An affected employee is important. They are the employees who work in the area of a potential hazard, and who might be affected by the hazards created by the work being done, but may not be directly involved. Frequently, we think of the definition of an affected employee as the one found in the Control of Hazardous Energy (Lock-Out/Tag-Out) regulation, 29 CFR, Part 1910.147, where it says:
“An employee whose job requires him/her to operate or use a machine or equipment on which servicing or maintenance is being performed under lockout or tagout, or whose job requires him/her to work in an area in which such servicing or maintenance is being performed.”
This distinguishes the employee from the Authorized Employee, who performs the Lock-Out/Tag-Out (LOTO). A similar term is Competent Person, which is described in 29 CFR Part 1926.32 as:
“one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.
Because we find that the affected employee is sometimes overlooked, we want you to consider that this is a very important employee, since this is the employee that might not have as much control over the situation, but in some circumstances, might get just as injured or ill from exposure to hazards. They are not in charge or handling the hazard, so they may not be able to control it or provide themselves with appropriate protection from the hazard.
OSHA thought about that issue, as OSHA requires affected employees to be trained in the basics of the LOTO program for the equipment they work with and in proximity to. You can see that in 29 CFR, Part 1910.147(c)(7), where they require that
“Each affected employee shall be instructed in the purpose and use of the energy control procedure.”
Why? Consider this scenario: let’s say that an affected employee usually works on machine A. This person has to finish up a project on machine A. But, without informing this affected employee, an authorized employee, a maintenance worker, decides to do a quick repair job. The authorized employee locks out the machine. But the affected employee is not informed of the repair job, does not understand the meaning of the locks and tags, and circumvents them, turning on the machine. Someone could get hurt – and it possibly could be either or both of them.
The Team at SCM believes that this requirement to train and inform affected employees reaches into other areas as well. Consider Hazard Communication Training. A company has employees that work with chemical X. There are other employees that work in the vicinity of chemical X, who might be the “affected employees” as they don’t directly work with the chemical. However, should there be a release of chemical X, these affected employees could be just as exposed as the employees working directly with the chemical. The employer is required to train all employees in the hazards of the chemicals to which they might be exposed (29 CFR 1910.1200 (h)(1)): “Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area….” It does not say to give the training to just those who directly handle the materials. The regulation says you shall provide employees with effective training. That means it’s mandatory and for all who are in the work area of the chemical(s).
We will give you just one more example, although we believe there are many others – Confined Spaces. We often provide confined space training to the entrants, attendants and the supervisors. But don’t forget the affected employees! These are the employees working around the confined spaces who might be just as affected by hazards presented by the space. OSHA did not forget about these employees. 29 CFR, Part 1910.146(g)(2) states that effective “Training shall be provided to each affected employee….”
Next time you are about to arrange for some health and safety training, consider all the workers, not just your authorized employees or competent persons. Think about the affected employees. OSHA believes them to be important, necessitating training. We think so too.
Safety Management System Palooza! A 2 day event, learning about Safety Management sponsored by ASSE. Ron is a featured speaker. March 30, noon EDT. $195 for ASSE members, $225 for non-members. Register here.
Ron Gantt Publishes
a Chapter in the Recently Released “Social Sensemaking A Reflective Journal, How We Make Sense of Risk” by Robert Sams. Ron’s chapter is entitled: The Future of the Safety Professional. To get your copy, go here, linked here.
Ron also has published a chapter in Human factors and Ergonomics In Practice. To order your copy, go here: Link.
Cal/OSHA Outreach 30 Hour Trainers!
SCM has two trainers that are available to provide this training to your workers, in English and/or Spanish. See the link here
Just call 925-362-2265 to learn more, or email us at firstname.lastname@example.org
Upcoming Training At SCM
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