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EXECUTION

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					Chapter 6
Execution

BACKGROUND
            This chapter addresses program execution. Execution is that part of the program
            where NOAA managers, employees and safety staff carry out the day-to-day
            safety activities identified in the NOAA Safety Strategy and funded through
            resource procedures.

            Our discussion will cover four major aspects of safety program execution: Injury
            Reporting; Operational Risk Management; Training; and Outreach.

INJURY REPORTING
Current State
            The U.S. Department of Commerce (DOC) Occupational Safety and Health
            Manual (March 2000), provides policies, procedures, and responsibilities for
            incident reporting, investigation and record keeping. Each employee is responsible
            for reporting accidents to their supervisor. Each supervisor is responsible for
            submitting Commerce Department form number 137 (CD-137), Report of
            Accident/Incident, to the appropriate Administrative Support Center (ASC) safety
            representative. The ASC representative completes the Occupational Safety and
            Health Association (OSHA) form number 200, Log of Federal Occupational
            Injuries and Illnesses.

            The DOC Occupational Safety and Health Manual also provides reporting
            procedures and responsibilities for completion and submission of Department of
            Labor forms CA-1, Federal Employee’s Notice of Traumatic Injury and Claim for
            Continuation of Pay/Compensation, and CA-2, Federal Employee’s Notice of
            Occupational Disease and Claim for Compensation. The employee completes
            their request for compensation, and forwards the form to their supervisor. The
            supervisor completes their section of the form within 10 working days, and then
            forwards the form directly to the DOC contractor managing the Federal
            Employees Compensation Act (FECA) program for DOC.




                                           6-1
Approximately 500 NOAA operating locations report injuries, as follows:

      Injuries with medical bills. Injured employees and their supervisors send
       CA-1 and CA-2 compensation claims to Contract Claims Services,
       Incorporated, a DOC contractor in Irving, TX, for claims processing:

        Approximately half of claims forms are currently being copied and
           sent to the Regional Safety Manager (RSM) to notify the RSM of the
           injury. RSM’s use the claim forms to count injuries and calculate
           injury rates by line office.

        DOC sends monthly copies of CA-1 and CA-2 claims forms to the
           ECHSSO Safety Division Chief, who faxes copies to the RSM’s. The
           Safety Division Chief also faxes copies of claims forms for National
           Marine Fisheries Service (NMFS) employee injuries to the NMFS
           safety manager to honor a request from the NMFS safety manager.

      Supervisors of injured employees send CD Form 137 to RSM’s to report
       accidents. CD 137s are required for injuries and for accidents and near-
       misses.

      The Lost Time Injury (LTI) rate from the Safety Information Reporting
       System (SIRS) is used:

        RSM’s enter OSHA 200 log type data into a SIRS spreadsheet, and e-
           mail an electronic copy monthly to the ECHSSO Safety Division Chief
           for collation into a master SIRS report for NOAA.

        The ECHSSO Safety Division Chief sends the reports to the line office
           safety managers.

Line offices have identified injury and accident reporting inconsistencies (e.g.,
what is reported and to whom it is reported, and the manner and timeliness of
reporting). The forms currently used to report accidents and injuries serve
different purposes for different offices. DOC and NOAA safety offices report that
this, as well as recent changes in reporting submission guidance, may be the
sources of the inconsistency.

Some line offices have recognized and developed procedures to resolve the
reporting inconsistencies within their line office, including the following:

      The Marine Operations Center has drafted an internal instruction for
       routing shipboard and marine center accident reports. The Marine
       Operations Center is evaluating the possibility of using vendor software to
       automate the injury reporting process.




                                6-2
                                                                                      Execution


                   NOAA Fisheries has implemented a reporting process that augments the
                    DOC reporting requirement. At Fisheries, each injured employee’s
                    supervisor sends a detailed e-mail regarding every mishap within 24 hours
                    of occurrence. The email notifies the Deputy Assistant Administrator for
                    Operations and leadership throughout NOAA Fisheries. Upon notification
                    of the mishap, all leadership levels within NOAA Fisheries take
                    appropriate corrective action.

Desired State
           Supervisors report accidents rapidly throughout the supervisory chain of
           command, with information available for review by the supporting line office
           safety staff. This timely reporting provides responsible managers information they
           need to take timely corrective action, and line office safety staff to provide advice
           to their managers in accident investigations and hazard abatement options.
           Accident information is available to all supervisory levels faster than the
           compensation claim information, and meets time requirements of 29 CFR 1960
           for notifying OSHA of fatalities and hospitalizations within 8 hours. Regional
           Safety Managers have access to accident information for them to fulfill their roles
           in providing technical support to NOAA locations in their geographic region.

DEFENSE LOGISTICS AGENCY

           Defense Logistics Agency has developed and implemented their Safety and Health
           Information Reporting System (SHIRS), which has been in operation for several
           years. SHIRS is a robust database designed to report and monitor mishaps and
           their associated costs throughout DLA. Safety staff record in SHIRS those
           accidents reported to them by supervisors. As a check on supervisor accident
           reports, SHIRS automatically receives injury compensation claim data from the
           DoD Civilian Personnel Management System (CPMS)/Department of Labor
           Workers Compensation Office, and matches injury claims against the accident
           reports. Injury claims without an accident report are referred to the safety manager
           and workplace supervisor for investigation and reporting in SHIRS. SHIRS
           currently operates using a client-server software system. A fully web-enabled
           version is being considered.

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

           NASA has a mature injury reporting process that has been in place for many
           years. Currently, this automated process is being modified to a web-based
           platform. Safety and health professionals crosscheck the mishaps reported in this
           in-house Incident Reporting Information System (IRIS) with activity reported in
           the workers compensation claims process.




                                            6-3
NATIONAL INSTITUTE OF SCIENCE AND TECHNOLOGY

           The National Institute for Standards and Technology (NIST), as an agency in the
           Department of Commerce (DOC) with NOAA, uses DOC procedures for injury
           compensation claims. DOC has hired a contractor to manage all workers
           compensation claims from all DOC organizations, including those originating at
           NIST and NOAA. DOC receives the claims directly from the contractor claims
           processor, and relies on these claims to monitor DOC accident rates.
           Unfortunately, this claims process has not generated accurate information for
           NIST or for NOAA. The NIST Occupational Health and Safety Directorate
           (OHSD) Director has discovered problems ranging from underreporting of
           accidents to claims assigned to the wrong organization. The NIST OHSD Director
           is instituting a major initiative to increase reporting and improve understanding of
           the sources of accidents.

           NIST is asking injured employees to report first to the NIST Health Unit before
           seeking medical care from their personal health care provider. The Health Unit
           has an on-site emergency medical technician and ambulance for transporting
           employees to a local hospital for more extensive care when needed. When
           employees report to the Health Unit, they fill out a workers compensation claim
           form and a CD-137. The Health Unit sends a copy of the CD-137 to the injured
           employee’s supervisor and to the Safety Office to collect additional information
           on the accident. For employees not using the Health Unit, NIST also provides a
           copy of the workers compensation claim forms and CD-137 on the NIST intranet
           web site. As a quality control check, the Safety Office reviews all workers
           compensation claims provided by DOC to make sure the Safety Office has
           accident reports for all injuries. OHSD summarizes the accident data and sends
           the Operating Unit Directors monthly reports of injuries.

           The OHSD Director feels that the new process with employees reporting to the
           Health Unit first is improving injury reporting. Since instituting the new
           procedures, the NIST accident rate increased in Fiscal Year (FY) 2003. The
           OHSD Director is expecting the accident rates to decrease in FY 2004 as the
           improved accident reporting provides information to prevent accidents.

           In addition to this traditional accident tracking and analysis by OHSD, the
           supervisory chain performs direct verbal notification of accidents from the
           supervisor to the line manager to the Operating Unit Director and to the NIST
           Director and Public Relations Office.

Recommendations
                 Issue policy requiring employees and supervisors report accidents within
                  eight working hours to the management level responsible for performing
                  accident investigations.



                                           6-4
                                                                                       Execution


                   Issue accident investigation policy identifying levels and oversight for
                    accident review.

                   Establish trained mishap investigation teams.

                   Conduct NEC reviews of serious mishaps (i.e., a mishap resulting in a
                    fatality, three or more hospitalizations, permanent disability, five or more
                    lost work days, or high potential for multiple injuries).

                   NOAA develop or purchase a web-based accident reporting system to
                    support accident reporting to line managers and supporting safety staff.

OPERATIONAL RISK MANAGEMENT
Current State
           Operational risk management (ORM) is the process whereby line managers
           manage safety risks for their operations using the following steps:

                   Identify safety hazards in work operations and locations.

                   Assess risk of accidents from these hazards.

                   Identify potential corrective actions, including cost of implementing
                    expected effectiveness and controlling risk and the risk remaining after
                    implementation.

                   Select corrective actions to be implemented, and the accompanying
                    residual risk, at the appropriate level of authority.

                   Implement corrective actions.

                   Evaluate corrective actions for their effectiveness.

           There is evidence of ORM principles being applied at multiple locations within
           NOAA. However, application of ORM is inconsistent. NOAA Marine and
           Aviation Operations (NMAO), National Weather Service (NWS) and National
           Marine Fisheries Service (NMFS) have an existing approach toward
           implementing ORM principles within their operations and tasks. Other line offices
           rely on job hazard analyses (JHAs) as a method to identify hazards. JHAs are also
           applied inconsistently throughout NOAA.

Desired State
           NOAA institutionalizes the principles of Operational Risk Management (ORM)
           throughout the organization. ORM will be a decision making tool used by people


                                             6-5
          at all levels to increase operational effectiveness by anticipating hazards and
          reducing the potential for loss, thereby increasing the probability of a successful
          operation or task. The benefits of applying the ORM process will reduce mishaps,
          lower injury and property damage costs, provide for effective use of resources,
          and improve training realism and effectiveness.

NAVY AND MARINE CORPS OPERATIONAL RISK MANAGEMENT

          Military commanders have a fundamental responsibility to safeguard highly
          valued personnel and material resources, and to accept only the minimal level of
          risk necessary to accomplish an assigned mission. Historically, a greater
          percentage of losses during combat operations was caused by mishaps than by
          enemy fire.

          Since 1991, ORM, applied both in day-to-day operations and during crisis
          periods, has produced dramatic results in reducing these losses. All naval
          missions, as well as daily routines, involve risk. Every operation, both on- and off-
          duty, requires some degree of decision making that includes risk assessment and
          risk management. The naval vision is to develop an environment where every
          leader, sailor, marine and civilian is trained and motivated to personally manage
          risk in everything they do, thereby completing all operations with minimum risk.

          ORM is a decision making process that enhances operational capability. ORM is a
          method for identifying hazards, assessing risks and implementing controls to
          reduce the risk associated with any operation. Implementation of ORM in the
          Department of the Navy will be accomplished as follows:

                ORM will be included in the orientation and training of all military
                 personnel. The level of training will be commensurate with rank,
                 experience, and leadership position.

                ORM lessons learned will be submitted to the Chief of Naval Operations
                 and/or Commandant of the Marine Corps for inclusion in ORM databases.

                The ORM process will be integrated into all levels of a command.

          The Navy and Marine Corps make it clear that the leader directly responsible for
          the mission makes ORM decisions. Prudence, experience, judgment, intuition and
          situational awareness are critical elements in making effective risk management
          decisions. When the leader responsible for executing the mission determines that
          the risk associated with that mission cannot be controlled at their level, or goes
          beyond the commander’s stated intent, they shall elevate the decision through
          their chain of command.




                                           6-6
                                                                                    Execution


         The ORM concept

               is a decision making tool used by people at all levels to increase
                operational effectiveness by anticipating hazards and reducing the
                potential for loss, thereby increasing the probability of a successful
                mission;

               increases the ability to make informed decisions by providing the best
                baseline of knowledge and experience available; and

               minimizes risks to acceptable levels, commensurate with mission
                accomplishment. The amount of risk taken varies, depending on the
                mission, but the process is the same. Applying the ORM process reduces
                mishaps, lowers costs, and results in a more efficient use of resources.

         ORM incorporates the following four principles:

               Accept risk when benefits outweigh the cost.

               Accept no unnecessary risk.

               Anticipate and manage risk by planning.

               Make risk decisions at the right level.

Recommendations
         Establish an ORM Process Improvement Team

         Develop an ORM chapter as part of the NOAA Safety Manual, which includes
         roles and responsibilities and an overall implementation plan.

         Develop curricula and incorporate ORM policy and instruction in each level of
         leadership training (senior-management, mid-level management, first-line
         supervisors and employee levels).

         Perform an ORM policy gap analysis of all written NOAA and line office policies
         and procedures.




                                         6-7
TRAINING
Current State
DEPARTMENT OF COMMERCE REQUIREMENTS

           Department of Commerce Safety Manual, Chapter 6, contains NOAA safety
           training policy. Table 6-1 of that Manual provides the recommended minimum
           safety training for job categories (top management, supervisory, non-supervisory,
           employee representatives, collateral duty representatives, and safety
           professionals).

           DOC has a strong, comprehensive training policy. It specifically states “top
           management personnel shall receive OSH [occupational safety and health]
           training to enable them to actively and effectively support OSH programs in their
           specific areas of responsibility.” In addition to the coverage of appropriate
           statutes, regulations, and applicable DOC OSH standards, management level
           training shall include the following:

                1. An in-depth examination of management’s responsibilities that includes
                   training topics covering analysis of compliance procedures, the study of
                   current accident and injury reporting procedures, and a thorough
                   understanding of investigation/inspection procedures;

                2. A review of DOC policy on all relevant aspects of the DOC OSH program
                   at all levels throughout the Department; and

                3. A comprehensive examination and analysis of the operating unit program
                   objectives and goals.

           The training goal for managers and supervisors is to enable them to recognize
           unsafe/unhealthful working conditions and practices in the workplace. Training
           goals also includes developing skills necessary to manage the OSH program at the
           work unit level, developing management skills training to motivate subordinates,
           and training that results in integration of occupational safety with job training.
           Finally, the supervisor training policy covers training for newly appointed
           supervisors.

           Specific safety training for non-supervisory personnel includes a requirement for
           specialized job safety and health training directed to the individual’s work site
           with input and direction from the workplace supervisor. For new employees, the
           manual lists required training, as follows:

                1. Individual responsibility for safety and health;
                2. Employee reporting procedures for hazardous operations/conditions;


                                            6-8
                                                                                        Execution


               3. Awareness of hazards common to the individual’s work site, trade,
                  occupation or tasks; and
               4. Departmental and local policy on occupational safety and health.

            The DOC Safety Manual also provides detailed training requirements for Safety
            and Health Specialists and Collateral Duty Personnel.

NOAA-WIDE TRAINING

            Currently, NOAA does not have a formal training program that follows the DOC
            training policy and training requirements. NOAA does not appear to have a
            standard way of certifying, recording, and tracking training that has been
            conducted and completed. While the NOAA ECS Training Team establishes
            budget priorities for training, the Training Team did not meet in FY2003 because
            there was no ECS budget for training. NOAA NFA is currently providing
            comprehensive safety training to supervisors on their roles and responsibilities
            through either DuPont training (funded by the line offices) or NOAA Stop Taking
            Avoidable Risks (STAR) (funded by NFA). These programs include safety
            behavior, injury reporting, and all other supervisor functions. NOAA NFA has
            initiated electronic safety training for all employees. These programs have been
            accepted and well supported.

LINE OFFICE TRAINING

            Each line office has implemented a safety training program, but the degree of
            implementation varies between line offices. The line office training efforts are
            described in detail in the line office reports provided as appendices to this report.

            NMAO provides its employees with additional job-related safety training. For
            example, all NOAA Corps Officers receive pre-assignment training that prepares
            them for NOAA ship and aircraft positions, NOAA shipboard personnel receive
            training based on established International Convention on Standards of Training,
            Certification, and Watchkeeping for Seafarers (STCW) requirements, and NOAA
            divers receive extensive training. Fleet inspectors attend U.S. Coast Guard
            training in ship inspection and shipboard safety standards. Aircraft maintenance
            personnel are trained to meet FAA and related requirements. Dive program and
            small boat program managers are fully trained and conversant in their areas of
            expertise.

            NWS and NMAO each have electronic training tracking systems. NMAO is
            investigating and implementing improvements in certification, record keeping,
            and tracking of personnel being trained. A manual record keeping system is
            currently in place at the Marine Operations Center (MOC) until an automated
            system can be implemented to meet Integrated Safety Management (ISM)
            requirements.



                                             6-9
PROFESSIONAL STAFF TRAINING

           NOAA has not established standard training requirements for its safety
           professionals. Some, but not all, of the collateral duty safety representatives have
           the 40-hour OSHA 600 Collateral Duty Safety training course.

Desired State
           Every job has been evaluated using a job hazard analysis to identify changes in the
           process and employee training requirements for unabated hazards. Employees
           have received the training per the requirements. The safety professionals assist
           managers, supervisors and employees in completing the Job Hazard Analyses.
           Managers and supervisors know and understand the hazards of each task.
           Managers, supervisors, and employees receive web-based safety training (i.e., e-
           learning).

           There is a training tracking system in place. Training information is electronically
           recorded into a database. The database reminds managers, supervisors, and
           employees about periodic training requirements.

           Managers/supervisors/employees evaluate the adequacy of their training. A
           training team uses these evaluations to improve each training course.

           All new employees receive safety orientation training. All new collateral duty
           safety representatives have received the OSHA 600 collateral duty safety class.

           Safety professionals obtain training and maintain their professional accreditation
           (i.e. CSP, CIH, PE). Safety professionals receive at least one 40 hour advanced
           course and attend one safety conference per year.

NATIONAL INSTITUTE OF SCIENCE AND TECHNOLOGY

           Training—All employees and associates receive training in the skills required to
           understand and comply with all safety policies and requirements applicable to
           their daily activities.

                   NIST employees and associates (including students) receive training in
                    NIST safety policies, practices, and procedures (routine and emergency),
                    with additional training for new employees and associates.

                   NIST Safety Council recommends a suite of suitable training materials
                    appropriate for different work environments.




                                           6-10
                                                                                        Execution


                 NIST ensures that all students and associates receive appropriate
                  supervision in safety procedures.

                 NIST developed incident investigation procedures and trains supervisors
                  in their use.

           The NIST Safety Office recognizes the difficulty of providing new employees
           training in safe work procedures. They currently provide a 5-minute introduction
           to safety during new employee training and provide supervisors with a standard
           form to train new employees.

           Additionally, NIST provides task-specific safety training to employees, and
           maintain a matrix of training completed for each employee. The Safety Office is
           considering using Training and Education in the 21st Century, Inc., to provide
           employees task specific safety training.

           OHSD has plans to complete accident investigation training for managers in the
           supervisory chain from Operating Unit Directors to Division Chiefs. After 2004,
           the Safety Office plans to train supervisors subordinate to Division Chiefs. The
           Chair of the Safety Council introduces each accident investigation training class to
           demonstrate accident investigations are a management responsibility, not a safety
           staff task.

           NIST senior management attended the 2-day DuPont Management Leadership
           Course. The DuPont Safety Director provided the introductory presentation.
           Attendees included the NIST Director, Operating Unit directors and deputy
           directors, and Division chiefs (typically GS-15 level). NIST managers took three
           field trips to the DuPont Research Facility and met with DuPont Senior
           Management. These trips gave NIST managers insight into how safety is
           integrated into the daily operations for a major research operation similar to NIST.
           After the field trips, NIST managers identified best practices NIST needed to
           follow to instill a safety culture into NIST operations. DuPont benchmarked the
           Chemical Science & Technology Laboratory and the Electronics and Electrical
           Engineering Laboratory and found the need to increase the safety culture in these
           operations.

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

           NASA provides an exhaustive array of safety training. It includes instructor-based
           training at central locations, instructor visits to Centers, and on-line courses at its
           “Site for Online Learning And Resources”(SOLAR) at
           https://solar.msfc.nasa.gov:443/solar/delivery/public/html/newindex.htm.




                                            6-11
U.S. POSTAL SERVICE

            USPS established a Safety Training Working Group in FY00 to evaluate the
            current state of safety training and to recommend a course of action to solve USPS
            training issues. One result was to focus the workgroup’s efforts on the most
            critical OSHA programs, which they achieved by developing a training matrix.

            The training matrix identified critical OSHA programs and corresponding
            OSHA/USPS training requirements. The matrix breaks training requirements into
            three groups: Customer Services; Vehicle Maintenance Facilities; and Plants,
            Bulk Mail Centers and Air Mail Centers. Designated assignments, job
            classifications and employee potential for exposure then serve to filter specific
            training needs.

            If the safety training is not available from USPS, the matrix contains guidelines to
            develop local training or to evaluate vendor training that meets the OSHA
            required elements. USPS distributed the matrices and advised the USPS Area
            Directors to develop a plan for identifying and addressing gaps in OSHA and
            postal required training.

            USPS identified the benefits of this approach to include: management
            commitment to safety training; completing required training; reducing injuries and
            illnesses; reducing training costs; and increasing the use of existing training
            resources.

            As the next step, the USPS Safety Training Working Group developed “InfoPaks”
            for all Facility Safety Coordinator (their collateral duty safety personnel) and
            made them available on the USPS Intranet. Of significance is the fact that the
            American Society for Training and Development recognized the USPS with an
            “Excellence in Practice” citation for the Facility Safety Coordinator Training
            Course, as follows: “This self-study course targets 35,000 postal managers who
            are assigned collateral safety duties. The product is available in both web-based
            and hard copy formats. ASTD is the world’s premiere professional association in
            the field of workplace learning and performance.”

            Currently, USPS is evaluating a prototype “Safety and Health Training Decision
            Tree (SOHDT)” web based application that will enable managers and supervisors
            to plan employee safety training requirements based on their assigned tasks.
            Managers and supervisors will use the SOHDT to identify employees that require
            training and select courses to meet OSHA and Postal Service safety and health
            training requirements.

            Each USPS Area/District/Plant safety office will answer a series of initial profile
            questions. By answering the profile questions, experienced safety professionals
            identify basic safety and occupational health (SOH) training requirements for each
            USPS plant, facility or installation. For example, the first profile covers asbestos.


                                            6-12
                                                                                    Execution


         The first profile question is “Does this facility have asbestos?” A safety specialist
         answers the asbestos profile question. If the answer is ‘Yes,’ asbestos training is
         included on the list of training subjects that managers and supervisors at that
         facility must address. If the answer to the profile question is ‘No,’ asbestos is
         eliminated from the SOH training requirements at that facility.

         Upon completion of the profile questions, each identified manager and supervisor
         with web access can view his/her facility-specific list of SOH training
         requirements.

         Accessing the list leads each manager/supervisor through a sequence of queries
         and data entry forms, for each of the applicable, facility-specific, OSHA training
         subjects. The queries and data entry forms enable managers and supervisors to
         develop and update an annual SOH training plan for each of his/her employees.

         The annual training plan will roll up to various levels (e.g., work unit, department,
         plant/facility, district and area) for review, analysis and approval.
         Managers/supervisors execute their training plan, monitor completion rates, and
         change or modify the training plan, as necessary, throughout the year.

         During the fiscal year, HQ USPS plans to visit each Area Office to review
         completion of objectives and training targets and reports. At the end of the year,
         HQ USPS and the Areas/District SOH Offices review annual training plans for
         completion of objectives, and compare these objectives against accident rates and
         other outcome measures to identify potential successes in affecting accident rates.
         HQ USPS and the Areas/District SOH Offices use the outcomes to update the
         SOHDT, the USPS Safety and Health Program Evaluation Guide and facility
         action plans and to choose objectives and metrics for the coming fiscal year.

Recommendations
               Develop and publish safety training policy and procedures for all
                employees in the NOAA Safety Manual.

               Establish training policy for Safety professionals to attend annual training
                to maintain their technical skills and certifications (i.e. CSP, PE, CIH).

               Implement a Job Hazard Analysis (JHA) program to evaluate each job and
                identify job-specific training needs and hazards

               Develop an automated training tracking system for NOAA-wide
                application, including a review of NWS, NMAO, and commercial training
                tracking systems.




                                         6-13
                   Develop and Implement a new employee safety orientation training and
                    checklist for supervisors to use for new employees or when they change
                    positions.

                   Analyze training options, including the course provider, course names and
                    content, cost, and the effectiveness of the training.

                   Advertise the availability of (and provide access to) online safety training
                    on the NOAA and line office homepages.

                   Evaluate training; recommend training programs; and purchase training
                    products and training courses for evaluation and reporting).

                   Host periodic safety workshops for the NOAA safety staff.

                   Host Annual safety conference for the NOAA safety community.

                   Implement ergonomics awareness training

                   Provide STCW training for shipboard employees to meet new and current
                    federal and international requirements.

INDUSTRIAL HYGIENE AND MEDICAL SURVEILLANCE
Current State
           NOAA conducts few industrial hygiene surveys to assure both management and
           employees that unhealthful exposures are not occurring in the work environment.
           The ability to conduct industrial hygiene surveys is limited by the insufficient
           number of industrial hygiene personnel, sampling equipment, travel funds and the
           costs of laboratory analysis.

           A medical surveillance program is a process that follows the medical condition of
           employees, over a period of time, who have been exposed to significant on-the-
           job health hazards. It is also required for employees who are required to wear
           respiratory protection or hearing protection. NOAA does not have a consistent
           medical surveillance program across all line offices to monitor health effects in
           exposed employees. As a notable exception, NMAO provides medical
           surveillance supported by extensive written protocols.

Desired State
           NOAA conducts industrial hygiene surveys consistent with “Best in Class”
           criteria. Surveys are completed annually for high risk operations (e.g., research
           facilities, laboratories), biannually for medium risk operations, and as needed for
           low risk operations.


                                            6-14
                                                                                     Execution


           NOAA performs targeted medical surveillance for employees to monitor for the
           health effects of workplace exposures, and to ensure they are qualified to perform
           assigned duties (e.g., wearing respirators, performing fire fighting).

Recommendations
                   Develop an inventory of required industrial hygiene surveys by location
                    and frequency

                   Conduct Industrial Hygiene surveys of work spaces identified by the line
                    office safety managers

                   Perform medical surveillance as determined by the industrial hygiene
                    surveys.

OUTREACH
Current State
PROFESSIONAL DEVELOPMENT

           The DOC Manual, Chapter 4.02, states clear support for safety staff participation
           in the Federal Advisory Council on Occupational Safety and Health (FACOSH)
           and Field Federal Safety and Health Councils sponsored by OSHA. Some of the
           NOAA safety staff participate in these and other professional organizations.

           NOAA schedules environment and safety meetings and conferences to provide
           forums for NOAA Environmental Compliance and Safety (ECS) professionals the
           opportunity to exchange information and plan activities. One of these forums is
           the NOAA annual ECS Conference. Unfortunately, due to funding constraints in
           FY03, NOAA cancelled this conference.

EMPLOYEE INFORMATION

           The Department of Commerce and NOAA have safety websites. However, the
           information posted on the websites requires more consistency. For example, the
           website could provide consistent reporting to management and employees of
           monthly, quarterly, and annual injury and illness rates for NOAA and each line
           office.

           Among the line offices, NMAO continues to evaluate other means to improve
           prevention and outreach. NMAO periodically publishes and distributes a safety
           newsletter to all NMAO employees. The newsletter serves as a reminder to keep
           safety foremost in employees’ minds and actions and provides a means to
           disseminate safety information on topics pertinent to ship and aircraft operations.



                                           6-15
          It provides a means to report on the status of safety-related projects, accident
          statistics, and other areas of concern.

          NWS conducts monthly conference calls with Regional and Operating Unit
          Environmental/Safety Coordinators to discuss various issues related to
          implementation of the safety program. The NWS Safety Officer communicates
          with Environmental/Safety Coordinators via e-mails on a daily basis. Other
          examples of NWS outreach include,

                   NWS designed a safety awareness poster that is in stock at the National
                    Logistics Support Center.

                   NWS has an environmental/safety web page that has NWS safety and
                    health policy, NWS safety manual, legal memoranda, and NOAA
                    information available for downloading.

          NOAA outreach efforts also include Regional Safety Managers (RSM) who
          conduct inspections and evaluations, and provide training and follow up support,
          as resources permit. The following examples offer opportunities to improve RSM
          outreach efforts.

                   RSM’s receive requests for support and funding directly from the line
                    offices. In those instances, if the line office does not have funding, the
                    RSM safety advisory support is further limited.

                   Field activity visits indicate that many field facilities do not post the
                    OSHA poster and very few offices post additional safety posters in their
                    workplace. Furthermore, was common to find that employees did not
                    know their safety representatives.

          Currently, the DOC Safety Manual does not address safety awards/recognition.
          NOAA’s safety awards and recognition program is beginning.

Desired State
          NOAA’s outreach efforts result in the following:

                   Managers and employees know whom they can contact for assistance and
                    information.

                   Managers and employees feel that they play a vital role in NOAA’s Safety
                    Program.

                   Employees are aware of the safety status of their work environment and
                    the steps that are being taken to ensure safe conditions.

                   A fully developed NOAA safety awards and recognition program exists.


                                             6-16
                                                                                   Execution


             Line offices and multi-agency facilities work together in a coordinated
              fashion.

             Data analysis becomes the launching pad for numerous safety initiatives.

             Facility employees interact with the communities surrounding them and
              work with local safety groups/agencies.

             NOAA urges safety professionals and safety officials to attend safety
              conferences.

             NOAA uses websites to serve as on-line safety offices, which provide
              substantial safety related content.

NASA

       NASA Headquarters and the Centers extensively use websites to serve as virtual
       on-line safety offices with substantial safety related content. NASA is currently
       putting in a new on-line system for incident reporting and corrective actions.

NIST

       The NIST intranet main page provides a direct link to a safety web page
       maintained by OHSD. OHSD posts safety messages, training materials, and a
       summary of recordable injuries for all NIST employees to view.

       The NIST intranet main page provides a direct link to a “Staff Forum” where
       NIST employees can provide feedback, suggestions, or other comments on NIST
       operations, including reporting hazards and improving safety. Employees can
       submit comments anonymously or identify themselves for direct follow-up. The
       NIST “Program Office” is the executive-level office that monitors employee
       submissions and refers comments to staff offices to provide responses. The
       Program Office sends employee comments about safety, including reported safety
       hazards, to OHSD for review and response. The Program Office publishes staff
       office responses on the web site for the viewing of all employees.

       NIST communicates their safety vision and expectations clearly and succinctly:
       “Safety will be a visible part of all activities at NIST. All persons are expected to
       report all incidents, accidents, and unsafe conditions. NIST management will
       communicate all accidents, near misses, and root causes to everyone at NIST.”

       NIST also makes it clear that they recognize and reward safe behavior, while
       noting “Unsafe behavior will be corrected promptly.” The NIST Administrative
       Manual is undergoing a revision that will increase consequences for unsafe
       conduct and behavior.




                                        6-17
Recommendations
         Enhance the ECS website as a one-stop location for employee safety information.
         Publicize its existence.

         Create an electronic safety suggestion box on the web.

         Establish safety councils/committees at all facilities or have membership on an
         established council/committee where NOAA is not the responsible official.

         Review and update the NOAA safety awards/recognition program and investigate
         other safety awards offered by outside agencies.

         Host NOAA safety days for NOAA employees

         Encourage NOAA Safety professionals to participate on safety committees and
         workgroups outside NOAA

         Publish a NOAA Environmental, Health, Safety & Emergency Preparedness
         Report




                                        6-18

				
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