ACCIDENT PREVENTION PLAN
The purpose of this APP is to provide Health and Safety guidelines per OSHA, WISHA and other industry requirements.
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ACCIDENT PREVENTION PLAN The purpose of this APP is to provide Health and Safety guidelines per OSHA, WISHA and other industry requirements.
Evergreen Goodwill of NW WA
Risk & Safety-P-001 ACCIDENT PREVENTION PLAN
Prepared by: Prithy Madhoo Rev B: 7-5-2023 Date Created: 12-29-2021
Contents 1.0 Purpose, Scope and Responsibilities................................................................................................. 3 1.1 Purpose ........................................................................................................................................ 3 1.2 Company Profile ......................................................................................................................... 3 1.3 Health and Safety Policy ........................................................................................................... 4 1.4 Roles and Responsibilities ........................................................................................................ 5 1.5 Normative references ................................................................................................................ 6 1.6 Terms and definitions ................................................................................................................ 6 2.0 Health and Safety Resources ............................................................................................................ 8 2.1 Risk & Safety (R&S) Department ............................................................................................. 8 3.0 Safety Bulletin Boards ....................................................................................................................... 9 4.0 Health and Safety Committees ....................................................................................................... 10 5.0 New Employee Health and Safety Orientation ............................................................................... 11 6.0 Reporting Accidents, Injuries, Illnesses, and Concerns................................................................... 12 6.1 Workplace Accidents, Injuries, Illnesses and Near Miss .................................................... 12 6.2 Safety Concerns: Reporting and Resolving ......................................................................... 12 7.0 Emergencies .................................................................................................................................... 14 7.1 Obtaining Emergency Assistance .......................................................................................... 14 7.2 Public Safety ............................................................................................................................. 14 7.3 Emergency Management and Business Continuity ............................................................ 14 7.4 Building Fire Safety and Evacuation Plans .......................................................................... 15 7.5 First aid ...................................................................................................................................... 15 7.6 Good Samaritan Act ................................................................................................................. 16 7.7 Blood-borne Pathogens Training (BBP) ............................................................................... 17 7.8 Sharps Waste ........................................................................................................................... 17 7.9 Automated External Defibrillators (AEDs) ............................................................................ 18 7.10 Working Alone/Isolated workers ............................................................................................ 18 8.0 Identifying and Mitigating Hazards ................................................................................................. 20 8.1 Job Hazard Analysis (JHA) ..................................................................................................... 20 8.2 Hierarchy of Control ................................................................................................................. 20 8.2.1 Elimination ......................................................................................................................... 20 8.2.2 Substitution ........................................................................................................................ 21
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Risk & Safety-P-001 ACCIDENT PREVENTION PLAN
Prepared by: Prithy Madhoo Rev B: 7-5-2023 Date Created: 12-29-2021
8.2.3 8.2.4 8.2.5 Design and Engineering Controls .................................................................................. 21 Administrative controls .................................................................................................... 21 Personal Protective Equipment (PPE) .......................................................................... 22 8.3 Introduction of New Chemical on site .................................................................................... 22 8.4 Chemical Hazard Communication (HazCom) ...................................................................... 23 9.0 Recognized Safety Hazards ............................................................................................................. 24 9.1 Slips, Trips and Falls ............................................................................................................... 24 9.2 Indoor Air Quality ...................................................................................................................... 25 9.3 Hearing Loss Prevention ......................................................................................................... 25 9.4 Ergonomics ............................................................................................................................... 26 9.5 Confined Spaces ...................................................................................................................... 26 9.6 Work at Height (WaH) .............................................................................................................. 27 9.7 Equipment/machines and other tools or work layouts ........................................................ 28 9.8 Powered Industrial Truck (PIT) .............................................................................................. 30 9.9 Lock Out/Tag Out ..................................................................................................................... 31 9.10 Scissor Lift ................................................................................................................................. 32 9.11 Working with Electricity ............................................................................................................ 33 9.12 Hot Work Permit ....................................................................................................................... 34 9.13 Compressed Air ........................................................................................................................ 35 9.14 Propane gas .............................................................................................................................. 36 9.15 Elevator ...................................................................................................................................... 38 9.16 Water Heater ............................................................................................................................. 39 9.17 Structural/building Integrity ..................................................................................................... 39 9.18 Manual Handling ....................................................................................................................... 39 9.19 Respiratory Protection ............................................................................................................. 40 9.20 Outdoor work exposure .............................................................................................................. 41 9.21 COVID-19 and other Health Pandemic ................................................................................. 43 9.22 Trench ........................................................................................................................................ 44 10.0 Workplace Safety Evaluation .......................................................................................................... 44 10.1 Disciplinary Policy .................................................................................................................... 44 10.2 Responsibilities beyond this APP .......................................................................................... 44
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Risk & Safety-P-001 ACCIDENT PREVENTION PLAN
Prepared by: Prithy Madhoo Rev B: 7-5-2023 Date Created: 12-29-2021
1.0 Purpose, Scope and Responsibilities
1.1 Purpose This document will serve as Evergreen Goodwill of Northwest WA (EGNW) Accident Prevention Plan (APP). It will apply to all stores, outlets, Attendant Donation Centers (ADCs) and Job Training & Education Centers (JTEC) and any locations under the management of EGNW. The term “locations” will be used to represent the entities supported by this plan, that is, stores, outlets, ADCs and JTE Centers and any locations under the management of EGNW. The purpose of this document is to address occupational hazards and any Federal/State Health and Safety regulations that will apply to all EGNW employees across its locations. This document outlines policies and procedures that will be implemented to reduce or eliminate those hazards. “Employees” will include all paid staff in permanent, part-time, student, volunteers and internship positions. In order to be effective, all employees will be required to understand this APP, know where they can get a copy of this document and its proper use. The APP will be used in-lieu of the Health and Safety Manual but will not replace existing policies, records, procedures and safe operating procedures or safe system of works. The APP will be kept as a PDF document on Vector and the original will be saved in R&S folder in J:\APP. This document will be reviewed and updated by R&S and the Safety Committee members when there will be new hazards introduced into the business or changes in existing processes. Any suggestions or proposed improvements from other business processes to the APP will be directed to R&S Department. Evergreen Goodwill of Northwest WA is referred as “The company or EGNW” in this document. Evergreen Goodwill is a non-profit organization founded in 1923. The company currently operates five Job Training Centres, 24 retail stores, and 30 donation sites in King, Snohomish, Skagit, Whatcom, and Kitsap County. It employs over 2,000 people in Pacific Northwest, WA region. 1.2 Company Profile
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Risk & Safety-P-001 ACCIDENT PREVENTION PLAN
Prepared by: Prithy Madhoo Rev B: 7-5-2023 Date Created: 12-29-2021
1.3 Health and Safety Policy
This APP will be used as EGNW Policy. The APP will promote the company commitment to provide a safe and healthy environment for all employees, students, volunteers, visitors, clients and customers. It will follow guidelines set in the Washington State Industrial Safety and Health Act (WISHA) ( WAC 296-24, 296-62, and 296-800 ), which is administered by the Washington State Department of Labor and Industries (L&I), Division of Occupational Safety and Health. 1.3.1 Evergreen Goodwill of NW WA Policy Statement “It is our intent to provide a safe and healthy workplace and safe, well-maintained vehicles for our employees and volunteers, a clean and safe learning environment for our students and safe and comfortable stores for our customers. We do this by establishing and maintaining a workplace free of recognized hazards and insisting upon safe work practices at all times, by all employees. The prevention of accidents is an objective affecting all levels of our organization and its operations. It is a basic requirement that each director, manager, and supervisor make safety an integral part of his or her regular management function. It is equally the duty of each employee to accept and follow established safety rules and procedures. Every effort will be made to provide adequate training to employees. However, if an employee is ever in doubt about how to do a job or task safely, it is the employee’s duty to ask his or her supervisor or department head for instructions. Employees are expected to assist management in accident prevention activities. Unsafe conditions or unsafe work practices should be reported immediately. Employees should always assist co-workers who need help. Every injury, collision, property damage or other incident that occurs on the job or in our stores or classrooms, even a slight cut, scrape or strain, should be reported to your supervisor as soon as possible. Under no circumstances should an employee leave the work site without reporting an injury. When an injury occurs everyone is hurt. Safety is every employee’s responsibility. Please work safely.”
Daryl Campbell President and CEO
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Risk & Safety-P-001 ACCIDENT PREVENTION PLAN
Prepared by: Prithy Madhoo Rev B: 7-5-2023 Date Created: 12-29-2021
1.4 Roles and Responsibilities
EGNW’s job descriptions will outline health and safety responsibilities for all employees. The People and Culture Department will be responsible to develop, review, update and distribute job descriptions as and when required. EGNW leadership will be responsible for ensuring that individuals under their supervision have sufficient authority to support and properly implement health and safety programs. Leadership will ensure compliance with health and safety training, act in support of R&S Department to monitor policy adherence applicable to health and safety regulations and policies, and establish priorities for committing resources to correct any such deficiencies to ensure EGNW zero accidents and injuries goals. R&S Department will be responsible to implement Federal, State, Local and EGNW operations policies by developing procedures and safe systems of work to ensure health and safety of visitors, customers, students, volunteers and employees at EGNW owned, operated and controlled locations. All employees will be responsible for doing their part to keep the business operating in a safe manner by observing and following health and safety policies and procedures, participating in training, and reporting safety hazards/incidents, injuries and illnesses. Every employee should understand that a violation of EGNW safety rules may result in disciplinary action, including and up to termination, as discussed in the Employee Handbook and the HR Policy and Procedures Manual (located on SharePoint for manager use)
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Risk & Safety-P-001 ACCIDENT PREVENTION PLAN
Prepared by: Prithy Madhoo Rev B: 7-5-2023 Date Created: 12-29-2021
1.5 Normative references
OSHA, WISHA, DOSH, RCW, WAC.
1.6 Terms and definitions For the purposes of this document, the following terms and definitions will apply:
Accident Prevention Plan
Document that set safety guidelines taking into consideration federal, states and EGNW requirements. To provide a safe and healthy work environment and to follow the applicable regulations as far it is reasonably practicable to achieve zero injuries and accidents goals. EGNW ( person or groups of people that has its own functions with responsibilities, authorities and relationships to achieve its objectives ). EGNW leadership refers to all those who direct and control the organization, has the power to delegate authority and provide resources within the organization (CEO and ET members). Internal and external interested parties, who can affect, be affected by EGNW decision or activities. Surroundings in which EGNW operates, including but not limited to air, water, land, natural resources, flora, fauna, humans and their interrelationships. Ability to apply knowledge and skills to achieve intended results as per EGNW requirements.
Safety Policy
Organization
Executive Team
Interested parties
Environment
Competence
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Risk & Safety-P-001 ACCIDENT PREVENTION PLAN
Prepared by: Prithy Madhoo Rev B: 7-5-2023 Date Created: 12-29-2021
Documented information
Information required to be controlled and maintained by EGNW and the medium on which it is contained.
Outsource
External organization outside of EGNW management system.
Process
Operational activities transforming donated goods into sellable materials. Internal audit - Systematic, independent and documented process for obtaining audit evidence and evaluating it objectively to determine the extent to which the safety audit criteria set by the organization are fulfilled. Fulfilment of a requirement described in this APP and other related policies, procedures and work instructions. Non-fulfilment of a requirement described in this APP and other related policies, procedures and work instructions. Action to eliminate the cause of non-conformity and to prevent recurrence. Recurring or new activity to enhance safety performance consistent with EGNW policy. Plan Do Check Act mode will be used to monitor R&S improvement and progress. Determined value by EGNW to measure improvements and progress. Performance related to the management of R&S objectives and reduction of work related injury/diseases. Measurable as determined by EGNW R&S Plan.
Audit
Conformity
Nonconformity
Corrective action
Continual improvement
Indicator
Monitoring
Measurement
Safety performance
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Risk & Safety-P-001 ACCIDENT PREVENTION PLAN
Prepared by: Prithy Madhoo Rev B: 7-5-2023 Date Created: 12-29-2021
2.0 Health and Safety Resources 2.1 Risk & Safety (R&S) Department
R&S will partner with departments to ensure a healthy and safe environment exists at all locations. R&S will be responsible for addressing occupational safety, health, and environmental concerns. R&S will provide resources, knowledge, and tools to help departments meet their health and safety compliance responsibilities. EGNW Management will ensure that there is at least one person to serve as R&S person for the company and that the person is qualified and experienced either through education or experienced in the field to perform R&S duties. R&S will collaborate with safety committee members or leadership in each location to address safety issues observed during inspections, incident reports and any other concerns. Safety committee members will have a range of responsibilities, including but not limited to: Promoting this APP in their department. Scheduling employee safety training as requested by supervisors. Coordinating with R&S on safety related issues or improvement. Providing assistance as needed to supervisors and employees to resolve safety concerns.
Conducting monthly safety inspections. Keeping safety bulletin boards current. Keeping the department head aware of current safety concerns.
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Risk & Safety-P-001 ACCIDENT PREVENTION PLAN
Prepared by: Prithy Madhoo Rev B: 7-5-2023 Date Created: 12-29-2021
3.0 Safety Bulletin Boards A safety bulletin board will be used to post required Labor & Industries posters, safety notices and safety information, health and safety committee meeting minutes, training schedules, safety posters, accident statistics, and other safety educational material. Every EGNW locations will be required to have a designated space to post health and safety information for its employees. The safety bulletin board will be located in a common area where all employees can view the posted information, such as break room or hallway. Departments may also choose to share a common bulletin board as long as all employees of the intended departments will have access to these information: Job Safety and Health Law Notice to Employees – If a Job Injury Occurs Your Rights to as a Worker in Washington State Citation and Violation Notice Signed OSHA 300A Summary (signed copy by CEO/ET to be posted on February 1 through April 1 each year) WA State and city employment law rules and ordinances.
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Risk & Safety-P-001 ACCIDENT PREVENTION PLAN
Prepared by: Prithy Madhoo Rev B: 7-5-2023 Date Created: 12-29-2021
4.0 Health and Safety Committees Health and safety committee is required by WAC 296-800-130 as a method of communicating and evaluating safety and health issues brought up by employees or employer in the workplace. The company will follow Washington State rule when establishing its safety committee. A safety committee will be required when a worksite has 11 or more employees on one or more work shifts. The committee will determine the frequency of the meetings, for example, stores with more than 11 employees in one or more work shifts will hold monthly safety committees and administrative/support department will hold at least a quarterly safety meeting or as needed. Worksite that do not have 11 or more employees on one shift or more work shifts, will hold safety meetings at least monthly or more often if required. Committee members will comprise of employee-elected and management-appointed representatives. Employee-elect elections will be held every year or sooner as a result of changes in the business affecting committee members. The number of employee elected members will be equal to and will not exceed the number of employer-selected members. When an employee-elected member position will become vacant, leadership will ensure that a new member is elected prior to the next scheduled meeting. The committee will elect their chairperson on a yearly basis and the meeting will be held on a monthly basis unless otherwise stated. The Safety Committee Secretary will send meeting invitation prior to next scheduled meeting (a month in advance) to safety committee members. Agenda of meeting will cover inspection reports to help correct safety hazards, evaluate accident investigations, prevention program, and discuss recommendations for improvement or any other business safety needs. Worksite requiring safety committee will be required to have written safety minutes for every safety meeting held. The Secretary will be responsible to draft safety minutes, take attendance and will post minutes on safety bulletin boards within a week from date of meeting. The Secretary or Store Manager will be responsible to send safety minutes to R&S using Vector. Safety minutes will be part of safety performance and safety coupons.
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Risk & Safety-P-001 ACCIDENT PREVENTION PLAN
Prepared by: Prithy Madhoo Rev B: 7-5-2023 Date Created: 12-29-2021
Health and safety committee members’ recommendations will be considered during review of this Accident Prevention Plan. Additional Safety Committee training will be provided to leadership/safety committee members upon request or when new leadership joins the business. 5.0 New Employee Health and Safety Orientation Health and Safety orientation is a very important tool to educate new employees on hazards and risks at their workplace and measures implemented to keep them safe. The company will ensure that all new employees, including those who are temporary or part time, undergo a health and safety orientation on the first day of employment.
The health and safety orientation must cover the following topics:
Safety Policy – Employer and employee responsibilities Emergency Preparedness Plan Location of first aid facilities/emergency equipment Accident Prevention Program On-the-job instructions on how to do job tasks safely Basics of Incident/hazards Reporting Hazard communication Program Safety Bulletin Board
A New Hire Checklist will be provided to area leadership by P&C, the week the new hire starts. Leadership will be required to complete this form within the first 2 weeks of hire and return to P&C for record keeping. P&C will follow up with leadership ensuring the new hire checklist is completed. Department managers will be required to complete this form by touring the workplace with the new hire. This document will be controlled by P&C. R&S will audit this form on a quarterly basis during quarterly inspection through random selection of new hires.
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Risk & Safety-P-001 ACCIDENT PREVENTION PLAN
Prepared by: Prithy Madhoo Rev B: 7-5-2023 Date Created: 12-29-2021
6.0 Reporting Accidents, Injuries, Illnesses, and Concerns 6.1 Workplace Accidents, Injuries, Illnesses and Near Miss
All incidents, no matter how minor must be reported to R&S immediately after occurrence. OSHA defines incident as "an unplanned, undesired event that adversely affects completion of a task." Accident reporting will be dealt as per (WAC 296-800-320). All incidents occurring in the workplace will be reported to the employee’s manager and to R&S as soon as possible using Vector or email. Department Management ( Store/Outlets/JTE/Administrative/Facilities/Asset Protection Managers/Assistant Managers/Supervisors ), Executive Team, Leadership Team and employees, will use Vector (online reporting system- ORS) to report any injuries, near misses and accidents. Department Management will be given access to Vector by R&S upon request. Access to Vector will be retrieved upon termination of leader(s) to protect company documents. An email from P&C will be sent to R&S notifying of employee release from the company. Copies of incident reports will be distributed to ET or L&I upon request and approval by R&S Director. Any incident resulting in worker’s compensation claims will be dealt by Worker’s Compensation Coordinator. R&S will lead the incident investigation in partnership with safety committee members/Department Management. R&S will use result from investigation to conduct root cause analysis and recommend actions to prevent recurrence. Employees will contact R&S Department for an explanation/clarification/investigation report if they have questions or concerns related to a workplace incident or exposure.
6.2 Safety Concerns: Reporting and Resolving
Employees will be encouraged to report any health and safety concerns (e.g unsafe workplace, damaged work station, rodents infestation, slip, trips and falls hazards, unsafe machineries, lack of trainings, lack of safe personal protective equipment, COVID related concerns, among others) to their supervisor or managers. If an employee does not feel
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Risk & Safety-P-001 ACCIDENT PREVENTION PLAN
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comfortable communicating a concern to their supervisor, or if an employee has expressed a concern that was not adequately resolved, the employee will have the option to discuss any concern directly with their safety committee representatives or R&S. Assistance from R&S will be available to resolve safety concerns. Department Management and employees will use Vector – Hazard Observation tab to report Environment, Health and Safety complaints or employees will report those concerns on Evergreen Goodwill’s Anonymous Reporting Hotline (844) - 916-0151 or email sgi.ethicspoint.com . All employees will be given access to Vector Public Portal and the Ethics Point website on provided computer at their locations or may use on their personal computer, cell phone as they deem fit.
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Risk & Safety-P-001 ACCIDENT PREVENTION PLAN
Prepared by: Prithy Madhoo Rev B: 7-5-2023 Date Created: 12-29-2021
7.0 Emergencies 7.1 Obtaining Emergency Assistance
Emergencies including but not limited to fire, first aid, medical assistance, drug overdose among others will be dealt by qualified responders. All employees will be informed on “know how to summon emergency assistance during their orientation.” The information below details how to obtain emergency assistance from common Goodwill locations: Life-threatening emergencies – Anyone can Call 911 from any phone (personal cell phone or company provided land line). Employee will report their location and type of emergencies to EMS team. First aid emergencies – All locations will have a certified first aid/CPR person during all shifts. Employees will contact their respective first responders for any injuries. EGNW will thrive to create a safe and secure place through awareness, problem solving, and enforcement for all its visitors, clients, customers and students. Host will be required to accompany their visitors or non-contractors around the business. Badges, if required, will be issued by Asset Protection, a formal request will have to be submitted prior to arrival of contractors/visitors. In the event of an evacuation emergency, all contractors/visitors will be required to follow their host at the designated Emergency Area at each location. Host will ensure that their visitors are accompanied to the Emergency Areas safely. 7.2 Public Safety
7.3 Emergency Management and Business Continuity
EGNW Emergency Response Plan (ERP) will provide detailed information related to locations crisis, natural disasters, and major emergency incidents that might help departments prepare for the potential emergency situations.
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Risk & Safety-P-001 ACCIDENT PREVENTION PLAN
Prepared by: Prithy Madhoo Rev B: 7-5-2023 Date Created: 12-29-2021
7.4 Building Fire Safety and Evacuation Plans
Evacuations plans are effective tools to ensure people are evacuated to a place of safety or out of a building safely. R&S will develop and review Emergency Response Plan to address building fire emergency procedures including evacuation. Refer to ERP for detailed procedures. The Emergency contact details will be posted in all buildings on the Safety Bulletin Boards. R&S will develop a single Evacuation Plan (EP) for each building. Leadership will ensure that EPs are posted at each exit door in all buildings. Any redesign or modification to the existing layouts will be communicated to R&S through email to update EP and ERP. Department Managers will ensure that all emergency exits, fire-fighting equipment, alarms and any other basic fire safety devices/equipment will be kept free of any obstacles at all times to ensure employees’ safety and properties. All employees shall have access to quick and effective first aid. Employees identified as first aid trained for the purposes of meeting regulatory requirements will do so as a collateral duty; it will not be their primary job assignment to provide first aid or CPR. EGNW will comply with federal and state first aid regulations. Compliance with WISHA under WAC 296-800-150, EGNW will ensure that: • first aid trained personnel are available to provide quick and effective first aid. • appropriate first-aid supplies are readily available. • all first responders wear their PPE while rendering first aid. • emergency eye wash equipment are provided and are readily accessible. • safety committee members inspect and activate emergency eye wash equipment during their inspection to ensure functionality of the equipment. R&S will organize a yearly or upon request, First Responders/CPR training by appointing an external resource based on their qualifications and experience. Upon successful completion of the training, first responders will be issued a certificate and a card. CPR/First aid certified persons will ensure that they are in possession of their first aid 7.5 First aid
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Risk & Safety-P-001 ACCIDENT PREVENTION PLAN
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card at all times. Training certificate will be forwarded to Training Development/P&C for record keeping purposes. First aid kits will be kept unlock and shall be made from material that will protect from damage, deterioration, or contamination in the work environment. Department Management/Safety Committee members will ensure a constant supply of First aid items are available, will check first aid kit on a monthly basis and purchase first aid items through D365 (reference items in purchase Catalogue found on EGNW P:\drive). All locations will be provided with emergency eye wash units, strategically placed for easy access. These areas will be identified through “eye wash” signs. EGNW has identified that there is no potential for an employee’s body to contact corrosives, strong irritants or toxic chemicals, hence no emergency shower will required, however, the company will continue to monitor its activities and will decide if emergency showers will be needed. Store managers will ensure during installation: that eye wash stations meet ANSI Z358.1, delivers at least 0.4 gallons (1.5 litres) of water per minutes for fifteen minutes or more; located no more than ten (10) seconds (50ft) of reach; installed 33” to 45” off floor, areas are kept free of obstacles and will conduct monthly inspection of those units to ensure proper functionality. Awareness and communication on use of emergency eye wash station and location will be covered during New Hire Orientation.
7.5.1 Refer to Eye Wash Unit Procedure for further information.
R&S will help to interpret first aid requirements and will act as a liaison with the State Department of Labor & Industries (L&I) for health and safety, including first aid requirements.
7.6 Good Samaritan Act
Employees who obtained first aid training as a collateral duty and not as a primary job assignment are covered by the Good Samaritan Statute (RCW 4.24.300), which states: “Any person, including but not limited to a volunteer provider of emergency or medical services, who without compensation or the expectation of compensation renders
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emergency care at the scene of an emergency or who participates in transporting, not for compensation, therefrom an injured person or persons for emergency medical treatment shall not be liable for civil damages resulting from any act or omission in the rendering of such emergency care or in transporting such persons, other than acts or omissions constituting gross negligence or willful or wanton misconduct.”
7.7 Blood-borne Pathogens Training (BBP)
EGNW employees who will be trained as first aid responder as a collateral job duty will be enrolled in an annual blood-borne pathogen (BBP) training and will be offered a Hepatitis B immunization. The immunization will be on a voluntary basis. Immunization Forms will be maintained by Department Management in Employee’s file for record keeping. BBP training will be available on “Training At Goodwill” (TAG) EGNW Learning Management System (LMS). In the event that an EGNW employee will be exposed to human blood or body fluids during the administration of first aid or any other activity in the workplace, the employee shall notify their supervisor immediately in order to be referred to the appropriate health clinic for post-exposure follow-up. In addition, an incident report via Vector will be completed by Department Management. Department Management will ensure that personal protective equipment and bio hazards kits for such task are available, approved and maintained. R&S will approve waste profile for BBP. Leadership will call BBP collector as and when required.
7.7.1 Refer to BBP Plan
7.8 Sharps Waste
Sharps waste will be regulated by state law and must be separated from the regular waste stream. The term “sharps” refers to items used to puncture or cut body parts like needles including syringes with needles, syringes without needles, lancets and scalpel blades.
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Risk & Safety-P-001 ACCIDENT PREVENTION PLAN
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Sharps will not be disposed in trash as they have the potential to cause punctures, cuts and poses a high risk of exposure to waste handlers, hence, special handling will be required. The following are considered as sharps waste if they are contaminated with a biohazard and will be disposed by outside vendors: • Broken glass • Razor blades • Metal shavings • Needles, syringes R&S will not collect bio-hazards waste. Leadership will contact outside vendor as outlined in their emergency contact list. Automated external defibrillators, or AEDs, are electronic devices designed to recognize cardiac arrhythmias and treat them through defibrillation, an electrical therapy shock which allows the heart to re-establish the proper rhythm. Under RCW 70.54.310, Department Management will ensure that AED’s are provided in each buildings; First Responders will receive training on proper use of AEDs; AEDs will be periodically tested (monthly) and maintained as per the manufacturer’s operational guidelines. AEDs location will be marked with AED signs throughout each building. After use of AED pads, managers will ensure that pads are replaced immediately by placing an order on D365. After emergency use of an AED, the individual providing first aid will call 911 and will assure that appropriate follow up data is made available as requested by an emergency medical service or other health care providers. 7.9 Automated External Defibrillators (AEDs)
7.10 Working Alone/Isolated workers
The Department of Labor and Industries (L&I) defines “Isolated Workers” as janitors, security guards, hotel housekeepers, and room service attendants who spend most working hours alone. Usually, employees in this line of work do not have a co-worker present throughout their day”.
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Risk & Safety-P-001 ACCIDENT PREVENTION PLAN
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EGNW has identified that in some operations like ADCs (trailer sites), employees will be called to work alone as well as in instances in sites that have 2-3 members and due to shift differential or call-outs, individual might have to work alone. In such cases, ADC managers/supervisors will be made aware of areas with only one employee, there will be constant communication between leadership and lone worker. In case of emergencies employee will be trained to call 911 by using their cell phone. ADC management will be required to determine the best method to ensure the availability of first aid for their employees. This determination depends on the work location(s) and type(s) of work activities.
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Risk & Safety-P-001 ACCIDENT PREVENTION PLAN
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8.0 Identifying and Mitigating Hazards 8.1 Job Hazard Analysis (JHA)
A JHA is one method of determining hazards at worksite. EGNW could require a Job Hazard Analysis every 5 years or when there is a new process introduction, new equipment acquisition or changes in work set up. R&S will assist departments in identifying hazards present in a work environment and will develop appropriate mitigation plans. It will be the responsibility of the department to enforce recommendations following the JHA to protect their employees. JHA records will be maintained by R&S Department for a period of 5 years. The JHA records will be available on company’s Risk and Safety drive.
8.2 Hierarchy of Control
R&S Department will use the hierarchy of control to propose measures to reduce risks.
8.2.1 Elimination
Physically removing hazard will be the most effective way in hazard control. R&S will choose to eliminate identified hazards, wherever possible, before the risk is introduced in the business through partnership with other department when buying new chemicals, re-
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Risk & Safety-P-001 ACCIDENT PREVENTION PLAN
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designing work layout, purchase of new equipment/devices and disposal of existing equipment/waste.
8.2.2 Substitution
When a risk being introduced cannot be eliminated due to some business requirements, R&S will coordinate with departments for other substitution. This will include replacing the hazard with something less hazardous or with something that does not produce a hazard.
8.2.3 Design and Engineering Controls
The most effective way to mitigate hazards will be to eliminate the hazard entirely or control the exposure to the hazard through engineering controls. Departments will consider health and safety requirements during the design phase of a building, purchase of equipment, chemical introduction or process improvement. Identification of hazards and methods to eliminate those hazards through inherent safe design early in the planning phase could prevent a hazard from being inadvertently created from the start. Department managers will work with R&S to identify and control risks in process change or property improvements. Training will be an essential part of ENGW plan to provide a safe environment. The type of training required will be based on the hazards identified in a department. Department Managers will be responsible for ensuring that employees are appropriately trained prior to starting a task. Any safety training conducted shall be documented. The training record should include, at a minimum, the topic of the training, the name of the employee trained, the date of the training and the name of the trainer. Health and Safety Training Matrix will help managers identify appropriate safety trainings for their department. This document will be available on EGNW Public Drive in R&S folder. This is not an exhaustive list of trainings that an employee may be required to take. Training records for all instructor-led, online classes provided by R&S, training warranting 8.2.4 Administrative controls
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Risk & Safety-P-001 ACCIDENT PREVENTION PLAN
Prepared by: Prithy Madhoo Rev B: 7-5-2023 Date Created: 12-29-2021
certification and renewal will be available on “Training At Goodwill” (TAG) or with R&S or P&C. Upon recruitment or promotion of leadership, EGNW will require leaders to complete R&S Leadership Training so they understand their roles and responsibilities, understand the hazards and safety requirements as much if not more than the line employees. New employees (FT/PT/Temps) and leadership will be required to go through the initial R&S Orientation training on the first day of their employment. Monthly safety toolboxes will be used as a communication method to create awareness on various R&S topics throughout the year. Eliminating hazards through engineering design or administrative controls will be preferred over providing PPE. PPE is the least effective means of controlling hazards. EGNW will require that employees wear their PPE when they are exposed to hazards which cannot be controlled by engineering controls or other methods in their work environment. Each department’s managers/assistant managers/supervisors are responsible for enforcing PPE procedure, provision of PPE and use of PPE, A PPE hazard assessment is required by WAC 296-800-160. R&S will use PPE Hazard Assessment Checklist to conduct a PPE Assessment when there is introduction of a new process/risk or whenever required. Employees will be trained on proper use of PPE during Orientation and PPE refresher training will be completed on a yearly basis through toolbox talks. All required PPEs except safety shoes or clothes will be provided to employees at no cost by EGNW. 8.2.5 Personal Protective Equipment (PPE)
8.3 Introduction of New Chemical on site
EGNW will require that any chemical to be introduced into the workplace be approved by R&S. All persons involved in purchase or trial of a new chemical will collaborate with R&S for risk assessment and approval of chemical. To ensure proper document control all Safety Data Sheet (SDS), chemical inventory and training records will be maintained
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Risk & Safety-P-001 ACCIDENT PREVENTION PLAN
Prepared by: Prithy Madhoo Rev B: 7-5-2023 Date Created: 12-29-2021
by R&S in ENW Public Drive under R&S folder. Employees can view and print SDS by requesting a copy from their managers.
8.4 Chemical Hazard Communication (HazCom)
Hazard Communication is a set of instructions to keep employees safe by providing information about potential sources of injury when using hazardous chemicals in the workplace. EGNW is not considered a manufacturer, importer or seller of hazardous chemicals. The company recognized that employees are exposed to hazardous chemical from donated items. New chemical purchase will be approved by R&S to ensure no new risk is introduced into the business, develop chemical emergency protocol, training of employees, availability of PPE and disposal of hazardous waste. SDS will be maintained by R&S in R&S folder. EGNW employees will receive formal and documented training on the Hazardous Communication Program within 90 days of recruitment. Training will be delivered during orientation on “Training At Goodwill” (TAG). The HazCom program will include: • Identifying and listing hazardous chemicals in use by employees. • Ensuring chemical containers are labeled. • Ensuring employees have access to Safety Data Sheets (SDSs). • Training employees on the hazards of chemicals they work with, safe work practices to avoid exposure, signs and symptoms of exposure, and what to do in the case of a spill or emergency. • Ensuring employees adhere to posted warnings and safety information. Employees working with hazardous chemicals will comply with chemical hazard requirements in the SDS, HazCom program, instructions and policies. Hazardous waste will have a proper waste profile approved and records maintained by R&S. Employees handling hazardous waste will be properly trained and certified on “Training At Goodwill” (TAG). For further details refer to HAZCOM Program.
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Risk & Safety-P-001 ACCIDENT PREVENTION PLAN
Prepared by: Prithy Madhoo Rev B: 7-5-2023 Date Created: 12-29-2021
9.0 Recognized Safety Hazards Measures to prevent injury from a recognized set of potential occupational hazards that affect EGNW employees are addressed below. Any hazards not covered in this APP will be covered in separate procedures. 9.1 Slips, Trips and Falls On-the-job slips, trips, and falls occur frequently and will be avoided by applying these simple safety measures: • Regular 5S of the areas (5S is a five step methodology for creating a more organized and productive workspace: Sort, Straighten, Shine, Standardize, and Sustain) • Remove or rearranged clutter, electrical cords, or anything else that might cause someone to trip. • Arrange or remove furniture so walkways are not blocked or obstructed. • Keep emergency exits clear of any obstructions at all times. • Clean up spills immediately. • Use handrails when walking on stairs. • Avoid carrying items on stairs that can impair visibility or handrail use. One hand should always be free to grab handrail. • Wear shoes that are appropriate for the work environment. • Avoid using mobile devices while walking, always maintain eye contact. • Visually check for any cracks, damage, leaks or any structural damages and report to Facilities through Facility Request.
Training on slips/Trips and falls will be provided through monthly toolbox talks.
Any employee can report a slip, trip and fall to their immediate supervisor or directly by entering the incident on Vector.
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Risk & Safety-P-001 ACCIDENT PREVENTION PLAN
Prepared by: Prithy Madhoo Rev B: 7-5-2023 Date Created: 12-29-2021
9.2 Indoor Air Quality "Indoor Air Quality" generally refers to indoor office, production floor, assembly lines as opposed to outdoor settings. Indoor environments often have ventilation from windows or a heating and air-conditioning (HVAC) system. Common causes of indoor air quality complaints include inadequate outdoor air supply, odors from indoor or outdoor sources, molds or chemical use in production area and fumes. Smoking is prohibited while on EGNW property unless within designated smoking areas. Individuals who choose not to follow this policy will be subject to discipline. EGNW will follow State of Washington law regarding smoking in workplace. This will also apply to electronic cigarette usage. Smoking in unauthorized areas can cause indoor air quality concerns or other safety issues. Although signs are posted, employees will be encouraged to remind their peers not to smoke inside the building or within 25 feet of the building or near wood pallets and flammable products. Employees will be trained on smoking requirements during orientation. 9.3 Hearing Loss Prevention R&S will identify and assess activities where employees could potentially be exposed to high noise levels that may exceed 85 decibels (dBA) averaged over an eight–hour period. For accurate results additional assessments may be conducted by an Industrial Hygienist for noise levels exceeding Permitted Exposure Limit. Employees will be provided with adequate hearing protections and signs will be posted in areas with high noise level. Audio devices will not to be used in lieu of hearing protection. EGNW will not require a baseline assessment during pre-employment medical examinations for employees as the work environment does not qualify as a high noise level over a 8 hour-period. Employees will be encouraged to report any noise above the 85dBA limit or induced hearing issues to their supervisors or R&S. If required, EGNW will conduct an industrial hygiene test for indoor air quality and noise every 5 years or when there are changes in processes or complaints. Indoor air quality test record will be kept by R&S Department and result will be communicated to employees through toolbox or email.
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