Site-Specific Safety Plan

I have studied this proposed rule and was disappointed when I observed that nowhere in the proposed rule are the terms JSA and site-specific safety plan mentioned. When you look at the description of how the employer is expected to maintain a safe and healthful work environment, however, both the site-specific safety plan and the JSA seem to be alluded to. The main body of this proposed rule is included in Appendix C of this book for your review. As previously stated, the OSHA guide to JSAs has been included as Appendix A of this book. 

Besides the general safety program, a site-specific safety plan is needed that provides the necessary details to ensure that the principles in the program are put to use. The plan should state the names of the individuals who are responsible to implement the work safely. The plan 

Now that we have discussed both the general safety program and the site-specific safety plan, let s look at some examples. 

A flowchart and other information to aid in determining that a space is a confined space 

Information to determine whether the confined space is permit required 

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Usually single scene Usually one substance Known or identified substance Not intended to cause harm Identifiable source and quantity Information available Site-specific safety plans in place Limited affected area0 Limited consequential disruption Generally few casualties0 Chemical effects likely to be main cause of injury... 

Because other sections of this Handbook deal more specifically with cleanup methods, policies, and detailed spill procedures, this section only emphasizes some key points related to adsorption cleanup. The safety, health, and environment department must prepare formal written procedures for all types of chemical spillage. The specification of sorbent type must be based on an expert analysis of the MSDS (material safety data sheet) for every chemical onsite. The manufacturers technical data or MSD sheets provide information for the site-specific safety plan, such as flash point, ignition temperature, solubility, toxicology, density, reactivity, and chemical compatibility. The written procedures must cover all chemicals on site and all possible spill scenarios, particularly What is the worst incident that could happen Prevention techniques must obviously be in place and emergency plan procedures carefully prepared and practiced. 

How are accident investigations handled Who handles them Are the results of these investigations revealed to the workers Does anyone learn from prior mistakes What changes have taken place to make the facility safer How does a team member know how to perform a job safely Is there a safety manual Does everyone who needs access to the safety manual have it Is there a site-specific safety plan for current work activity Who has access to this plan How about job safety analyses (JSAs) Have all of the work tasks been analyzed for safety concerns and appropriate safety systems been implemented What does a worker do after a close call Is there any investigation when no damage is done Is any report made out ... 

In a well-developed safety culture, there will typically be two types of documents used for planning field compliance a safety program (or general safety manual) and a site-specific safety plan. These two documents are sometimes intertwined and used interchangeably, even among safety experts, but these two documents are very different. These two key planning documents will aid in attaining safe work performance. 

Remember, the safety program is a general document that spells out the general safety principles by which a company operates. Some companies have a document called the safety manual. Depending on the contents of the safety manual, it may fit OSHA s definition for a safety program. Safety programs usually change less frequently than site-specific safety plans. We will see some examples of how these two types of documents interrelate later in this section. 

The site-specific safety plan will likely contain a copy of the general confined-space procedure from the safety program, along with the following ... 

Clearly, JSAs are an integral part of our safety program and need to be included with the site-specific safety plan. The more developed the safety culture in our organization is, the more likely that many JSAs will be written to describe a certain work task. Let me emphasize that the JSAs are not part of the safety program. The JSAs are part of the site-specific safety plan. Let s look at some more examples of how the safety program and site-specific safety plan are interrelated. 

Let s look at hazard communication (HAZCOM) from the standpoint of the safety program versus the site-specific safety plan. For HAZCOM, companies will likely have the key components specified in the safety program. These key components might include the following ... 

So the general safety program or safety manual will discuss the necessity and general applicability of HAZCOM to the company, and the site-specific safety plan will get into the details. These details might include the following ... 

I t s look at an example of when the safety program and site-specific safety plan might be the same document. 

If this example describes your company, then it is likely that the safety program and site-specific safety plan will be one and the same. It is also likely that your company experiences none, or at least very few, accidents. If your organization does not experience any accidents, it is unlikely that the reader would be interested in this material anyway however, if your company does not fit this description, then you probably need both a safety program (general safety manual) and a site-specific safety plan as described earlier in this chapter. 

To address compliance issues in a more hands-on manner, a site-specific safety plan should be used. This site-specific plan fills in the details of how safety compliance will be met, including the actual roles and responsibilities of those team members who are responsible for compliance issues. The site-specific safety plan document can and probably will contain other documents, such as JSAs. In an atmosphere where the safety culture is well developed, these JSAs will contain somewhat intricate detail regarding how team members will be protected against every hazard that will be encountered during work task activities. 

Although various examples are offered, it is unlikely that any business can and should operate without both a safety program and a site-specific safety plan. The safety program and site-specific safety plan are two types of documents that are interrelated but serve different purposes and functions. 

Described as follows are two tools that are used extensively in measuring field compliance the audit and the inspection. I define these two tools as related but different. The main differences between them are in their scope. Many health and safety professionals do not realize or believe that there is a difference between the safety program and the site-specific safety plan. Similarly, many health and safety professionals will not admit to a difference between the safety inspection and safety audit, but there is a difference—and the difference is substantial. Safety inspections, and why these safety inspections are important, is discussed in the following section. After completing the discussion on safety inspections, safety audits are discussed. 

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