|About Safety||Posted: 10:55 AM - 7/24/02|
|* * * CURRENT EVENTS * * *|
NEW - Effective Dec 1, 2014
Prescription Safety Eyewear: Increase in reimbursement for actual cost up to $125 for employee's out of pocket expense
NEW – Effective Jan 1, 2015
OSHA Injury Reporting Requirements
NEW – Safety Training Calendar 2015
* * *SAFETY TOPICS 2015* * *:
JANUARY: Flu Season
FEBRUARY: Accident Reporting - Call Safety to report:
BCB OSHA 300 Form: OSHA requires all employers to post (between Feb. 1 and April 30) a summary of the total number of job-related injuries and illnesses that occurred during the previous calendar year. It is to be displayed in common areas with other employee notices. As of Jan. 1, 2015, employers are now required to report all work-related fatalities within 8 hours; and all in-patient hospitalizations, amputations, and losses of an eye within 24 hours of finding out about the incident.
APRIL: Safe Lifting (Material Handling) of heavy items is one of the leading causes of injury in the workplace. The biggest factors - overexertion and cumulative trauma. Use smart lifting practices and work in your “power zone” to prevent injuries caused by lifting heavy objects. Don't know if it's too heavy? See How Much is Safe to Lift.
MAY: Heat Stress
AUGUST: Back to School Safety
SEPTEMBER: National Emergency Preparedness Month
OCTOBER: Fire Safety Month (Evacuation Plans & Drills; Fire Extinguishers)
OSHA Weekly E-Newsletter
Safety Tip Sheets (NFPA)
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Safety is each and every Board employee's responsibility
What needs reporting? Click on Safety Quick Reference Sheet
VISION: To provide a safe work environment for our employees, customers and the general public.
MISSION: To enable employees to prevent workplace injury or illness by recognizing then correcting known and potential hazards. (see full Safety Mission Statement, Program & Guidelines)
Employees should be intrinsically motivated towards safety. This means they need to go beyond compliance to understand the value of safety for its own sake. Conventional wisdom has supervisors and employees training and checking on other employees. Intrinsic motivation has individuals, even when they are working alone, conduct personal safety briefings to remind themselves of what is expected in terms of tool selection, personal protective equipment and work procedures before starting to work and whenever tasks change. Their ability to live the life they want is affected by the safety decisions they make or fail to make at work and at home.
SAFETY COMMITTEES: Successful businesses improve safety performance by listening to employee input. By implementing their recommended best practices and hazard abatement measures, workplace illnesses, injuries and property damage can be reduced if not eliminated. A safety committee for each major work area is one way we manage our safety program.
NEW: 2015 FM Safety Committee Members & Schedule (Minutes for March 2015 .)
OSHA Poster: Employers in South Carolina are required to post the OSHA (Occupational Safety and Health Act) Safety and Health Protection on the Job employment notice from the South Carolina Department of Labor, Licensing and Regulation in a place or places where employees can have free access to read them.
Filing an OSHA Complaint with SC OSHA: Employees are encouraged to correct hazards themselves or identify them to their supervisor or to the Safety office. However, employees have the right to report a safety or health hazard directly to SC OSHA by contacting the complaint office at (803) 896-7825 and must submit a written OSHA Complaint Form. Click on Whistleblowers for information about how they are protected under law from employer retaliation because they reported an illegal, unsafe or unacceptable behavior or condition in the organization.
Accountability: Safety Dashboards track safety performance measures monthly then are rolled up each Fiscal Year for state government accountability purposes. These reports analyze accident causes and trends, and compare against other state government. OSHA also requires reporting each Calendar Year. This information can be found by clicking on Internal Documents (restricted access - call Safety if you forgot the User Name and Password).
|ASBESTOS||Posted: 2:24 PM - 11/29/01|
|OSHA Standard: Click on Asbestos|
Asbestos Safety Policy sets forth requirements to protect employees in and around work areas that contain or are suspected of containing asbestos.
Asbestos Log is a matrix that quickly summarizes which materials in Board facilities have been surveyed to contain asbestos (+) or not (-); if no test results (blank) then assume material contains asbestos (+). More detailed information is in each building's Asbestos Operations & Maintenance Manual kept in the Facilities Management Construction and Planning Office, Room 208. (See How to Read the Asbestos Log)
OSHA Pamphlet 3096 contains asbestos information from Federal OSHA.
Asbestos Questions is a quick information sheet on asbestos in a question and answer format.
Asbestos Contact: JP Gouffray, Asbestos Inspector, Facilities Management - Construction & Planning, 737-8038
|Confined Spaces||Posted: 2:32 PM - 11/29/01|
|OSHA Standard: Click on Confined Spaces|
Confined Space Entry Training Presentation provides an overview of the DGS Confined Space Entry Program.
Confined Space Test - Employees must take and pass this test as well as attend hands-on training (both annually).
Confined Space Policy sets forth requirements to protect employees when performing confined space entry.
Confined Space Program stipulates procedures to conduct a confined space entry.
Confined Spaces Flowchart shows the decision process on how to classify spaces as Confined Spaces and whether or not a Permit is required.
Confined Space Classifications lists all spaces in SC Budget and Control Board facilities that have been surveyed and classified as Confined Spaces.
Confined Spaces A-E and F-Z contain specific hazards and control measures as well as photographs and diagrams for each confined space listed alphabetically by building name or system.
Confined Space Entry Permit is a form used by the responsible supervisor to plan and authorize employees to enter a Permit-Required Confined Space
Confined Space Entry & Rescue Equipment - video by Miller Fall Protection (20 mins)
Gas Monitors: Atmospheric testing for a confined space is required prior to and during the entry. See instructions below on how to use the gas monitor. Two (2) multi-gas monitors along with rescue tripod, winches and full body harnesses are kept in the FM Building Maintenance Equipment Storage Room; see Kurt Patrick.
|EMERGENCY PLANNING||Posted: 3:33 PM - 11/5/01|
|OSHA Standard: Click on Emergency Action Plans, Fire Prevention Plans or Fire Safety Standards|
Fire Prevention Week , Oct 4-10, 2015
DGS Fire/Evacuation Drill Schedule – Oct 2015 (To Be Published Sep 2015)
FIRE PREVENTION, EMERGENCY ACTION & HOMELAND SECURITY PLAN: As owner and operator of a number of buildings, the State Budget and Control Board has fire and life safety responsibilities to include detailed immediate emergency response and follow-on actions required of tenant agencies; building maintenance; and coordination with city, county and state Emergency Management Services (9-1-1: police/SLED/Bureau of Protective Services, ambulance, fire). Facilities Management maintenance and tenant agency emergency staff personnel are identified as well as those needing assistance, and those trained in CPR & 1st Aid. Anticipated emergency situations such as evacuation due to fire, bomb threats, severe weather and more are included in each building's emergency plan.
Requests for the attachment to the basic plan for a specific building, or for Safety to conduct training for tenant agencies should be sent to BLee@gs.sc.gov or call Bernie Lee of the Safety office at 737-2315.
TRAINING PRESENTATION- This PowerPoint presentation covers OSHA emergency action plan requirements to include fire evacuations, severe weather, intruders in the workplace, bomb threats and terrorist events. All you have to do is supplement this with your organization's and building specific information (see Training Outline) then your training package is ready to go!!!
PERSON-IN-NEED of Assistance During Emergencies: Persons with restricted mobility or impaired sight or hearing (permanent or temporary), especially in a multi-story building where descending stairs is difficult, may want or need assistance during an evacuation or other emergency (see form).
Incident Command is formed when multi-agencies take action in response to emergencies. They need information but are on the outside so must communicate with persons from inside the building. The Building Incident Command (BIC) emergency staff inside the affected building is also necessary in emergency planning, response and recovery efforts. Managers, supervisors and BIC members should take free on-line training offered by FEMA (see below).
PORTABLE FIRE EXTINGUISHERS: Monthly checks of portable fire extinguishers, normally conducted by Building Maintenance, are the responsibility of the tenant if installed for their special purpose areas. Annual inspections and maintenance are required to be performed by a SC-licensed fire technician. (See Extinguisher Inspections and FEMA Teaches How to use a Portable Fire Extinguisher ; contact the SC BCB Material Management Office for state contract on extinguishers)
SMOKING IN STATE BUILDINGS: SC has legislated restrictions on smoking in certain areas through the Clean Air Act of 1990 to include all state buildings. Some exceptions are allowed. There is to be no smoking in state buildings except in a designated area and these smoking areas must be identified with conspicuous signs and have adequate ventilation to keep the other areas smoke free. Fire code (IFC 310) also requires designated smoking areas to provide suitable noncombustible receptacles (not standard trash containers that hold combustible materials) so as to properly dispose of matches, cigarettes, cigars, and other smoking materials to prevent fire.
SPACE HEATERS & OPEN FLAMES:
Space heaters are a fire hazard and can be especially dangerous when they don't meet Underwriters Laboratory (UL) safety standards or when used improperly. (In general, any home appliances in the workplace are discouraged due to the fire hazard from an overloaded electrical system and increased energy costs.) To make a complaint about it being too cold in your office area, please call the Work Order Desk, 734-3308. Space heaters are only allowed after making a cold complaint, investigation by Facilities Management Building Maintenance then their appliance inspection and approval.
Open flames (i.e., candle, incense burner) are prohibited in SC Budget and Control Board buildings. Exceptions (i.e, sterno type food tray warmers for catering) can be approved on a by case request to the BCB Safety office.
Extension Cords - can be used for up to 90 days but must be used properly. The available guidance describes potential hazards and recommendations for proper use. However, a sufficient number of well located grounded outlets can eliminate the need for extension cords.
Earthquakes: Columbia SC is in an earthquake zone. "Drop, cover, and hold on" until the shaking has stopped. For information on how to respond to an earthquake visit this OSHA webpage.
Active Shooter in the Workplace: Your options - Run, Hide or Fight
|Excavations & Fall Protection||Posted: 8:24 AM - 1/19/05|
|OSHA Standard: Click on |
**Fall Protection - General Industry
** Fall Protection - Construction Industry
**Excavations – Construction Industry or Excavation E-Tool
Employees working over four (4) feet above the ground or above a lower level are exposed to Fall Hazards.
LADDER SAFETY (PPT):
** Training (from Louisville Ladder)
** Ladders – A Simple Tool But Deadly If Not Used Properly (video)
** Ladders – Look Up and Live (Overhead Power Lines) (video)
**Mobile App – Ladder Safety (NIOSH)
EXCAVATIONS such as holes or trenches from earth removal are hazardous due to falls, cave-ins, contact with underground utilities, flooding and dangerous atmospheres. See Presentation and Trenching – Prevent Collapse
SPECIAL INTEREST: Our leading cause of preventable injuries - Slips, Trips and Falls has cost the Board $1.5 million over the years. See - How to Stop Falls. Read ISHN article (Mar 14, 2013)
Other OSHA standards related to fall hazards include but are not limited to:
|Forklifts||Posted: 3:04 PM - 11/29/01|
| OSHA Powered Industrial Truck (Forklift) Standard |
DGS employees who will operate forklifts are required to know the BCB Powered Industrial Truck (PIT) Policy (which sets forth the operational, training and certification procedures) and the Forklift Safety Program; see OSHA Forklift E-Tool and the DGS Forklift Training Presentation. After classroom and supervised on-the-job training and a written Forklift Test the employee must pass a performance evaluation prior to being authorized to operate a forklift solo.
|Hazard Communication (HAZCOM)||Posted: 2:58 PM - 11/29/01|
|OSHA Standard: Click on Hazard Communication Standard (HCS)|
DGS strives to reduce or eliminate the use of hazardous chemicals by Transitioning to Safer Alternative Chemicals.
Employees have the RIGHT TO KNOW and UNDERSTAND about the hazardous materials with which they work. The Safety Data Sheet (SDS, formerly Material Safety Data Sheet-MSDS) is the primary tool for finding information about the chemicals you work with – work precautions such as required personal protective equipment, handling and storage; health sypmtoms and how to treat a victim of exposure; spill cleanup; and other important information. All SDSs are readily accessible at any time through our on-line system - click on SDS Look Up (see Tutorial).
This Hazardous Communication (HAZCOM) Program sets forth how each employee will be made aware of hazardous materials and the necessary safety precautions for their protection.
OSHA GHS Update (3/26/12): OSHA published its new HCS to align with the Globally Harmonized System (GHS) of Classification and Labeling of Chemicals. The new Safety Data Sheets have a specified 16-section format. New labels include a signal word, pictogram, hazard statement for each hazard class and category, and precautionary statements. Manufacturers have until 6/1/15 to publish new SDSs for all chemical products; all new shipments must have new SDSs/Labels as of 12/1/15. For more information click on OSHA HCS.
|HEALTH / FIRST AID PROGRAM||Posted: 10:33 AM - 7/24/02|
|OSHA Standard: Click on First Aid or Bloodborne Pathogens|
OSHA requires employees be provided a safe and healthy workplace that is reasonably free of occupational hazards. Realistically, injuries happen (see Reporting A Work Accident) so adequate first aid is available in the workplace for the critical minutes until receiving professional care by emergency services or at a clinic/hospital. Designated and volunteer employees are trained to render first aid in a timely manner and have readily accessible first aid kits, which include blood-borne protection, and Automatic External Defibrillators.
The Bloodborne Exposure Control Plan provides information and requires training for hazard recognition and protection of employees whose job potentially exposes them to contact with blood or other infectious materials.
Health - Click on:
SC Clean Air Act of 1990 for places where smoking is allowed and prohibited.
Computer Workstations to learn how to set up an ergonomically correct office work station.
OSHA Heat Stress Guidance provides recommended methods to protect employees whose work exposes them to hot/cold weather conditions that can lead to a heat-related illness.
Workplace Violence - Domestic problems, drug and alcohol abuse, termination or disciplinary actions can trigger violence in the workplace. If an employee notices a co-worker acting strangely or makes a verbal or physical threat against themselves or someone else, immediately report it to a supervisor.
|HOT WORK - Cutting, Welding & Brazing||Posted: 11:00 AM - 7/24/02|
|OSHA Standard: Click on Welding, Cutting and Brazing|
The Cutting, Welding and Brazing Program sets forth training and procedural requirements to protect employees during "hot work" or any operations involving an open flame, i.e., Welding, Cutting, Brazing, and Soldering. Hazards include exposures to metal fumes and to ultraviolet (UV) radiation, burns, eye damage, electrical shock and more. Many of these can be controlled with proper work practices and personal protective equipment.
Live Work involves working on equipment or machinery which is not de-energized. See the LOTO (Lockout-Tagout) Program.
OSHA Standard: Click on Lead
Because of health concerns, Lead from gasoline, paints and ceramic products, caulking, and pipe solder has been dramatically reduced in recent years. The OSHA Lead regulation has established an exposure limit and work procedures which are amended by a Board work process to be followed especially prior to welding.
|Housekeeping||Posted: 2:43 PM - 11/29/01|
|OSHA Standard: Click on Housekeeping|
This Housekeeping Policy sets forth general protective procedures for the workplace that include trash disposal, storage, spill cleanup, personal hygiene, and reporting dangerous conditions.
Burned Out / Broken Compact Fluorescent Light (CFL) Bulbs: CFLs contain a very small amount of mercury so cannot simply be thrown away when they burn out and there are some special clean up precautions if one breaks. Call the FM Work Oder Desk, 734-3308, for proper disposal.
|INSPECTIONS||Posted: 9:26 AM - 12/11/02|
| OSHA Standard and DGS Inspection Policy|
OSHA OFFICER INSPECTION VISIT: For ALL BCB divisions / offices / personnel - Immediately notify DGS Safety, (803) 513-5352/5354 work cell, whenever OSHA officers come on site. Ask OSHA to wait for Safety to arrive to accompany the inspectors and assist in any inspection or accident or complaint investigation.
FIRE MARSHAL INSPECTION VISIT: Facilities owned or operated by the BCB Division of General Services are under the jurisdiction of the Resident Fire Marshals of the DGS Safety Office. Please ask visiting (State, City of Columbia, Richland / Lexington County or the University of South Carolina) Fire Marshals to contact DGS Safety should they have fire and life safety issues with Board facilities.
Accident Prevention requires proactive actions. Safety, with worker and tenant participation, inspects the workplace to identify hazards and address them by analyzing work processes, recognizing needed improvement, and eliminating or controlling hazards before they cause an injury.
Avoid the Top 10 OSHA Violations by conducting your own workplace inspections. Just adapt information from:
** OSHA's General Industry (29 CFR 1910) Checklist, General Industry Digest
** OSHA's Construction Industry (29 CFR 1926) Checklist
** Fire & Life Safety Checklist
To report an Unsafe Condition or Process, Call or E-Mail Safety (name and phone number - optional).
JOB SAFETY ANALYSIS: When teams document the steps of a work process, they should also look for the hazards of each step and how to eliminate or control each of those hazards. An overview describes this simple process improvement technique, and a worksheet is provided.
Performance Measures: (Click on Internal Documents. Forgot the Password? Call Safety)
1) The number of Actual versus Planned Facility Safety Inspections
2) Hazards (hazardous conditions and code violations: New, Closed and Open)
RECALLS: Obtain recall information from web sites for the Consumers Product Safety Commission or the Underwriters Laboratories
SPECIAL EVENTS: Provides information for groups wanting to hold an event on the Capitol Complex such as reservations and how to comply with fire and safety regulations; designed for event planners.
|LOTO - Control of Electrical and Other Hazardous Energies||Posted: 10:43 AM - 7/24/02|
|OSHA Standard: Click on |
LOTO – Control of Hazardous Energy
OSHA Subpart S - Electrical Standard (eTool)
The LOCKOUT/TAGOUT (LOTO - Control of Hazardous Energies & Safe Electrical Work Practices) Program - Every electrical circuit or other hazardous energy is dangerous until we have made it safe and verified it is safe, no matter how sure we "turned off" the system, and you can't de-energize without doing "live" work! LOTO protects employees from injuries that could occur during the unexpected energizing, start up or release of stored energy while servicing or maintaining equipment. Employees are taught to recognize the various types of energy sources, to understand their potential hazards, and how to take precautions to protect themselves and persons working around equipment in need of service or repair.
Arc Flash: How to Protect Yourself (video)
|Personal Protective Equipment||Posted: 2:28 PM - 11/29/01|
|OSHA Standard: Click on Personal Protective Equipment |
PPE Policy - Employees are to wear approved and/or provided Personal Protective Equipment (PPE) when exposed to hazards in the workplace.
PPE Assessment - Prescribes required PPE for hazards by work process.
Eyewear Policy - Employees are to wear eye/face protection when the job has potential for eye or face injury. If employees have a prescription for glasses or contacts, an allowance is provided for prescription safety eye glasses which must meet ANSI Z87.1-2010 or later standards.
* * Protect Your Eyesight
* * NEW– Effective Dec 1, 2014 - Prescription Safety Eyewear: Increase in reimbursement for actual cost up to $125 for employee's out of pocket expense
Footwear Policy - Employees are to use foot protection against crush, puncture, electrical, slip and other foot-injury hazards. Employees needing safety footwear (including prescription safety footwear) are provided an allowance. After the employee's Supervisor approves the request, safety footwear can be purchased from the vendor of choice. Reimbursement is made after the supervisor inspects and ensures the safety footwear complies with the ASTM F 2412-05 and F 2413-05 standards. NEW reimbursement allowance effective 10/27/08.
Hearing Protection - Employees may have routine but short term exposures to noise where hearing protection is recommended and/or be required to limit how long they work in a high-noise environment. Find out more - Hearing Protection (presentation) or OSHA Noise and Hearing Conservation E-Tool
Respirator Policy - Employees are to wear respirators when they are exposed to occupational dusts, fumes, mists, gasses, vapors or other respiratory hazard. The primary methods to prevent excessive exposure to respiratory hazards are to minimize use of hazardous chemcials, proper ventilation, and/or wearing respirators. The wear of respirators requires prior medical evaluation, operational knowledge and fit testing.
|REPORTING A WORK ACCIDENT||Posted: 11:12 AM - 10/12/01|
|OSHA Standard: Click on Reporting Occupational Injuries & Illnesses / NEW (Effective 1/1/2015): OSHA Injury Reporting Requirements|
* * * Safety Recognition * * *
ON-THE-JOB INJURY or ILLNESS: When an employee is injured or becomes ill at work immediately notify the supervisor and the Safety Office (Holly Bockow, WP 737-2311 / Cell 513-5354 or Bernie Lee, WP 737-2315 / Cell 513-5352). Safety will verify employment and coordinate for the employee's care through our case management organization. Then submit an electronic fill-in-the-blank incident report (Report An Accident) as soon as possible. The completed incident report is simultaneously submitted to Safety and to the SC Budget and Control Board Human Resources and Workers Compensation offices. The Board also has a Return-to-Work Policy to address the situation where the physician allows the injured employee to continue working with restrictions until fully recovered. The doctor's Return to Work form, prescription information, leave requests and other supporting documents should be sent to Safety, 921 Main Street, Room 112, Columbia SC ATTN: Holly Bockow, or to Fax(803)737-3065.
CONTRACT WORKERS: The BCB, as host employer, and staffing agencies both have roles in complying with OSHA workplace health and safety requirements for temporary workers. Workplace injuries and illnesses that occur to contract workers must also be reported to Safety as well as to the contracting agency using their procedures (see Marathon Staffing-Accident Reporting). OSHA Bulletin - Accident Reporting of Contract Workers
VEHICLE ACCIDENTS: When involved in a job-related vehicle accident in a state vehicle, employees are to submit a Vehicle Accident Report along with the police officer's report to their Supervisor. All accidents involving a BCB leased or owned vehicle is to be reported to AMERICAN SOUTHERN INSURANCE @ (800)713-2205, Fax (803) 256-0861; Safety ATTN: Bernie Lee, 513-5352 (to include injuries); and State Fleet Management ATTN: Brandi Smith, Vehicle Accident Coordinator,737-1982, and the Commercial Vehicle Repair Program (800) 277-3686.
Each division / office in the Board with leased and/or owned vehicles is to submit a Quarterly Vehicle Accident Summary Report to Safety by the 5th calendar day of each quarter.
ROUTINE DRIVERS of state owned or leased vehicles are designated employees trained in accordance with the Board Driver Safety Program, including those requiring a Commercial Driver License. Routine drivers will have their driver records screened at least annually (October) and those that have not incurred any violations or accidents will be eligible for the Safe Driver Award (see attached information).
- SC DMV On-Line Driver Record Check (See the form below for how to get up to a 4 point reduction)
- CELL PHONE USE & TEXTING WHILE DRIVING: SC Budget and Control Board policy states employees should not use an electronic communication device (i.e., cell phone, texting) while driving.
- Take the pledge to drive cell free!
- Drive Safely Work Week
- Hot Weather Driving
- Tire Safety
- Backing / Parking Safely
- Seat Belt Tips
Golf Carts & Special Purpose Vehicles Operating Policy (Nov 2012) - Employees may drive golf carts and SPVs to cross roads but if required to operate on the roads will require permits/licenses
Performance Measures: Monthly and annual reported accident information can also be found by clicking on Internal Documents. Forgot the password? Call Safety
1) OSHA Form 300A, Summary of Work-Related Injuries and Illnesses, is required to be posted in your work areas from February 1 to April 30.
2) The number of OSHA Recordable Employee Workplace Injuries and Illnesses in relation to the number of hours worked (incident rate)
3) The number of BCB Vehicle Accidents in relation to miles driven (incident rate)
|Training||Posted: 3:22 PM - 11/29/01|
|OSHA TRAINING REQUIREMENTS: Safety training is essential to instill hazard awareness and protect employees from occupational injuries and illnesses. OSHA requires the employer to train employees in the safety and health aspects of their jobs. Find out what "certified," "competent" and "qualified" mean. |
SC Budget and Control Board TRAINING: The Board requires an initial orientation, further job training depending on the job, and every employee is afforded opportunity for professional development; course registration.
DGS SAFETY TRAINING: DGS employees are to receive initial and regular refresher safety awareness training according to OSHA regulations and BCB-DGS policy. All DGS employees will begin on their first day of hire with new employee safety training, emergency procedures and your right to know about hazardous chemicals in the workplace. Other safety training will follow based on the employee's job requirements. Safety also provides driver training to employees throughout the Board as well as other safety training upon request. Employees will be registered by the Safety office and notified when and where to attend instructor-led classes (see - Safety Training Schedule (2015))
NEW - Self-Paced Learning: The following courses can be reviewed at your own pace then receive credit by passing a written test
Contract Employees also require safety training. Supervisors are to send the Temp Agency's form or use the Contract Personnel Action Form to notify Safety of New Hire, Promotion, Transfer and Separation for contract employees. This information is also needed in case of employee injury. Additionally, Work Hours are needed for the annual FY Accountability and OSHA 300 CY reports. Note: BCB HR provides this information to Safety for all other employees.
Performance Measure: (Click on Internal Documents. Forgot the Password? Call Safety)
Actual versus Planned Safety Training