On-site consultation program

S Montana. Division
363.1l75of Uorkers*
W20bLc Compensation. Loss
19a7 Control Section
Basic loss
£?-( control manual for
Montana employers

DIVISION OF

WORKERS'

COMPENSATION

BASIC LOSS CONTROL MANUAL

FOR
MONTANA EMPLOYERS

>

Developed by:

Division of Workers' Compensation
Safety Bureau
Loss Control Section
Helena, Montana

PLEASE RETURN

:

DWC-MIS PAM 10 (New 12/87)

GS8/M

SEP 2 9 1993

MONTANA STATE LIBRARY

S363.1175W20bLc1987c.1

Basic loss control manual for Montana em

3 0864 00060577 7

>

151y E. 6f!

HELENA, MONTANA 59620

*

TABLE OF CONTENTS

TITLE PAGE

Introduction

Loss Control Program Outline

Section I : Management Commitment 1-1

Section II: Hiring Practices II-l

Section III: Safe Operating Procedures III-l

Section IV: Training IV-1

Section V: Equipment Provision & Maintenance V-l

Section VI: Hazard Identification & Elimination VI-1

Section VII: Accident Reporting & Investigation VII-1

Section VIII: Emergency Preparedness* VIII-1

Section IX: Recordkeeping IX-1

Section X: Other Loss Control Activities X-l

FORMS AND INSTRUCTIONS

Sample Statement of Policy 1-3

Sample Job Application Form II-3

Reference Checking Instructions & Form II-4

Job Safety Analysis Instructions & Forms III-2

New Employee Checklist IV-4

Safety Meeting Form IV-5

Job Safety Observation Instructions & Forms VI-3

Accident Investigation Instructions & Forms VII-3

Accident and Illness Summary Form IX-3

Incident Rate Calculation Instructions IX-4

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Digitized by the Internet Archive

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http://www.archive.org/details/onsiteconsul2001mont

INTRODUCTION

Purpose : This manual is designed to provide a basic blueprint
of a sound loss control program for Montana employers. The
primary goal of such a program is to reduce occupational
injuries and illnesses and their associated costs. The
policies, procedures and activities described herein will
allow you to reduce losses if practiced consistently in your
daily operations. The manual is essentially generic in nature
so that it can be utilized by employers in a wide variety of
industries. Each individual firm must tailor the program to
their particular type of operation.

Organization : The manual is divided into 10 chapters. The
chapter titles and page numbers are shown in the Table of
Contents. Each chapter begins with a rationale section
explaining the reasons for the particular policies, procedures
or activities in that chapter. Next, are the Core
Requirements. These are the items which are essential to a
good program and if you are participating in the Safety
Discount Program, must be implemented for certification.
Following the Core Requirements section is an Optional
Considerations section. These are additional elements which
will further enhance a loss control program as the program
becomes more sophisticated. Finally, in many of the chapters,
instructional materials and examples of forms or documents
have been included to help you implement the core requirements
in that chapter. In attempting to keep the manual from being
overly lengthy, instructions and example forms or documents
were not included for every core requirement.

11

Should you desire additional information on a core requirement
or an optional item, please feel free to request it from your
Loss Control Consultant or the Safety Bureau Office directly.
Also, any portion of the manual may be reproduced for use in
your operation.

Summary : Research has shown that a business has a greatly
improved chance of being successful if a business plan is
developed and followed. A loss control program is nothing
more than a part of management's overall plan of doing
business in terms of containing costs and maximizing
resources. But for a plan to work, it must be implemented and
followed. This takes perserverance, determination and a
considerable amount of time. The benefits are real and we
hope this manual will assist you in attaining them.

111

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LOSS CONTROL PROGRAM OUTLINE

I . Top Management Commitment to Safety
Core Requirements :

1. Develop or adopt a written loss control plan.

2. Include a written policy statement from management,

3. Implement the plan and insure adherence to it.

a. Allocate adequate resources.

b. Assign proper authority, responsibility and
accountability.

c. Set a good example by participating in safety
efforts .

d. Insure compliance with applicable safety and
health regulations.

>

>

II . Hiring Practices

Core Requirements:

1. Use written application form.

2. Consult with previous employers.

Optional Considerations:

1. Have applicant take a preemployment physical
examination.

2. Incorporate probationary period of employment for
new hires.

3. Conduct personal interviews with all applicants
prior to hiring.

4. Utilize your local Job Service for applicant
referrals .

IV

Ill . Establish Safe Operating Procedures
Core Requirements :

1. Perform job analysis to develop safe operating
procedures .

2. Review procedures periodically.

3. Outline general safety rules and regulations.

IV. Provide Training

Core Requirements:

1. Management training on plan implementation.

2. Newly hired or transferred employee training.

a. Orientation on safety plan contents and safe
operating procedures.

b. Employee acknowledgement form.

c. On-the-job training.

3. Ongoing employee training.

a. Safety meetings held regularly.

b. First aid, CPR trained personnel.

c. Other mandated training.

Optional Considerations :

1. Provide formal classroom or seminar training
sessions .

V. Equipment Provision and Maintenance

Core Requirements:

1. Provide necessary and adequate production and
protective equipment.

(

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2. Maintain equipment to manufacturers specifications
and applicable regulations.

3. Keep maintenance and inspection logs when required
by regulations.

Optional Considerations:

1. Develop a scheduled preventive maintenance program.

2. Keep maintenance records even when not required by
regulations .

VI . Hazard Identification and Elimination

Core Requirements:

1. Routine daily hazard identification and elimination.

2. Documented periodic self -inspections of the
workplace.

3. Documented periodic job safety observations.

4. Noise and air contaminant monitoring.

5. Chemical hazard identification and labeling.

6. Disciplinary policy for rule enforcement.

Optional Considerations:

1. Documented daily hazard reports

2. Inspections by outside entities

VI

VII . Accident Reporting and Investigation
Core Requirements:

1. Insure prompt accident reporting to management.

2. Prompt written accident investigation by supervision,

3. Insure the prompt submission of claim forms to the
Division of Workers' Compensation when applicable.

4. Review and communicate investigation results to
prevent future accidents.

Optional Considerations:

1. Investigate non-injury accidents.

VIII. Emergency Preparedness
Core Requirements:

1. Establish emergency procedures.

2. Provide necessary first aid equipment.

Optional Considerations:

1. Notify emergency medical service of remote job site
locations .

IX. Recordkeeping

Core Requirements:

1. Establish a loss control filing system.

a. Written company loss control plan.

b. Accident records.

i. Accident investigation reports,

ii. Workers' compensation claim forms,

iii. Accident summary log.

iv. Man hour totals or number of employees.

VI 1

(

i ) c. Hazard Identification and Elimination Records

i. Formal self inspection reports,
ii. Job safety observation reports,
d. Training records

i. Safety meeting documentation.

2. Establish personnel files.

a. Employment applications and previous employer
check forms.

b. Employee acknowledgement forms.

Optional Considerations:

1. Maintain non-core requirement records.

>

X. Other Loss Control Activities
Core Requirements:

1. Periodic contact with injured workers who are off
work .

2. Periodic review of the loss control program to
insure continued effectiveness.

Optional Considerations:

1. Monetary or other rewards for attaining and
maintaining safety performance goals.

2. Initiate a "back to work" policy.

3. Promote Off -Job Safety.

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SECTION I

MANAGEMENT COMMITMENT

Rationale : The commitment of top management to an effective
loss control plan has to be the first step in implementing
such a plan. Also, it is the most important element of the
plan as the remaining elements will not be implemented and
maintained unless management is strongly committed to do so.

The commitment must be properly communicated to employees and
management must be involved in safety and health activities to
demonstrate their concern.

Core Requirements :

1. Management must adopt or develop a written loss
control plan which contains all of the core
requirements as outlined in the remainder of this
packet. Employee participation is encouraged.

2. The plan must contain a written policy statement
expressing management's commitment and goals. The
example on page 1-3 can be adopted or develop your
own.

a. The policy statement must be signed by the chief
executive officer.

1-1

3 . Management must implement the plan and insure that
it is followed.

a. Allocate adequate resources to allow the plan to
be implemented and maintained.

b. Assign proper authority, responsibility and
accountability for safety and health.

c. Set an example of safety by adhering to the
rules and participating in safety activities.

d. Insure compliance with applicable safety and
health regulations.

1-2

SAMPLE

LOSS CONTROL PROGRAM STATEMENT OF POLICY

In recognition of the responsibility of the management of

(Company Name) to establish procedures

for the prevention of employee accidents, this Loss Control
Program has been developed.

Our objectives are to provide to the best of our ability:

1. An accident and injury free work environment.

2. Protection of the general public.

3. Reduction of costs associated with accidental losses.

The achievement of these objectives is based upon good planning
and making sure safety is an integral part of day to day
operations and work procedures. This can only be accomplished
if all personnel take an active interest and participate in the
Loss Control Program and abide by the applicable Federal, State,
Local and Company rules and regulations.

The success of our program can be measured directly by its
ability to control unnecessary loss. An accident resulting in
personal injury, property damage or equipment loss represents
needless waste. It is imperative that all employees recognize
their responsibility to control these losses and that they take
all necessary actions to do so. Their performance in this regard
will be measured along with their overall performance.

It is my earnest request that all employees of (Company Name)

devote their serious attention toward making this program an
integral part of day to day business operations.

PRESIDENT/OWNER DATE

GENERAL MANAGER DATE

1-3

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J ) SECTION II

HIRING PRACTICES

Rationale : Good hiring practices are the employers' only
means for being selective in obtaining a new employee.
Through a formal screening process, you are making your best
attempt at hiring an employee who will work safely and
productively in your business.

Core Requirements ;

1. The employer must utilize a written job application
form for all job applicants. An example of such a
form is shown on the next page. This form has been
reviewed and deemed not to contain any unlawful
questions .

2. The employer must do an employment history check
with at least two (2) of the applicants' previous
employers listed on the job application. A brief
outline on conducting reference checks and an
example of a reference check form are included.
When reference checks cannot be made, it should be
so noted in the personnel file.

Optional Considerations :

1. For physically demanding jobs, the applicant should
take a preemployment physical examination. Provide
the examining physician with a job description and
have the exam results reported directly to you.

2. Incorporate a probationary period for newly hired
employees .

II-l

3. Conduct a personal interview with prospective
employees to gain further knowledge about their
background, experience, etc. Be sure to keep all
questions job related.

4. Utilize your local Job Service Office for applicant
referrals.

(

II-2

PLEASEPRINT NOTICE : This is an application for work onjj

SAMPLE

1-3. Name - First,

Middle, Last

8. Circle highest
school year
completed
12 3 4 5 6 7

8 9 10 11 12 13

14 15 16 17 18

19+ Yr. Grad.

9. Highest Degree
None

HS or GED

_ Associate
Bachelor
Master
Ph. D.

10.

Driver's License
Operator 1 s
Chauffeur's

11. Vocational, trade
or technical
school attended

Months of training
completed

4. Address

Date Completed

5. City, State, Z

p Code
7. Msg. Phone

"1

Courses Taken

6. Phone

IMPORTANT CIVILIAN AND MILITARY EXPERIENCE
Describe your longest and most important jobs - Begin with your most recent job

12. Name of Firm or Branch of Service

16. Name job and describe exactly what you did and how you did it.

13. Address

14. Employer's Type of Business

15. Length of Job Date Ended Pay

Reason for Leaving

17. Name of Firm or Branch of Service

21. Name job and describe exactly what you did and how you did it.

18. Address

19. Employer's Type of Business
)

20. Length of Job Date Ended Pay

Reason for Leavinq

22. Name of Firm or Branch of Service

26. Name job and describe exactly what you did and how you did it.

23. Address

24. Employer's Type of Business

25. Length of Job Date Ended Pay

Reason for Leaving

27. Name of Firm or Branch of Service

31. Name job and describe exactly what you did and how you did it.

28. Address

£9. Employer's Type of Business

30. Length of Job Date Ended Pay

Reason for Leaving

32. Summary of Other Work Experience:

3° vVolunteer Work:

Do you have any physical or mental handicap which will limit your ability to perform the job for which you are applying?

Yes No If Yes, explain:

. II-3

R eference Checking

{ ) Many of the problems of subjectivity which affect the interview are present in
reference checking as well. Similarly, by using a systematic procedure,
reference checking can be improved.

The same guidelines for interview questions apply to questions asked of
references.

° Ask only for job-related information (based on job analysis) or for
verification of information provided by the applicant.

Write down in advance the questions or areas which will be explored.

Cover the same areas for each applicant.

Develop criteria against which to judge the reference giver's response,
(what sort of responses would be qualifying? What kinds of responses would
disqualify an applicant?)

Contact only former supervisors or persons who have direct knowledge of the
applicant's qualifications to perform the job.

° Ask for factual information which can be documented. Stay away from
subjective impressions of character, personality, etc.

Don't ask the popular rehire question. Since nearly everyone answers "yes"
the question is meaningless.

II-4

Applicants can request that they be notified before their current employer isr
contacted. Determine if that is their desire before such a contact is
made .

The EEOC offers two broad guidelines which are useful reference checks.

1. Will the answers to the question, if used in making a selection decision,
have a disparate effect in screening out minorities and /or members of one
sex, i.e., disqualifying a significantly larger percentage of members of a
particular group than others?

2. Is this information really needed to judge an applicant's competence or
qualification for the job in question?

Research seems to indicate that the reference check has more use as a verifica-
tion of information provided by the applicant rather than as a predictor of job
success. Until additional methods for checking references are developed, other
applications are not generally recommended.

i

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II-5

SAMPLE

Name of Applicant

I ) REFERENCE CHECK

FORM

Name Title

Agency/Business Telephone

Questions:

1. Verify employment?

2. Verify duties?

3. Supervisory relationship to applicant?

4. Meets timeframes/deadl ines/objectives?

5. Works as member of team; gets along with other workers; can gain cooperation?

6. Accuracy of work; number of errors; need for review?

7. Represents organization; professional demeanor; verbal skills?

8. Rule compliance; does applicant comply with organizational rules; attendance,
leave, punctuality.

Signature (person checking reference) Date

II-6

i )

{ ) SECTION III

»

SAFE OPERATING PROCEDURES

Rationale: Development of written job-specific safe operating
procedures and their subsequent use in training employees has
been proven to shorten the length of time required to bring a
newly hired or transferred employee up to full production
potential. In addition, it is done safely. These procedures
are also used to perform job safety observations on regular
employees as discussed in Section VI.

General rules are also necessary to cover company wide
policies on accident reporting, absenteeism, and topics of a
broad nature.

Core Requirements ;

1. Perform a written job safety analysis (JSA) for
those positions deemed hazardous using the
instructions and forms on the following pages or an
equivalent.

2. Review the written safe operating procedures from
the job analysis periodically to insure completeness,

3. Develop a set of written rules covering general
topics. (Note: Sections VI, VII, and VIII require
written policies and procedures regarding hazard
reporting, accident reporting and emergency
procedures. These can be incorporated into the
general rules or addressed separately).

III-l

JOB SAFETY ANALYSIS (JSA)

Job Safety Analysis (JSA) is a procedure that identifies the hazards in each
step of a job and involves the development of safe job procedures to control or
eliminate each hazard. The basic steps in making a JSA are:

• Break the job down into successive steps.

• Identify hazards in each step.

• Eliminate or guard against potential hazards.

• Develop safe job procedures for each job step.

A job safety analysis worksheet is on the following page. In the left column,
the basic steps of the job should be listed in the order in which they are
performed . The middle column should describe how to perform each successive
job step. The right column should indicate the safe job procedures that should
be followed to eliminate or guard against potential hazards.

Priority of Jobs to be Analyzed

The priority of jobs to be analyzed should be determined by the following
factors:

• Frequency of accidents.

t Severity of accidents or injuries,

t A high severity potential.

• Repetition of the job.

• New jobs or changed job procedures.

A job that has a history of many accidents should be analyzed immediately. Any
job that has produced disabling injuries or has the potential for a serious
accident or injury should have a JSA developed. Persons working on repetitive
jobs have a high rate of exposure to hazards. If new jobs are created by
changes in equipment or operating procedures, it is important that a JSA be
developed for the jobs immediately because the safe operating procedures are
not always clear.

Those are the five factors that should be used for determining the
priority of jobs to be analyzed. After job priorities have been
established they should be listed on a form similar to the one on
Page III-7 and scheduled for analysis.

III-2

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III-3

Breaking the Job Down Into Steps

The steps in a job should describe exactly what is done in the order each step
is performed. The following is an example of this procedure:

Job: Pre-start of a Front-End-Loader

t. Check for the presence of safety shields.

2. Check for loose parts.

3. Check for small cracks on safety equipment.

4. Check tires for proper air pressure.

5. Check crank case oil level.

6. Check coolant level.

7. Check air cleaner condition.

8. Test control levers for free movement.

9. Check yourself for personal safety equipment and unsafe
clothing.

10. Place transmission lever in neutral.

11. Install safety belt.

Additional factors that should be considered when performing a JSA are:

• Select the right person to observe.

• Brief the person on the purpose of the JSA.

• Personally observe the job being performed.

• Record each step on the worksheet.

• Check the job steps with the persons when the JSA is done
to get their input.

III-4

) Identify Hazards

J

After the steps in the job are listed on the worksheet, each step should be
analyzed to identify hazards or potential accident causes. Each should be
recorded on the worksheet in the center column. Keep the hazards in line with
the steps recorded.

Developing Solutions and Safe Operating Procedures

When the hazards and potential accident causes have been identified, the next
step is to develop solutions and procedures to eliminate or guard against the
problems you have identified. Solutions and procedures may include some or all
of the following:

• A different method of performing the job.

t A change in physical conditions or environment.

• A changed job procedure.

• A change in the frequency of how often the job is performed.

For each hazard or potential accident cause listed on the worksheet, ask "what
can be done differently and how should it be done?" Answers and solutions must
be very specific to be of value. Solutions which state "Be more aware" or "Be
careful" are of no value in determining safe operating procedures. The
solutions should state exactly what must be done to perform the job safely.

Benefits of JSA

For the supervisor, the JSA will enable him/her to clearly understand the safe
way of performing all jobs in their area of responsibility. In addition to
providing the supervisor with a basic training guide, the JSA will provide a
tool for:

• Making safety contacts with all employees.

t Determining whether safe work procedures are taught in training and
followed on the job.

• Issuing uniform safety instructions.

• Analyzing jobs for possible methods of improved operating procedures.

• Assisting training personnel in updating safe operating procedures
relative to program content.

• Reviewing job procedures after accidents occur.

III-5

The JSA allows the supervisors and employees to work together in developing
effective safe operating procedures which can be used as OJT training guides.
The JSA is an excellent tool for eliminating non-applicable content in job
skills training. If the JSA's are not used as training guides, a lot of time
and effort will have been wasted presenting ineffective training.

III-6

HIGH RISK JOB LIST WORKSHEET

Department

Department Supervisor

Occupations and Jobs

Priority

Remarks (notes)

Occupation:

Jobs: 1.

2.

3.

4.

5.

6.

7.

Occupation:

Jobs: 1.

2.

3.

4.

5.

6.

7.

Occupation:

Jobs: 1.

2.

3.

4.

5.

6.

7.

)

III-7

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SECTION IV

TRAINING

Rationale ; There are a number of benefits to be derived from
relevant training. In the implementation of new procedures,
new processes and for new employees, you are asking personnel
to make a transition and learn a particular new role.
Providing training will help gain acceptance and make the
transition safer and faster. Also, existing safe work
procedures and operational procedures must be regularly
reviewed and reinforced to prevent complacency. This can be
accomplished through periodic refresher training.

Core Requ i rements :

1. Management must receive training on how the plan
will be implemented and operated. Topics include
forms to be completed, areas of responsibility,
accountability, etc.

2. Newly hired or transferred employee training
procedures must comply with the following
criteria :

a. Prior to actually starting work, the employee
must become familiar with the safe operating
procedures (SOP's) applicable to that position
and the general safety rules as developed under
Section III.

IV-1

b. The employee must sign an acknowledgement form
such as the one shown on page IV-4 or an
equivalent indicating that this has been
performed .

c. Once the employee begins work, an on-the-job
training period must be provided where job
procedures are demonstrated by a trained person
and then the new employee is observed to insure
proper work practices are being followed.

3. Ongoing training must be provided for all employees
meeting the following requirements:

a. A minimum of one (1) safety meeting every two
(2) weeks where job hazards, accident
investigations, current safety goals or records
and other pertinent information are discussed.
These meetings must be documented using the form
shown on page IV-5 or an equivalent. For mobile
worksites such as construction, a safety meeting
must be held prior to the start-up of each
project and at least bi-weekly thereafter.

b. There must be an adequate number of first
aid/CPR trained persons so that at least one ( 1 )
such person is available on each shift or job
site. Documentation of such training must be
maintained.

Note: Periodic job safety observations and retraining
are outlined in Section VI, Hazard
Identification and Elimination.

IV-2

(

)

c. Training required by Federal or State

regulations, such as annual hearing conservation
training, must be provided and documented. This
may be accomplished through the required Safety
Meetings if appropriate.

Optional Considerations :

1. Allow management and employees to attend formal
safety and health seminars, classes, etc. if
feasible.

Note: Training assistance can be provided by your Loss
Control Consultant and/or the Safety Bureau,
however, this will be on a limited basis.

IV-3

NEW EMPLOYEE CHECK LIST

)

Company Name:

Employee Name:

Employee Position:

Date :

Started Date

_of Training:

Completed Date

_of Training:

Date of Completion

1. Provide employee with a copy of the Loss
Control Plan to read.

2. Review general Company regulations.

3. Review emergency medical plan and procedures,

4. Your immediate supervisor is

He reports to

5. Explain fire fighting equipment procedures and
evacuation plan.

6. Review job safety analysis.

7. Review personal protective equipment required.

8. Review Company disciplinary procedures.

I do hereby acknowledge that the above items were discussed on

(Date)
Employee Signature

Date

Supervisor's Signature

(Continual observations should be performed so to insure employee competency.)
To be filled in by the Supervisor or person responsible for training.
(See Job Training Section.)

First Observation_

Needs Training

Observation

(Date/Comments)

Completed Training_

Keep as a permanent personnel record.

IV-4

SAFETY MEETINGS

Date:

Company Conducted
Name: By:

Items Discussed:

Follow-up Need:

Signature of Employees:

IV-5

I

>

SECTION V

EQUIPMENT PROVISION AND MAINTENANCE

Rationale ; The right tools for the right job is a basic
safety and production rule. The right tools include both
production and protection equipment. For these tools to be
used properly, they must be maintained.

Core Requirements ;

1. The employer must insure that adequate production
and personal protective equipment is available so
that tasks can be performed safely.

2. All equipment must be maintained in accordance with
manufacturers specifications and applicable
regulations.

3. Where required by specific regulations, equipment
maintenance and inspection logs must be kept.

Optional Considerations ;

1. Develop a scheduled preventive maintenance program
for equipment.

2. Document maintenance activities in areas even when
not required by regulations.

V-l

(

!

>

SECTION VI

HAZARD IDENTIFICATION AND ELIMINATION

Rationale ; There are essentially two (2) major types of
hazards in the workplace. The unsafe condition and the unsafe
act. Both of these types of hazards must be identified and
corrected for a program to be successful. This is
accomplished through daily routine observation and scheduled
formal observations by management and employees. A policy
must also be available to deal with continuous disregard for
safety rules by personnel.

Core Requirements ;

Management must encourage the reporting of hazards on a
daily basis and insure correction. A written statement
of this policy must be contained in the loss control plan
such as in the safe operating procedures or the general
rules. Instructions on hazard reporting systems are
available.

2. Formal, planned self -inspections must be performed
at least monthly. The use of an inspection
checklist is suggested. Example checklists can be
provided by the Loss Control Section. The
correction of hazards noted during the
self-inspection must also be documented.

3. At least annually, planned job safety observations
of employees must be performed using the safe
operating procedures developed under Section III as
a guide. Job observation instructions begin on page
VI-3.

VI-1

4. A policy for rule enforcement must be established.

The policy should be applied fairly and consistently
to all employees including management. Additional
informational material on disciplinary procedures is
available.

Optional Considerations ;

1. Develop a hazard report form for use in daily
observations to further insure correction of
reported hazards. Use of small pocket cards or
slips is an effective way to allow daily hazard
reporting.

2. Periodically request inspections or program audits
by outside organizations.

I

VI-2

E

JOB SAFETY OBSERVATION (JSO)

Detecting unsafe practices promptly is one of the best ways to prevent acci-
dents. Why do employees do what they do? Generally because they have been
taught to do it and because they receive satisfaction from doing, it. Employees
do things that are foolish, dangerous, or illegal for the same reasons that
they do smart, safe, and legal things. . .because their actions are reinforced by
someone or something. For example, an employee does silly things because other
employees laugh.

Often, we feel there is no need to reinforce safe performance. An employee
"ought" to want to work safely or wear eye protection for his or her own good.
"You oughta wanna do it for your own good" is not a potent motivator; it is one
of the weakest techniques known for influencing anyone to do something. What
reinforces safe performance depends on the individual to some degree, but there
are some generally applicable reinforcers. Two of the most potent reinforcers
known are praise and recognition. They are universally available to the super-
visor. By timely use of praise and recognition, the supervisor can provide
effective feedback and incentive for employees to perform safely. Such a posi-
tive performance feedback and evaluation system may be accomplished through a
program of job safety observation (JSO). The basic idea of job safety observa-
tion is simple. It is essentially nothing more than observing employees doing
their jobs to find out if they are working safely.

There are three types of job safety observations. They are listed below along
with a brief narrative pertinent to each.

1. Incidental Safety Observation

Part of a supervisor's job is keeping his/her eyes and ears open for unsafe
actions and conditions. You probably do it every day whether you realize it or
not. The key to effective incidental safety observations is to look around
with safety on your mind. If you don't do this already, remind yourself to
look for unsafe practices while conducting daily work place inspections.

2. Deliberate Safety Observation

This is one step beyond the incidental observation. The supervisor pauses in
what he/she is doing and deliberately watches how an employee handles some part
of the job. He/she observes from a safety standpoint. . .Is the employee doing
the job safely? Why a deliberate safety observation? The employee may be new,
or performing a particularly hazardous job. The employee may also have a repu-
tation for being unsafe. Whatever the reason, the supervisor stops and
observes the employee deliberately. This observation should be more than a
casual glance in his/her direction, although it might start out that way.

VI-3

3. Planned Safety Observation

In this instance, the safety observation is planned in advance and, if possi-
ble, in conjunction with an established JSA of a particular job. It is best to
plan safety observations for all employees under your supervision. Sinqling
out individuals leads to a "picking on me" response by some. But definitely
some employees need more frequent safety observation than others.

If results of a safety observation show that employees are not working safely,
the following may be some of the reasons for the unsafe behavior.

a. They do not know how to work safely: If the problem is a lack of
skill, you train. It is a major responsibility of every supervisor and
instructor to see that employees are trained to do their work safely
and efficiently. The level of skill necessary to accomplish a work
task can be assessed to some degree by question and discussion, but the
final check is to watch the employee do the job. If necessary, rein-
struct, arrange practice, or assign him to a more skilled employee for
further on-the-job training.

b. They are prevented from working safely: Sometimes employees would do
their jobs safely, but they are prevented by someone or something in
the work environment. Inspection of the work place will pick up such
hazards as poorly maintained work equipment, but a well documented
safety observation is necessary to isolate such equally hazardous con-
ditions as insufficient time, poor work flow, no clear-cut chain of
command, and inadequate supervision.

c. They do not want to work safely: Some supervisors categorize all per-
formance problems under the motivational incentive label - "They could
do it if they wanted to." Although lack of incentive is often closely
associated with the work environment, solutions to these problems
differ from the solutions to environmental problems. In looking at
motivational incentive problems, we need to define why employees per-
form the way they do. In order to accomplish this goal, the personal
safety observation should be integrated with a system of performance
analysis and evaluation.

A Job Safety Observation (JSO) provides supervisors and trainers with a proce-
dure to determine if employees are following safe work procedures on the job
after training. Following the procedures outlined below, supervisors and
trainers are provided with an opportunity to check on the results of past
training; revising content for future training; make immediate, on-the-spot
corrections and improvements in work practices; and compliment and reinforce
safe performance.

VI-4

Follow these steps when implementing a JSO Program:

Worker Selection

All employees should be observed performing the job. The following factors
should determine which employees to observe first:

• A new employee on the job.

• Employee recently trained for a new job.

• Below-average performers.

t Employees consistently involved in accidents.

• Risk takers.

• Employees with special problems.

Making the JSO

With few exceptions, tell employees what will be taking place prior to the
personal observation. Then simply observe the employee performing in his
normal operation. Make any notes on the worksheet provided on the following
page about work practices and procedures observed. Be sure not to interfere
with the employee performing the job or distract him, in any way.

Recording the Information

Fill out the Job Safety Observation Worksheet describing any unsafe procedures
or work practices observed. Examples of some basic types of unsafe work
procedures and practices which will probably be observed are:

• Failure to secure equipment or materials against unexpected movement.

• Operating or working at an unsafe speed.

• Using unsafe tools and equipment.

• Using tools and equipment unsafely.

• Failure to warn or signal as required.

• Assuming an unsafe position.

• Removing or making safety devices inoperable.

"l • Repairing, servicing, or riding hazardous equipment.

VI-5

(<

t

PLANNED SAFETY OBSERVATION RECORD

)

Department

Employee

Position

Job

Date

Supv.

S

R

Comments

1.

2.

3.

4.

5.

6.

7.

8.

9.

10.

11.

12.

S = Satisfactory Performance
J= Reobserve

VI-6

(t

Failure to wear required personal protective equipment.

Wearing unsafe personal clothing.

Violation of known safety rules and safe job procedures.

Engaging in other unsafe practices (not violations).

Indulging in horseplay, practical jokes, fighting, sleeping, creating
distraction, and so on.

Discussing the JSO with Employee

After completing the JSO, review the results with the employee. Your feelings
about the work habits and practices observed should be discussed informally and
in a friendly manner. Do not let the discussion be one-way communication.
Encourage the employee to talk and give his/her views about any problems or
barriers they see in following the current operating procedures.

The Follow-up

Follow-up the JSO as needed. In some instances, the follow-up will be often.
How often follow-up is needed depends on the employee, the results of the
initial observation, and the job.

Benefits of the Job Safety Observation

The JSO is a feedback device. It provides excellent information of the effec-
tiveness of training and on the adequacy of established safe job procedures.
Through the JSO, unsafe practices can be identified and corrected before an
accident happens. Additionally, any weaknesses taught in training relative to
safe operating procedures can be revised and included in the OJT content.

Since the firstline supervisors are responsible for making sure that safe
operating procedures are followed on the job, they should be allowed to provide
feedback to training personnel on how well training prepared employees to per-
form their assigned jobs.

Job safety observation provides an effective way of determining the accuracy of
the job safety analysis. In addition, implementation of a Job Safety Observa-
tion program is an excellent method of assuring supervisory involvement in all
training efforts.

vi-7

t

SECTION VII

ACCIDENT REPORTING AND INVESTIGATION

Rationale : The primary purpose of accident investigation is
to determine how a reoccurrence can be prevented and thus
improve the safety of your operation. Obviously, an accident
must be reported before the investigation can be performed.
Accident investigations must be done in a thorough and
objective manner based on the facts and must not attempt to
place blame on the individuals involved. In regard to the
validity of a reported accident, a good accident investigation
report can be a very important source of information in
subsequent investigations or proceedings.

Core Requirements :

1. A written policy stating that accidents must be
reported to management within a specified time
period must be included in the written plan.

2. All injury or illness incidents must be investigated
as soon as possible after they are reported by
management. Investigation findings must be
documented. Procedures for conducting a proper
accident investigation and example forms begin on
the following page VII-3.

VII-1

I

3. Insure that the appropriate workers' compensation
claim forms are completed and sent to the State
Compensation Insurance Fund (located within the
Division of Workers' Compensation) as soon as
possible after an accident or illness is reported
involving medical treatment or lost time.

4. Corrective actions taken as a result of accident
investigations must be documented.

Optional Considerations ;

1. Investigate non-injury accidents to determine causes
and preventative measures.

VII-2

)

>

ACCIDENT INVESTIGATION

INTERVIEW TECHNIQUE AND SKILLS

1. Keep the purpose of the investigation in mind.

a. To determine WHO was injured? WHEN, WHERE, and
HOW did it happen? WHAT materials or equipment
were involved? WHY did it happen?

b. To reveal causes so reoccurrence can be prevented.

2. Approach the investigation with an open mind (it will
be obvious if you have preconceptions about the
individuals or the facts ) .

a. Do not attempt to place blame;

b. Stay away from conjecture.

3. Promptness will reduce the possibility of:

a. Destruction of physical evidence (changed work
site ) ;

b. Forgetf ulness of witnesses or victim;

c. Interjection of opinion or conjecture by witnesses
or victim after they evaluate the accident from
their perspective;

d. Witnesses and victim talking together and getting
confused about what they know and what they've
been told by others.

4. Go the scene. (Just because you're familiar with
the location or the victim's job, don't assume that
things are always the same).

5. Interview the people involved (victim, witnesses,
people involved with the process, i.e., forklift
driver, mechanic, so on).

a. Attempt to do the interview at the site.

Circumstances may not permit (noise, lack of
privacy, congestion). If not possible, use:
i. Combination (look, then go somewhere to talk);
ii. Photos;
iii. Blueprints;
iv. Sketches.

VII-3

Put the person at ease:

i. Explain the purpose and your role;
ii. Sincerely express concern regarding the
accident and desire to prevent a similar
occurrence ;
iii. Express to the individual that the infor-
mation he gives is important;
iv. Be friendly, understanding and open-minded ;
v. Be calm and unhurried.

Interviews should be private and in a neutral
location .

Let the individual talk:

i. Ask background info; name, job, address;
ii. Ask the witness to tell what happened:
Don't ask leading questions;
Don't interrupt; and

Don't make expressions (facial, verbal)
of approval or disapproval;
iii. Then: Ask questions to clarify particular *
areas or to ask "why" . Do not put the person on
the defensive. Try to avoid "yes" and "no"
questions .
iv. Ask for their suggestions;
v. Repeat the facts and sequence of events back
to the person to avoid any misunderstandings;
vi. Notes should be taken very carefully and as
casually as possible. Let the individual
read them if he desires;
vii. Recordings should only be made with the know-
ledge of the witness; (Some people may be
very intimidated by a recorded interview and
not speak as freely).

VII -4

)

viii. Conclude the interview with a statement of
appreciation for their contribution. Ask
them to contact you if they think of any-
thing else;
ix. Do not hesitate to reinterview; and
x. Avoid reenactment if at all possible.

;

VII-5

SUPERVISOR'S ACCIDENT INVESTIGATION REPORT

COMPANY/EMPLOYEE INFORMATION

-^/1I

PANY

EMPLOYEE

DATE OF INJURY

DEPARTMENT

AGE OCCUPATION

LOCATION

HOUR

A.M._P.M._DATE REPORTED TO EMPLOYER

ON THIS JOB SHIFT

LENGTH OF EMPLOYMENT

DESCRIPT ION

1. Describe the accident. Include the machine, object, or substance involved and explain exactly what the
injured worker was doing.

2. What did each co-worker or witness say about the accident (if necessary, attach additional sheets),

3. If pain gradually occurred, how does the employee relate this problem to work?

4. Have other employees had injuries, accidents, or near misses at or near this job site? If so, when, where
and how are they related to this accident?

PPSULT
F~
6. Has the worker sought medical treatment?

Date

6. What part(s) of the body were injured? (Be specific, e.g. left knee).
CAUSE

7. Identify the causes of this accident by checking the appropriate boxes below. Remember all causes should be
identified so they can be eliminated.

J

ORGANIZATIONAL CAUSES

L ] Inadequate job training procedures

t ] Failure to enforce safe job procedures

[ ] Inadequate standards for hiring, placement

and upgrading
L ] Lack of safe job procedures
t J Lack of motivation or incentive to work safely
[ J Lack of adequate supervisory training
t J Management disinterest in accident prevention
[ J Lack of competent safety staff services
L ] Management unawareness of safety fundamentals
[ J Failure to assess true accident costs
[ ] Failure to conduct planned safety inspections
I ] Failure to implement adequate preventative

maintenance measures
] Failure to incorporate safety standards in

purchasing practices

[ ] Failure to incorporate safety standards into
the design of production facilities.

t ] Rapid expansion of supervisor and employee
work forces

L ] Active antagonism between management and labor

L ] Drastic up and down changes in production rates

PERSONAL CONDITIONS

[ ] Pre-existing medical conditions or impairment

of worker or co-worker
[ ] Worker's hobbies
[ ] Worker's off job activities
[ ] Worker's personal problems

VII-6

CAUSE (CON'T)

UNSAFE CONDITIONS

] Inadequately guarded

] Defective tools, equipment or substance

] Hazardous arrangement

] Improper illumination

] Improper ventilation

] Unsafe clothing

] Unsafe design or construction

] Faulty equipment

I ] Operating without authority

[ ] Operating at unsafe speed

[ ] Making safety devices inoperative

[ ] Using unsafe equipment

[ ] Using equipment unsafely

[ ] Unsafe loading, placing or mixing

[ ] Distraction, teasing, horseplay

[ ] Failure to use personal protection devices

[ ] Acts of another person not employed by your fii

[ ] Short-cut to save time or effort

i

OTHER CAUSES

I ] Explain:

8. If an unsafe act(s) was a cause of this accident, why was the unsafe act committed?

9. If an unsafe condition(s) was a cause of this accidnet, why did the condition exist?

10. If an organizational cause(s) was a cause of this accident, why did the cause exist?

PREVENTION

11. Complete the following table:

Corrective Action Proposed Responsible Person Target Date Action Taken

Date Completed

CLAIMS COST CONTROL

12. Have all parts of faulty equipment, machinery, or other evidence associated with this accident been preserved

13. If your employee is filing a workers' compensation claim, and you doubt the validity, specify reasons below.
(Attach additional pages if necessary.)

-

Supervisor

Date

Reviewing Mgr.

Date

I

J

SUPERVISOR'S REPORT OF INDUSTRIAL INJURY

ORIGINAL TO YOUR MAIN OFFICE FILE

EMPLOYER .

MAILING ADDRESS
POLICY NO

EXPIRATION DATE

J L

MO DA VR

NAME OF INJURED-
HOME ADDRESS _
JOB TITLE

OEPT

BIRTH DATE

J L

MO OA VR

SOC SEC NO

INJURY DATE.

TIME.

AM
PM

NATURE OF INJURY

(SCRATCH. CUT, BRUISE. ETC I

PART OF BODY INJURED .

HEFT RING FINGER, RIGHT ANKLE. ETC I

NAME OF DR OR HOSPITAL.

WHERE DID ACCIDENT HAPPEN?.

HOW DID ACCIDENT HAPPEN? (STATE SPECIFIC JOB BEING DONE AND WHAT
WENT WRONG INCLUDE MACHINE/TOOL OR OBJECT CONNECTED WITH
ACCIDENT )

IF ACCIDENT WAS CAUSED BY NON-COMPANY PERSON OR BY FAULTY EQUIP-
MENT. GIVE NAME AND ADDRESS

NAME OF WITNESSES

WHAT HAVE YOU DONE OR WILL YOU DO TO PREVENT A SIMILAR TYPE OF
ACCIDENT?

EMPLOYEE S SIGNATURE

DATE REPORTED

SUPERVISOR S SIGNATURE

REVIEWING MANAGER S SIGNATURE

64 too .' mo Supervisor — Send this copy to YOUR main office

This type of accident investigation form normally comes in triplicate bound
in pocket size books. The original is sent to the main office, duplicate to
the doctor with the injured person if possible, and the triplicate remains
in the book for the supervisor.

VII-8

s

1

J

I

SECTION VIII

EMERGENCY PREPAREDNESS

Rationale: The ability to deal with an emergency situation in
the workplace depends on the degree of planning and preparing
that has been done prior to the actual emergency. When
properly prepared, the impact of an emergency on personnel and
property can be greatly reduced.

Core Requirements:

1. Emergency procedures must be established and
emergency phone numbers posted. For remote job
sites, either radio or telephone communications must
be available. Supplemental materials are available
on how to handle emergency situations in the
workplace .

2. Provide first aid materials necessary to allow those
persons trained in first aid, as required in Section
IV, to render prompt treatment.

Optional Considerations:

1. When the job site is located in a remote area, the
location should be known to the emergency medical
service for that area.

J

VIII-1

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SECTION IX

RECORDKEEPING

Rationale : Just as production, sales, etc. must be accounted
for, so must your loss control activities. Recordkeeping is
often viewed as a "necessary evil", however, when properly
planned and organized the burden can be minimized. The types
of activities which must be documented and filed have been
discussed in the preceding Sections and are summarized below.

Core Requirements :

1. Establish and maintain an organized loss control

filing system where the required records are kept as
follows :

a. A copy of your written loss control plan.

b. Accident records (copies or originals);

i. Accident investigation reports as required in
Section VII.

ii. Workers' compensation claim forms.

iii. An accident summary log such as the OSHA 200
shown on page IX-3 or an equivalent.

iv. An accurate record of either total employee

hours worked or the number of employees in any
given quarter. The accident summary log and
employee hours are used to calculate incident
rates. See page IX-4.

IX-1

c. Hazard identification and elimination records I v
(copies or originals).

i. Formal self -inspection reports and written

documentation of corrective action as required
in Section VI.

ii. Job safety observation reports as also
required in Section VI.

d. Training records.

i. Documentation of safety meetings and other
training must be maintained. This should
include a brief description of the topics, who
attended, and any correction actions taken.

Establish and maintain an organized set of personnel
files where the following records are kept:

a. Job application forms and previous employment
history check forms as required in Section II.

b. The signed employee acknowledgement form
indicating familiarity with the loss control plan
rules and procedures as required in Section IV.

Optional Considerations :

1. Maintain any additional records that are related to
the loss control plan but that are not core
requirements .

IX-2

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Incidence Rates for
Safety Management

Incidence rates can be used to show the relative level
of injuries and illnesses among different industries,
firms, or operations within a single firm. Because a
common base and a specific period of time are involved,
these rates can help determine both problem areas and
progress in preventing work-related injuries and ill-
nesses.

How to compute incidence rates

An incidence rate of occupational injuries and ill-
nesses can be calculated quickly and easily. The formula
requires:

(a) The number of injuries and illnesses. Count the
number of recordable cases from the Log and Summary
of Occupational Injuries and Illnesses, osha No. 200
(Appendix C), or refer to the TOTALS line for the year-
ly total for fatalities, injuries and illnesses with lost
workdays, and injuries and illnesses without lost
workdays.

(b) The number of hours all employees actually
worked. Use payroll or other time records. "Hours
worked" should not include any nonwork time, even
though paid, such as vacation, sick leave, holidays, etc.
(If actual hours worked are not available for employees
paid on commission, by salary, or by the mile, etc.,
hours worked may be estimated on the basis of sched-
uled hours or 8 hours per workday.)

An incidence rate of injuries and illnesses may be
computed from the following formula:

(a) Number of injuries and illnesses X 200,000 = Incidence rate
(b) Employee hours worked

(The 200,000 hours in the formula represents the
equivalent of 100 employees working 40 hours per week,
50 weeks per year, and provides the standard base for
the incidence rates.)

NOTE: You can use the same formula to compute in-
cidence rates for:

(1) The number of lost workday injuries and illnesses;

(2) The number of nonfatal injuries and illnesses
without lost workdays;

(3) Cases involving only injuries or only illnesses.

Here is an example of how to compute an incidence
rate:

Jones Furniture Co. recorded 11 injuries and illnesses
(from log and summary, osha No. 200). The total
"hours worked by all employees were 130,000 (from
payroll or other time records).

1 1 x 200,000

16.9

130,000
Therefore, Jones Furniture Co. experienced a rate of
16.9 injuries and illnesses per 100 full-time employees.
To compute an incidence rate for your own firm,
enter the data in the appropriate spaces below and com-
plete the formula.

Number of injuries and
illnesses in your firm

X 200,000

Incidence rale
for your firm

(Round to the
nearest tenth)

Hours worked by
all your employees

The incidence rate for your firm is the number of in-
juries and illnesses per 100 full-time employees.

IX~4

c

I

c

SECTION X

OTHER LOSS CONTROL ACTIVITIES

Rationale ; In addition to the essential elements of a loss
control program already discussed, a number of other activities
can be performed which will further enhance and broaden your
program. Two of these activities are required, as shown below,
while the remainder are optional.

Core Requirements ;

1. When an employee is injured and must be off work,
regular contact with the worker should be maintained.
Such contacts convey concern and can be used to assist
workers in dealing with the compensation system.
Assure the employee that you are not "prying or
checking up", but that you are genuinely concerned
about their progress and well being.

2. Periodically the loss control plan must be reviewed to
insure that it's scope, content and effectiveness is
adequate.

X-l

Optional Considerations :

1. Safety incentives, where employees are rewarded for
attaining and maintaining safety goals, can produce
increased safety awareness on the job.

2. Develop a "back to work" policy where injured workers
are encouraged to return to the job and can perform
alternate duties until fully recovered. Of course,
this must be cleared by the physician treating the
worker, but, again this conveys your concern and
keeps the employee in touch with the workplace.

3. Promote off-the-job safety, such as seat belt use,
through posters or handouts. Even though an
off-the-job injury is not compensable, it may prevent
that individual from working thus creating a hardship
on the employer.

X-2

c

1

DIVISION OF WORKERS' COMPENSATION

Margaret "Peg" Condon Building

5 South Last Chance Gulch

Helena, Montana 59601

FOR RESPONSE TO QUESTIONS ABOUT:

CALL

1. State Fund claims or available benefits. 444-6500

2. State Fund insurance coverage; i.e., enrollments, cancellations, endorsements,
experience modification, volume discount, etc. 444-6440

3. State Fund payroll audits. 444-3247

4. State Fund premium billings. 444-6490

5. Benefit claims of private insurance companies or self-insured employers. 444-6530

6. Approval to operate as a self-insured employer or a private insurance company. 444-6530

7. Silicosis & Occupational disease benefits. 444-6530

8. Vocational Rehabilitation 444-6530

9. Policy Services for employers with private insurance coverage. 444-6530

10. Uninsured Employer's penalties. 444-6530

11. Independent Contractor Applications. 444-6530

12. Subsequent Injury Fund 444-6530

13. Industrial safety, on-site consultations, boiler & mine safety, etc. 444-6401

14. Message Center 1-800-332-6102

6

t

500 copies of this public document were pub-
lished at an estimated cost of $2.28 per copy, for
a total cost of $1,142.50 which includes
$1,020.00 for printing and $122.50 for distri-
bution.