Total Environmental Health and Safety Management See attached BOS 3651, Total Environmental Health and Safety Management 1
Course Learning Outcomes for Unit VI
Upon completion of this unit, students should be able to:
4. Examine the components of an effective hazard prevention and control system.
4.1 Examine the relationship between prevention through design and safety management systems.
4.2 Describe the safety design review process.
7. Examine management tools necessary to implement effective safety management systems.
7.1 Explain the role and importance of safety in a safety management system.
Unit VI Essay
Unit VI Essay
Unit VI Essay
Required Unit Resources
Chapter 12: Safety Design Reviews
Chapter 13: Prevention Through Design
Chapter 24: On System Safety
In Unit V, we examined how a decision hierarchy can be used to reduce risk. At the top of the hierarchy is
eliminating the hazard. No one will dispute that this is the most effective method of reducing risk. Why,
then, is it not applied to more hazards? One reason often given is cost. For example, carbon monoxide (CO)
buildup is a common hazard when gasoline-powered forklifts are operated in warehouses. An effective way
to eliminate the CO hazard is to replace the gasoline forklifts with electric lifts. Electric lifts produce zero
emissions; however, it is expensive to replace an entire fleet of forklifts. In addition, battery-charging
stations must be constructed, and battery-powered vehicles introduce a new set of hazards like dealing with
Reduced effectiveness is another common concern. Electric forklifts do not have the same lifting capacity as
gasoline-powered lifts and may need to be charged more frequently. Improving warehouse ventilation is a
typical engineering solution to CO buildup, but ventilation only modifies the release of the haz ard. It will likely
reduce risk to a tolerable level, but the hazard is still present. Sometimes, reducing the risk to workers results
in a less effective product. Methylene chloride has long been the main ingredient in most paint strippers, but
the chemical is a serious health hazard to workers, so new paint-stripping products that contain less harmful
ingredients have been introduced. Most workers who use these new, less hazardous products will say they do
UNIT VI STUDY GUIDE
Reducing Risks Though
the Design Process
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not work as well, and use of them may even create new hazards. Mechanical methods are sometimes added
to the stripping process and tools used can cause musculoskeletal problems due to vibration.
Simply put, it is often easier and less costly to go to the middle of the hierarchy of controls when looking for
ways to reduce risk. Some organizations choose to use the easiest and least costly method for reducing risk,
personal protective equipment (PPE). As we learned in the previous unit, PPE should be used only when no
other controls are possible or as a supplement to another higher-order control.
Section 5.1.3 of ANSI/ ASSP Z10.0-2019 requires design reviews to ensure hazards and risks are addressed
(Manuele, 2020). Many safety professionals already participate in these reviews within their organizations.
Unfortunately, the reviews often take place at the end of the design process. While it is possible to make an
impact on safety at this stage, which is much better than finding the hazards after the project is complete,
organizations may be reluctant to make changes since changes can delay the project and affect the budget.
Project leaders may not see the possibilities of cost avoidance that accompany safer designs. Nonetheless,
safety professionals need to proactively identify and document design flaws that result in risks to personnel
Design reviews for safety can be time consuming, but there are numerous resources available. The
Occupational Safety and Health Administration (OSHA) standards once again provide a good starting point.
Ensuring that applicable standards are addressed in designs reduces the risk of injury or illness as well as the
risk of OSHA fines and citations, and it keeps the costs visible to management. What about hazards and risks
that are not covered by standards? How are those identified? Manuele (2020) suggests that ergonomic issues
would be a good place for the safety professional to start. Much research has been done relative to
ergonomics, and applying one of the many ergonomic design criteria checklists that are available can result in
Consider, for example, a conveyor line in a poultry plant where the employer hires individuals to
perform various cuts on turkeys that come down the lin e. Without thinking the process through up front, a
short person would have to reach above the shoulders to make cuts where a tall person might have to stoop 8
to 10 hours a day making thousands of cuts. This could result in repetitive motion injuries for both individuals
and the possibility of a back injury as well for the tall individual. If work stations were designed with
adjustable-height standing platforms or adjustable conveyor heights at work stations, associated labor and
medical costs could be reduced. Such an approach could actually be engineered into the operation before the
facility even opened its doors.
In the textbook, Manuele (2020)
makes a strong case for a
concept called prevention
through design (PtD) as a
preferred methodology for
reducing hazards and risks.
Please see the image to the left
for more information regarding it.
It is well-documented that the
sooner hazards are identified in
the design process, the more
effective and less costly the
controls will be. Original
installation of a large ventilation
system during facility
construction, for instance, is
much less costly than a retro-
fitted system because the
installation can be fluidly
designed to align with the design
of the building without having to
work around existing walls and barriers or having to figure out solutions to existing space restrictions.
Consider a situation, for instance, where the only place to install a large baghouse for a new ventilation
system is on the other side of the building from the source of the metal fume emissions. This would result in a
need for large fans and long lengths of ducting in order to make the ventilation system fit the existing
(National Institute for Occupational Safety and Health, 2014)
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structure. If the building was designed with the need for a baghouse in mind, however, a nearby pad for the
baghouse could have easily been drawn into the building plans.
Installation during facility construction can also be performed at an optimal point in the construction process.
This, once again, can limit the need for working in tight corners and punching holes through existing barriers
as the ventilation and ducting system can be installed before barriers are erected and when other trade
workers that may need to work with the installation such as electricians are available to complete their part of
the installation. There is also the benefit of not interrupting the production process in an existing facility. Retro-
fits often have to be completed when the facility is in operation and may interfere with the facility’s operations
from time to time.
In 2007, the National Institute for Occupational Safety and Health (NIOSH) began a PtD initiative. The intent
of this initiative is to get employers to consider managing risks by getting them to an acceptable level as soon
as possible in the life cycle of the product or in the workplace (NIOSH, 2014). It is important to note that
NIOSH does not limit PtD to the construction of facilities but to anything in the workplace that creates risk.
This would include equipment, products used, and work processes. For instance, given our forklift scenario,
the decision to purchase electric forklifts in the first place instead of LP-gas powered vehicles could be
considered a PtD approach to limiting CO emissions in the facility.
Current research shows that 80% of companies are aware of PtD, and 77% included PtD in their operations
(NIOSH, 2013). Going back to our gasoline-powered forklift example, if PtD was applied when the warehouse
was being designed (or redesigned) the need for forklifts might be limited significantly by including automated
handling and conveyor systems.
Prevention through design is not necessarily new to the safety profession. The aerospace industr y recognized
early in its existence that the fly-fix-fly approach to safety was not a cost-effective way to identify design
hazards. In response, the industry, led by the U.S. Air Force, adopted an identify-analyze-control
methodology we now know as system safety. Manuele (2020) acknowledges that there are many definitions
for system safety, but for the safety professional looking to reduce risk at the design stage, it is a way to
analyze hazards and quantify the effectiveness of selected risk controls. In the aerospace and nuclear power
industries, system safety analyses can be complex and are usually conducted by specially trained engineers.
In less complex industries with less complex designs, system safety tools can easily be adapted and used by
Hopefully, as you read through your unit readings, you will come to appreciate the concept of prevention
through design. Considering and mitigating hazards up front can save headaches and money down the road.
Indeed, there are a lot of benefits to thinking things through up front. This goes for everything from planning
our summer vacations to strategic management planning performed by Fortune 100 firms.
Planning to mitigate risks is also found in multiple industries. The Occupational Safety and Health
Administration’s Process Safety Management standard, for instance, requires a PtD approach in their
Management of Change provisions for significant process changes in facilities that process or store large
quantities of highly hazardous substances. This is because it is makes much more sense to deal with
significant risks up front than to take the risk later.
Manuele, F. A. (2020). Advanced safety management: Focusing on Z10.0, 45001, and serious injury
prevention (3rd ed.). Wiley. https://bookshelf.vitalsource.com/#/books/9781119605409
National Institute for Occupational Safety and Health. (2014, May). The state of the national initiative on
prevention through design (DHHS [NIOSH] Publication No. 2014–123). Department of Health and
Human Services, Centers for Disease Control and Prevention. http://www.cdc.gov/niosh /docs/2014-
National Institute for Occupational Safety and Health. (2016, July 29). Prevention through design
[Infographic]. Centers for Disease Control and Prevention. http://www.cdc.gov/niosh/topics/ptd
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UNIT x STUDY GUIDE
Suggested Unit Resources
In order to access the following resource, click the link below.
Learn more about reducing risks through the design process in the following suggested reading:
Go to the CDC website, and search for “prevention through design.” Explore the many informative webpages
containing information on this topic.
Learning Activities (Nongraded)
Nongraded Learning Activities are provided to aid students in their course of study. You do not have to submit
them. If you have questions, contact your instructor for further guidance and information.
Note: This activity can be used as one of the building blocks of the Unit VIII Project.
Using Chapters 12, 13, and 24 of the course textbook and the other readings in this unit as guides, evaluate
safety design reviews at your current organization or an organization with which you are familiar. For objective
evidence to support your evaluation, look for organizational documents such as safety manuals and
instructions, safe operating procedures, job hazard analyses, safety meeting minutes, mishap logs, audit
reports, Occupational Safety and Health Administration citations, inspection reports, risk assessments, and
training records. Interview management personnel, supervisors, and employees. Prepare a report to
management that summarizes the positive and negative results of the evaluation, and provide
recommendations for improvement.