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SAFETY AUDIT/ INSPECTION MANUAL A Publication of the American Chemical Society Committee on Chemical Safety Copyright © 2000 Washington, DC All rights reserved. PREFACE udits and inspections play ever-increasing roles in our workplaces.The ACS Joint Board Council Committee for Chemical Safety produced this manual in response to numerous requests. In addition to being available in print, this manual is the first to be published by the committee on the Web site of the American Chemical Society. The Committee for Chemical Safety is pleased to introduce this manual and thanks the subcommittee that produced it. The subcommittee includes the chair, Stephen Sichak, Sr., and members Ann M. Norberg, Russell W. Phifer, Diane G. Schmidt, and Eileen B. Segal. We welcome all comments. Please direct them to the Committee for Chemical Safety, American Chemical Society, 1155 Sixteenth Street, NW, Washington, DC 20036. A Henry C. Ramsey Chair, ACS Committee on Chemical Safety 1998–1999 ii DISCLAIMER he materials contained in this manual have been compiled from sources believed to be reliable and to represent the best guidelines and procedures for conducting a thorough safety audit and inspection in the workplace. This manual is intended to serve only as a starting point for managers and employees in their task of establishing good safety practices. The manual does not purport to specify any minimal legal standards or to represent any specific policy of the American Chemical Society. No warranty, guarantee, or representation is made by the American Chemical Society as to the accuracy or sufficiency of the information contained herein, and the Society assumes no responsibility in connection therewith. This manual is intended to provide workplace managers with basic guidelines for conducting safety inspections. Therefore, it cannot be assumed that all necessary checklists, guidelines, and precautionary measures are contained in this document and that other or additional information or safety measures may not be required or implemented. Users of this manual should consult pertinent local, state, and federal laws and legal counsel before initiating any safety audit or inspection program and be especially well informed about any compliance issues with respect to the handling of any hazardous chemical substances in laboratories. T iii TABLE OF CONTENTS INTRODUCTION ....................................................................vi 1. SAFETY AUDITS ................................................................1 1.1 ADMINISTRATIVE CONCEPTS ...................................................1 Assignment of Responsibility...................................................................2 Emergency Preparedness.........................................................................2 Employee Awareness,Acceptance of Responsibility, and Participation...2 Identification, Control, and Monitoring of Potential Hazards ..................2 Management Leadership ..........................................................................4 Maintenance of Safe Working Conditions ................................................4 Medical and First Aid Systems..................................................................5 Safety, Health, and Environmental Record Keeping and Statistics ...........5 Safety Organization and Administration...................................................5 Safety Policy, Programs, and Activities......................................................5 Safety Rules, Regulations, and Procedures ...............................................5 Safety Training and Education..................................................................6 1.2 PHYSICAL CONCEPTS ...............................................................6 Compliance..............................................................................................6 Identification of Exposure .......................................................................6 Safeguarding Exposures ...........................................................................7 Protection and Guarding .........................................................................7 Safety Organization ..................................................................................7 Environmental Controls ...........................................................................8 1.3 PROTECTING YOUR AUDITS ........................................................9 2. SAFETY INSPECTIONS .........................................................10 Inspection Teams ...................................................................................10 Effective Safety Observation ..................................................................11 Starting the Inspection ..........................................................................11 Inspection Team Obligations .................................................................12 Inspection Procedures ...........................................................................12 iv Technical Problems................................................................................12 Chemically Related Inspections.............................................................12 Specialized Inspections..........................................................................13 Health Surveys .......................................................................................13 Overhead Inspections............................................................................13 Condemning Equipment........................................................................13 Taking Notes ..........................................................................................14 Making the Report .................................................................................14 Handling Recommendations..................................................................15 3. SAFETY INSPECTION CHECKLIST ..........................................16 Animal Handling and Biohazards...........................................................16 Building Conditions ...............................................................................17 Carcinogens ...........................................................................................18 Compressed Gas Cylinders ....................................................................19 Cryogenic Safety ....................................................................................20 Electrical ................................................................................................20 Emergency Evacuation and Equipment .................................................22 Employer Posting ...................................................................................23 Environmental Protection......................................................................23 Fire Inspection/Fire Protection..............................................................24 Hand and Power Tools ...........................................................................26 Housekeeping ........................................................................................26 Laboratory Hazard Analysis ....................................................................27 Ladders...................................................................................................29 Lasers .....................................................................................................29 Lockout/Tagout Procedures...................................................................30 Machinery and Guarding .......................................................................30 Personal Protective Equipment .............................................................31 Radiation Protection ..............................................................................32 Signs and Tags ........................................................................................33 Waste Accumulation...............................................................................33 Working Environment............................................................................33 4. APPENDIX ..........................................................................35 Federal Laws and Regulations Affecting Laboratories............................35 v INTRODUCTION W hat is a safety audit? What is a safety inspection? Although the words audit and inspection are frequently used interchangeably, they are not the same. Broadly defined, an audit is a systematic review of operations and practices to ensure that relevant requirements are met.Traditionally, the term audit is associated with principles of accounting. Because of this, many people perceive a safety audit as an Internal Revenue Service (IRS) procedure or a financial accounting procedure. Indeed, the safety audit may apply similar methodologies used in financial audits to mitigate safety risks within any facility or operation. A sound business enterprise must check its safety practices as carefully as its accounting records.The debits of possible loss or injury situations should balance against the credits of adequate safeguards. Audits are not inspections. Audits evaluate all aspects of the program with special emphasis on the quality as well as the quantity of safety and health activities at every level.The basic goal of an audit is to verify that health and safety activities comply with institutional policies and federal, state, and local regulations. The Committee on Chemical Safety is well aware of the possible negative perception of the word audit. Once you understand its meaning as used in this document, you may, at your discretion, replace it with alternatives. Examples of alternative terms include safety survey, safety consultation, safety assessment, field observation, field assessment, or operational survey. Throughout this manual, the concept of environment, health, and safety is intended, but for the sake of simplicity, safety is used. No matter what term(s) you use, you should assign significant importance to the assessment of safety practices in the workplace. Inspection, on the other hand, is defined as that monitoring function conducted in an organization to locate and report existing and potential hazards that could cause accidents in the workplace. Legally, the Occupational Safety and Health Administration (OSHA) or the Environmental Protection Agency (EPA) conducts inspections.What we are discussing are discussing are surveys, not inspections. Safety surveys frequently reveal potential causes of accidents and, thus, provide an opportunity to take corrective action before an injury occurs. Surveys are conducted at the line or operating levels; audits, on the other hand, are a managerial or corporate activity. Safety surveys are effective ways of preventing accidents. You should take corrective action as soon as possible to abate all hazards found during an inspection. If the hazard presents an imminent danger to employees, you must take corrective action immediately. If you must delay corrective action for nonimminent hazards, you should document the reason for the delay and the estimated date of correction.When the corrective action has been completed, you should document the action date. vi 1. SAFETY AUDITS afety audits are report cards on the success of safety and health programs, environmental programs, and process safety management. Like financial and IRS audits, safety audits are structured evaluations on performance and compliance.A safety audit is a structured, methodical assessment and evaluation of how workplace activities affect safety and health. It reveals how an organization is doing in maintaining a safe and healthy environment. Its goal is to ensure a safe and healthy workplace by striving to eliminate unsafe practices and hazards that lead to injuries and accidents. An audit consists of two parts: gathering data about a program and evaluating the data.The audited program must comply with a variety of regulations and guidelines: federal environmental, safety, and health regulations; local and state requirements; and internal institutional performance requirements. Governmental controls may include laws that cover environmental management, right-to-know issues, or process safety management. An audit should identify the strengths as well as the weaknesses of a program. It should reveal to management and the employees where and how they could and should make improvements. On-site audits require three main actions. First, arrange interviews with facility personnel who have key roles in developing or implementing safety management systems. Next, review documentation that defines safety system records or verifies completion of critical tasks.These tasks may include emergency preparedness; hazard identification, control, and monitoring; and safety education and training. Last, conduct field assessment of the facility or equipment. Here, the assessment might include verification of implementation of safety practices. For example, are only certified welders performing hot work (welding)? Does he or she have hot work permits? Audit data, obtained by reviewing written records and procedures, interviewing personnel, and personal observation, are collected from both an administrative area and a management or operational area, which controls the physical environment.Audit of the administrative area includes a review of how well or how poorly management has implemented the program. Audit of the operational areas, whereby management controls the physical environment, includes assessing the surroundings and external conditions that influence the daily operation of the organization. S 1.1 ADMINISTRATIVE CONCEPTS In its broadest terms, an audit includes all or some of the administrative concepts described in this section. Some of these concepts are provided to establish a “Framework for Evaluating Safety.” The following information provides a framework for developing evaluation criteria. It should not be used as a checklist, which can be limiting. 1 Assignment of Responsibility • Are department heads, supervisors, and staff assigned safety responsibilities as a policy or procedure, and is the policy communicated to all levels? • Is there a clear line of responsibility? • Who is responsible for coordinating the compliance program? • What steps has the organization taken to comply with OSHA and other regulations? • Is the safety staff competent and qualified? • Is safety responsibility monitored? Emergency Preparedness • Does the employer have an emergency action plan? Is it tested by drills? • Do personnel receive training on the proper way to report emergencies and summon help? • Does the organization have an emergency response procedure, including backup systems for controlling spills and releases and evacuating personnel? • Are procedures in place for reentry and cleanup? Employee Awareness, Acceptance of Responsibility, and Participation • Is there active participation in a safety and health committee? • Are the engineering and administrative controls effective? • Is there an effective personal protective equipment program? ■ What type of equipment is used? ■ What is the rationale for use? ■ What are the maintenance procedures? ■ Is equipment available to and used by all employees? ■ Is mandated training performed? • Is there safety publicity (newsletters, bulletins, etc.)? • Discipline: ■ Are violators of safety rules disciplined? ■ Are supervisors setting a good example? ■ Is the safety and health performance effective? Identification, Control, and Monitoring of Potential Hazards • Is top management aware of all health and physical safety risks in the workplace? • Hazardous substance control program: ■ Is one in use? ■ Are all substances identified? ■ Are employees aware of the risks? • Are procedures in place to inform and educate employees about all health and physical safety risks? Does this procedure include informing employees about the potential hazards of nonroutine tasks and educating contract employees about potential hazards on-site? Do employees receive testing to ensure that they understand what they learned? 2 • Does the employer provide written information and training procedures? • Does the employer document information and training session outcomes? Do employees sign attendance sheets and state in writing that they understood the material presented? Does it document who was trained, when they were trained, and whether they successfully completed the training? What procedure is in place to coordinate documentation of training materials? Are the training logs entered into a database? How are the original sign-in sheets stored? Are they easy to retrieve? • Is a knowledgeable person assigned responsibility to determine the presence and use of hazardous materials? • Is a list of all hazardous substances available? • Have suppliers provided material safety data sheets (MSDSs) covering hazards and precautions for all chemicals? • Are these MSDSs available to all employees on request? • Is every nonexempt container of hazardous chemicals in the workplace appropriately labeled? ■ The hazard communication standard generally applies only to those chemicals (including elements, compounds, and mixtures) to which employees are exposed in the workplace under normal conditions or in a foreseeable emergency. ■ Hazardous wastes regulated by the U.S. Environmental Protection Agency (EPA), chemicals produced and used only in a laboratory, and items for personal consumption are exempt. ■ Piping and containers into which an employee transfers hazardous chemicals for use during that workshift are exempt from the labeling requirement. • How does the safety coordinator find out when a new chemical is introduced into the workplace? How does the safety coordinator ensure that unused chemicals are disposed? For every known health hazard, does a definite control plan exist that covers ■ periodic monitoring of the hazard? ■ continued maintenance and monitoring of employee exposure records? ■ periodic physical examinations for employees in exposure areas? Is strict enforcement of rules governing provision, care, and use of personal protective equipment followed in all cases? • Is a list of symptoms and antidotes for toxic substances circulated and posted where necessary? • Are known health exposures studied to eliminate or reduce exposures through process or design changes or engineering controls? How are such studies conducted? How are the results communicated? • Do employees understand and comply with OSHA standards or safe practices recommended by manufacturers or other agencies? • Have certified industrial hygienists evaluated the operations? • What actions are taken regarding recommendations made by industrial hygienists? What actions still remain to be taken? 3 • Are safety rules and approved signs relating to health hazards posted in areas where hazards are present? • What is the procedure to confirm that supervisors and employees exposed to potential health and safety hazards understand the nature of the risks, the preventive measures, and related safety rules? • What evidence is there in the workplace that the hazards are known and adequate controls are in place and working? • Are appropriate safety devices available? Is personal protective equipment (PPE) provided and used properly? • Is PPE in conformance with appropriate standards such as NIOSH (National Institute for Occupational Safety and Health) or ANSI (American National Standards Institute)? Management Leadership Fundamentally, all safety work must proceed from the proper motivation of management.The effectiveness of any program increases or diminishes according to the degree of support and encouragement that management displays. • Is there a written safety policy/program? • Is employee participation solicited? • Is management setting a good safety example? • Is off-the-job safety a management concern? • Is there a systematic review of safety performance? • Do safety issues flow down from management or up to management? • To whom in top management does the chief safety coordinator report? • Are adequate funds made available to ■ support the safety program? ■ correct unsafe conditions? ■ support training and other educational activities? • Are new employees indoctrinated with safety and health training by management’s edict? Are they then tested to ascertain that the safety and health training is inculcated? Maintenance of Safe Working Conditions • Is there proper maintenance of good housekeeping conditions in the workplace? Are equipment and materials organized and adequate? Are work areas and the exterior of the plant clean? • Workplace inspection program: ■ What is the frequency of inspections? ■ Who performs them? ■ Is a record maintained? ■ Is there a preventive maintenance program? • Are the inspection team personnel trained? • Are the engineering and/or administrative control programs routinely evaluated? 4