Hazard Control Program

Prevention and Control of Workplace Hazards

Section 19(a) of the Occupational Safety and Health Act (OSHA) requires that employees be provided with a safe and healthful place of employment. Identification of hazardous conditions may be accomplished at the planning and design stage, as a result of workplace inspections, or by employee reports. All recognized safety and health hazards shall be eliminated or controlled as quickly as possible, subject to priorities based upon the degree of risk posed by the hazards. The preferred method of hazard abatement shall be through application of engineering controls or substitution of less hazardous processes or materials. Total reliance on personal protective equipment is acceptable only when all other methods are proven to be technically and/or economically infeasible.

Principles of Hazard Control

Substitution. The risk of injury or illness may be reduced by replacement of an existing process, material, or equipment with a similar item having more limited hazard potential Some examples include: brush painting instead of spray painting to reduce inhalation hazards, welding instead of riveting to reduce noise levels, use of safety cans instead of bottles to store flammable liquids, etc. Care must be exercised in any substitution to ensure that the substitute materials are technically acceptable and to avoid introducing new or unforeseen hazards.

Isolation. Hazards are controlled by isolation whenever an appropriate barrier or limitor is placed between the hazard and an individual who may be affected by the hazard. This isolation can be in the form of physical barriers, time separation, or distance. Examples include machine guards, electrical insulation, glove boxes, acoustical containment, and remote controlled equipment.

Ventilation. The control of a potentially hazardous airborne substance by ventilation can be accomplished by one or two methods: diluting the concentration of the substance by mixing with uncontaminated air or capturing and removing the substance at its source or point of generation. Local exhaust ventilation is generally the preferred and more economical method of hazard control. However, dilution ventilation can be very effective for the removal of large volumes of heated air or for the removal of low concentrations of non-toxic or low toxicity contaminants from minor and decentralized sources.

Administrative Control. This method of hazard mitigation depends on effective operating practices that reduce the exposure of individuals to chemical or physical hazards. These practices may take the form of limited access to high hazard areas, preventive maintenance programs to reduce the potential for leakage of hazardous substances, or adjusted work schedules which involve a regimen of work in high hazard and low hazard areas. Adjusted work schedules are appropriate only when the hazard is recognized as having a limit below which nearly all workers may be repeatedly exposed without adverse effect.

Personal Protective Equipment. This method of hazard control is least preferred because personal protective devices may reduce a worker's productivity, while affording less effective protection against the recognized hazard than other methods of control. Nevertheless, there are instances where adequate levels of risk reduction cannot be achieved through other methods, and personal protective devices must be used, either alone or in conjunction with other protective measures.

Application of Hazard Control Principles

Hazardous conditions in the workplace may be prevented through appropriate actions when facilities are designed, when operating procedures are developed, and when equipment is purchased. Notwithstanding these preventive measures, hazards will arise as a result of the dynamics of the workplace environment. Once hazards are identified, whether through inspection or complaint, immediate action shall be taken to avoid unreasonable danger.

Design Reviews. Safety and occupational health issues shall be considered, designed, and engineered into all facilities which are acquired or constructed for use by campus employees. To ensure that appropriate hazard control techniques are applied, the Office of Risk Management (ORM) participates in the review of plans and specifications for construction and renovation projects. Projects that involve potential health hazards such as toxic material, radiation, noise, or other health hazard shall be designed in accordance with established principles of good safety and industrial hygiene engineering.

Operating Procedures. Standard operating procedures or similar directives developed by the supervisor that are issued to direct the manner in which work is performed shall include appropriate health and safety requirements. Supervisors are encouraged to submit standard operating procedures to the Greater Acadiana Region 4 Safety Coordinator
or designee and Campus Safety Committee for review. Recommendations for changes/additions to the procedures for safety and health purposes shall be submitted in writing to the originating supervisor.

Purchasing Procedures. Many hazards can be avoided by incorporating appropriate specifications for purchased equipment/material and contracted efforts that involve work at campus facilities. Obviously the campus has little control over specifications for equipment/material purchased through the state supply system; however, a considerable amount of equipment/material is purchased directly. Campus personnel responsible for developing specifications for such purchases should coordinate with other knowledgeable personnel to insure that health and safety requirements are considered in these specifications. Similarly, contracts that require work to be performed by contract personnel at campus facilities should be coordinated with the proper agencies.

Interim Hazard Abatement Measures. During the time needed to design and implement permanent hazard control measures, immediate, temporary measures are needed. Where engineering controls are not immediately applicable, administrative controls and/or personal protective equipment are appropriate for use as interim hazard abatement measures.

Permanent Hazard Abatement. Engineering control methods are the preferred method of hazard control, followed by administrative control and personal protective equipment. Feasible engineering controls shall be used to reduce hazardous exposure, even when only partial reduction of exposure is possible through engineering methods.

Two criteria may be applied to determine whether engineering controls are feasible. First, a control is technologically feasible if it is available "off the shelf" or if technology exists which can be adapted to the hazard in question. Second, a control is economically feasible if it can be shown that the cost of the control is justified by the benefit it produces. On the other hand, if the expected reduction of the hazard through implementation of engineering control is insignificant in terms of increased protection, and the cost of implementing the control is great, then the control is economically infeasible.

Development of Hazard Control Recommendations

The following possible actions will be considered when recommendations are developed for prevention or reduction of hazards:

• Avoiding, eliminating, or reducing deficiencies by engineering design, material selection or substitution;
• Isolating hazardous substances, components, and operations from other activities, areas, personnel, and incompatible materials;
• Incorporating "fail-safe" principles where failures would disable the system or cause a catastrophe through injury to personnel, damage to the equipment, or inadvertent operation of critical equipment;
• Relocating equipment/components so that personnel access during operation, maintenance, repair or adjustment shall not result in exposure to hazards such as chemical burns, electrical shock, electromagnetic radiation, cutting edges, sharp points, or toxic atmospheres;
• Providing suitable warning and notes of caution concerning required personnel protection in operation, assembly, maintenance, and repair instructions;
• Providing distinctive markings on hazardous components, equipment, or facilities;
• Requiring use of personal protective equipment when other controls do not reduce the hazard to an acceptable level;
• Monitoring exposure to insure that engineering controls effectively reduce the hazard; and
• Training employees to recognize hazards and take appropriate precautionary measures.

Hazard Reporting

Identification and reporting of potentially unsafe or unhealthful working conditions is the responsibility of all campus employees. All campus employees are encouraged to report unsafe or unhealthful working conditions to their immediate supervisor who will promptly investigate the situation and take appropriate corrective actions. Supervisors will contact the Campus Safety Contact or designee for assistance as necessary. Supervisors will keep the reporting employee informed of all actions taken.

• All employees are responsible for reporting any potentially hazardous condition or practice they find.
• The employee is to record any unsafe condition on the Hazard Control Log (Form HC-1-90) which must be kept in each operating area.
• The Maintenance Supervisor and/or Greater Acadiana Region 4 Safety Coordinator
  or designee is responsible for checking the Hazard Control Log and is authorized to take immediate temporary control of any area to prevent exposure to the hazard until permanent corrective action is taken.
• If the Maintenance Supervisor or Greater Acadiana Region 4 Safety Coordinator
  or designee cannot correct the hazard, they will report to the Campus Administrator.
• If a hazard still exists for more than 30 days, the Campus Administrator will send copies of the Hazard Control Log to the Office of Risk Management’s Unit of Risk Analysis and Loss Prevention.
• The Hazard Control Log is to be retained in the originating work area for at least one year or until all hazards have been corrected.

In addition to this Hazard Control Program, this manual provides information on Hazard Communication & Incident Control, Emergency and Fire Procedures, Safety, First Aid, and various other safety and health information which provide information in preventing exposure to unsafe conditions or acts.