JSA/JHA: Does every worker at your facility have one in place and know what his/her role is in it? Are these updated as needed and evaluated at least annually or when job duties change?

The Everyday Balance of Vision Protection Programs

Every job needs to have not only a job description, but also a hazard analysis, which can change over time.

"Is your vision protection program balanced with wants and needs?"

Before you answer that you want "zero vision accidents," evaluate the needs and baseline status of your vision protection program, and also the costs and benefits to both your employees and loss prevention goals. A well-designed and –managed, "successful" vision protection program is not simply about product selection. To manage and be successful with a critical program such as vision protection, you have to look beyond the simple code compliance.

The simplistic "thou shalt wear vision protection" fails to consider all the critical key elements of running and maintaining a solid, workable program. Quoting the code is the baseline for any safety program, but especially vision protection. Our programs must move past basic compliance into true performance programs in order to succeed. Consider these areas to help you determine where your program really stands, ranging from nothing to fully compliant and actually proactive and working:

  • As safety, what is your involvement in the planning/implementation of personal protective equipment and how it translates into loss prevention? Exactly like upper management, supervisor, or line worker, you have the knowledge, background information, and method to ensure your program is not only functional . . . but successful at all levels.
  • Not just product selection: Have you made sure all the needed elements of a functional program are in place, such as education and training? Are these measures kept current and fresh, or do the employees groan when they are forced to endure training?
  • Program evaluation: Has a true vision protection program evaluation been done and discussed with all levels of employees, the safety committee, and management?
  • Eye injuries matter: Detail every process that could possibly create the situation where an eye injury could occur. Not just high-hazard items, such as grinding or welding—think about janitorial chemicals, floor strippers, etc. If it can splash, splinter, or fly . . . that is a good place to start. Every job needs to have not only a job description, but also a hazard analysis, which can change over time. (When was the last time your company's were updated?)
  • JSA/JHA: Does every worker at your facility have one in place and know what his/her role is in it? Are these updated as needed and evaluated at least annually or when job duties change? More importantly, does upper management fully understand what exactly a JSA/JHA is and how it can contribute to the long-term loss control bottom line? ( I often notice managers disregarding these valuable documents and signing without really reading/understanding them.)
  • Leadership at all levels: Every worker at your facility knows immediately when a new program is honest or if it is only hot air to appear to be within compliance. Your top leaders have to understand and be up front about their strengths and backgrounds. No one is an expert at everything, and your employees accept willingly when leaders admit this and ask questions. A great leader knows when to give advice and apply it to the process at hand and when to keep his or her mouth shut. (Which are you?)
  • Disciplinary action efforts: Do you coach your employees or simply whack them with disciplinary action, which often creates a disgruntled employee and defeats your purpose. This is especially true when any disciplinary action is tied to conduct, bonuses, or promotion. Disciplinary issues are real but need to be stepped in order to be fair and consistent.
  • Feedback: Do employees have a venue to report vision protection items that simply do not meet the need? Or request changes such as sizing or immediate availability? If employees have to wait to replace a broken/damaged PPE item, chances are they will hesitate to report it, and either work with damaged PPE (scratched lenses, for example), which increases the potential for personal injury or injury to others and even production loss. I do not endorse open-pocketbook purchasing, but it needs to be balanced so that costs are tracked and employees have accessibility. If they do not have it, the item does not fit or is hard to adjust, then they cannot wear it right now on this shift. Your program loses.
  • Leadership from the ranks: Are you using your safety meetings to full advantage before an incident? Is there a method for proactive feedback from the rank and file employee? Often managers become out of touch with production issues, and your employees on the line have excellent ideas and can save time, money, and make simple process changes that improve morale while reducing the potential for injuries. Your employees know when you treat them like "little children" or, worse yet, like "drones." Involving them in the simplest of your safety programs gain their respect and open the door to solid problem-solving ideas on other topics.
  • Program history: What is the impact of vision protection program management over the years? Have the number of associated injuries gone down, stayed the same, or increased? Consider the employment levels, not just injury numbers, and also review overtime hours, new production issues, and employee turnover levels.
  • Employees: Managers and employees alike know specifically the injury data for their department. Do you share timely information or last year’s data? Make it current . . . your employees may have really good advice on changes to processes that will reduce injuries. Are you willing to listen to them?
  • When asked, your workers' comp rep knows the costs associated with eye injuries and how many lost work days per year, what salary costs, occupation, long-term disability, etc. Make sure the department managers know specifically for their areas so that they can keep a keen eye on specific processes.
  • Safety matters: Is your program documentation in order? Do you conduct a regular walk-through with corrective actions? Are programs associated with vision protection, such as chemical safety, up to date? First aid program? Training? Grinding? Remote employee duties? Make a list of every safety program that could apply to your employees' vision protection initiative and start there.
  • Keeping all parts of the program in place and up to date: If you are struggling with this, call on consultants, trainers, and the vast array of educational materials available!
  • Active training and learning environment: This includes the safety committee, teamwork, and toolbox talks being used. Is it documented, timely and appropriate for the work being done? Bilingual? User friendly? Adaptable 24/7? Upgradable as processes or codes change? Do employees actually use it or sleep through it?
  • Problems are viewed as challenges to be resolved, not barriers: Process changes occur all the time within most companies. Make sure there is a method for reviewing all of the conditions and new or unique hazards that may be created—each and every one afforded protection and full treatment. This needs to be done before the first injury occurs, not as a follow-up.
  • New products are introduced when possible, and employees are given a choice of appropriate PPE for the job to facilitate comfort: However you want to introduce and discuss these new products is great. Some employers leave them out in break areas; others provide at tailgate or toolbox talks as prizes. Others provide sample products at structured meetings with feedback. Do whatever works to get the products into the hands (and on the faces) of your workers. Many companies are going the extra mile and providing PPE such as safety sunglasses, a faceshield for home use (weed eating, lawn mowing, pressure-washing houses, etc.), knowing that reduced injuries at home mean increased work time. It's another benefit for your workplace, although hard to track. Employees learn safety integrity by using PPE regularly.

Safety is becoming less of a "thou shalt" bully and intimidation environment and more into team and looking at the entire picture of the employees, the corporate culture, and long-term goals. It's about time, in my opinion!

Those workplaces that continue to use only the negative reinforcement and go light on the education and leadership will cultivate drone mentality in the workplace, and a failure-to-report accident culture. When employees are afraid of being written up for the slightest infractions, it breeds the insecure employee who does not communicate with management or safety representatives, and the workplace will suffer for this.

Successful management of vision protection or any safety program is making sure all employees feel the ownership of all the elements and know they have a place at the table to make needed changes before the accident happens. I have long endorsed having a partnership and promoting a positive safety presence instead of dread. Safety should be the eyes and ears of upper management and be in the position to provide honest, up-to-date analysis and data to a management that will listen. We still have work environments where safety is "I'll call you when I want your input," and this defeats our goal of prevention. Our workforce is changing with better-educated, more-informed employees who know the codes and also their rights. Gone should be the days of "us and them" on shop floors, and our role as safety professional has moved into analysis rather than dreaded corporate snitch.

The downside is management who do not listen even though our experienced advice and overall goal is exactly the same . . . protection in the workplace, sending employees home uninjured, and reducing loss. You have to decide how to best balance the need of the program and the wants of both management and employees at your facility—taking a stand for the ethical service and management. What you do with this knowledge and how you expose everyone at the facility and the method/tone you use will make or break your program. Make a list of what efforts you are making to promote a positive, benefit-driven image of your vision protection program.

The choice is yours; your employees' vision depends on it. We have to be proactive through transparency in effort and in deed.

2018 Vision Protection Program Checklist—A Reminder of Important Program Elements
While no checklist is a substitute for a safety program, it serves as "reminders" of areas to focus additional attention as you strengthen your safety leadership role. Many effective safety programs begin as a simple checklist that grows as understanding of the requirements improves. As you evaluate your vision protection program at a glance, consider the following on your own or in discussions with employees or your safety committee:

Yes/No: You have an effective safety program on site. This includes all aspects of a functional safety program. Be honest with your evaluation, taking into account accident history, employee turnover, and associated costs. Is the program documented, and is the documentation up to date and easy to locate in event of an audit?

Yes/No: An assessment for possible eye injury hazards has been conducted at your facility and is updated as needed or at least annually. This in-depth assessment includes physical hazards and any processes that may produce splinters, dust, chemical exposures, radiation hazards, bloodborne pathogens, or new emerging hazards that are just now being discovered.

Yes/No: Each position has been evaluated for duties that require vision/face protection. Every position has an active JSA/JHA on file that is up to date and monitored/signed off on by upper management. Do you include temporary, contract employees or visitors in your protection program, depending on duties, or explain requirements in contracts with vendors?

Yes/No: Your on-site workers' comp representative (or whoever maintains the OSHA logs) knows how to record injuries correctly and the protocol for reporting loss of eye(s), hospitalizations, and fatalities? Do you maintain a current set of appropriate codes or quick access to them?

Yes/No: You track year to year/month to month, and by shift/process, etc., the previous record of eye injuries and location/type of injury so that special consideration of duties can be evaluated to prevent future injuries. Do different years compare or is each injury unique?

Yes/No: Updates to training and awareness for supervisors is regularly provided with special emphasis for higher hazard operations. How about after an injury? Do employees understand best practices and PPE on the job?

Yes/No: Employees understand the danger of not wearing required PPE such as safety glasses, goggles, faceshields, or chip guards and types of injuries that can occur. Do you ensure they understand? Do you have any type of disciplinary system for non-compliance/repeat offenders who do not wear required PPE? Is this documented through HR?

Yes/No: Do you ensure employees understand the use of systems for protection, such as wearing a faceshield and chemical goggles together for vision/face protection when needed? How? Skills training? Classroom? Mentor?

Yes/No: Do you maintain a positive safety leadership attitude and follow the rules on the job? Are you sure? (What would your employees say about your attitude?)

Yes/No: All levels of management wear PPE when needed. This includes upper management, safety, visitors etc. (Nothing breaks a safety program like a "do as I say, not as I do" attitude of upper management.)

Yes/No: As part of their training, each employee is shown how to use, wear, clean, and when to replace each item? Employees understand there is no repercussion for needing to replace an item?

Yes/No: If more than one language is present in the workplace, training is conducted in the employees’ first language or translation is available to ensure understanding. This affects awareness items, posters, etc., as well.

Yes/No: Awareness items are also bilingual if needed for employees. Are they updated?

Yes/No: Employees are allowed the opportunity to ask questions concerning wearing, cleaning, and replacement of PPE for vision protection.

Yes/No: Employees are aware of prescription safety glasses options available through work.

Yes/No: There is appropriate first aid on site for an eye-related injury. Is this training up to date?

Yes/No: As part of your first aid program, appropriate flushing/eyewash and safety showers are located where and when needed? Are these inspected and maintained correctly and activated weekly? (Are you sure?)

Yes/No: An accident investigation is initiated following all eye/vision injuries and reported to management. This is a time-sensitive issue; is it handled quickly?

Yes/No: Safety is called immediately after any serious injury. The supervisor is immediately made aware of any injury, serious or otherwise.

Yes/No: Upper management is made aware of serious eye injuries and corrective actions taken, and the costs/treatment are tracked appropriately.

Yes/No: Eye injury statistics and costs are tracked for increase/decrease on a regular basis. Is this information shared with employees for feedback?

Yes/No: Purchasing statistics on type, cost, and replacement is tracked to monitor use and replacement for departments to monitor what products are working the best.

This article originally appeared in the August 2018 issue of Occupational Health & Safety.

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