Course 112 Introduction to Safety Supervision

The First STAR Responsibility

S - Provide Supervision

Kevin Burns - The Greatest Influence on Safety Is Not Who You Think

Let's start with the basics. If you look up the word supervise in Webster's Dictionary, you'll see is derived from the Latin term, "super-videre," which means "over-to see". Before the common use of the term, "supervisor," the term used most commonly was "overseer." To supervise now commonly means:

  • observe and direct the execution of (a task, project, or activity).
  • observe and direct the work of someone.
  • keep watch over someone in the interest of their or others' security.

The Supervisor is Important

So, why are supervisors so important? They can take immediate, direct action to make sure their work areas are safe and healthful for all employees.

In his text, Occupational Safety and Health Management, Thomas Anton relates that the supervisor bears the greatest responsibility and accountability for implementing the safety and health program because it is he or she who works most directly with the employee.

It is important supervisors understand and apply successful management and leadership principles to make sure their employees enjoy an injury- and illness-free work environment. But how does management and leadership differ? Management may be thought of as applying organizational skills, while leadership involves effective human relations skills.

The Key: "Super Vision"

It's extremely important for a supervisor to provide adequate oversight so he or she may uncover hazardous conditions (materials, tools, equipment, environment) and unsafe work practices before they injure or kill a worker.

It may be difficult to prove to OSHA that the employer has provided adequate supervision when an accident occurs because an accident implies failure on the part of the employer to proactively detect and correct hazardous conditions and unsafe behaviors before an accident occurs.

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1. Adequate safety supervision is defined as _____ before an accident occurs.

a. reporting hazards and unsafe behaviors to OSHA
b. detecting and correcting hazards and unsafe work practices
c. disciplining employees for infractions
d. inspecting and training employees

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What the Law Says

Chart depicting the hierarchy of controls
President Nixon signs the OSHAct of 1970.

As detailed in the Section 5 (The General Duty Clause) of the OSHA Act of 1970, the employer is assigned responsibility and held accountable to maintain a safe and healthful workplace. The following is an excerpt from Public Law 91-596, 91st Congress, S. 2193, December 29, 1970.

Section 5

(a) Each Employer -

  • (1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees;
  • (2) shall comply with occupational safety and health standards promulgated under this act.

Employer Accountability

Employers can be cited by OSHA for violation of the General Duty Clause if a recognized serious hazard exists in their workplace and the employer does not take reasonable steps to prevent or abate the hazard. The General Duty Clause is used only where there is no standard that applies to the particular hazard.

Supervisors: Agents of the Employer

A key concept to understand is that legally, supervisors are "agents of the employer," and assume the responsibilities of the employer to the degree they are given authority. This first module discusses some of the basic employer and supervisor obligations to employees under OSHA law. Fulfilling these obligations is a key requirement of effective safety supervision.

2. Under the OSHAct, employers must keep workplaces free of _____.

a. non-compliant performance
b. unsafe behaviors
c. recognized hazards
d. all hazards

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OSHA-Mandated Responsibilities

Chart depicting the hierarchy of controls
The OSHA "It's the Law" poster.
(Click to enlarge)

As you can see, employers have clearly defined responsibilities under the Occupational Safety and Health Act of 1970, and as the "agent of the employer" the supervisors have the same responsibilities for the employees they supervise. The following list are basic responsibilities stated throughout OSHA standards.

  • Provide employees a workplace free from recognized hazards. It is illegal to retaliate against an employee for using any of their rights under the law, including raising a health and safety concern with you or with OSHA, or reporting a work-related injury or illness.
  • Comply with all applicable OSHA standards.
  • Report to OSHA all work-related fatalities within 8 hours, and all inpatient hospitalizations, amputations and losses of an eye within 24 hours.
  • Provide required training to all workers in a language and vocabulary they can understand.
  • Prominently display this poster in the workplace.
  • Post OSHA citations at or near the place of the alleged violations.

Employee Rights

Under OSHA law, you are entitled to working conditions that do not pose a risk of serious harm. Workers have certain rights, under OSHA law, and employers have certain responsibilities.

Workers have the right to:

  • A safe and healthful workplace.
  • Be free from retaliation for exercising safety and health rights.
  • Raise a safety or health concern with your employer or OSHA, or report a work-related injury or illness, without being retaliated against.
  • Receive information and training on job hazards, including all hazardous substances in your workplace.
  • Request an OSHA inspection of your workplace if you believe there are unsafe or unhealthy conditions. OSHA will keep your name confidential. You have the right to have a representative contact OSHA on your behalf.
  • Refuse to do a task if you believe it is unsafe or unhealthful.
  • Participate (or have your representative participate) in an OSHA inspection and speak in private to the inspector.
  • File a complaint with OSHA within 30 days (by phone, online or by mail) if you have been retaliated against for using your rights.
  • See any OSHA citations issued to your employer.
  • Request copies of your medical records, tests that measure hazards in the workplace, and the workplace injury and illness log.

3. According to the OSHAct, each of the following is an employee right under the OSHAct, EXCEPT _____.

a. requesting an OSHA inspection for any reason
b. filing a complaint to OSHA
c. a safe and healthful workplace
d. raising a safety and health concern

Next Section

You have a right to file a complaint without fear of retaliation.

Right to File an OSHA Complaint

As a supervisor, you must be familiar with the conditions under which employees may file a complaint with OSHA. They may contact OSHA if they believe a violation of a safety or health standard or an imminent danger situation exists in their workplace. They may request that their name not be revealed to their employer. They can file a complaint on OSHA's website, in writing or by calling the nearest OSHA area office. They may also call the office and speak with an OSHA compliance officer about a hazard, violation, or the process for filing a complaint.

If the above conditions are met, they may take the following steps:

  1. They must first ask the employer to correct the hazard, or to be assigned other work;
  2. They may tell your employer that they won't perform the work unless and until the hazard is corrected; and
  3. They should remain at the worksite until ordered to leave by the employer.

If they file a complaint, they have the right to find out OSHA's action on the complaint and request a review if an inspection is not made.

Discrimination Against Employees

Chart depicting the hierarchy of controls
OSHA's Whistleblower Website
(Click on link above.)

It's also important to know Section 11(c) of the OSHAct authorizes OSHA to investigate employee complaints of employer discrimination against those who are involved in protected activities. Protected activities generally fall into four broad categories:

  1. Providing information to a government agency;
  2. Filing a complaint or instituting a proceeding provided by law such as the OSHAct;
  3. Testifying in proceedings and participating in OSHA inspections and investigations; and
  4. Refusal to perform work if the employee has a good faith or reasonable belief that working conditions are unsafe or unhealthful and the employer has not provided an adequate explanation that the conditions are safe.

Some examples of discrimination are firing, demotion, transfer, layoff, losing opportunity for overtime or promotion, exclusion from normal overtime work, assignment to an undesirable shift, denial of benefits such as sick leave or vacation time, blacklisting with other employers, taking away company housing, damaging credit at banks or credit unions and reducing pay or hours.

4. Employees may refuse to perform work if they believe working conditions are unsafe or unhealthful and the employer _____.

a. reassigns them to another approved task
b. recommends common sense when exposed to hazards
c. does not adequately explain that the conditions are safe
d. is making good faith attempt to make corrections

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Identifying Hazards

copyright oshacademy MEEPs images
To remember the hazard categories, just say "MEEPS".

The employer is responsible for identifying hazards. It's useful to categorize them into five categories:

  • The first three categories (materials, equipment, and the environment) represent hazardous conditions. Hazardous conditions are the surface causes directly account for only a small percentage of all workplace accidents.
  • The fourth category (people) describes employee behaviors. Employee behaviors represent the surface causes that contribute to or cause a higher percentage of workplace accidents.
  • The fifth category (system), identifies safety management systems weaknesses. They are the root causes that ultimately contribute to or cause most accidents.

Let's review these five categories:

Materials: liquids, solids and gases that can be hazardous to employees.

  • Liquid and solid chemicals (such as acids, bases, solvents, explosives, etc.) can produce harmful effects.
  • Raw materials (solids like metal, wood, and plastic) used to manufacture products are usually bought in large quantities and can cause injuries or fatalities in many ways.
  • Gases, like hydrogen sulfide and methane, may be extremely hazardous if leaked into the atmosphere.

Equipment: machinery and tools used to produce or process goods.

  • Hazardous equipment that is improperly guarded and places workers in a danger zone around moving parts could cause injury or death.
  • Lack-of a preventive and corrective maintenance will make it difficult to ensure equipment operates properly.
  • Tools that are not in good working order, improperly repaired, or not used for their intended purpose is only an accident waiting to happen.

Environment: general area that employees are working in.

  • Poor facility design, hazardous atmospheres, temperature and/or noise can cause stress.
  • If areas in your workplace are too hot, cold, dusty, dirty, messy or wet, then measures should be taken to minimize the adverse conditions.
  • Extreme noise that can damage hearing should not be present.
  • Workstations may be designed improperly, contributing to an unsafe environment.

People: employees, managers, supervisors, in the workplace.

  • Unsafe employee behaviors include taking short cuts or not using personal protective equipment.
  • Employees who are working while fatigued, under of influences of drugs or alcohol, distracted for any reason, or in a hurry are "walking and working hazards."

System: Ultimately, the root cause of most accidents is one or more weaknesses within the safety management system.

  • Management may unintentionally promote unsafe behaviors. For example, they may ignore non-compliance.
  • Inadequate or missing safety plans, programs, policies, processes, procedures, practices, and rules (written and unwritten) may somehow result in injury, illness, or death in the workplace.

5. Which of the following MEEPS hazard categories includes root causes and ultimately is the result of most accidents?

a. Materials
b. Equipment
c. Environment
d. System

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Supervisor Tools

There are several effective tools supervisors can use to help them identify and correct hazards including, observations, inspections, job hazard analyses (JHA), and incident/accident investigations.

Make Observations

rf123 photo 18124011_s
Observers are much better at detecting unsafe behaviors. I think we should tell this observer to turn around.

Observation is important because it can be a great tool to effectively identify behaviors that directly account for the greatest percentage of all workplace injuries. It's better than other tools that we will discuss because observation focuses on discovering unsafe behaviors rather than hazardous conditions. There are two types of observation:

Informal observation. An informal observation process is nothing more than being watchful for hazards and unsafe behaviors throughout the work shift. No special procedure is involved. All employees should be expected to look over their work areas once in a while.

Formal observation program. One of the most effective proactive methods to collect useful data about the hazards and unsafe behaviors in your workplace is the formal observation program because it includes a written plan and procedures.

For example, safety committee members or other employees may be assigned to complete a minimum number of observations of safe/unsafe behaviors during a given period of time. Here is what can be done with the data gathered:

  • This data is gathered and analyzed to produce graphs and charts reflecting the current status and trends in employee behaviors.
  • Posting the results of these observations tends to increase awareness and lower injury rates.
  • The data also gives valuable clues about safety management system weaknesses.

Note: An important policy for successful formal observation procedures is that they are not, in any way, linked to discipline. Observers should not discipline or "snitch" on employees. Discipline should never be a consequence of an observation. To do so ensures any observation program will fail as an accurate fact-finding tool. Follow these best practices:

  • Use only employees who do not have authority to discipline as observers in the program.
  • If managers or supervisors participate, make sure they do not observe in their own areas of responsibility.
  • Make sure everyone understands the policy regarding "no discipline" as a consequence of an observation.
  • It is also important for observers to express appreciation when safe behaviors are observed, and remind or warn employees to use safe practices if they are not performing a task safely.

6. Which of the following hazard identification activities focuses on analyzing unsafe behaviors in the workplace?

a. Investigations
b. Observations
c. Job Hazard Analysis (JHA)
d. Inspections

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Conduct Safety Inspections

rf123 photo 20651058_s
Inspections are good at finding conditions, but not so good at uncovering unsafe behaviors.

Another important activity to ensure a safe work area is to conduct an effective walkaround safety inspection. To be most effective, it makes sense that the safety inspection responsibility be delegated to the supervisor. Who is better positioned to effectively identify and correct workplace hazards? Remember, as an agent of the employer, the basic responsibility to inspect the work area should rest with supervisors.

During the inspection, look for hazards in the five MEEPS categories. In some instances, using an inspection checklist may be a good idea to make sure a systematic procedure is used. The only downside from using a checklist regards the "tunnel vision" syndrome: hazards not addressed on the checklist may be overlooked. Another problem is that inspectors may be looking only for "conditions" and ignoring "behaviors." Check for both when inspecting.

Make everyone an inspector. Supervisors should not be the only persons inspecting for safety in the work area. Everyone should be an inspector. But how does the supervisor get employees to willingly inspect for safety every day? Simple, supervisors set the example by inspecting regularly, they insist that everyone inspects, and they recognize (thank) their workers for inspecting and reporting hazards.

Perform Job Hazard Analyses (JHA)

Sisk & Co. - Job Safety Analysis.

Another effective activity to ensure a safe and healthful workplace is the Job Hazard Analysis (JHA). This process is also called a Job Safety Analysis (JSA) In the JHA process, supervisors and employees together analyze each step of a particular task and come up with ways to make it safer.

Why the JHA?

The Problem: Unfortunately, the walkaround inspection is usually just an assessment. It merely attempts to determine if a hazard is present or not. It's conducted by one or two persons who walk around looking high and low to uncover hazardous conditions (We call this the "rolling eyeball syndrome"). If properly trained, they may effectively uncover hazards. If properly trained they may know how to effectively question employees during the inspection (they ask questions other than "any safety complaints?"). The most serious weakness inherent in the safety inspection process is that very little time is devoted to analyzing any one particular work area. For more information on conducting a JHA, see course 706 Job Hazard Analysis.

7. Why is the Job Hazard Analysis more effective than the walkaround inspection in helping to make the workplace safe and healthful?

a. The JHA is more popular than the inspection.
b. The JHA emphasizes hazardous conditions.
c. The JHA focuses only on behaviors.
d. The JHA focuses on hazards and behaviors.

Next Section

Investigate Incidents and Accidents

Action Form - Step by Step SAIF Corp.

Another important responsibility of the supervisor is to investigate near-miss incidents and injury accidents. Although incident/accident investigations are "reactive" because they occur after the near-miss or injury event, they may still be quite effective by identifying hazards and preventing future injuries. Check out the video to the right to learn more about the "Action Steps" in the incident/accident investigation process.

Make sure employees report near-misses. It's a proven fact investigating near-miss incidents is effective for a number of reasons.

Investigating incidents is always less expensive than investigating accidents because an injury or illness has not occurred.

Accident investigation - Safety triage Accident investigations that occur after someone is injured are still very important if the primary purpose is to uncover root causes.

Fix the system: not the blame. It is never appropriate to conduct accident investigations to place blame: to do so is basically a waste of time and will harm the safety management system in the long term. Discipline should be administered only after it can be shown that no safety management system components somehow contributed to the accident.

Investigate all accidents. Although OSHA requires the employer to investigate only serious-injury accidents, it's important to investigate even minor accidents because, what might be today's cut finger, might be tomorrow's amputated hand. It's that simple.

The Incident/Accident Investigation Process

Accident investigation is a seven-step process with the ultimate of conducting accident investigations.

  1. Secure the scene - to make sure evidence is not moved or disappears.
  2. Document the scene - to gather data about the scene.
  3. Conduct interviews - to determine events that led up to and included the accident event.
  4. Develop the sequence of events - to determine exactly what happened in the proper sequence.
  5. Conduct cause analysis - to determine surface and root causes associated with each event.
  6. Determine the solutions - to develop immediate corrective actions and long-term safety management system fixes. Discipline is not a long-term solution.
  7. Write the report - that emphasizes events, causes, solutions, costs, and benefits. Do not recommend discipline. That should be the job of a safety professional and the human resources department after careful analysis of the accident report.

8. Accident investigations should be conducted to fix the _____, not the _____.

a. system, blame
b. blame, system
c. behavior, hazard
d. hazard, behavior

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The Accident Weed
Click to Enlarge

Get To The Root Causes

Whenever hazardous conditions and unsafe behaviors are discovered through observations, inspections, JHAs, or investigations, it's important to determine their root causes.

A hazard, unsafe behavior, near-miss, or injury may be the result of many factors that have interacted in some dynamic way. When conducting hazard analyses or incident/accident investigations, be sure to include each of the following levels of analysis to make sure you uncover the root causes:

Injury analysis - How did the injury occur? At this level of analysis, we focus on trying to determine the direct cause of the injury that may or did occur. Examples of the direct causes of injury include:

  • Strain due to lifting heavy objects
  • Concussion from impact forces due to a fall
  • Tissue damage from contact with by a toxic chemical
  • Burns from exposure to flammable materials

Surface Cause Analysis - Why did the accident occur? Here you determine the unique hazardous conditions and unsafe behaviors that interacted to produce the accident. Each of the hazardous conditions and unsafe behaviors uncovered are the surface causes for the accident. They give clues that point to possible root causes/system weaknesses. Examples of surface causes include:

  • A broken ladder
  • A worker removes a machine guard
  • A supervisor fails to conduct a safety inspection
  • A defective tool

Root cause analysis - Why did the surface causes occur? At this level, you're analyzing the weaknesses in the safety management system that contributed to the accident. These weaknesses are inadequate/missing safety components such as policies, programs, plans, processes, procedures, or practices. Examples of root causes include:

  • Inadequate or missing safety management system components.
  • Inadequate performance or failure to carry out system components such as: failure to train, failure to provide PPE, and inadequate implementation of safe procedures.
  • Failure to enforce safety rules, discipline for safety infractions or recognize safe performance.
  • Failure to conduct safety inspections, JHAs, and incident/accident investigations

9. Which of the following is considered a root cause for an accident?

a. Inadequate safety procedures
b. Employee fatigue
c. Faulty equipment
d. An unsafe behavior

Next Section

Controlling Hazards and Behaviors

Hierarchy of Controls
Click to enlarge

Controlling hazards and behaviors are the two basic strategies for protecting workers. Controlling hazards are more effective than controlling behaviors, and for good reason. If you can eliminate the hazard, you don't have to worry about exposure due to human behavior. Traditionally, a "Hierarchy of Controls" has been used as a template for implementing feasible and effective controls.

ANSI/ASSP Z10-2012, Occupational Health and Safety Management Systems, encourages employers to use the following hierarchy of hazard controls:

Controlling Hazards

  1. Elimination: "Design out" hazards and hazardous exposures.
  2. Substitution: Substitute less-hazardous materials, processes, operations, or equipment.
  3. Engineering controls: Isolate process or equipment or contain the hazard.

Controlling Behaviors

  1. Warnings: To raise awareness of the hazards to which employees may be exposed, warnings in the form of signs, placards, cones, and barriers are used.
  2. Administrative/work practice controls: Job rotation, work scheduling, training, well-designed work methods, and organization are examples.
  3. Personal protective equipment: Includes but is not limited to safety glasses for eye protection; ear plugs for hearing protection; clothing such as safety shoes, gloves, and overalls; face shields for welders; fall harnesses; and respirators to prevent inhalation of hazardous substances.

As you can see, the preferred control strategies first try to control hazards through elimination, substitution, or engineering. If the hazards can't be eliminated, replaced, or engineered, the hierarchy next attempts to control exposure to hazards through warnings, administrative methods and personal protective equipment. It's important to understand that:

  • Elimination, substitution, and engineering controls are independent: they do not rely on behavior to be effective: that's why they are preferred.
  • Warnings, administrative, work practice, and PPE controls are dependent: they rely on compliant human behavior to be effective. Any solution that relies on human behavior is inherently unreliable in the long term.

The "big idea" behind this hierarchy is that the control methods at the top of the list are potentially more effective and protective than those at the bottom. Following the hierarchy of controls leads to the implementation of inherently safer workplace environments, where the risk of illness or injury has been substantially reduced.

10. Which of the following is the preferred method to control hazards?

a. Any two or more control methods in the Hierarchy of Controls
b. Work practice controls and personal protective equipment
c. Elimination, substitution, and engineering controls
d. Administrative and work practice controls

Check your Work

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Optional Video

Two years is a long time to be trying to get it right as a supervisor. Especially when it comes to safety. On this episode, Kevin Burns at PeopleWork, discusses the three C's to becoming a better safety supervisor.

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