Discussion: Compliance Level Audit Machine Guarding

Discussion: Compliance Level Audit Machine Guarding Discussion: Compliance Level Audit Machine Guarding ORDER NOW FOR CUSTOMIZED AND ORIGINAL NURSING PAPERS Unformatted Attachment Preview Meeting ISO 45001 Lesson 8 Clause 9 Performance Evaluations Clause 9 covers internal audits and management review. Clause 9.2 is titled internal audits. In general the organization shall conduct internal audits at planned intervals to provide information on whether the safety management system: A. Conforms to: 1.) The organization’s own requirement such as policy and objectives. 2.) Meets the ISO 45001 requirements B. Is effectively implemented and maintained Specific requirements include: 1.) Planning, implementing, and maintaining (establishing) an audit program including the frequencies, methods, responsibilities, consultation, planning requirements, and reporting which shall take into account the importance of the processes concerned and the results of previous audits; 2.) Define audit criteria and scope for each audit; 3.) Select auditors and conduct audits to ensure objectivity and impartiality of the process; 4.) Ensure that the results of the audits are reported to relevant managers, ensure that relevant results are reported to workers and/or worker representatives, and other relevant parties; 5.) Take action to address nonconformities and continually improve safety performance; 6.) Retain documented information as evidence of the implementation of the audit program and audit results. In the Employee Oriented Safety System the general requirements are interpreted to mean that it corresponds to the establishment of compliance level audits, where adherence to policy/procedures is measured and effectiveness level audits where the initiatives or core and compliance programs are measured for effectiveness and continual improvement practice in the meeting and setting of goals and objectives in the function of strategic planning. The general requirements also mention that the system itself should be evaluated on a scheduled basis to examine if it meets ISO 45001 and document how. Within these specific types of audits Clause 9 will require an overall policy and procedure document that addresses the overall auditing initiative. In this policy or procedure document, it must establish and probably by safety topic, such as lock out tag out, machine guarding, confined spaces, etc., the scheduling of the audit. Discussion: Compliance Level Audit Machine Guarding For example we might schedule machine guarding audits on sections of the plant during the same month or quarter of the year, or order a frequency and schedule that varies from this. The policy must also then cover the responsibilities under the program. Methods of conducting the audit and the level of engagement with workforce level associates must at least be consultative in nature. Each audit conducted must define the scope of the audit and have the criteria documented. The policy must cover the structure of reports, who the results are reported to, which must include workers and / or worker representatives and other safety customers or parties relevant and interested. This should also cover the chain of developing and implementing countermeasures and a summary of past results and progress on the implementation of past countermeasures. The reports must be kept as organizational history and evidence of good faith in continual improvement of safety performance. In the Employee Oriented Safety System any audit, investigation, report of a problem that produced a countermeasure resulted in a countermeasure report. All countermeasure reports were considered open until the correction was implemented. This was used as an overall measure of management commitment. The allocation of resources is a primary duty of management. This was a supporting element of the system that not unique to audits alone, accounted for the requirement in ISO 45001. SAMPLE AUDIT INSTRUMENT (INFORMAL/INTERNAL) Dept:__________________ DATE: ___/___/_____ AUDIT # _____________ AUDITOR(s): _________________________________ Location: __________________ SUBJECT: GOAL: Item 1 Ref Hazard Level Criteria Level 1 ? Level 2 ? Level 3 ? One of more methods of machine guarding are present to protect the operator of the machine Safety Device: __________________ Findings Pass ? 1 pt Fail ? 0 pt Comments:______________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ OSH 410W Weeks 6 and 7 Self-Assessment Initiatives Self-assessment is a safety initiative where a company is proactively finding discrepancies in conditions and practices and in good faith is correcting the issue. The program centers on what we refer to as audits. An audit is a type of investigation that examines for a listed set of criteria. So it is formally constructed on an audit instrument. Usually an audit is created from requirements of regulatory agencies, state laws, policy, best management practices, and letters of interpretation. Ideally audits are proactive although they can be completed as part of an investigation of an incident in order to help identify causal factors. Audits exist as either compliance level audits or program effectiveness audits. Compliance level audits are aimed more at finding substandard conditions and effectiveness level audits are management review for practicing continual improvement at the root cause level and operational levels. Each safety program or initiative should have two types of audits produced for it. Discussion: Compliance Level Audit Machine Guarding. The first is a basic compliance audit and the second is a program effectiveness audit. You will be tasked in week 6 to produce a basic compliance audit and in week 7 you will produce a program effectiveness audit. Compliance Level Audits A compliance level audit measures the compliance to policy, procedure, and best management practices adopted as organizational standards. These standards are based upon regulations from regulatory agencies, federal law, state law, consensus standards, and letters of interpretation, legal case law, or best management practices. The starting point for developing compliance level audits begin with the regulations, either state, federal, or both that apply to the activity and situation. Let’s look at a common example in regard to machine guarding. Part 1910 section 212 covers the general requirements for all machines. Subsequent sections cover specific machinery, such as section 213 covering woodworking machines. But for all machines, paragraph (a) states, “one or more methods of machine guarding shall be provided to protect the operator and other employees in the machine area….” This is best broken down into two criteria for compliance auditing. The first criteria would cover the operator and the second criteria would cover others in the area. This is because protection for the operator is not necessarily the same protection used for others in the work area. We can also write the criteria in a manner that requires the examiner to identify the device used for protection. Here is an example of the first criteria for a compliance level machine guarding audit. Item Ref 1 1910.212(a)(1) Hazard Level Criteria Level 1 ? Level 2 ? Level 3 ? One of more methods of machine guarding are present to protect the operator of the machine Safety Device: __________________ Findings Pass ? 1 pt Fail ? 0 pt In the above example you can see that the investigator is to write in the safety device used to protecting the operator and if in compliance a score of 1 is indicated. Scoring results for compliance in this manner helps compare facility areas or facilities to each other. It also helps you measure compliance, which in this case is specifically compliance to machine guarding general requirements. The findings section includes a scoring methodology. Compliance level criteria are not ranked in order of any priority or importance. It’s just not practical as conditions that seem minor can result in serious consequences when factors align correctly. However, scoring a positive result to compliance allows the safety manager to track compliance by audit topic and compare departments, facilities, or any divisional structure for performance. Compliance is an element of culture at both the management and workforce associate levels that can be measured. Compliance level audits reveal the level of management compliance in an organization. The scores of compliance level audits should be used to indicate this component of culture and is a leading indicator for management responsibility. The criteria should have a reference or references that it is based upon in order for others or your replacement to truly understand the origins of the criteria. It is a practice for sustainable management efforts. The criteria are also numbered so the investigator can make notes or comments on their findings or lack of findings when appropriate. There is a plain, blank example in course documents for your use if necessary. In this example you will notice that the heading or banner records some basic data. You may want to include more data that you may need to report on or track such as the incident control number in place of the audit number. Discussion: Compliance Level Audit Machine Guarding. The goal is also important. Goals are measurable. They can also vary from manager to manager. This week’s assignment also include filling in the goal section of the audit instrument. Hazard Levels Assigning levels to the criteria in a compliance level audit in a manner that matches hazard levels from the hazard recognition program allow you to delegate certain portions of an audit or to measure how well workforce level associates actually participate in that it can be one measure that combines to reveal participation at the workforce level. It helps you measure competency in that when a competent level associate such as a safety officer discovers a level 1 hazard that should have been recognized and corrected at the workforce level, it shows that either competency or participation is lacking. Line associates are not expected to be as advanced in hazard recognition skills or compliance requirements as other positional associates such as safety professionals, maintenance personnel, or engineering personnel. Hazard recognition expectations match the level of training, experience, and knowledge of compliance standards and best safety management practices. Level 1 hazards then are those that the authorized associate has been trained to recognize. Level 2 hazards are those hazards that require more knowledge of compliance standards and best management practices. Level 2 hazards are those safety professionals should be competent to find and correct. Level 3 hazards are above safety professional competency and require specific skills to troubleshoot for or to plan and correct. Let’s look at machine guarding for an example. Line associates should be able to perform a per-operational check of light curtains for operation. Safety professionals would be expected to be able to perform at level 1 but to also understand safety distance and basic definitions of control reliability. Engineers would be expected to be capable of troubleshooting safety device programming for faults and able to adequately program a programmable logic controller and program safety devices in reliable manners. It is really a matter of assigning responsibility based upon competency. Other Uses The overall chain of action is that the safety topics relevant to the facility, based upon a hazard assessment or hazard inventory, produce safety initiatives like that of lock out tag out. These topics are then audited for compliance over the relevant areas of the facility. They should be scheduled, but also conducted as situations warrant. If a critical event occurred that warranted auditing for causal conditions or practices, then this should be conducted regardless of scheduled auditing. Audits then produce reports of performance. Discrepancies are prioritized and countermeasures are produced in the same manner the organization uses for investigations. In fact it may be useful to utilize the causal analysis instrument and countermeasure report for selfassessments as well. Audits are also used as learning tools and guides for successful project completion. Discussion: Compliance Level Audit Machine Guarding. A basic compliance audit for erecting scaffolding in accordance with OSHA requirements and company practices can be given to a work crew or project foreman as a quick reference guide. They can also be used to help ensure that training efforts are covering all requirements. Audits are a common and effective management tool for safety. Program Effectiveness Audits Program effectiveness audits look at criteria that measure performance of the program and rate key topics of the program that are critical for effectiveness. All initiatives and the overall program must be examined for effectiveness if continual improvement is to be practiced comprehensively. Effectiveness level audits have a structure to the criteria that measure management’s responsibility, cultural dynamics, and performance measures. This structure reflects the strategy learned in week 3 of the course. Indicators Leading Indicators: Leading indicators are positive precursors or positives (opposite to causal factors) that we accept can make something effective, safer, less risky, etc. So they predict future performance based upon actions conducted now that are deemed to have positive future impact. Let me give an example we can all see. What are the indicators that UK (or any college basketball team) will be competitive for conference and NCAA championship runs next season? Can we say ranking of recruiting class? Yes Can we say returning players? Yes Can we say retention of coaches? Yes See the above examples are really positive precursors to next season’s success. Now let me example the standard status or performance (lagging indicators) indicators. Lagging indicators are predictors of future success based on past records or occurrences. Many say that in safety lagging indicators measure failures. Which is more true that with sports teams if they have winning records. In safety we often measure frequencies or rates of injury, incidents, or costs. These are the failures of the overall program. However, it is like looking at a glass of water that is either half full or half empty. From the sports team example a lagging indicator would be: Last season’s record Average points per game last year Number of past conference or NCAA titles Now let’s look specifically at structuring an effectiveness level audit. Let’s work with LOTO because OSHA requires annual LOTO review. So let’s build on something you can really use now. Management Level Criteria: Level 1 Leading Precursors: Here we begin with deciding who management is and what are their duties in regard to LOTO? (these general duties are typically universal to all programs but can be measured in different ways) Management is the positions of authority or company personnel. So department managers, safety personnel, supervisory personnel represent the company. What are our duties as management? I will argue there are 5: (notice these are the measures of culture) 1. Provide the resources: policy, training, education, equipment (commitment) 2. Provide supervision: review for improvement, inspect, observe, enforce policy, develop the raw skill (develop competency) 3. Participate: form cross functional committees to develop procedures, review. 4. Motivate: portray as important (positive perceptions) 5. Comply: comply to our own policy, ensure compliance. So now we decide how to measure these 5 elements as leading precursors for management–Level 1: Lets look at examples for Commitment: Does management provide a written LOTO program that covers the scope of facility needs? Scoring: (please circle) 3. Program meets all facility needs and is readily available 2. Program is available but does not meet facility needs/cover all types of equipment or processes. 1. Program is not made available 0. No written program The above shows that management has a policy and it meets the scope of needs. Providing equipment: Does management provide necessary LOTO devices for Authorized Personnel? Scoring: (please circle) 3. Facility has necessary LOTO devices and in enough number 2. Facility has necessary LOTO devices but not in enough numbers 1. Facility does not have all necessary LOTO devices 0. LOTO devices are not provided Machinery, equipment, or processes are design capable for all functions of rendering safe at a zero energy state? Scoring: (please circle) 3. All equipment, machinery, processes designed with necessary 0 energy exposure controls (special tools, bleeding valves, blocking pts) 2. Most equipment is designed for 0 energy safety 1. Much equipment design does not allow for adequate safety at 0 energy 0. # Equipment is not assessed for risk exposure at 0 energy Management provides training to all personnel on LOTO? Scoring: (please circle) 3. Management has classified and trained all personnel with remedial training program developed and implemented; Periodic observational reviews indicate 100% passage or remedial training conducted. 2. Management has classified and trained all personnel; remedial training program developed and implemented 1. Management has classified and trained all personnel as authorized or affected personnel 0. Management has not trained 100% of personnel on LOTO Now for Supervision: Management conducts compliance level audits of LOTO for meeting 1910.147? Scoring: (please circle) 3. Compliance level audits conducted more than 2 times per year and factored into effectiveness level audit. 2. Compliance level audits conducted less than 2 times per year 1. Compliance level audits do not include procedural demonstrations 0. Compliance level audits are not conducted Now with compliance level audits they might include observations of procedures, inspection of locks/tags, etc. Participation: Cross functional teams for LOTO development and review are maintained? Perception: (probably reported in the Operational/Cultural Metrics) Managers and Supervisor feel that LOTO is vital for workplace safety? Managers and Supervisors feel they provide adequate equipment and training to authorized personnel? Managers feel they provide adequate equipment and training to affected personnel? Compliance: Overall compliance score from total of compliance audit results: Now here depending on how we tally a compliance level audit we can show the results of findings. Even if we do not tally a score from them, we could ask for the ratio of corrected discrepancies. Is this not compliance as well as allocation of resources? Operational Criteria: These are perceptions and behaviors mainly. See below examples. Operational Criteria Level 2 Leading Precursors Affected employees demonstrate Stop Call Wait Procedure? (total behavior score from LOTO compliance demonstration for affected personnel: Item # c on compliance audit) Scoring: (please circle) 3. Score of 15 2. Score of 12 to 14.9 1. Score of 9 to 11.9 0. Score below 9 Score: Authorized employees can demonstrate proper sequence on various types of machines, equipment, & processes? (total behavior score from LOTO compliance level demonstrations by authorized personnel: 3 authorized on all different classes of LOTO equipment) Scoring: (please circle) 3. Score of 15 2. Score of 12 to 14.9 1. Score of 9 to 11.9 0. Score below 9 Authorized personnel feel management places proper priority with LOTO? (results from annual perception survey for LOTO) Scoring: (please circle) 3. Mean score of 2. Mean score of 1. Mean score of 0. Perceptions not surveyed/tallied Authorized personnel feel LOTO is important? (results from annual perception survey for LOTO) Scoring: (please circle) 3. Mean score of 2. Mean score of 1. Mean score of 0. Perceptions not surveyed/tallied Affected personnel feel management places proper priority with LOTO? 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Discussion: Compliance Level Audit Machine Guarding
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