SETTING UP AN EFFECTIVE SAFETY PROGRAM October 2011 Prepared by: Dan Dunn DOES YOUR COMPANY HAVE A SAFETY, HEALTH AND ENVIRONMENTAL PROGRAM ? “Be Safe” “Safety First” “Think Safety” Safety Scorecards LTIR TRIR Training Videos Safety Award A written Safety and Health Policy Statement: • Communicate managements commitment to a safe and healthy work environment; • Strives to eliminate occupational health and safety risks in all drilling activities; • Raises the health and safety awareness and responsibility of all employees; and • Conforms to all relevant legislation. A written Environmental Policy Statement: • Recognizes company and employee responsibilities to protect the communities in which we work; • Protects the employee’s environmental health; • Committed to preserving natural resources; and • Requires compliance to all applicable environmental laws and regulations. Safety, Health & Environmental Issues and Hazards: • Identify the major safety, health and environmental issues and potential hazards that employee’s might face; • Form a committee made up of individuals from various areas of your organization to identify these issues; and • Interview employees and managers, listen to their concerns and recommendations. Prepare written programs Each program should contain several sections: Purpose • List the objectives of the program. Scope • Is this program directed to your drillers, supervisors, sub- contractors, shop and yard employees, office staff? The entire company? Clearly define to whom this program applies. Responsibilities • Define the individual responsibilities of your employees. Prepare written programs (continued) Various Program Elements • This is the backbone of the program, it should provide the how-to information to the reader; • Outline in as much detail as practical, the safety guidelines and practices required by your company; and • Include regulatory agency requirements. Training Requirements • Determine your company training requirements; and • Determine any regulatory agency training requirements. Training Design a Training Program that satisfies the following requirements: • Makes employees aware of the policies and programs; • Makes employees aware of their individual responsibilities under the programs; and • Provides technical training along with safety training to the employee. Title 29 CFR Part 1910 deals with occupational safety and health standards necessary to provide safe or healthful employment and places of employment. Title 29 CFR Part 1926 deals with construction industry regulations requiring the same. Who must receive OSHA training? • All employees working on site (such as but not limited to equipment operators, general laborers and others) exposed to hazardous substances, health hazards, or safety hazards and their supervisors and management responsible for the site. • All employees working on sites receiving federal funding under a stimulus program. Training shall cover the following elements: • Names of personnel responsible for site safety and health; • Safety, health and other hazards present on the site; • Proper use of personal protective equipment; • Work practices by which the employee can minimize risks from hazards; • Safe use of engineering controls and equipment on the site. • Recognition of symptoms and signs which might indicate over exposure to hazards; and • The contents of the site safety and health plan which includes decontamination procedures, emergency response plans and spill containment programs. Initial training 40 hours • General site workers engaged in hazardous substance removal or other activities which expose or potentially expose workers to hazardous substances and health hazards shall receive a minimum of 40 hours of instruction off the site, and a minimum of three days actual field experience under the direct supervision of a trained experienced supervisor. Initial training 24 hours • Workers on site occasionally for a specific limited task and who are unlikely to be exposed over permissible exposure limits and published exposure limits shall receive a minimum of 24 hours of instruction off the site, and the minimum of one day actual field experience under the direct supervision of a trained, experienced supervisor; or • Workers regularly on site who work in areas which have been monitored and fully characterized indicating that exposures are under permissible exposure limits and published exposure limits where respirators are not necessary, and the characterization indicates that there are no health hazards or the possibility of an emergency developing, shall receive a minimum of 24 hours of instruction off the site, and the minimum of one day actual field experience. Refresher Training 8 hours • Employees, managers and supervisors shall receive eight hours of refresher training annually on the same elements of initial training and any critique of incidents that have occurred in the past year that can serve as training examples of related work, and other relevant topics. Qualifications for OSHA 40, 24 and 8 hr. trainers: • Trainers shall be qualified to instruct employees about the subject matter that is being presented in training. Such trainers shall have satisfactorily completed a training program for teaching the subjects they are expected to teach, or they shall have the academic credentials and instructional experience necessary for teaching the subjects. Instructors shall demonstrate competent instructional skills and knowledge of the applicable subject matter. Training Certification • Employees and supervisors that have received and successfully completed the training and field experience shall be certified by their instructor and trained supervisor as having completed the necessary training. A written certificate shall be given to each person so certified. Any person who has not been so certified shall be prohibited from engaging in hazardous waste operations. Employees requiring medical surveillance The medical surveillance program shall be instituted by the employer for the following employees: • All employees who are or may be exposed to hazardous substances or health hazards at or above the established permissible exposure limit, above the published exposure levels for these substances; • All employees who wear a respirator for 30 days or more a year; • All employees who are injured, become ill or develop signs or symptoms due to possible overexposure involving hazardous substances or health hazards from an emergency response or hazardous waste operation; and • Members of HAZMAT teams. Frequency of medical examinations Medical examinations and consultations shall be made available by the employer to each employee on the following schedules: • Prior to assignment; • At least once every twelve months for each employee covered; • At termination of employment or reassignment to an area where the employee would not be covered if the employee has not had an examination within the last six months; • As soon as possible upon notification by an employee that the employee has developed signs or symptoms indicating possible overexposure to hazardous substances or health hazards, or that the employee has been injured or exposed above the permissible exposure limits or published exposure levels in an emergency situation; and • At more frequent times, if the examining physician determines that an increased frequency of examination is medically necessary. Recordkeeping Employee training records • All records of employee training and training certificates for initial training and refresher training shall be preserved and maintained for at least the duration of employment plus 5 years. Employee medical records • The medical record for each employee shall be preserved and maintained for at least the duration of employment plus thirty (30) years. OSHA 10 hour Construction Industry Outreach Training Programs • Voluntary program to train entry level workers in the basics of safety and health hazard recognition and prevention. OSHA 30 hour Construction Industry Outreach Training Programs • Provides a variety of training to workers with some safety responsibility and focuses on hazard identification, avoidance, control and prevention. OSHA authorizes trainers who complete construction and general industry train-the-trainer courses to conduct occupational safety and health classes for workers. Title 30 CFR deals with mining and mineral resources, and includes safety standards for surface mining and underground mining operations. Part 46 – Training and retraining of miners engaged in shell dredging or employed at sand, gravel, surface stone, surface clay, colloidal phosphate, or surface limestone mines. Part 48 – Training and retraining of surface and underground miners. Who must receive MSHA training? • Any person working in a surface or an underground mine and who is engaged in the extraction and production process, or who is regularly exposed to mine hazards, or who is a maintenance or service worker employed by the operator or a maintenance or service worker contracted by the operator to work at the mine for frequent or extended periods. Training shall include the following courses: • Explosives; and • Health and safety aspects of the tasks • Instruction in the statutory rights assigned; of miners; • Self rescue and respiratory In addition to this training, all devices; underground miner training shall • Transportation controls and also include the following communication systems; courses: • Roof and ground control and ventilation • Introduction to work environment; plans; • Escape and emergency • Mine maps; escapeways; and emergency evacuation plans; evacuation; and • Prevention of accidents; • Mine gases. • Ground controls; • Health; • Hazard recognition; • Electrical hazards; • First aid; Initial training Surface mines • Each new surface miner shall receive no less than 24 hours of training. • Each experienced surface miner must receive at least 8 hours of training. Underground mines • Each new underground miner shall receive no less than 40 hours of training; • Each experienced underground miner must receive at least 8 hours of training. Experienced miner means a miner who has completed MSHA approved new miner training and who has had at least 12 months of mining experience. Refresher Training 8 hours • Each miner shall receive a minimum of 8 hours of annual refresher training. Task Training Miners assigned to new work tasks as mobile equipment operators, drill rig operators and other machine operators shall not perform new work tasks until given training in the following areas: • Health and safety aspects and safe operating procedures for work tasks, equipment, or machinery in an on-the job environment; and • Safe operating procedures applicable to new or modified machines or equipment to be installed or put into operation. Hazard Training At least once every 12 months, a miner must receive hazard training that includes the following instruction, which is applicable to the duties of such miner: • Hazard recognition and avoidance; • Emergency and evacuation procedures; • Health and safety standards, safety rules and safe working procedures; • Self-rescue and respiratory devices; and • Such other instruction as may be required based on circumstances and conditions at the mine. Training certification and recordkeeping Upon completion of MSHA approved training program, the certified instructor shall record and certify on MSHA Form 5000-23 that the employee has received the specified training. • A copy of the training certificate shall be given to the employee at the completion of the training. This certificate must be available when working at a mine site, for inspection by MSHA; and • Copies of training certificates for current employees shall be kept for 2 years or for 60 days after termination of employment. Title 49 CFR – Transportation “Commercial Vehicle” defined Part 390 of the Federal Motor Carrier Safety Regulations defines a commercial motor vehicle as any self-propelled or towed motor vehicle used on a highway in interstate commerce to transport passengers or property when the vehicle: • Has a gross vehicle weight rating or gross combination weight rating, or gross vehicle weight, or gross combination weight of 10,001 pounds or more, whichever is greater; or, • Is designed or used to transport more than 8 passengers for compensation; or, • Is designed or used to transport more than 15 passengers and is not used to transport passengers for compensation; or, • Is used in transporting hazardous material in a quantity requiring placarding under regulations. Driver Qualification Chart Medical Certificate 0 10,000 26,000 80,000 + Non CDL with limitations Class "C" CDL Class "B" CDL Class "A" CDL Class A - Any combination of vehicles with a gross combination weight rating of 26,001 pounds or more if the vehicle(s) being towed have a GVWR of more than 10,000 pounds. Class B - Any single vehicle with a GVWR of 26,001 pounds or more. Any single vehicle with a GVWR of 26,001 pounds or more towing another vehicle with a GVWR of 10,000 pounds or less. Class C - Any vehicle that is not included in classes A or B that carries hazardous materials or is designed to carry 16 or more passengers, including the driver. Inspection, repair and maintenance Every motor carrier shall systematically inspect, repair, and maintain, or cause to be systematically inspected, repaired, and maintained, all motor vehicles subject to its control. • Parts and accessories shall be in safe and proper operating condition at all times. Annual inspections on each vehicle must be performed by a qualified inspector. Inspection, repair and maintenance records Every motor carrier shall maintain, or cause to be maintained, the following record for each vehicle: • An identification of the vehicle including company number, make serial number, year and tire size; • A means to indicate the nature and due date of the various inspection and maintenance operations to be performed; and • A record of inspection, repairs and maintenance indication their date and nature. The records shall be retained where the vehicle is either housed or maintained for a period of 1 year and for 6 months after the motor vehicle leaves the motor carrier’s control. Driver qualification file Each motor carrier shall maintain a driver qualification file for each driver it employs. The file must include: • The driver’s completed application for employment; • A written record with respect to each past employer who was contacted and a copy of the response by each State agency involving investigation and inquiries; • The certificate of driver’s road test or a copy of the license; • The response of each State agency to the annual driver record inquiry; • A note relating to the annual review of the driver’s driving record; • A list or certificate relating to violations of motor vehicle laws and ordinances; and • The medical examiner’s certificate of the driver’s physical qualification to drive a commercial vehicle. Driver’s record of duty status Each motor carrier shall require every driver used by the motor carrier to record his/her duty status for each 24 hour period. Each motor carrier shall maintain records of duty status and all supporting documents for each driver it employs for a period of six months from the date of receipt. Alcohol and controlled substance testing Each motor carrier shall comply with the alcohol and controlled substances testing requirements for each of the following types of tests: • Pre-employment testing; • Post-accident testing; • Random testing; • Reasonable suspicion testing; and, • Return-to-duty testing. Test results and record retention Each employer shall maintain records of its alcohol and controlled substances testing. 5 years • Records of driver alcohol test results indicating an alcohol concentration of 0.02 or greater; • Records of driver verified positive controlled substances test results; and, • Documentation of refusal to take required alcohol and/or controlled substances tests. 1 year • Records of negative and canceled controlled substances test results and alcohol test results with a concentration of less than 0.02. An investment in our future that will protect us from: Fines Citations Disqualifications Poor Safety Ratings Damaged Reputation A comprehensive safety program includes all the ingredients of a successful drilling contractor. A comprehensive safety program is the next step toward a firm footing in the drilling industry ahead.
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