Basic Occupational Safety and Health Program - Revision 3

1. PURPOSE
   This directive provides instructions for the basic components of the Agency's Occupational Safety and Health (OSH) Program and describes how the program fulfills the responsibilities required by the Occupational Safety and Health Administration (OSHA). FSIS is reissuing this directive to provide updated information regarding OSHA regulations and how FSIS complies with them.
2. BACKGROUND
   1. FSIS is required to maintain an OSH Program that complies with the OSHA Safety and Health Act of 1970 (the Act), Section 19, Federal Agency Safety Programs and Responsibilities; Executive Order 12196, Occupational Safety and Health Programs for Federal Employees; and 29 CFR 1960, Basic Program Elements for Federal Employees.
   2. For FSIS employees working in privately owned establishments, the Agency does not have authority to abate hazardous conditions directly. However, the Agency is required to provide employees with safe and healthy working conditions as part of the overall inspection process. Means used by the Agency to reduce exposure to hazardous work conditions include: administrative controls, providing employees with proper personal protective equipment (PPE), and removing employees (including withdrawing inspection program personnel (IPP)) from unsafe conditions as necessary for protection.
   3. As required by 29 CFR 1960.6(a), the Agency has a Designated Agency Safety and Health Official (DASHO) who has overall authority for the organization, administration, and implementation of the FSIS Safety Program.
3. CANCELLATION
   • FSIS Directive 4791.1, Basic Occupational Safety and Health Program, Revision 2, 2/1/00
   • FSIS Directive 2780.1, Environmental Management at FSIS Facilities, 1/18/01
   • FSIS Directive 2791.2 Laboratory Environmental, Health and Safety Management, 12/11/00
4. AGENCY SAFETY POLICY
   1. It is FSIS policy that the Environmental, Safety and Health Group (ESHG) administer an OSH program that:
      1. Reduces or eliminates human and financial losses incurred from injury or illness in the workplace;
      2. Motivates employees to work safely;
      3. Ensures the rights of employees, including freedom from reprisal; and
      4. Complies with applicable Federal, Departmental, and Agency regulations, policies, and directives.
   2. This directive does not affect current collective bargaining agreements or the authority of FSIS and its employees to consult on matters covered by this program, if statutory provisions and Executive Order 12196 are observed.
5. REPRISAL
   The Agency has established policy to protect employees from restraint, interference, coercion, discrimination, or reprisal for exercising any of their rights under the FSIS OSH Program. See FSIS Directive 4771.1, Administrative Grievance System for more information.
6. ENVIRONMENTAL, SAFETY AND HEALTH GROUP
   1. The Agency has established an ESHG to administer the OSH Program. The ESHG is part of the Office of Management (OM), Employee Safety, Health and Wellness Staff (ESHWS).
   2. The ESHG maintains an FSIS safety website at: Environmental, Safety and Health Topics. The public website contains information such as forms and directives related to the safety program, information about OSHA injury forms, and contact information for Occupational Safety and Health Specialists.
   3. The ESHG also maintains an internal safety website on the FSIS intranet at: Inside FSIS Environmental, Safety and Health Topics (Level 2 eAuthentication is needed to access this site). The intranet site contains occupational health and safety information for FSIS employees and safety committees such as injury and illness reports.
      
      NOTE: Supervisors are to print information from either the public or the FSIS intranet safety and health website and make it available to all FSIS employees, including those who may not have access to electronic mail when required information is posted to the website.
   4. The ESHG is comprised of three types of technical specialists:
      1. Occupational Safety and Health Specialist (OSHS) - The OSHS administers the OSH Program for FSIS employees in geographic regions of the country. An OSHS is assigned one or more Districts in the Office of Field Operations but is responsible for the safety program of all employees within that area. Contact information for each OSHS can be found at Environmental, Safety and Health Topics.
      2. Industrial Hygienist (IH) - The IH provides technical advice and support in identifying, assessing and minimizing workplace hazards that can cause illness, impaired health or significant discomfort as a result of exposure to chemical, physical and biological agents; and
      3. Environmental Manager - The Environmental Manager assists the agency with the management of hazardous materials, proper disposal of regulated wastes, administration of local Environmental Management Systems (EMSs) and compliance with Federal, state and local environmental regulations.
7. FSIS SAFETY POSTER
   1. OSHA requires that every FSIS workplace display the "Federal Agency Occupational Safety and Health Protection for Employees" poster (Safety Poster) in a prominent location within the workplace. The Safety Poster is available at: Environmental, Safety and Health Topics.
   2. The Safety Poster lists the rights of employees and their representatives. These include the right to:
      1. Participate in Department and Agency OSH Programs;
      2. Access OSHA standards, monthly injury and illness reports (via Inside FSIS Environmental, Safety and Health Topics), and Agency OSH procedures;
      3. Report and require correction of unsafe and unhealthy working conditions; and
      4. Report unsafe or unhealthy working conditions without reprisal.
   3. Although not listed on the safety poster, the Agency recognizes the rights of employees and their representatives to:
      1. Participate in the development of safety and health standards; and
      2. Decline to perform an assigned task because of reasonable belief that it poses an imminent danger of serious bodily harm or death and there is not sufficient time to seek effective corrective action through normal hazard reporting and abatement procedures.
   4. The DASHO contact information is listed on the FSIS Safety Poster.
8. SAFETY COMMITTEES
   1. The Agency supports safety and health committees and encourages active participation by employees. Safety committees for FSIS are primarily found within the Office of Field Operations (each circuit has a safety committee) to assist employees working in potentially hazardous conditions. However, they may also be formed in other program areas, as needed. Contact the OSHS for your area for assistance.
   2. Safety committees are to be comprised of up to two union representatives and at least one Agency representative to ensure compliance with OSHA requirements found in 29 CFR 1960.37 and the Labor Management Agreement (LMA).
   3. Each safety committee is to have a committee chairperson as determined by the committee members. The committee chairperson (or designee) is to:
      1. Prepare an agenda for each safety committee meeting;
      2. Lead the committee in the review of injuries and illnesses for the circuit or FSIS workplace. Injury and Illness information is available at: Inside FSIS Environmental, Safety and Health Topics; and
      3. Complete meeting minutes using FSIS form 4791-2 "FSIS Circuit Safety and Health Committee Report."
   4. The circuit safety committee is to meet twice annually. When mutually agreed to between management and the union, the committee may meet more often.
   5. The circuit safety committee is to:
      1. Solicit feedback on safety related issues from IPP;
      2. Collaborate with establishment safety committees when possible;
      3. Conduct a safety walk-through at two establishments per year and record findings on FSIS forms 4791-23 and 4791-24;
      4. Follow up on previous findings found on FSIS forms 4791-23 and 4791-24 to ensure corrective actions were taken;
      5. Verify that employee complaints of potentially hazardous conditions filed on FSIS form 4791-27 have been resolved and the completed form has been returned to the employee;
      6. Provide OSH findings and concerns to FSIS management who will in turn work with establishment management to mitigate hazards; and
      7. Provide a copy of completed form 4791-2 "FSIS Circuit Safety and Health Committee Report" to the Frontline Supervisor and post in the USDA office.
   6. All employees appointed to a safety committee are to review the following OSH training materials within 12 months of their appointment:
      1. FSIS video "The Safe Circuit." The video is available on CD from the CFL CD/DVD library;
      2. The directives listed in section IX. Training;
      3. Section 19, Federal Agency Safety Programs and Responsibilities of the OSH Act of 1970;
      4. Executive Order 12196; and
      5. 29 CFR 1960.58, "Training of Collateral Duty Safety and Health Personnel and Committee Members."
9. TRAINING
   1. All employees are to receive safety training appropriate to their position and duty station.
   2. Due to the potential for exposure to significant workplace hazards, all FSIS employees who work in Federally inspected establishments are to read this directive and the following FSIS directives within 30 days of hire:
      1. FSIS Directive 4791.5, Hazard Communication;
      2. FSIS Directive 4791.6, Procedures for Workplace and Travel Emergencies;
      3. FSIS Directive 4791.12, Reporting and Correcting Occupational Hazards; and
      4. FSIS Directive 4791.13, Workplace Inspections, and Injury, Illness and Motor Vehicle Incident Reporting.
   3. All employees at FSIS laboratories will receive safety training appropriate to their position. Training material is to be developed locally by laboratory employees responsible for the environmental, safety and health program. The ESHG provides assistance and resources for laboratory training as needed.
   4. All IPP with offline duties are required to take the course "Identifying and Reporting Workplace Safety and Health Hazards" (formerly known as AgLearn Course 8500) within 60 days of a new appointment. The course is available on CD and can be ordered from the Agency CD/DVD Library at: CD, DVD Request, (Level 2 eAuthentication is needed to access this site). In-plant FSIS supervisory personnel and FLS's are to provide bargaining unit employees with off-line inspection responsibilities up to four hours of administrative time to complete the AgLearn Course.
   5. All occupational health and safety training is to be recorded using either AgLearn or FSIS form 3530- 12. Training records are to include the topics covered, date, and employee name. The Agency is to retain all training records for a minimum of five years.
   6. Supervisors and Safety Committee Chairs may request training material about OSH topics from the ESHG by contacting the OSHS for their District or geographic location. Training services will be provided as time and resources permit.
   7. All new FSIS supervisors receive safety training from the ESHG through the New Supervisor Training Program that is administered by the Office of Outreach, Employee Education and Training (OOEET), Center for Learning (CFL), Organization and Employee Development Branch (OEDB).
10. SUPERVISORY RESPONSIBILITIES
    1. Supervisors are responsible, within the extent of their authority, for furnishing employees with workplaces free of recognized hazards that can cause serious injury, illness, or death. They also are to comply with all FSIS safety policies and procedures as well as applicable OSHA regulations.
    2. Supervisors are to respond promptly to reports of unsafe or unhealthful workplace conditions reported by FSIS employees. Employees may report hazardous conditions verbally, by e-mail or through FSIS form 4791-27. More information about the use of form 4791-27 can be found in FSIS Directive 4791.12.
    3. The Frontline Supervisor, Inspector-in-charge, or designee, is to conduct a safety workplace inspection annually using FSIS forms 4791-23 and 4791-24. More information about workplace inspections can be found in FSIS Directive 4791.13.
11. PERSONAL PROTECTIVE EQUIPMENT (PPE)
    1. The ESHG provides recommendations for required PPE to FSIS management for all FSIS personnel working in potentially hazardous conditions. All required PPE will be provided to employees by the Agency at no cost (or employees will be reimbursed for costs if needed). The ESHG provides assistance so that all Agency personnel who review or visit a plant on official business wear appropriate PPE.
    2. All PPE provided by the Agency can be obtained through the Material Management Service Center (formerly the Beltsville Service Center). PPE is found in the "Specialty Supply Catalog".
    3. Supervisors are to ensure that FSIS employees do not use PPE that has not been provided or approved by the Agency (e.g., PPE purchased by employees and brought into the workplace including: dust masks, hard hats, hearing protection).
12. PPE REQUIREMENTS FOR IPP
    1. PPE requirements are based on an assessment of hazards in the workplace. The ESHG may conduct a Job Hazard Analysis (JHA) in the future as needed or when requested by a supervisor or manager to evaluate exposure to workplace hazards. If a new hazard is identified that can be mitigated by specific PPE, the Agency will provide the new PPE to inspection personnel at no cost.
    2. Based on hazards identified in the JHA, all IPP at FSIS inspected workplaces are to wear the following:
       1. Hard Hat - The protective helmet is to be Agency provided and approved and meet the American National Standards Institute (ANSI) standards. Hard hats may not be cut, drilled or mutilated in any way and stickers may not be placed on hard hats. A ‘bump cap' is not a hard hat and is not approved for use;
       2. Slip-resistant Shoes - While working in an inspection assignment, all employees are to wear slip-resistant shoes. Employees are reimbursed for the purchase of slip-resistant shoes. See FSIS Directive 3410.3, Reimbursement Provisions for Inspection Expenditures;
       3. Hearing Protection - All employees who are exposed to noise levels exceeding an 8-hour time-weighted average (TWA) of at least 85 decibels (DBA) are to wear hearing protection; and
       4. Cut Resistant Gloves - Employees working with knives in red meat slaughter are to wear a cut-resistant glove on the non-knife hand at the head or viscera inspection station. A second glove, made of impervious material, is to be worn over the cut-resistant glove.
       
       NOTE: Any employee using a knife may request a cut resistant glove at any time and a cut-resistant glove may voluntarily be worn on both hands.
    3. A medical exemption for required PPE is to be approved, in writing, by District Management and the ESHG. If an approval is not granted, the employee may request reasonable accommodation or begin the grievance process.
    4. The following are optional PPE that IPP may choose to wear:
       1. Eye protection - IPP may obtain non-prescription eye protection free of charge from the Agency;
       2. Respirators - If IPP would like to voluntarily use a respirator for comfort (e.g., an N95 mask), please contact the OSHS for your area for written approval and training;
       3. Disposable Gloves - IPP may request gloves from the supervisor or inspector-in-charge of the establishment. Gloves are available from the Material Management Service Center. More information about gloves types and sizes can be found in the Specialty Supply Catalog;
       4. Freezer Coats - Freezer coats, vests and jackets are available as needed; and
       5. Heat Relief Items - Neck cooling scarves are available as needed.
    5. The ESHG is to work with District Management to evaluate an establishment's policy that would require IPP to wear PPE not required by the Agency.
       1. If the establishment requirement for PPE is based on a recognized OSH hazard for IPP, the Agency will provide the required PPE.
       2. If the ESHG and District Management determine that the establishment's PPE requirement is not necessary to protect IPP from a specific hazard, the establishment is to provide the PPE for inspection personnel.
    6. IPP are to obtain approval from the District Manager before using any protective equipment or working tools provided by the establishment.
13. HEARING CONSERVATION PROGRAM
    1. IPP exposed to noise levels exceeding an 8-hour time-weighted average (TWA) of at least 85 decibels (DBA) are included in the FSIS Hearing Conservation Program (HCP).
    2. Supervisors are to record noise levels at inspected establishments on FSIS Form 4791-20. Supervisors are to update the posted noise levels anytime the establishment makes a significant change in the process or layout of equipment. Annual updates are not required.
    3. Within six months of exposure to high noise levels, all employees who are included in the HCP are to have a baseline audiogram which will be used to compare against subsequent audiograms to determine if a hearing loss has occurred. Baseline audiograms are provided during the initial onboarding process for employees who will be potentially exposed to high noise levels as defined in "A" above.
    4. All employees in the HCP are to complete annual hearing conservation training. Employees may complete AgLearn course "Hearing Conservation" (produced by Skillsoft) to fulfill this requirement. Supervisors are to make the training material available to all employees who do not have access to a computer or e-mail. Other training material that may be used to satisfy the annual training requirement is available from the Occupational Safety and Health Specialist for the District.
    5. Hearing protection is provided at no cost by the Agency for all employees in the HCP.
    6. Supervisors are to ensure that employees in the HCP wear required hearing protection.
    7. All employees in the HCP may get a hearing test annually, if they so choose, that will be paid for by the Agency.
    8. Contact the OSHS for the District for more information about required training and instructions on how to request a hearing test for new and existing employees.
14. PROGRAM EVALUATION
    The ESHG will request an audit of the OSH program every three years through a third party. The audit will evaluate the program against the requirements for a Federal safety and health program found in 29 CFR 1960
15. XV. QUESTIONS
    For further information on any topic addressed in this Directive, contact the Occupational Safety and Health Specialist for your location. Names and phone numbers are available at: Environmental, Safety and Health Topics.