Job Hazard Analysis
How a Complimentary Site Visit from Approach Management Services and a Job Hazard Analysis Saved a Local Client From DOSH Citations
Approach is proud to offer an annual safety visit to our clients, included with their Retro participation, which can take place at any location. Once on site, we can provide a document review and/or walk your facility/job site to help identify hazards by conducting a Job Hazard Analysis, or JHA. Safety director Holly Markee recently talked with us about the annual review process and how the JHA helped one of our construction clients in Olympia.
Ask Approach: How did you come to work with this construction client?
Holly: Not every employer knows that they need a safety visit and that was the case here. This company contacted me in early 2018 wanting information on the new Silica rule that was coming into effect. While talking with the owner, it came up that they had recently received a citation from DOSH. So, I offered to bring the silica documents to them directly and do a safety visit while I was there.
While talking with the owner, it came up that they had recently received a citation from DOSH.
Ask Approach: What did you find when you were on-site?
Holly: I found a situation that’s really pretty common – a fast-growing company that was trying to do the right thing, but didn’t understand all of the requirements that exist, especially for general contractors. My safety visit with the client led us to identify several areas where they needed to improve.
Ask Approach: Can you provide some examples?
Holly: First off, the company did not understand the importance of documentation. DOSH is going to want to see that you have a safety plan that’s communicated to employees, along with a disciplinary policy to back it up. If there’s no documentation there’s no proof, and that was the problem here. They didn’t have a firm “safety communication,” or disciplinary, program and they didn’t understand the concept of Unpreventable Employee Misconduct.
As I mentioned, there are special requirements for general contractors and this client didn’t have a good handle on their roles and responsibilities.
Finally, their safety monitoring was not adequate considering the number of existing job sites they had and they didn’t understand how important it is to always have safety staff on each jobsite.
Ask Approach: How were you able to help this client?
Holly: As I said, this company wanted to do the right thing, so it just came down to education. I explained best practice requirements including site safety supervisors, an effective disciplinary program, safety meetings, and documentation. Then, I provided templates so that they could update their Accident Prevention Program and conduct Job Hazard Analysis for every position.
Ask Approach: Have you seen positive results since your first visit?
Holly: Absolutely! They’ve really done better than I could have hoped. When I went back a year later, they had hired site superintendents to cover all job sites. Their new disciplinary process was in place and all documentation and record-keeping was as it should be.
On the general contractor front, they implemented new requirements for their sub-contractors, starting with a review of each sub’s Accident Prevention Program and injury rates prior to hire. They’re also providing safety information in Spanish when needed for their subs and then performing walk-around inspections once the subs are on-site.
Ask Approach: And, has the client seen benefits from taking these extra steps.
Holly: Definitely. There was another DOSH inspection and they were nearly cited. However, the client was able to show evidence that proved Unpreventable Employee Misconduct. The company was not penalized.
Plus, they have just joined the A-Team Retro, which would not have been possible before these extra measures were in place. This should reward them with positive Retro refunds for years to come!
There was another DOSH inspection and they were nearly cited. However, the client was able to show evidence that proved Unpreventable Employee Misconduct. The company was not penalized.