Program Elements

You should note that there are consistent elements associated with each OSHA Voluntary Safety and Health Program. We will discuss these elements in more detail throughout the book [2]. 

We have chosen to use a combination of each voluntary program as discussed, because they are all similar. The bottom line is that an effective system will meet the following criteria no matter if it is OSHA mandated, a best management practice (BMP), or above and beyond compliance (ABC). They should look similar in content. 

OSHA has concluded that effective management of employee safety and health is a decisive factor in reducing the extent and severity of work-related injuries and illnesses. An effective management program addresses work-related hazards, including those potential hazards that could result from a change in workplace conditions or practices. In addition, it addresses hazards that are not regulatory driven [2]. 

OSHA encourages employers to implement and maintain a program that provides systematic policies, procedures, and practices that are adequate to protect employees from safety hazards. In other words, an effective system identifies provisions for the systematic identification, evaluation, and prevention or control of workplace hazards, specific job hazards, and potential hazards that may arise from foreseeable conditions. Compliance with OSHA standards is an important objective. However, if you develop a successful management system, this becomes a non-issue. 

Whether a safety program is in writing or not is less important than how effectively it is implemented, managed, and practiced. It should be obvious that as the size of the workplace, the number of employees, or the complexity of an operation increases, the need for written guidance will increase. The program should help to make sure that there is clear communication to all employees with consistent application of policies and procedures. 

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The HASP, on the other hand, foeuses on the site-speeifie aetivities and outlines the appropriate elements of the site s existing health and safety program to the related task. The existing programs are reviewed to identify those elements meeting the needs of the planned site aetivity. Program elements and proeedures are supplemented with worksite-speeifie detail and tailored to meet speeial or unique aspeets of the hazardous waste aetivity on an as-needed basis [1]. 

Not all existing procedures or program elements of the overall health and safety program need to be incorporated into the HASP. For example, if noise is a hazard, the plan does not have to cite the entire hearing conservation program. Procedures already established elsewhere may be referenced, as applicable. In another example, if a confined-space-entry procedure is required, the HASP could reference the particular procedure which is part of the overall program. The next step would be to identify confined spaces at the worksite where the procedure applies, and then provide appropriate implementation procedures (e.g., conditions to be monitored, evaluation of the space, issuance of an entry permit). If special operational procedures apply to the worksite, they can be attached to the HASP using an appendix. 

Amendments to the Clean Air Act require employer-employees consultation to develop and implement PSM program elements and hazard assessments. Section 304 requires employee training and education on the findings of PSM incident investigations. 

Relemnce to the PSM model selected. Whichever assessment tool or method you decide to use, it should reflect the PSM model you have selected for your compan)r s PSM program framework. This model of PSM program elements establishes characteristics for the goals you have selected for your PSM system, and provides a structure for the baseline assessment. For example, the CCPS PSM model comprises 12 elements, each of which should be assessed if you have selected this model. 

The level of effort estimates given in Exhibit 4-1 are for time used by the project team. Design time is an estimate of the number of person days that will be needed to develop a fully defined system program/element or management process starting with the data collected during the assessment phase. 

Management responsibility requires that each program, element or management process is overseen by a manager. This individual should take responsibility for putting improvement initiatives into motion. 

Facilities will need to iinpleinent a streamlined RMP. This category provides facilities witli substantial flexibility to address the specific program elements. 

An overall management system to put these program elements into... 

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