of workers, including frontline workers who are most familiar with job hazards. That phrase, “Consultation and participation,” basically translates to not simply involving employees in safety, but giving them a seat at the table so we can learn from them when developing our safety program policies. This ensures we get better information and also directly addresses the problem of employees feeling like they’re “left out” of key decisions about their safety, a factor that so often contributes to psychosocial risks.

The International Organization for Standardization (ISO) also created a supplemental guidance document, ISO 45003, specifically to help employers address psychosocial risks within the context of an SMS as described by ISO 45001. ISO’s development of 45003 underscores the value and importance of integrating traditional and psychosocial safety management.  

Enhancing Risk Management with Job Safety Analysis (JSA)

JSA is an effective tool for improving risk management and is an ideal exercise for engaging workers in addressing risks as envisioned by ISO 45001. One of the best examples of how JSAs help engage workers in addressing risks is the job task breakdown. During this step of the JSA, workers help define the individual tasks required to perform a job, and involving frontline workers and operators enables better identification of hidden hazards and risks.

Following the job task breakdown, the team performing the JSA assesses risk levels for each hazard, selects appropriate controls to reduce risks, and then performs a follow-up assessment to calculate a residual or “post-control” risk level. These steps also benefit tremendously from the consultation and participation of workers who are most familiar with the job, ensuring a diligent and accurate risk assessment and improving both traditional and psychosocial risk management.

Once you complete the JSA you need to implement processes to ensure it stays up to date. Periodically reviewing your JSAs to identify areas for improvement, rather than simply filing them away and not revisiting them until something bad happens, is key to proactive risk management. Incident investigations should always inform the JSA process and prompt a review to identify gaps and improve controls but keeping your JSAs front-and-center will enable everyone, including workers, to be more responsive to new or previously unforeseen risks before they can lead to an incident.

Depending on your facility’s complexity and your operational risk management maturity level, you may also need to supplement JSAs with other risk assessment tools. Techniques such as Failure Mode Effects and Criticality Analysis (FMECA), Event Tree Analysis, and the ‘Five Whys’ method can provide deeper insights into risks. A risk bowtie diagram is a particularly useful tool for visualizing risk pathways, causes, and consequences, making it easier for employees to understand and engage with risk management processes. Risk bowties consolidate information from various risk assessments into a simple, intuitive format, enhancing comprehension and facilitating better decision-making.

For high-risk facilities, Process Safety Management (PSM) is essential. PSM involves a structured approach to managing risks associated with highly hazardous chemicals, often requiring compliance with specific regulations. A Process Hazard Analysis (PHA) is a key component of PSM, providing layers of protection to prevent accidents. Effective PHA requires input from knowledgeable employees and can reduce both traditional and psychosocial risks. Facilitators can help ensure meaningful participation and improve the quality of PHA output. Executive summaries and inclusive brainstorming sessions can further enhance employee engagement and understanding.

Technology Can Help You Create and Use Better JSAs

Even though JSAs can help you improve your management of both traditional and psychosocial risks, there are often challenges to overcome. There can be variability in the JSA process itself which can lead to very different JSAs findings for identical processes at two different company work locations, and that compromises the effectiveness of your JSA process. You may also have a difficult time selecting appropriate controls for identified risks or identifying correct risk reduction factors for those controls. Finally, the problem of JSAs often languishing without use or updates is often worse due to employers lacking effective tools to access and share JSAs, and operational risk software helps overcome that challenge.

Technologies such as operational risk software can significantly enhance the effectiveness of JSAs by making JSAs more accessible and functional, helping organizations to revise them as needed and visualize patterns in risk controls. Software also helps employees participate directly in the process, which is the type of “consultation and participation” envisioned by ISO 45001.

Closing Thoughts on Psychosocial Risks and JSAs

Managing psychosocial risks is essential for workplace safety. Understanding these risks and their impact enables businesses to develop effective mitigation strategies. This proactive approach involves the active participation of frontline workers and the integration of both traditional and psychosocial safety management practices. Creating a supportive and inclusive work environment enhances employee well-being, reduces absenteeism and turnover, and ultimately boosts the bottom line.

Employee engagement in risk management not only improves safety but also reduces psychosocial risks, promoting a healthier and more productive work environment. Continuously refining risk management practices and using advanced tools like risk bowties and PHA ensures better risk governance, safeguarding the workforce, improving overall business performance, and reducing both traditional and psychosocial risks in the workplace. Make sure the software tools you’re using facilitate your ability to create and use better risk assessments with the collaboration of your team.

For more information about JSAs and psychosocial risks, watch our on-demand webinar.

Let VelocityEHS Help!

VelocityEHS Operational Risk software provides advanced JSA capabilities that are purpose-built to help you standardize the JSA process across your entire organization and manage it from a central dashboard. Users get a flexible, intuitive JSA management tool that makes it easy to accurately identify hazards to your workers, assess risks confidently and consistently, select, assign and verify risk controls, and communicate vital JSA information in real-time to help prevent incidents and continuously strengthen worker safety.

Operational Risk is only one of the innovative solutions included in the VelocityEHS Accelerate® Platform, alongside our Safety, Chemical Management and Industrial Ergonomics solutions. Ready to see for yourself how our software can help you? Set up a meeting to learn more!

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By Greg Duncan, MELP, CSP, Sr. EHS & ESG Content Manager at VelocityEHS

Job safety analysis (JSA) is one of the most widely relied-upon methods EHS professionals use to identify, assess, and control the hazards of job tasks. Job safety analysis is so valuable in performing this core occupational health and safety (OH&S) management function that OH&S regulators including OSHA, the Canadian Centre for Occupational Safety & Health (CCOSH), the UK Health & Safety Executive (HSE) and many others have all published volumes of guidance to help employers apply JSA in the workplace. Unfortunately, many EHS professionals still aren’t using this important tool to its full potential.

I had an enlightening experience recently at the 2024 Wisconsin Safety Council Annual Conference where I met with some folks after my session “Are Your JSA’s Good Enough? Don’t Wait for a Workplace Incident to Find Out.” In those discussions, I heard some interesting and inventive ways that attendees were managing job safety analysis at their organizations. For the most part, though, most businesses are still reliant on paper and/or spreadsheets for performing job safety analysis. This is despite the fact that modern JSA tools and technologies are available to help bring this incredibly valuable hazard and risk assessment tool to life in a way that paper or spreadsheet-based JSA methods simply can’t. This is particularly evident when we get to the risk assessment step of the JSA process.

Job Safety Analysis Risk Assessment

For a more comprehensive discussion of the JSA process (Figure 1) and JSA best practices, I’d invite you to check out our on-demand webinar “Are Your JSA’s Good Enough? Don’t Wait for a Workplace Incident to Find Out.” Here, however, let’s focus on the risk assessment step of the JSA.

Figure 1: The JSA Process

The JSA risk assessment step, like any other risk assessment, looks at potential risk causes (i.e., hazards) and asks what is the likelihood and severity of an accident or injury occurring as a result. These two fundamental risk factors (likelihood and severity) and overall risk score are commonly visualized using a basic risk matrix (Figure 2).

Figure 2: Sample Risk Matrix

A risk matrix offers a simple, qualitative means of evaluating risk likelihood and severity, while also providing an intuitive way to help prioritize and communicate the risks that have the greatest potential impact, cost, and consequence for the organization. Risks with the highest likelihood and severity fall in the upper-right of the matrix shown in red, while low-probability, low-severity risks fall in the lower-left in green.

This basic risk matrix is very common tool for JSA risk assessment, but it begs the question: “What are we actually basing our assessment of risk likelihood and severity on, and to what extent are we incorporating quantitative data to help assess these two critical risk factors?”

Expanding the Job Safety Analysis Risk Calculus

Data drives virtually every business decision-making process, and workplace safety should be no exception. EHS professionals need to be able to justify our actions, recommendations, and workplace safety improvements to many different stakeholders. That list can include regulatory agencies, management, workers, contractor providers, supply chain partners, insurance carriers, and many others. While qualitative assessment of risk likelihood and severity will always be part of the equation, hard data is increasingly becoming an essential part of the risk calculus.

So, when evaluating risk likelihood and severity, we should consider what quantitative data is available to better inform our JSA risk assessments. Even if we’re relying solely on our best judgement to assess risk likelihood and severity, we’re still ultimately basing those judgements around a number of safety metrics that describe risk likelihood and severity. So, why wouldn’t we formally account for these metrics in our calculation of risk to establish a more standardized, objective, and verifiable set of risk assessment criteria?

For example, let’s think about risk severity. Some metrics we might consider in our calculation of risk severity could include:

• Number of people impacted
• Exposure duration
• Exposure level/intensity
• Direct/indirect costs
• Lost time/productivity

Similarly, our assessment of risk likelihood relies on consideration of metrics such as:

• Injury or illness case frequency
• Exposure frequency
• Number of workers exposed
• Hours worked per job

As EHS professionals, we should always consider these metrics into our assessment of risk likelihood and severity if our goal is to improve the accuracy and reliability of our JSAs. I recognize that incorporating these metrics into our JSA risk assessments can sound like a lot of extra work, but to get a truly accurate picture of risk it’s absolutely necessary. The good news is that we’re ideally already collecting these safety metrics as part of our existing OH&S program. Unfortunately, this is where paper-based JSAs and even spreadsheets present significant obstacles, and we need to look toward tools like a purpose-built JSA software system that allows us to access and reference these metrics while performing the JSA and incorporate into the JSA risk assessment so we can simplify and expedite our risk calculations and more accurately assess JSA risks.

To illustrate this fact, let’s look at the example JSA (Figure 3) below:

Figure 3: Example JSA

Rather than a simple qualitative (high/medium/low) assessment of risk likelihood and severity, JSA software offers the ability to incorporate multiple semi-quantitative factors into the calculation of overall risk score. They are semi-quantitative because even though they still rely on a range of pre-defined categories to describe risk likelihood and severity, those categories are represented by a numerical value that is used by the software to calculate a quantitative risk score.  

Figure 4: JSA Risk Assessment Variables

If we zoom in (Figure 4), we can see several semi-quantitative risk factors have been incorporated into the risk score calculation, resulting in a quantitative risk score that can then be objectively compared to other risk scores within the JSA to help prioritize job hazard control activities, or compared against the risk scores from other JSAs in the workplace or across the organization for reporting purposes and to support continuous improvement. VelocityEHS JSA capabilities allow for configuration of the JSA process to include consideration of these variables and other basic safety metrics (Figure 5) to help improve the accuracy and objectivity of our risk likelihood and severity assessments.

Figure 5: Additional JSA Risk Assessment Variables

Relying on semi-quantitative risk factors like the ones above rather than simple qualitative (high/medium/low) risk assessment criteria helps us to refine the accuracy and objectivity of our JSA risk scores. The trick is to ensure that metrics like injury and illness rates, incident rates, incident costs, exposure level, and exposure frequency are easily referenced while performing the JSA so we can use them to inform our assessment of these semi-quantitative risk factors. This is one of the key advantages of JSA software systems.

Standardizing Job Safety Analysis Risk Factors

In addition to improved accuracy and objectivity of JSA risk assessments, introducing semi-quantitative risk factors into the JSA also helps to standardize workers’ perceptions of risk and how those risks are assessed from job-to-job and across the entire organization. Risk perception is unique to every individual, and is influenced by multiple variables including workers’ level of experience and skill, past exposure to risks, and degree of risk tolerance or risk aversion. What one worker considers to be a medium risk, another may perceive as a high risk, even when looking at the exact same job task performed under identical conditions. You can imagine how this could introduce significant disparities in how risk likelihood and severity are assessed from one JSA to the next.  

By using more objective, semi-quantitative risk factors and building these into the JSA process, we’re able to establish a standardized set of criteria for how risk likelihood and severity are assessed, minimize the impact of disparities in risk perception, and ultimately improve the accuracy of how risk scores are calculated. Within a single JSA, this enables EHS professionals to compare initial and residual risk scores in a more consistent manner so that each time the JSA for a given job is reviewed, we’re able to verify that the controls we’ve selected are truly effective at reducing risks. When looking at JSAs for jobs across multiple locations, this standardization allows for an “apples-to-apples” comparison of job safety and control effectiveness across the organization.

VelocityEHS JSA Capabilities

As EHS professionals, we need to be able to easily reference our safety metrics and factor those into our assessments of risk likelihood and severity. We need to be able to share and compare JSA information across the organization to help ensure job safety is managed using a consistent and standardized process. We need JSAs that actively contribute to continuous improvement of worker safety, and don’t simply sit on the shelf. JSAs should be living documents that provide workers with a dependable resource for understanding safe work practices, while simultaneously helping EHS professionals to better understand and control workplace risks. Spreadsheets unfortunately lack the functionality and flexibility that is necessary to get the most from JSAs and use them to their full potential.

VelocityEHS Job Safety Analysis capabilities, part of our Operational Risk solution, is a purpose-built JSA software system that helps you standardize the JSA process across your entire organization and efficiently manage it from a central dashboard. Users get a flexible, intuitive JSA management tool that makes it easy to accurately identify hazards to your workers, assess risks confidently and consistently, select, assign and verify risk controls, and communicate vital JSA information in real-time to help prevent incidents and continuously strengthen worker safety.

Ready to see how our JSA capabilities can help you? Click here to request a demo and speak with one of our EHS experts today!

The post Improving Job Safety Analysis Using Semi-Quantitative Risk Factors appeared first on VelocityEHS.

By Phil Molé, MPH

The Seveso III directive is one of the most important regulations in the EU, requiring operators of certain facilities storing dangerous chemicals to develop and implement emergency planning and response procedures. The directive officially covers approximately 12,000 EU establishments, and EU member states implement the directive through national legislation and enforce it through local regulatory agencies.

In what follows, you’ll learn about the background and purpose of Seveso III, as well as its requirements. You’ll also get some key takeaways to ensure compliance and improve your operational risk management practices.

What is the Background of Seveso III?

Accidents at chemical storage or processing facilities can have disastrous consequences. For example, one of the more significant accidents in the EU is the 2019 fire at a Lubrizol factory in Rouen. While it did not result in fatalities, it disrupted local business and destroyed harvests, leading to a 1,600-foot exclusion zone surrounding the facility. In January 2020, an accident involving two explosions at a Chemical Industries of Ethylene Oxide (IQOXE) facility in Tarragona, Catalonia, Spain killed three offsite people and injured seven. Because accidents like these can take a huge toll on human health and the environment, operators of chemical facilities need to be very proactive in their planning for emergency prevention and response. The Seveso III directive is intended to ensure exactly that.

Seveso III is the third version of the Seveso directive. It follows Seveso I (Directive 82/501/EC) and Seveso II (Directive 96/82/EC), taking its name from a 1976 industrial disaster near the Italian town of Seveso, located approximately 12 miles north of Milan. The accident occurred when plant management stopped a batch process before distillation could remove ethylene glycol built up from the reaction mixture. This resulted in a chain of events that led to the release of the highly toxic chemical 2,3,7,8-Tetrachlorodibenzodioxin (TCDD). Thousands of animals (mostly poultry and rabbits) near the facility died in the immediate aftermath of the accident, and officials ordered tens of thousands more to be killed to keep TCDD-infected meat from being sold to consumers. The most immediate health effect for humans was 193 cases of chloracne, a skin condition caused by exposure to chlorinated compounds. However, a 1991 follow-up study on the population exposed to TCDD from the Seveso disaster identified a higher incidence of health effects such as peripheral neuropathy, liver enzyme induction, and diabetes, as well as an elevated mortality rate from cardiovascular and respiratory diseases.  It’s no wonder why a 2010 Time magazine article on the worst environmental disasters in history ranked the Seveso disaster at #8.

European countries developed the first version of the Seveso directive (Seveso I) after years of planning and stakeholder discussions about the best ways to prevent or mitigate accidents like the Seveso disaster. They enacted Seveso I in 1982. The EU reviewed and revised the directive in 1999, resulting in Seveso II, and the most recent set of updates resulting in Seveso III occurred in 2012.

Compared to Seveso II, Seveso III introduced several changes, including:

• An updated list of substances covered by Seveso to align with the CLP Regulation
• Revision of some definitions used in the directive
• Updated emergency planning provisions to require co-operation by designated authorities in tests of external emergency plans (for upper-tier facilities).
• Strengthened requirements for providing public information, including a duty for lower-tier establishments to provide public information.
• Broadened discussion and requirements of “domino effects” (discussed later).

The intention behind Seveso III is to require facility operators to take all necessary measures (both technical and organizational) to prevent accidents and limit their consequences. You’ll soon learn about the specific requirements within Seveso III intended to accomplish those objectives, but first, it’s important to understand a little context.

The creators of Seveso III clearly intended for it to facilitate better operational risk management with a goal of preventing accidents when possible and minimizing the impacts of accidents if they do happen. EHS managers measure risk as the product of the probability of a bad outcome, like an accident happening, and the severity of the outcome if it happens. The most common tool used to present risk measures is a risk matrix, shown in the image below:

Risks with the largest calculated products of probability and severity appear in the top right corner of the matrix, highlighted in bright, alarmist red. Risks with the lowest ranked scores wind up in the bottom left quadrant, highlighted in a much more calming green color. This visual organization of information makes the matrix intuitively understandable for everyone from EHS management to frontline workers.

A popular risk management tool called the risk bowtie builds on this concept of risk by mapping out risk pathways. These show the relationship between risk causes, the unplanned/undesired event, and risk consequences, as shown in the image below.

If you look closely at the diagram above, you’ll see that the bowtie diagram also shows the placement of controls used to reduce levels of risk. Since risk management involves both the “before” and “after” aspects of an accident, so do the categories of controls, as shown in the table below.

Here’s an example to help you think about how you might use preventive, mitigative and detective controls in practice. Suppose you have a facility with large aboveground tanks (ASTs) of volatile liquids that tend to evolve vapors. One useful preventive control would be a safety valve, or pressure-relief valve, to vent some of the vapors before they can build up enough pressure to result in a tank rupture or explosion. What if the tank still ruptures? A bermed structure around the tanks designed to contain at least some of the overall liquid volume would be a mitigative control, because it would reduce the severity of the chemical spill. You can also use a detective control such as vapor monitors connected to an alarm system (consisting of both sound and visual warnings, like flashing lights) to let you know that harmful vapors are escaping, so you can immediately take measures to prevent a larger release and protect the safety of your employees.

As you read on about the requirements of Seveso III, try to see them as parts of an effective risk management strategy, as they’re intended to be. Compliance with Seveso III is not a foolproof method for preventing major accidents—in fact, the 2019 Lubrizol fire and the 2020 IQOXE explosion both occurred at facilities covered by Seveso III. Still, the requirements in Seveso III reduce the likelihood of accidents, and certainly enable smoother and safer response if accidents happen.

Which Facilities are Subject to Seveso III?

Now that you have some background in the history and intentions behind Seveso III, it’s time to understand its applicability. Not all EU facilities are subject to Seveso III, because the directive is intended to prevent major accidents at facilities storing and using large quantities of dangerous chemicals listed in Annex I of the directive.

Applicability of Seveso III depends on Substances that trigger coverage under Seveso III, which fall into two main categories:

1) Substances specifically named on list; and

2) Substances listed as part of a group of classifications under Classification, Labeling and Packaging (CLP)

The European Chemical Agency (ECHA) provides lists of these two groups of chemicals in the C + L Inventory, which is Annex I of Seveso III.

There are also two tiers of applicability to Seveso III, depending on quantities of chemicals stored at the facility. For reference, these thresholds (taken from Part 2 of Annex I) are shown in the table below.

Article 3 defines a lower-tier establishment as an establishment where dangerous substances are present in quantities equal to or above of the quantities listed in Column 2 of Part 1 or in Column 2 of Part 2 of Annex I, but less than the quantities listed in Column 3 of Part 1 or in Column 3 of Part 2 of Annex I.

An upper-tier establishment is an establishment where dangerous substances are present in quantities equal to or above the quantities listed in Column 3 of Part 1 or in Column 3 of Part 2 of Annex I, where applicable. Upper-tier establishments have higher risks due to the higher quantities of dangerous chemicals stored. Because of this, they have more stringent requirements to ensure they’re doing what’s necessary to prevent major accidents and minimize their consequences.

What Does Seveso III Require?

Here are some of the major requirements of Seveso III.

Notification Requirements

A facility operator who determines that their facility is subject to Seveso III must notify the competent authority about each accident that meets the major accident criteria published in Annex VI of Seveso III.

The major accident criteria are:

1.   There are dangerous substances involved

Any fire or explosion or accidental discharge of a dangerous substance involving a quantity of at least 5 % of the qualifying quantity laid down in Column 3 of Part 1 or in Column 3 of Part 2 of Annex I.

2.  People were injured, or damage to real estate occurred

Specifically, facility operators must report incidents involving any of the following:

If a facility operator determines that an incident met one or more of the reporting criteria listed above, they must complete and submit a report using the Major Accident Reporting System (eMARS) managed by the Major Accidents Bureau. The report submitted must include the following information:

• The name and/or trade name of the operator and the full address of the establishment concerned;
• The registered place of business of the operator, including the full site address;
• The name and position/title of the person in charge of the establishment;
• Information sufficient to identify the dangerous substances and category of substances involved or likely to be present;
• The quantity and physical form of the dangerous substance or substances involved in the incident;
• The activity or proposed activity of the installation or storage facility; and
• The immediate environment of the establishment, and factors likely to cause a major accident or to aggravate the consequences. This information must include (where available) details of neighboring establishments, areas and developments that could cause or increase the risk or consequences of a major accident and of domino effects.

Develop and Maintain a Major Accident Prevention Policy (MAPP)

Seveso III requires facility operators subject to the directive to develop and maintain a MAPP.  The directive states that facility operators must design their MAPP to ensure “a high level of protection of human health and the environment.” Additionally, the MAPP must have a prioritized focus on the major-accident hazards that could occur at the facility and include the operator’s overall aims and principles of action, the role and responsibility of management, and the commitment to continuously improving the control of major-accident hazards.

Operators of lower-tier establishments may meet their obligation to implement the MAPP through other appropriate means, structures and management systems, as long as the methods are proportionate to major-accident hazards and are based on the principles set out in Annex III.

The directive also specifies that the operator must implement the MAPP via a safety management system (SMS). Annex III expands on this by saying that operators need to make sure their safety management system is suitable for the hazards, industrial activities, and organizational complexity of the organization. Facility managers must ensure that the SMS accounts for methods of identification and control of hazards, integration of safety into operations, and emergency planning, and define the organizational roles responsible for managing different aspects of safety.

The organization must have a management of change (MOC) process to ensure that all planned modifications to the facility or operations go through a formal review to assess and control potential risks before the changes go into effect. This is especially important to assess in the context of Seveso III because some planned operational changes may potentially change an establishment from lower-tier to upper-tier classification and change its corresponding regulatory obligations.

Finally, the SMS must involve performance monitoring. This includes reviewing key performance indicators (KPIs) and committing to a continuous improvement process that uses performance monitoring to identify opportunities to improve safety management.

What is a Safety Management System?

It might be worth parking on the SMS discussion for a while because an SMS is essential to comply with Seveso III and not all EHS managers fully understand what it is.  .

To get a better handle on what an SMS is and should be, you should familiarize yourself with ISO 45001, the international standard for occupational health & safety (OH& S) management systems.

To understand why, let’s look at how ISO 45001 defines the term. In the “definitions” section, 45001 defines “management system” as a “set of interrelated or interacting elements of an organization to establish policies and objectives and processes to achieve those objectives.” In a note to the definition, 45001 further explains that “the system elements include the organization’s structure, roles and responsibilities, planning and operation, performance evaluation and improvement.”

In other words, an SMS isn’t something you can just buy and unbox because it consists of all  the people, programs, policies, metrics, job-specific work instructions, and cultural aspects that collectively affect your environmental performance. It consists of your EHS team and all your employees from the shop floor to the C-suite, your individual facility’s environmental policy manual, and all the standard operating procedures (SOPs) for every work task with environmental aspects. A good shorthand to remember is that your system consists of “people,” “policies,” and “places” as show in the image below.

Following and especially certifying to ISO 45001 can not only help you improve your general safety and risk management practices but also can improve your compliance with the requirements of Seveso III. Look back at some of the Seveso requirements you’ve learned about. All of these are also facets of a successful management system as modeled by ISO 45001. For example, Section 6.1.2 addresses hazard identification and assessment of risks and opportunities, Section 8.1.3 addresses Management of Change, and Section 8.2 covers emergency preparedness and response.

ISO 31000 is another useful ISO standard to understand. Unlike 45001, ISO 31000 is not a standard that companies can certify to—it’s intended for guidance only. Still, it provides a broad framework to manage many kinds of risks, including not only OH&S or environmental risks but also financial risks and reputational risks that may follow a major chemical accident.

Establishment and Implementation of Emergency Plans

The emergency preparedness and response provisions of ISO 45001 are useful because they can help establishment management meet the analogous requirements in Seveso IIII.

All operators of facilities covered by Seveso III need to develop and implement an internal emergency plan describing their methods for responding to and minimizing the impacts of major accidents. The plans must also address how to communicate relevant information about the incident to the public, when necessary, and procedures to follow when cleaning up and disposing of chemical waste from a spill.

Operators of facilities classified as upper tier must also provide necessary information to the competent authority to develop external emergency plans that this authority could implement in the event of an accident at the facility. This information should include details about the identities and storage locations and quantities of chemicals at the site, and any other information the authority needs to develop adequate plans to respond to potential accidents at the facility involving those chemicals. Seveso III states that the authority has two (2) years from receipt of that information to develop an external emergency plan.

Leaders of global companies who are more used to regulations in say, the United States, may not be used to a regulation like Seveso III because it creates joint responsibilities for a facility manager and the local government authority for management and oversight of facility safety. This collaborative approach between the facility manager and the competent authority can only be effective if facility management can share accurate and readily understandable information about operations, including chemical storage practices. For example, the competent authority will need to know the identities and quantities of chemicals stored at the facility, along with the storage container types (e.g., 55-gallon drums, ASTs, totes, etc.) and their storage locations, because that information is relevant to planning emergency response procedures.

Identification of “Domino Effect” Risks

Managers of facilities subject to Seveso III must provide information to competent authorities identifying risks for “domino effects” from chemical accidents. The directive defines domino effects as situations in which “establishments are sited in such a way or so close together as to increase the likelihood of major accidents or aggravate their consequences.”

Seveso III also advises that operators who identify potential for domino effects should cooperate with each other. They should exchange appropriate information, and also cooperate in informing the public, including neighboring establishments, that major accidents could impact them.

The potential for external impacts, such as domino effects, are the reason Seveso III requires that decision making for specific individual projects at a Seveso III covered facility needs to involve public consultation, and public stakeholders in decision making. Facility managers can have legal liability if they do not involve the public in these matters. This again points to the need to have accurate and accessible information about chemicals that will be used, or the proposed workflows for facility changes.

Does the EU Provide Data on Chemical Accidents at Facilities Covered by Seveso III?

Yes. The Major Accident Hazards Bureau of the European Commission Joint Research Centre created a portal called MINERVA publicizing the details of major industrial accidents in the EU. The purpose of MINERVA is to provide the public with access to all information on current activities, relevant publications, and tools related to control of major accident hazards.

The Major Accident Hazards Bureau also sometimes issues reports summarizing data submitted by facilities covered by Seveso III. This includes a report about lessons learned from accidents in waste management facilities, and another on lessons learned from accidents in warehouses.

What are the Key Takeaways About Seveso III?

There are a lot of moving parts to Seveso III. Here are some of the key takeaways to help you maintain compliance with Seveso III and improve your SMS.

It Starts with Risk Management

As you learned earlier in this piece, the fundamental purpose of Seveso III is to address operational risk management practices. You need to have a good understanding of your facility and its operations to evaluate the probability of different accident risks and the potential severities of accident outcomes. You’ll also need intuitive and engaging ways to share information with your whole workforce about risk pathways and the importance of the controls you have in place to prevent or mitigate risks.

You’ll have an easier time managing operational risk if you have better tools. Modern operational risk management software tools facilitate easier completion of different risk assessment methodologies like hazard identification (HAZIDs), risk bowties, process hazard analyses, and Five Whys.

Know Your Chemical Inventory

Since the applicability of Seveso III depends on the storage levels of chemicals listed in Annex I, you’ll need to have a good understanding of your chemical inventory to determine if your facility is subject to the directive’s requirements.

The best chemical management software can help by providing barrier-free 24/7 access to your entire safety data sheet (SDS) library, and information about chemical and physical properties and hazards, safe storage practices, acute and chronic exposure symptoms, first aid measures, and cleanup/disposal procedures. If you’re an upper-tier facility, or even a lower-tier facility that wants to be as proactive as possible, chemical management software can also help you map your chemical storage locations onto a facility diagram that you can share with the competent authorities with oversight of your facility.

Don’t Forget Management of Change (MOC)!

There’s no use going through the effort to develop effective risk management practices if you don’t also have management of change plans in place to review planned changes to the facility or its operations that could affect risk levels. MOC is an essential part of your SMS as outlined by ISO 45001, because it helps you ensure that you’re getting a chance to assess and control risks from planned changes before those changes go live.

If MOC is so important, why doesn’t everyone do it? One of the main reasons is that without good technological support, MOC can be a tedious and time-consuming process. With the right MOC software, you’ll have an easier time reviewing workflows for proposed changes, and develop pre and post start-up checklists, automate alerts when review or approval tasks are coming due or past due, and maintain an audit trail for the whole workflow review process.

Let VelocityEHS Help!

Streamline and improve risk management with the Velocity Operational Risk Solution. Gain unparalleled visibility and control of workplace risks, drive enhanced collaboration and engagement with your stakeholders, and adapt and scale to your organization’s needs. You’ll have direct ability to conduct risk assessments such as HAZIDS, risk bowties, and PHAs, and keep your entire team aligned with risk management practices. We also offer effective and easy MOC capabilities that help you easily manage reviews and approvals of entire workflows of planned changes and provide an audit trail so that you know that all the right boxes have been checked before the changes go live.

Major facility accidents are scary, but operational risk management doesn’t have to be. Contact us today to schedule a demo and learn how we can help you comply with Seveso III and improve your risk management practices.

The post Understanding the Seveso III Directive appeared first on VelocityEHS.

Changes occurring within an organization’s operations are inevitable, and it’s imperative that the crucial process of Management of Change (MOC) procedures be completed to assess and address the risks or unintended consequences that stem from changes made.  

MOC is a systematic method for identifying and controlling safety, health and environmental risks associated with planned changes to facilities, personnel, policies or operations – whether they’re intended to be permanent changes, but also (and maybe especially) when they’re considered temporary. There’s an old saying that there’s nothing quite so permanent as a “temporary change,” and plans thought to be temporary are even more likely to bypass reviews to assess and control risks. 

A common response to the idea of developing MOC from organizations is a sense of hesitation, that developing all those processes will take too much time, use too many resources, and will not be worth all the effort it would take. However, when considering the alternative — the consequences of inadequate change management leading to disasters and their required response — the value becomes strikingly clear. 

What is Management of Change?

The primary purpose of MOC processes is to engage key stakeholders in the systematic evaluation and management of potential risks associated with operational changes. This structured approach involves assessing the impact of changes on safety, health, and environmental factors before implementation.

Here’s how effective MOC processes can reduce the risk of incidents:

• Risk Identification and Assessment: MOC processes systematically evaluate potential risks associated with operational changes before implementation. This proactive approach allows for thorough risk assessment and mitigation planning, to avoid disasters occurring. 

• Compliance and Regulatory Alignment: Agencies like Occupational Safety and Health Administration (OSHA) establish and enforce regulations such as Process Safety Management (PSM) requiring covered facilities to conduct MOC. Having a documented and effective MOC process not only ensures legal compliance, it also fosters a safer work environment.  

• Operational Efficiency: Contrary to common belief, implementing MOC processes can streamline operations by reducing disruptions when unexpected changes occur, as well as the downtime caused by incidents. 

The Cost of Disaster Response vs. Prevention

According to the Environmental Protection Agency (EPA), the National Safety Council (NSC), and OSHA, workplace disasters not only result in immediate human and environmental impacts, but also incur staggering financial burdens.  

According to NSC, work injuries in 2022 cost, in dollars: 

• $167B, including $50.7B in wage and productivity losses (down from $171B in 2020) 

• $37.6B in medical expenses 

• $54.4B in administrative expenses 

• $15B in uninsured costs 

• $5.6B for vehicle damage 

• $3.7B for fire losses 

On average thus far in the 2020s, medical consultations for injured employees cost $40,000 each, while deaths cost $1,390,000, encompassing wage, medical, administrative, and employer costs (excluding property damage).  

On the grander scale of things, organizations have to do significant clean-up after an incident, more than just physically. Imagine a scenario where a chemical spill occurs due to an unapproved process change, resulting in injury to workers and significant environmental contamination.

In this reactive stance, the organization now faces: 

• Financial Fallout: Immediate costs include cleanup expenses, fines, legal fees, and potential compensation claims. Long-term costs may involve reputation damage, increased insurance premiums, and diminished investor confidence. 

• Operational Disruption: The incident disrupts production schedules, halts operations, and strains resources as the organization scrambles to mitigate the damage. Many facilities that experience major accidents do not resume operations afterward. 

• Human Impact: Beyond financial implications, incidents can harm employees’ health, morale, and trust in management, impacting productivity and organizational culture. Depending on the nature of the incident, communities outside the company can be greatly affected, such as through environmental exposure risks like water, air and pollution.  

Here’s why investing time and effort into MOC processes pays off far more than relying on disaster response measures: 

• Risk Identification and Mitigation: By analyzing potential hazards and assessing their impact, organizations can proactively address risks before they escalate into disasters. 

• Regulatory Compliance: By adhering to structured MOC protocols, organizations ensure compliance with regulatory requirements, avoiding penalties and regulatory scrutiny. 

• Operational Continuity: Properly managed changes reduce the likelihood of unplanned downtime or interruptions, maintaining smooth operations and preserving productivity. 

• Safety Culture Reinforcement: Prioritizing MOC fosters a culture where safety and environmental stewardship are core values. Employees are more likely to engage in safe practices and report potential hazards, further reducing risks. 

Building a Resilient Future

While developing and implementing Management of Change processes may require upfront investment in time, resources, and effort, the alternative — disaster response — is exponentially more costly and detrimental to an organization. Organizations need to view MOC not as a burden, but as a strategic investment in safeguarding their most valuable assets: their employees, communities, and operational continuity. 

By prioritizing proactive risk management through MOC, companies can not only enhance their EHS performance but also contribute positively to their bottom line and reputation. With all these points in consideration, the value of developing MOC processes today to avoid the catastrophic costs of disaster response tomorrow is an obvious choice. 

By investing in proactive risk management through MOC, organizations not only safeguard against potential disasters but also cultivate a culture of safety, compliance, and operational excellence. The effort expended in thoughtful planning and implementation upfront far outweighs the reactive costs incurred in the aftermath of an incident.  

The choice between disaster response and proactive risk management through MOC is not merely about avoiding crises; it’s about ensuring sustainable success and safeguarding the well-being of everyone involved – the organization, its employees and its communities. 

Our VelocityEHS Management of Change software streamlines the complex processes for evaluating the impacts of organizational process changes. It’s designed to give you the flexibility needed to manage organizational change anywhere, anytime. 

The post If You Think Management of Change Processes Take a Lot…Try Disaster Response appeared first on VelocityEHS.

By Greg Duncan, MELP, CSP, Sr. EHS & ESG Content Manager at VelocityEHS

One of the most important steps in performing any job safety analysis (JSA) is assessing the likelihood and severity of risks encountered during performance of job tasks. This risk assessment is crucial to the subsequent JSA steps of identifying and implementing the appropriate hazard controls, as well as evaluating the effectiveness of those controls to verify that risks are managed to an acceptable level. One of the greatest challenges with JSA risk assessment, however, is that different people with a diverse range of knowledge, skills, expertise, and perspectives who are performing the JSA can unfortunately introduce discrepancies in how risks are perceived and evaluated. These discrepancies can result in uncontrolled risks to workers, poorly designed or ineffective hazard controls, and ultimately, an unsafe workplace.

To help illustrate this challenge, let’s look at a risk matrix. EHS professionals are likely familiar with the concept of a risk matrix which commonly uses qualitative terms like high/medium/low to describe and evaluate risk severity, likelihood, and overall risk level.

A risk matrix is certainly a valuable tool for documenting JSA risk assessment and communicating those risks in an easy to understand format, but it has its limitations. Specifically, a risk matrix that relies on qualitative risk assessment criteria (high/medium/low) to evaluate the likelihood and severity of risks fails to give us a precise picture of the actual risk level. To counter this, JSAs often incorporate additional risk factors such as the frequency of hazard exposures and number of workers exposed to help further assess the likelihood and severity of risks, but if we rely on qualitative terms to describe those additional risk factors as well, the JSA risk assessment is still imprecise .

This is because qualitative terms are inherently subjective, and how these terms are interpreted is heavily influenced by the risk perception of both the person(s) assessing the risk and the workers who rely on the JSA to inform safe work practices. A risk that is defined as “medium” in the JSA may be interpreted differently by different people, and therefore, the level of precaution and hazard controls workers employ when performing job tasks can vary significantly. This is a bad situation.

This lack of standardization can also lead to a situation where the risks documented in the JSAs for the same job performed in different areas of the workplace or across multiple locations are not assessed consistently. This can lead to different hazard controls being implemented to manage identical risks, and potentially, reliance on less-than-effective hazard controls. Moreover, it prevents any meaningful “apples-to-apples” comparison of incidents or other risk information concerning those jobs when evaluating job safety and/or periodically reviewing the JSA.

So, how can we standardize our risk assessment criteria so we can minimize the subjectivity in our JSAs and manage risks more consistently across the organization as a whole?

JSA Risk Assessment Best Practices

Standardize Your Safety Training

One of the fundamental goals of workplace safety training is ensuring workers possess the knowledge and skills necessary to recognize and avoid hazards, which should of course include the ability to accurately assess the likelihood and severity of those hazards. If you can develop and deliver safety training in a uniform manner to all workers performing the same jobs and even similar job tasks throughout the workplace (and across the entire organization), you’ll make significant progress toward standardizing and aligning workers’ perceptions of the hazards and risks associated with those job tasks. With a more uniform perception of job task hazards and risks, you’ll help to minimize the subjectivity in workers’ interpretation of job task risks so that all workers have a common understanding of how to recognize and control them.

This is, itself, a big challenge because there are a lot of variables that impact the effectiveness of workplace safety training. Different trainers, different training methods and content, trainees’ own attitudes and existing levels of knowledge and experience — these all influence how training is received and retained. If we, as safety professionals and trainers, can standardize not only what training we deliver but also how we train, then we give ourselves the best odds of giving workers the most comprehensive and accurate understanding of job task hazards and risks.

Hands-on learning will always be an essential aspect of workplace safety training, but eLearning (online computer-based training) helps to minimize the inherent variability in workplace training that can be introduced due to different trainers, training content, and training settings. It enables safety professionals to provide consistent, standardized training to workers and evaluate training performance and retention using a single, uniform set of metrics. This lends itself to a more consistent perception of job task hazards and risks among workers, and fosters a more uniform approach to controlling those risks using the most effective and accepted control measures.

Leverage the Knowledge & Experience of your JSA Team

There’s a reason I’ve addressed training as the first area of best practice here, and that’s because knowledge of hazard recognition and controls forms the foundation for the entire JSA process. If the people performing the JSA lack the ability to recognize job task hazards, consistently assess risks, and select the most appropriate and effective controls, the resulting JSA will be inadequate and incomplete, potentially leading to unrecognized and uncontrolled hazards.

That said, JSA should be a collaborative exercise that incorporates the knowledge of hazard recognition and control from multiple individuals. Two heads are better than one, right? How about three, or six, each bringing unique expertise and representing a diverse range of stakeholder interests. Performing JSA in a team setting allows for JSA team members to confer and ideally reach a consensus on how to properly evaluate and describe risks. This helps you to reduce the subjectivity of risk categorization and gain a more balanced and accurate assessment of risk likelihood and severity.

By performing JSA in a team setting, you’re simultaneously turning the whole exercise into a training opportunity with JSA team members actively learning from one another and developing a more consistent perception of risk. This further reduces the subjectivity of risk categorization and assessment. You might think that having a team of diverse voices and perspectives could complicate or confuse the JSA process, but when JSA is performed in a team setting, team members tend to develop a genuine sense of shared responsibility and accountability for workplace safety. This is particularly true when employees who perform the job being analyzed are included in the JSA team. When those workers are given a direct role in evaluating the risks they encounter on a day-to-day basis and in developing safe work practices and controls, this strengthens ownership, engagement, and understanding of job task safety. This has the direct benefit of improving the JSA, and the secondary benefit of fostering a more proactive safety culture within the organization.

Achieving the benefits of a team-based, collaborative JSA process is only possible, though, if you have JSA tools and systems that accommodate that collaborative approach. It’s difficult to coordinate and capture JSAs using a paper-based document, and paper-based JSA processes are severely limited in the ability to access, share, edit, update, and communicate JSA information. Unfortunately, many EHS professionals still rely on paper-based JSAs, and these limitations create barriers that keep them from realizing the full safety program benefits they are intended to provide. As a result, paper-based JSAs are often simply filed away, underutilized, infrequently updated, and only re-visited when something goes wrong.  

Software-based JSA, by contrast, offers not only enhanced collaboration, access, updating and sharing capabilities, but system configuration options that allow JSA team members to quickly select from a centralized knowledge base of standard hazard definitions, risk assessment criteria, and hazard controls. This makes it easier to perform JSAs consistently and accurately from job to job and throughout your entire organization, further reducing the subjectivity when performing JSA risk assessment.

Incorporate Semi-Quantitative & Quantitative Risk Assessment Criteria in your JSAs

As we’ve already discussed, many EHS professionals rely on qualitative terms (high/medium/low) to describe risks when performing JSA risk assessment, and often depend solely on their best professional judgment to determine risk likelihood and severity. Relying purely on qualitative risk assessment criteria for risk likelihood and severity limits the accuracy of the JSA, even with the combined best professional judgement of the entire JSA team. This judgement and experience are certainly essential factors in assessing risks, but they fail to tell the whole story.

To minimize any confusion, EHS professionals should consider how to incorporate more quantitative risk assessment criteria into their JSAs to generate a semi-quantitative risk assessment. A go-to source for quantitative data to support more objective and standardized JSA risk assessment is your actual injury and illness records. Specifically, injuries and illnesses associated with the job being analyzed in the JSA. EHS professionals should ideally have injury and illness data in-hand when performing JSAs to support and confirm the judgement of the JSA team, providing empirical evidence of risk likelihood and severity.

Referencing historical incident data will help you to improve the accuracy of your JSA risk assessments while further minimizing the subjectivity of your risk assessment criteria. There are several common incident metrics you should consider when it comes to evaluating risk likelihood and severity for a given job. These include, but are not limited to:

Frequency metrics

• total recordable incident rate (TRIR)
• length/duration of hazard exposures
• lost time injury frequency rate (LTIFR)
• fatal accident rate (FAR)
• equipment failure rates/service life estimates

Impact metrics

• nature of injuries or illnesses (e.g. fatal vs. non-fatal injuries, extent of injuries)days away restricted or transferred (DART) and other commonly tracked incident rates)
• number of workers affected/involved
• direct costs of injuries and illnesses (medical treatment, workers’ compensation claims, legal penalties, etc.)
• indirect costs (civil liability, lost productivity/downtime, worker turnover and retraining, reputational damage, etc.)

Earlier on, we mentioned incorporating frequency of hazard exposures and number of workers exposed as additional criteria that can help us better assess the likelihood and severity of risks. Incorporating these criteria not only gives a more defined picture of risk, but describing these additional criteria quantitatively or even semi-quantitatively (see below) will further minimize the subjectivity of our JSA risk assessments and standardize our perception of risk likelihood and severity.  

Applying more qualitative criteria to your JSA risk assessment will help you generate a more objective, standardized picture of workplace risks, but it first requires tracking this data and being able to easily reference it when performing JSA. This way, you’ll be able to access, calculate, compare, and apply this information easily when performing your JSA risk assessments so you don’t have to hunt down important incident metrics across different files or systems. How often are injuries, illnesses, near-misses, and uncontrolled hazards encountered by workers performing the job? What is the outcome and impact of those incidents? The answers to questions like these are important considerations when evaluating risk, and making this information easier to access and understand increases the likelihood that they will be incorporated into JSA risk assessments.

VelocityEHS Can Help!

Paper and spreadsheet-based systems simply lack the flexibility and shareability EHS professionals need to use JSAs to their full potential. VelocityEHS JSA software gives you the tools to overcome these limitations while providing a standardized, intuitive interface for conducting JSAs step-by-step (including job task breakdown, hazard identification, risk assessment, control implementation, and JSA reviews) so your JSA teams can do them the same way, the right way, every time.

VelocityEHS JSA software capabilities also enable you to quickly and easily select standard controls for identified risks from a drop-down menu, apply industry-standard risk reduction factors, and then automatically calculate risk reductions based on the selected controls, helping to significantly reduce potential for errors in risk assessment and control selection.

In addition, VelocityEHS Incident Management software provides comprehensive injury and illness recordkeeping capabilities including powerful reporting and data dashboard tools that allow you to quickly access and reference the incident data you need to help you refine your JSA risk assessments. With a more accurate, standardized, and informed view of job task risks in your workplace, you’ll be able to put the right controls in place to protect your workers and manage risks to the greatest extent possible. From there, you can also utilize our Audits and Inspections software to schedule, assign, and perform regular follow-ups to verify that controls prescribed in the JSA are in place and performing as expected.

Click here to request a demo today and see first-hand how VelocityEHS JSA software can help you give your JSAs a serious upgrade.

The post Standardizing JSA Risk Assessment Criteria appeared first on VelocityEHS.

In all my research and study of OSHA workplace standards over the years, I’ve yet to come across a specific requirement that employers must apply and document a job safety analysis (JSA) to comply with an OSHA standard. In fact, you don’t really see any references to JSAs within the text of OSHA’s volume of occupational safety and health standards. At the same time, OSHA points to job safety analysis as an essential tool for hazard recognition and control, worker safety training, and communicating safe work practices—all of which ARE core requirements at the heart of numerous OSHA standard requirements. In other words, JSA is integral to compliance with many aspects of a broad range of OSHA standards and is therefore a valuable tool that every safety professional should be using and improving on a regular basis.

If you’re a safety professional, you’re probably familiar with JSAs but might not be as familiar with how you can apply the information and findings they provide to address, document, and verify compliance with various OSHA requirements. If you’re not familiar with JSAs, here’s some quick background.

What is Job Safety Analysis?

There are numerous definitions of job safety analysis out there but at its core, JSA can be simply described as a “systematic method for identifying, assessing, and controlling job task hazards and risks.” It involves a six-step process that goes as follows:

1. Job selection
2. Job task breakdown
3. Task hazard identification
4. Task risk assessment
5. Identification and implementation of controls
6. JSA review

The ultimate output of a JSA is a detailed list of individual job tasks, recognized hazards of each job/task, the corresponding risk level of each hazard (usually in the form of a qualitative or semi-qualitative risk assessment), specific hazard controls required to minimize those risks, and an assessment of the control effectiveness for each recognized hazard. The completed JSA might look a little something like this:

Sounds simple, right? While the process for documenting JSAs is a relatively straightforward exercise, there are many nuances that safety professionals and other members of your JSA team should be aware of to obtain the most accurate JSA information possible.

For more information on JSA techniques and best practices, view our on-demand webinar “Job Safety Analysis: Facts & Myths.”

How Can Job Safety Analysis (JSA) Help with OSHA Compliance?  

There are nearly 1,000 distinct OSHA standards covering employers and jobs performed across the construction, maritime, agriculture and general industries, each with very specific and often prescriptive requirements. However, I would argue that all these standards have three common essential objectives: hazard recognition and control, worker safety training, and ensuring safe work practices. I would also argue that JSAs provide an ideal tool for performing and achieving all three of these objectives.

Hazard Recognition & Control

At the end of the day, safety is all about risk management – identifying hazards, evaluating the risks, and applying the most effective risk controls. This concept is the core of safety and underlies numerous OSHA standards:

Respiratory Protection Standard 1910.134(d)(1)(iii) – “The employer shall identify and evaluate the respiratory hazard(s) in the workplace; this evaluation shall include a reasonable estimate of employee exposures to respiratory hazard(s) and an identification of the contaminant’s chemical state and physical form. Where the employer cannot identify or reasonably estimate the employee exposure, the employer shall consider the atmosphere to be IDLH.”

Respirable Crystalline Silica 1926.1153(d)(2,3) – “The employer shall assess the exposure of each employee who is or may reasonably be expected to be exposed to respirable crystalline silica at or above the action level in accordance with [1926.1153(d)(2)(ii, iii)]. The employer shall use engineering and work practice controls to reduce and maintain employee exposure to respirable crystalline silica to or below the PEL, […]”

Personal Protective Equipment 1915.152(b) – The employer shall assess its work activity to determine whether there are hazards present, or likely to be present, which necessitate the employee’s use of PPE. If such hazards are present, or likely to be present, the employer shall […]”

Hazard Abatement Verification1903.19 –  “The employer must inform affected employees and their representative(s) about abatement activities covered by this section by posting a copy of each document submitted to the Agency or a summary of the document near the place where the violation occurred.”

The list of standards rooted in the fundamental risk management process of identifying, assessing, controlling, and communicating workplace hazards goes on and on, and job safety analysis (JSA) offers an excellent tool for performing, documenting, and communicating every stage of this process.

Worker Safety Training

Safety training is also woven into nearly all OSHA standards, with more than 60 individual subparts of 29 CFR containing specific safety training requirements. At their core, however, all these requirements have a common purpose – to ensure workers have the training necessary to recognize hazards and work safely and ensure employers can demonstrate that they have provided that training.

Click here for more detailed information about Training Requirements in OSHA Standards

JSAs provide an ideal tool to identify training needs and corresponding training requirements, assign required training to the workers who perform the jobs being reviewed, and verify that required training has been completed.

For example, let’s say a worker needs to perform maintenance on a conveyor system in a food manufacturing facility. To repair the conveyor, the worker needs to shut down and isolate the conveyor system at the main control panel and potentially other isolation points, remove machine guards, and potentially risk exposure to unexpected release of hazardous mechanical or electrical energy.

This scenario would most definitely require a lockout/tagout (LOTO) procedure and trigger the requirements of the OSHA LOTO standard, including requirements to train workers on LOTO procedures and the function of the workplace LOTO program. In this example, compliance with the LOTO standard requires identifying what job task hazards are present, determining which tasks involve hazardous energy and are therefore covered under the OSHA LOTO standard, and satisfying any LOTO training requirements that are applicable to those job tasks. Because the JSA process is all about breaking a job down into tasks to better identify and control associated risks, it can help employers ensure that they don’t miss these kinds of job-critical training responsibilities.

This same basic process of job task hazard identification and delivery of required training is common to all OSHA training requirements. Fortunately, JSA provides a user-friendly format to identify applicable regulatory requirements, assign required training activities accordingly, and verify training compliance as you would with any other control prescribed under applicable OSHA standards.

Safe Work Practices

JSAs offer an excellent tool for safety professionals to identify training requirements and deliver required training to ensure compliance, but simultaneously provide an ideal format to communicate work instructions and safe work practices to employees. Remember, at a fundamental level a JSA is intended to break down a job task-by-task, identify the hazards present, specify necessary hazard controls, and spell out step-by-step instructions for how to perform each job task safely. This is an essential component of worker safety, which is why many OSHA standards contain requirements for employers to develop and communicate safe work practices to workers, including:

29 CFR 1910.333 Subpart S covering safe work practices in performing electrical installation and maintenance specifies that employers must develop and implement safety-related work practices “to prevent electric shock or other injuries resulting from either direct or indirect electrical contacts, when work is performed near or on equipment or circuits which are or may be energized. The specific safety-related work practices shall be consistent with the nature and extent of the associated electrical hazards.”

29 CFR 1926.502(k) covering fall protection systems criteria and practices establishes requirements for employers to develop and implement a fall protection plan that communicates fall protection measures applied in the workplace, identification of workers performing jobs where uncontrolled fall hazards are present, any changes to fall protection systems and hazards in those areas, and requires that “In the event an employee falls, or some other related, serious incident occurs, (e.g., a near miss) the employer shall investigate the circumstances of the fall or other incident to determine if the fall protection plan needs to be changed (e.g. new practices, procedures, or training) and shall implement those changes to prevent similar types of falls or incidents.”

29 CFR 1910.119 “Process safety management of highly hazardous chemicals” contains multiple requirements for development and communication of safe work practices including 1910.119(f)(4) stating that “The employer shall develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. These safe work practices shall apply to employees and contractor employees.” The standard continues at 1910.119(g)(1)(i) stating “Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, shall be trained in an overview of the process and in the operating procedures as specified in paragraph (f) of this section. The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee’s job tasks.”

1910.119(h)(2)(iv) “The employer shall develop and implement safe work practices consistent with paragraph (f)(4) of this section, to control the entrance, presence and exit of contract employers and contract employees in covered process areas.”1910.119(l)(5) “If a change covered by this paragraph results in a change in the operating procedures or practices required by paragraph (f) of this section, such procedures or practices shall be updated accordingly.”

1910.119(o)(1) “Employers shall certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed.”

There are numerous other OSHA standards requiring employers to develop and communicate safe work practices to workers, and JSAs offer an ideal means of doing so. I recently spoke at the 2024 Wisconsin Safety Conference and met with an attendee who approached me at the end of my session to share how they use their JSAs as a tool to communicate safe work practices to their workers. Basically, they print out their JSAs and post them at each corresponding workstation where each job is performed. In practice, the JSAs are used as an instruction manual for workers to operate that equipment and perform those jobs safely. I complimented the attendee that I thought this was an excellent use of their JSAs since in many cases they are often simply filed away, never really put to use, and rarely updated.

However, our conversation soon shifted to what systems their organization had in place to update their JSAs when new job task hazards are recognized, how those newly recognized hazards are communicated and controlled, how JSA safe work practices can be scaled across similar jobs and across multiple locations, and ultimately how those learnings are incorporated into safe work practices. That’s really the point where a paper-based JSA format fails. After all, if a JSA is inaccurate or incomplete and the true hazards of the job are not addressed within it, that job presents uncontrolled risks to workers.

JSA Brings it All Together

I’m a firm believer in the utility and value of JSAs as a tool for OSHA compliance. They’re a practical and valuable tool for inventorying applicable compliance requirements for each of the jobs performed in your workplace, documenting compliance with corresponding training requirements, and providing step-by-step safe work instructions in an easy to understand format to workers. In addition to all of that, they are a collaborative exercise in safety that provides an excellent opportunity to engage workers and other stakeholders in your safety program.

At VelocityEHS, one of the biggest barriers we hear about when talking to safety professionals is that most are still using paper-based systems to perform and document their JSAs. This imposes significant and unnecessary limitations when it comes to getting the greatest value from your JSAs, primarily because paper-based JSAs are, by their nature, static documents. A JSA should be a dynamic, living document that is easily communicated, responsive to the changing nature of training requirements and job hazards, and provides an easily accessible resource for workers to understand how to perform their jobs safely. With the right systems for managing your JSAs, you can realize all of the benefits that JSAs can provide to your safety and risk management programs and get the greatest value from them.  

VelocityEHS can Help!

Risk management is the most fundamental purpose of any workplace safety program and our Operational Risk solution has the capabilities you need to do JSAs right. You get centralized, enterprise-wide visibility of your JSA processes to help you easily monitor hazards and control activities, standardize your risk assessment and scoring criteria, and take the guesswork out of JSAs with access to a consolidated control library that allows you quickly select the right controls for the jobs being reviewed. Most importantly, you’ll have the insights you need to assess performance and prioritize your workplace safety improvement efforts.

If you’re looking for a system to help you implement and coordinate a world-class safety program built around continuous improvement principles, we can help you there, too. Our Safety Solution gives you the support you’re looking for, with intuitive capabilities for inspections, audits, safety observations, incident investigations, safety meetings, compliance management, corrective actions, safety performance tracking and reporting, and much more.

Contact us today to learn more about how we can help you get the most from your JSAs and help you build a safer and more sustainable workplace.

The post Job Safety Analysis (JSA): The Essential OH&S Compliance Tool appeared first on VelocityEHS.

by Phil Molé, MPH

EHS professionals are always seeking out ways to improve their workplace safety management programs, and implementing a safety management software system represents a major milestone along that journey. Good safety software simplifies key tasks such as safety data sheet (SDS) management, completion and tracking of inspections, incident investigations, training, and management of follow-up actions while reducing the time, effort, and resources required to effectively manage workplace safety. Unfortunately, many EHS professionals fail to make the most of their safety software purchase because they overlook the fundamental connection between safety and risk management and how operational risk management techniques like job safety analysis (JSA) can equip them with insights that drive greater levels of safety performance. The EHS professionals who think about JSA software stand to gain significant advantages and benefits.

In what follows, we’ll discuss why organizations looking to implement safety software should also think about JSA software capabilities to capitalize on those insights and get the most from safety software.

Operational Risk Management is the Foundation of Safety Management

Everything EHS managers do really comes down to managing and controlling risk. A brief distinction between two often confused terms, hazards and risks, will help to illustrate this point.

First, remember that “hazards” and “risks,” while often used interchangeably, have very different meanings. “Risk” describes the potential likelihood of something bad happening, coupled with the expected severity of outcome if it happens. A “hazard” is a condition that leads to risks and can be a physical factor you can see (e.g., chemical storage areas, equipment with dangerous exposed parts that can cut or strike an employee), an operational factor like prioritizing production goals at the expense of safety, or a human factor like hazard perception, stress, or fatigue.

These categories of hazards can interact and mutually reinforce each other. For example, operational factors such as long work shifts and a solitary focus on production goals can lead to human factors such as exhaustion and decreased awareness of risks.

The chart below shows some examples of hazards, associated risks, and potential risk outcomes.

As you can see from this discussion and the chart above, the underlying reason for safety incidents such as occupational injuries and illnesses is the presence of hazards that cause risks. The job of an EHS professional is to identify and address these hazards and implement appropriate controls to reduce the likelihood of an incident or injury happening and/or reduce the potential impacts if they happen.

Many Safety Management Tasks Are About Risk Management

When you reflect for a moment, you’ll see that all your safety management activities are, at their foundation, risk identification and control activities. For example:

Inspections

Why do you conduct inspections? Well, you might answer because some inspections are required for compliance with workplace standards and regulations such as inspections for hazardous waste storage locations, inspections of powered industrial trucks (PITs) such as forklifts, or inspections of fire suppression systems and other emergency response equipment. Other inspections may be required by internal management policies, by manufacturers’ specifications, or are just common-sense aspects of safety management, such as ensuring that walkways are unobstructed.

However, there are deeper objectives to inspections beyond simply checking a box. In the US, OSHA requires employers to inspect their PITs precisely because failing to inspect your PITs makes an incident more likely to occur, due to equipment failure such as loss of hydraulic pressure that can result in a falling load and potentially serious injury or death. When you conduct your inspections, you’re really looking to identify hazards so they can be addressed before the worst happens – i.e., to reduce the risk of adverse outcomes.

Incident Investigations and Reporting

This category may have a little less obvious of a foundation in risk management because, by definition, you conduct an incident investigation after an incident such as an occupational injury, a first aid incident or a serious “near miss” or “close call” happens. So, it’s important to reflect on the underlying reason why you’re doing the investigation and filling out the required forms. It’s not just a bookkeeping exercise. You’re trying to gather information about the underlying reasons, or root causes, why the incident happened so that you can address those causes and prevent the incident from recurring. That’s why, for instance, OSHA designed Form 301(“Injury and Illness Report”) to capture very specific details about why and how the incident happened, as the screen capture below shows.

Employers covered by the OSHA Injury & Illness Recordkeeping Standard need to complete Form 301, including the fields shown above, within 7 days of learning that a recordable injury or illness happened. Employers not covered by the Standard should have a process for mapping out the causes of a serious incident, so that the employer can have the information they need to identify and control the associated risks.

Safety Meetings

There are many reasons for having safety meetings, and many different teams or stakeholders who may be involved in them. Meetings build employee engagement (an important aspect of safety management, as you’ll soon learn more about) and give you a chance to share details about safety performance with your people, and to hear from them, in turn. But what’s the endgame? You’re using safety meetings to find out about things that you, as an employer, need to know to manage safety effectively. Specifically, you’re finding out about risks, as employees share details of unsafe conditions in their work areas, so that you can then gather additional information about the issue and then develop and implement appropriate risk controls.

Employee Engagement is Central to Safety and Risk Management

As mentioned above, employee involvement in safety management is an important ingredient for success. Even so, many companies historically have failed to provide their people with direct opportunities to contribute to key safety tasks. This fails to utilize the diversity of their knowledge, experience, and skills, while simultaneously saddling EHS managers and perhaps a small safety team with the bulk of the workload. This situation isn’t fair for anyone involved (or not involved) and greatly increases the likelihood that major workplace risks will go unidentified and uncontrolled.

It’s precisely because of considerations like these that the developers of ISO 45001, the international standard for occupational health & safety (OH&S) management emphasizes the importance of involving all employees in safety management. Section 5.4 of 45001 states:

“The organization shall establish, implement and maintain a process(es) for consultation and participation of workers at all applicable levels and functions, and, where they exist, workers’ representatives, in the development, planning, implementation, performance evaluation and actions for improvement of the OH&S management system.”

Section 5.4 goes on state that the organization needs to emphasize the consultation and participation of non-managerial workers, the group most often excluded from involvement in safety management tasks, and lists some of the specific activities they should participate in, including:

1. identifying hazards and assessing risks and opportunities;
2. determining actions to eliminate hazards and reduce OH&S risks;
3. determining competence requirements, training needs, training and evaluating training;
4. determining what needs to be communicated and how this will be done;
5. determining control measures and their effective implementation and use; and
6. investigating incidents and nonconformities and determining corrective actions.

As you can see from the above list, some of the management areas where the developers of ISO 45001 expect to see frontline employees involved are areas involving risk assessment and control. It turns out that a risk assessment method known as a job safety analysis (JSA) is, by its very nature, a perfect tool for assessing and controlling risks and promoting employee engagement in the process.

JSAs Are an Integral Part of a Robust, Proactive Safety Management System

A JSA, also sometimes referred to as job hazard analysis (JHA), is a way of identifying occupational hazards and appropriate controls to reduce the risk of injuries and illnesses. It involves breaking down work into job tasks and paying close attention to employees as they perform the tasks, use tools, and interact with the work environments. Once hazards are identified, you can then initiate corrective actions to reduce risk.

The effectiveness of JSAs (when done right) is widely recognized among EHS professionals and regulators, alike. This includes US OSHA, who’ve published extensive guidance on their use. In this guidance, OSHA concludes that employers can use JSAs to “eliminate and prevent hazards in their workplaces,” resulting in “fewer worker injuries and illnesses; safer, more effective work methods; reduced workers’ compensation costs; and increased worker productivity.”

To complete JSAs, employers need to follow these steps:

• Involve employees: Determine which employees should be involved in the process of creating the JSAs, based on their job functions and familiarity with the specific tasks.
• Review incident records: Identify which areas and associated jobs have the highest injury rates, and especially the highest rates of severe injuries leading to restricted duty or days away from work. Use this analysis to prioritize which jobs need JSAs.
• Preliminary job review: Work with the employees you selected to discuss the hazards they know to exist and ideas for controls to address the risks. Then use this information to further prioritize jobs to focus on.
• Outline the job tasks: Once you have prioritized your jobs based on risk and have an idea where to start, break the job down into several distinct tasks. The idea is to have enough tasks broken out to be able to accurately identify hazards or risks at each step, but not so many that the job becomes overwhelming. Then, describe the controls currently in place, or the additional controls needed to reduce risks to acceptable levels.

JSAs are only effective when employees participate in the process (as intended), allowing EHS professionals to capture important direct experiences and expertise about the tasks involved, their associated risks, and the controls needed to reduce likelihood of accidents and injuries. The process of completing JSAs with employee involvement will foster even more of the kind of “consultation and participation” that ISO 45001 maintains is important for better safety performance.

Think About JSA Software to Get the Most Out of Your JSAs!

Many EHS professionals already know about JSAs and have completed them at some point. However, completing JSAs and getting the most out of JSAs are two different things. Arguably, most EHS managers aren’t doing as much as they can to use their JSAs to improve workplace safety, because they don’t have the right tools. Luckily, operational risk software can help them overcome the limitations of paper and legacy desktop applications.

Here are some of the reasons that you should think about JSA software, and the ways that the software can improve your insights into workplace hazards and reduce risks for your people.

Think About JSA Software to Improve Accuracy

Theoretically, JSAs offer the potential to improve accuracy of your assessment and control of workplace risks, especially because the exercise of breaking a job down into tasks facilitates better identification of risks associated with different points in the job, and it improves likelihood that you’ll be able to choose and implement effective controls. In practice, a lack of standardization in the JSA process itself leads to variability, particularly in the area of risk scoring and assessment, and decreases the reliability of the results. Adding to these challenges, many EHS professionals completing JSAs lack an extensive background in operational risk management, and so they may have uncertainty regarding selection of controls, or determination of the risk reduction factor associated with a specific control.

Think about JSA software so you can overcome these challenges by offering a standardized methodology for conducting JSAs, so your people do them the same way – and the right way – every time. Even better, the best operational risk software enables you to select appropriate controls for identified risks from a drop-down menu, applies industry-standard risk reduction factors, and then automatically calculates risk reduction based on the selected controls. As a result, you’ll significantly reduce potential for errors from selection of risk controls or calculation of risk reduction. That’s a great reason why you should think about JSA software. You won’t have to be an operational risk management expert anymore to do your JSAs like an expert, because expertise is built into the software.

Think About JSA Software to Encourage Better Participation in Safety Management

Recall that ISO 45001 places a premium on “consultation and participation” of frontline workers. Unfortunately, too often the process of developing JSAs is a classic example of how not to encourage employee engagement with safety management. There are many cases in which a person or two from the company’s EHS department completes the JSA, perhaps with involvement of a consultant, the department supervisor, and/or a high-level facility manager. What’s missing in this common scenario is the direct involvement of the frontline workers who regularly perform the job being analyzed and are the most familiar with its risks, and who likely have valuable insights about the controls that should be applied.

One reason the JSA development process often excludes frontline workers is the methodology used. For instance, JSAs existing only on paper or desktop applications are timebound and more physically inaccessible (a point you’ll revisit soon!), and it just isn’t as easy for multiple employees to share responsibility and contribute. Since the JSA document itself is usually just a form providing no additional guidance, employees often don’t have the support they need to know how to effectively complete the JSA, and awareness of that lack of support can be disincentivizing.

On the other hand, operational risk software democratizes the JSA process by letting employees access and participate in the process from anywhere, using a tablet or their mobile device. It lays out an intuitive stepwise methodology with prompts to guide employees through the process so they understand how to best complete the JSA. Another benefit is that it’s easier to share the completed JSAs and associated activities (e.g., implementation of controls) with employees to show them that their participation has had real results in the form of job safety improvements, which engages workers and makes their future participation more likely. Think about JSA software so you can boost participation in risk identification and control.

Think About JSA Software to Make Your JSAs Accessible

Earlier, when reading about the purpose of JSAs, you learned that JSAs are supposed to provide accurate information about risks and controls associated with different tasks within a specific job to inform safe work practices.

EHS management often fails to capitalize on these intended benefits because their JSAs are inaccessible. Anyone who’s had the chance to review JSA management practices at many facilities has most likely seen this effect. Paper JSAs are stashed in a file cabinet somewhere, gathering dust, and once retrieved, they turn out to be long out-of-date. The same is often true of electronic JSA files sitting dormant in a virtual folder on a computer desktop – not many people access them, or even know how to access them.

The best operational risk software solves these problems by making your JSAs accessible from anywhere on either desktop or mobile devices via the cloud. As a result, you and your people can use the JSAs as guidance for working safely. Not to mention, if any significant changes in your job processes occur that affect either the way you need to perform the job tasks or the effectiveness of your associated risk controls, you can easily revise the JSA and reshare the updated document with your people.

Software Provides Enterprise-Level Insights into Risk Trends

A related challenge with JSAs often being manual and inaccessible is that, quite often, it’s very labor intensive and time consuming to extract actionable information out of them.

With operational risk software, you can easily get the information you need to assess and improve your safety performance. Dashboards will help identify trends in types of hazards across your facilities, so you can get the enterprise-level view of risk patterns you need for better decision making. Think about JSA software. You’ll also be able to verify that risk controls are in place and working as planned.

Let VelocityEHS Help!

Our Operational Risk solution has the capabilities you need to do JSAs right. You get a JSA template configured to your organization’s needs and enterprise-wide visibility of hazards and control activities to help minimize data inconsistencies and monitor the effectiveness of control measures. You’ll also take the guesswork out of control selection for you and your people through access to a control library that has standardized controls and associated risk reduction factors, and automatic calculation of risk reduction based on application of selected controls. Most importantly, you’ll have the insights you need to assess performance and prioritize your workplace improvement efforts.

If you’re looking for just the right safety software, we can help you there, too. Our Safety Solution gives you just the support you’re looking for, with 24/7 access to electronic SDSs from anywhere, easy completion of inspections and incident investigations using a mobile device, seamless initiation, prioritization and tracking of follow-up actions, and much more.

Contact us today to learn more about how we can help you get the most from your JSAs and help you build a safer and more sustainable workplace.

The post Thinking About Safety Management Software? Think About JSA Software, Too appeared first on VelocityEHS.

We’ve come to the final installment in our VelocityEHS Blog Series on OSHA’s Top 10 Most Frequently Cited Standards for 2022, where we’ll discuss number ten on the list, the OSHA Machine Guarding Standard. Don’t let the tenth-place ranking fool you. Machine hazards are severe, often resulting in serious injury, amputation, and even death.

Here, we’ll take a closer look at OSHA’s Machine Guarding Standard, including the most commonly cited provisions of the Standard, key enforcement initiatives and directives you should have on your radar, along with best practices and tools you can use to simplify and strengthen compliance.

OSHA’s Machine Guarding Standard Requirements: A Persistent Compliance Challenge for Employers

In case you missed the list, here’s a quick recap of OSHA’s Top 10 Most Frequently Cited Standards for FY 2023:

1. Fall Protection – General Requirements (1926.501): 7,271 violations
2. Hazard Communication (1910.1200): 3,213 violations
3. Ladders (1926.1053): 2,978 violations
4. Scaffolding (1926.451): 2,859 violations
5. Powered Industrial Trucks (1910.178): 2,561 violations
6. Lockout/Tagout (1910.147): 2,554 violations
7. Respiratory Protection (1910.134): 2,481 violations
8. Fall Protection – Training Requirements (1926.503): 2,112 violations
9. Personal Protective and Lifesaving Equipment—Eye and Face Protection (1926.102): 2,074 violations
10. Machine Guarding (1910.212): 1,644 violations

OSHA’s Machine Guarding Standard has consistently ranked among the Top 10 Most Frequently Cited Standards for years, and it’s important to think about why. One potential root cause is the surprising brevity and arguably intentional vagueness of the Machine Guarding Standard. The entire body of text of the Machine Guarding Standard is just 388 words, and that includes the section numbers, and yet it is so critical in protecting workers from machine hazards.

We say the Machine Guarding Standard is intentionally vague because we believe OSHA anticipated the applicability of the Standard to a virtual universe of machine types and configurations used in the industry. Similar to its Control of Hazardous Energy Standard (Lockout/Tagout), the Machine Guarding Standard was written broadly enough to cover as great a variety of machine types and configurations as possible, including those yet to be designed or invented. As a consequence of this vagueness, there continues to be a great deal of confusion among employers as to how to apply the Machine Guarding Standard, and how to ensure compliance. In fact, OSHA has published 152 Letters of Interpretation (LOIs) since the original Standard was published in 1973, with each LOI addressing specific employer questions and concerns regarding the specifics of compliance. Despite this ongoing confusion and the continuing evolution of industrial operations and technologies, OSHA is not formally considering any updates to the Machine Guarding Standard as of its recently published Fall 2023 Regulatory Agenda.

OSHA Machine Guarding Standard Enforcement

As we mentioned in the first installment of our blog series, OSHA’s Fall Protection Standard was, by far, the most frequently cited OSHA Standard in 2023. While it is last on OSHA’s Top 10 List, the OSHA Machine Guarding Standard is certainly not least. If you look at the total numbers of violations cited under the OSHA Machine Guarding Standard relative to others on the Top 10 list, there’s not a great difference among OSHA’s Powered Industrial Trucks, Fall Protection Training Requirements, and Personal Protective and Lifesaving Equipment—Eye and Face Protection Standards, meaning it remains a strong priority for OSHA’s enforcement efforts.  

This is supported by the fact that OSHA is currently pursuing two separate National Emphasis Programs (NEPs) aimed specifically at addressing machine hazards. These include:

• OSHA Instruction – CPL 03-00-026 – National Emphasis Program on Warehousing and Distribution Center Operations – 07/13/2023 – PDF
• OSHA Instruction – CPL 03-00-022 – National Emphasis Program on Amputations in Manufacturing Industries – 12/10/2019 – PDF

OSHA also establishes numerous Regional Emphasis Programs (REPs) across the US, many of which are focused, at least in part, on addressing machine hazards and Machine Guarding Standard enforcement. Examples include:

• Region 1 – CT, ME, MA, NH, RI, VT
  • CPL-04-00-026 – Local Emphasis Program for the Seafood Processing Industry – PDF
• Region 4 – AL, FL, GA, KY, MS, NC, SC, TN
  • CPL 23/09 (CPL 04) – Regional Emphasis Program (REP) for Poultry Processing Facilities – PDF
  • CPL 23/10 (CPL 04) – Regional Emphasis Program (REP) for Safety Hazards in Auto Parts Industry – NAICS 3363XX (Motor Vehicle Parts Manufacturing) – PDF
• Region 5 – IL, IN, MI, MN, OH, WI
  • CPL 04-05-2304 – Local Emphasis Program for the Wood Pallet Manufacturing Industry – PDF
  • CPL 04-05-2306 – Regional Emphasis Program for Food Manufacturing Industry – PDF
  • CPL 04-05-2301 – Regional Emphasis Program for Grain Handling Facilities – PDF
• Region 6 – AR, LA, NM, OK, TX
  • CPL 2 02-00-028B – Regional Emphasis Program for Grain Handling Facilities – PDF
• • CPL 2 02-00-030B – Regional Emphasis Program for Poultry Processing Facilities – PDF
• Region 7 – IA, KS, MO, NE
  • CPL 02-11-03J – Kansas Local Emphasis Program (LEP) for Grain Handling Facilities – PDF
  • CPL 2-13-001I – Nebraska Grain Handling Industry Local Emphasis Program (LEP) – PDF
  • CPL 02-16-05E – Nebraska Local Emphasis Program (LEP) for Meat Processing Industries – PDF
• Region 8 – CO, MT, ND, SD, UT, WY
  • CPL 20-06 (04-01) – Regional Emphasis Program for Automotive Services – PDF
  • CPL 20-03 (04-01) – Regional Emphasis Program for Grain Handling Facilities – PDF
  • CPL 23-01 – Regional Emphasis Program for Wood Manufacturing and Processing Facilities – PDF
  • CPL 2022-01 – Regional Emphasis Program on Silica in Cut Stone and Slab Handling – PDF
• Region 9 – AZ, CA, HI, NV, and American Samoa, Guam and Northern Mariana Islands
  • CPL 04-09-2401 – Regional Emphasis Program on Amputations – PDF
• Region 10 – AK, ID, OR, WA
  • 21-05 (CPL 04) – Local Emphasis Program for Inspections in the Grain Handling Industry – PDF

OSHA’s current NEPs and REPs targeting Machine Guarding Standard compliance and enforcement, span a wide range of industry types, but if we look at the most recent enforcement numbers for FY 2023, we can see that the vast majority of citations (80% of 1,638 total violations in 2023) were given to employers in the manufacturing industries (NAICS 31-33).   

Analyzing OSHA’s Most Cited Machine Guarding Standard Provisions

Of the 1,644 violations cited under OSHA’s Machine Guarding Standard in FY 2023, here are the five most commonly cited provisions of the Standard:  

1. 1910.212(a)(1): “Types of guarding. One or more methods of machine guarding shall be provided to protect the operator and other employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips and sparks.” –1,089 violations
2. 1910.212(a)(3): “Point of operation guarding.” –402 violations
3. 1910.212(a)(2): “General requirements for machine guards. Guards shall be affixed to the machine where possible and secured elsewhere if for any reason attachment to the machine is not possible. The guard shall be such that it does not offer an accident hazard in itself.” –60 violations
4. 1910.212(b): “Anchoring fixed machinery. Machines designed for a fixed location shall be securely anchored to prevent walking or moving.” –57 violations
5. 1910.212(a)(4): “Barrels, containers and drums. Revolving drums, barrels and containers shall be guarded by an enclosure that is interlocked with the drive mechanism, so that the barrel, drum or container cannot revolve unless the guard enclosure is in place.” –13 violations

If we look at the numbers, we find that the five most common violations here account for 98% of all violations of OSHA’s Machine Guarding Standard.

The Costs of Non-Compliance

Penalties for violations of OSHA’s Machine Guarding Standard (and all OSHA Standards) can quickly pile up, with a single inspection or workplace injury often resulting in multiple citations. That’s because in addition to OSHA’s continuing focus on machine hazards and strong enforcement of Machine Guarding Standard requirements, OSHA announced earlier this year that it would expand the application of “Instance by Instance” (IBI) citations.

Employers should also be conscious of the fact that federal civil penalties for non-compliance with federal regulations have gone up in 2023…way up. In January, OSHA published their 2023 annual civil penalty adjustments as required under the Federal Civil Penalties Inflation Adjustment Act of 2015. Under the Act, all federal agencies are required to revise and publish their schedule of civil penalties based on the previous year’s rate of inflation, which is calculated based on the US Bureau of Labor Statistics Consumer Price Index for all Urban Consumers (CPI-U). 2023 federal civil penalty adjustments are based on a published Consumer Price Index (CPI-U) multiplier of 1.07745.In other words, all federal fines and penalties for non-compliance went up by 7.7%—roughly equal to the average rate of inflation faced by all consumers in the US during 2022.

January 2024 will bring new annual inflation-adjusted penalty increases across OSHA and all federal agencies, and even though rate of inflation in the US has contracted significantly compared to 2022, preliminary CPI figures from the BLS for November 2023 place that number around 3.1%, and the reference point agencies will use to calculate 2024 inflation adjustments will likely be around this amount.

Machine Guarding-Related Injury & Illness Statistics: The Human Costs

The financial penalties for non-compliance with OSHA’s Machine Guarding Standard can certainly damage your business’ bottom line, as well as its reputation in the eyes of customers, partners, investors, and other stakeholders. Sadly, it’s all too easy to overlook the cost to your business’ most important resource…your workers. Great companies focus on protecting the safety and health of their workers and the physical and mental costs of failure to do so, rather than worrying about the regulatory risks and compliance costs of OSHA Machine Guarding Standard violations.

The monetary costs of these injuries are difficult to quantify, but OSHA’s Safety Pays calculator allows us to calculate estimated costs of a wide range of occupational injury and illness types. For example, a simple laceration that can be caused by improper or faulty machine guarding is estimated to have direct costs of $21,872 and indirect costs of $24,059 for a total of $45,931. That’s quite a lot for just a cut, and this estimate does little to account for the ongoing legal and workers’ compensation costs that could arise because of a potential disability and associated injury claims.

Machine Guarding Best Practices

Fortunately, OSHA’s enforcement data and enforcement priorities (vis a vis OSHA’s NEPs and REPs) allow us to see where some of employers’ greatest weaknesses lie and draw some general assumptions about what provisions of the OSHA Machine Guarding Standard employers should focus on to help strengthen the compliance of their own machine guarding programs.

Unlike a lot of other Standards on OSHA’s Top 10 List of Most Frequently Cited Standards, the OSHA Machine Guarding Standard is primarily directed at the design features and specifications of machines and machine guarding devices, and has little to say about training, inspection, or other personnel-related requirements as many other OSHA Standards. In that way, the Machine Guarding Standard is primarily a technical standard. Therefore, verifying that machine hazards are identified and assessed, and that sufficient/compliant machine guarding devices and machine hazard controls are installed are the fundamental basis of compliance.

Fortunately, there are several aspects of your existing safety management system that will be instrumental in performing these machine hazard assessments and control verification tasks. Here are a few to focus on:

Inspections

You need to establish inspection systems that allow you to identify inspection targets (i.e., machines and machine guarding devices) and schedule periodic and regular inspections for each individual target. This includes:

• Identifying the assigned/responsible inspector roles and personnel
• Verifying that inspectors possess the necessary knowledge, training, and qualifications to perform that inspection
• Developing inspection checklists for each machine/machine guard configuration and being able to integrate OSHA Machine Guarding Standard requirements and other regulatory/design requirements into those checklist criteria
• The ability to quickly report and respond to checklist discrepancies/non-conformances
• The ability to create and assign corrective actions for individual checklist discrepancies/non-conformances
• Visibility of inspection activities and performance to verify inspection programs and procedures are being implemented, and that they are effective

For additional information on inspection program management, check out our on-demand webinar “Beyond Checklists: A Systems-Based Approach to Inspection Program Management.”

Hazard Identification & Observations

Everyone throughout the workplace, especially machine operators, maintenance personnel, supervisors, and safety managers, should possess sufficient knowledge and training to identify machine hazards, and to identify non-compliance of machine guarding devices with OSHA Machine Guarding Standard requirements. They also require rapid, real-time ability to document and report these hazards, and to have visibility into the corrective action planning and implementation process to confirm that hazards are being identified, assessed, and controlled.

And it’s not just about identifying hazards. It’s also about observing employee behaviors, both safe and unsafe. Many machine guarding-related injuries occur because workers bypass functional machine guards so that they can clear the point of operation, perform some sort of quick maintenance or repair, or just to get the job done faster because of pressure from supervisors or managers. That’s never acceptable.

It’s the responsibility of the employer to provide comprehensive work instructions on how to clear jams or resolve other types of maintenance issues safely, and ensure workers are trained and knowledgeable in how to effectively operate machines and machine guarding devices. It’s also the responsibility of workers to remain vigilant and not think of observing unsafe actions or behaviors as “calling out” their co-worker but reporting an unsafe behavior that others might repeat in the future. Though they might get away with it unscathed this time, the next time could result in a life-altering injury. On the flip side of that coin, we also want to be capturing and documenting safe behaviors that help us better understand how to do things safely, and even recognize opportunities for how to be safer.

The key is being able to capture and report these hazards and behaviors and put them on the map so that safety managers and others can learn from them, and that means having a system to document them in real-time where and when they occur.

Task Hazard Assessment (THA)

THA is a type of pre-job inspection designed to evaluate job-specific hazards and ensure appropriate safety precautions, controls, operator training and qualifications, and other preventive measures are in place prior to beginning the job. THA is an invaluable method for machine operators to verify the proper function and design of machine guarding devices and should, ideally, be performed before every work shift to verify this. If they are not in conformance with the THA, operators should be reporting any unrecognized or insufficiently controlled hazards to responsible employees so corrective actions, including installation of sufficient machine guards or repair to existing controls, can be performed.

Also, if an operator identifies a faulty or insufficient machine guarding device, that worker (and all workers) should be clearly delegated with “stop work authority”. This authority strengthens the quality of your workplace safety culture. No worker should feel pressure to continue using a machine with recognized hazards, nor should they feel like they do not have the right to refuse unsafe work.  

Job Safety Analysis (JSA)

A JSA is a comprehensive job evaluation designed to fully assess and control hazards during the job design phase, and periodically thereafter. It involves breaking jobs down into individual tasks or steps and carefully analyzing potential hazards at each step that may be introduced by the tools, equipment, work environments, and work practices used. Once hazards are identified, risks are qualitatively evaluated, prioritized, and corrective actions are taken to manage individual hazards and risks.

You should perform JSAs prior to start-up of any machine in your workplace to clearly identify, assess, and implement effective machine design and hazard controls before work ever begins. The JSA should be readily accessible to operators and other potentially affected employees to provide clear guidance on the hazards of a given job and is also invaluable as a training tool for machine operators. You should periodically and regularly evaluate the JSA to ensure it fully addresses the hazards of the job, especially after you’ve made any alterations or modifications to the machine in question. Also, you should perform JSAs in collaboration with operators, supervisors, maintenance personnel, safety managers, and other impacted employees so you get a full perspective on the hazards presented by a given machine and given job.

For more information on how to optimize your hazard identification practices and programs, task hazard assessments, and JSAs, download our guide Hazard ID & Observation, Task Hazard Assessment (THA), & Job Safety Analysis (JSA).

For additional guidance on OSHA Machine Guarding compliance and safety best practices, check out OSHA’s Machine Guarding eTool.

Final Thoughts…

We hope you’ve enjoyed our VelocityEHS Blog Series on the OSHA Top 10 Most Frequently Cited Standards for 2023 and learned some valuable insights on how to not only improve compliance with OSHA Standards, but more importantly, protect the health and safety of your people. Follow us on LinkedIn and stay tuned to the VelocityEHS blog page for further information on the EHS topics that impact businesses like yours, and to learn how VelocityEHS can help you surpass your compliance challenges and achieve EHS & ESG excellence.

Simplify Compliance & Strengthen Workplace Safety with VelocityEHS

The Velocity Safety and Operational Risk Solutions, part of the VelocityEHS Accelerate^® Platform, offers EHS professionals full and flexible capabilities to meet every aspect of your safety management system needs. From inspections, Hazard ID & Observations, THAs, JSAs and much, much more, you’ll get a system that provides a rock-solid foundation for your management programs and help you ensure you have a full picture of the machine hazards and controls present in your workplace.

Check us out and Request a Demo today to learn how we can solve your safety management and compliance challenges.

The post OSHA’s Top 10 List of Most Frequently Cited Standards: Machine Guarding appeared first on VelocityEHS.

Recently, we hosted an essential webinar discussing “Integrating Risk Assessments for Effective Management of Change,” presented by Dana Garber, VelocityEHS Senior Product Manager for Operational Risk. This session explored the dynamic relationship between Management of Change (MOC) and Risk Assessments, highlighting the importance of an integrated approach between them to:

• Pair the right risk assessments with different change scenarios.
• Effectively manage multiple risk dimensions involved in changes.
• Apply lessons learned for continuous improvement.
• Enhance risk mitigation and decision-making.
• Contribute to organizational resilience.

What is the dynamic relationship between Management of Change (MOC) and risk assessments?

Management of Change (MOC) serves as the foundation for safely executing changes at an organization, while risk assessments are responsible for identifying and minimizing potential risks linked to those changes. Management of Change (MOC) and risk assessments work hand-in-hand to enable companies to adapt and innovate while minimizing potential hazards and disruptions.

What are the types of assessments used for different change scenarios?

The three fundamental categories of these change scenarios are process, design, and personnel or strategy changes.

• Process Changes: When implementing process changes, like a change in job, task, or procedure, it is essential to identify potential hazards that could occur. Regularly updating job risk assessments ensures that new hazards or risks will be appropriately addressed and resolved, and process changes open the door to potential unknown risks or could modify existing ones. Job risk assessments to complete may be JSAs, JHAs, or JRAs. It’s essential to understand the significance of updating job risk assessments with process changes, as it helps prevent potential accidents or incidents and ensures employees’ continued safety and well-being.
• Design Changes: To assess potential risks that can occur as a result of design modifications, utilize process hazard analyses (PHAs). While this can be a lengthy process with many stakeholders, the systematic approach of PHA allows organizations to identify and implement the appropriate controls and safeguards needed. Conducting PHAs helps organizations identify and mitigate risks in the early stages, overall reducing the likelihood of incidents and enhancing safety. Watch the webinar to see an example from the Chemical Safety Board of a catastrophic equipment rupture, explosion, and fire that resulted from poorly managed design and process changes.
• Personnel or Strategy Changes: Proposed personnel modifications or strategy changes should have a business risk assessment completed to evaluate potential risks to the organization’s overall risk profile, including operational, financial, and reputational risks. It’s important to consider the impact on the overall organization and to include the right people in the assessment, as specific jobs and tasks might be siloed.  

How can organizations effectively align Management of Change and risk assessments for ideal outcomes?

Organizations should focus on establishing clear communication channels, involving relevant stakeholders, and integrating appropriate risk assessments into the MOC framework. Moreover, creating standardized templates, defining clear roles and responsibilities, and fostering a risk-aware culture within the organization are critical elements for successful alignment.

How does integrating risk assessments with MOC ensure they’re completed in a timely manner?

By incorporating risk assessment milestones into the MOC process, you ensure that the risk assessments are conducted at the appropriate stages. This helps to keep people on track with assessments, which informs proactive decision-making and promotes effective risk mitigation strategies.

For more best practices on integrating risk assessment into your Management of Change framework, watch this webinar on demand now.

Elevate your Management of Change Process with VelocityEHS Operational Risk Solution Today!

The Management of Change (MOC) capabilities in the VelocityEHS Operational Risk Solution can help you streamline and verify your processes to reduce potential hazards associated with changes to your organization. With our MOC software, you’ll be able to easily maintain a record of changes and approvals, provide Management of Change program transparency, and maintain a clean audit trail with efficient tracking for each stage.

Be sure to attend more of our webinars on effective risk management. You can also learn more about Management of Change on our blog.

The post Webinar Recap – Integrating Risk Assessments for Effective Management of Change appeared first on VelocityEHS.

We recently hosted a webinar on the important topic of Integrating Psychosocial Risk Management with Process Hazard Analyses, presented by Dana Garber, VelocityEHS Senior Product Manager of Risk Management. This session broke down the big picture ideas of this concept, sharing:

• Data that shows how better understanding of risk controls reduces levels of workers’ self-reported work-related anxiety (the psychosocial risk)

• Where Process Hazard Analyses (PHA) outcomes can improve worker mental wellbeing and psychosocial risk

• Practical PHA tools that will improve personnel input and outputs in the PHA process

What Are Psychosocial Risks? 

Psychosocial risks are the organizational, management, and interpersonal aspects of the workplace that increase mental stress for employees. It also includes anxiety related to perceived risks at work, or to workers not being included in safety programs. The biggest contributing factors to psychosocial risks are a lack of visibility of safety data, no employee participation in safety tasks and not addressing specific employee risks and concerns.

What are some Important Facts About Psychosocial Risks? 

• Nearly one in three EU workers report that they are affected by stress at work.

• EU-OSHA poll shows ~50% of workers consider problems with work-related stress to be common in their workplace.

• It’s estimated that stress-related diseases are responsible for the loss of 6.5 million working days each year in the United Kingdom.

What is a Process Hazard Analysis (PHA)?

A PHA is an organized and structured approach to assess the potential hazards associated with a process. Process hazard analysis is intended to assist safety, risk and plant managers in making decisions needed to improve safety, such as by reducing the potential or impact of unplanned “loss of control” events such as chemical releases.

How Do PHAs Mitigate Psychosocial Risk?

Employee education and skill development are the two biggest ways to mitigate psychosocial risks. HAZOP and HAZID reporting is extensive and detailed, which can make PHA comprehension difficult for personnel. Developing communication strategies, ensuring that personnel feel confident in their tasks, and restricting any kind of observation program (monitoring employees completing tasks outside of training opportunities, thus adding to their anxiety) in the workplace will help employees gain a better understanding of the reporting from HAZOPs/HAZIDs.  

In the session, Garber also shares the importance of managing the personal work environment to not just remove/mitigate stressors (ambient noise, air quality concerns, ergonomic issues), but also to ensure that personnel understand what those hazards are and the impacts they can have.  

Ultimately, by addressing the psychosocial risks of a workplace, the organization will experience the key benefits of lower absenteeism rates, reduced benefits cost, lower incident and injury rates and a reduction in disability claims/rates. 

To see the conclusions of the session and learn more of the facts on integrating psychosocial hazards for yourself, watch the session on-demand from our resource library.  

The post Integrating Psychosocial Risk Management with Process Hazard Analyses – Webinar Summary appeared first on VelocityEHS.