CHAPTER 1:

INTRODUCTION

A. Site Safety Policy 

1. The JAC Site Safety Policy is reproduced here.

HEALTH AND SAFETY AT WORK
STATEMENT OF SAFETY POLICY AT THE JAC
(Joint Astronomy Centre)

1.      The policy of the JAC is that, as far as is reasonably practicable, healthy and safe working conditions will be provided for all members of staff and all visitors to the JAC facilities.

2.    The minimum standards for safety will be those laid down by the State of Hawaii Occupational Safety and Health standards. The JAC is also required to comply, where the requirements are more stringent and where it is reasonably practicable, with UK standards encompassed by the Health and Safety at Work Act 1974.  

3.      All members of staff have a duty to ensure that this safety policy is implemented and that all provisions herein are fully carried out.

4.  While all staff have a role to play in promoting and maintaining an effective health and safety regime at the JAC, particular groups/individuals have specific responsibilities as follows:

a.   the Director, through the management chain, for the practical application of the JAC’s overall health and safety policy and procedures, including their development, implementation, monitoring and review;

b.      the Heads of Divisions and Sections to ensure safe and healthy conditions for those whom they supervise;

c.       employees to implement the provisions in this manual and to take care of the health and safety of themselves and their colleagues;

d.      visitors to the JAC's facilities to behave responsibly;

e.       contractors who are engaged to carry out work at the JAC facilities to do so in a safe manner.

5.      Any safety training which may be necessary for the implementation of this policy will be provided by the JAC. 

6.      The general health and safety at work policy of the Science and Technology Facilities Council (STFC) is stated in their Health and Safety Policy of which a copy is posted on the Safety Notice board.

7.      In compliance with Hawaii State law, smoking is prohibited in all JAC buildings, including the facilities at the summit.  In addition, smoking is prohibited within 20 feet of entrances, exits, windows that open, and ventilation intakes that serve an enclosed or partially-enclosed area where smoking is prohibited. (Note: Hawaii State law defines a partially-enclosed area as any area with a roof and two or more walls.)

8.      The JAC has a site safety advisor who has been charged to consider, recommend, monitor, review and implement any changes which may be necessary to ensure safe working conditions at all the JAC sites.

9.      The JAC has a safety committee which enables free discussion of safety topics to take place between management and other safety representatives. The terms of reference and membership of this committee are displayed on the safety notice board.

This statement is issued by the Director of the Joint Astronomy Centre (JAC), Hilo, Hawai'i.

Signed: by Gary Davis, Director
Date:        30-September-2009
Reissued: ) 01-October-2009, Simon Craig, Chairman Safety Committee

2. Implementation of Site Safety Policy.

The JAC's site safety policy is implemented through:

1. certain named post holders such as the Site Safety Advisor. The current list of post holders is given in Addendum 1 to the Safety Manual;

2. the safety training program;

3. health and safety orientation of new staff;

4. the Safety Manual;

Note: The Safety Manual is updated by a rolling review at the Safety Committee meetings; each chapter is reviewed at least once every 2 years. Chapter 7 (Bloodborne Pathogens) is reviewed at least once a year to comply with HIOSH 12-205-1(c)(iv), which uses identical wording to OSHA 29CFR 1910.1030(c)(1)(iv). Chapter 13 (Lockout/tagout) is reviewed at least once a year to comply with HIOSH 12-67.2-2 which subsumes OSHA 29CFR 1910.147 (c)(6)(i).

The safety manual is available in two forms: via the World Wide Web on the JAC server, and in hard copy. The World Wide Web version is maintained as the definitive up-to-date version. In addition, eight controlled hard copies of the manual are maintained up to date under the supervision of the Site Safety Advisor; these are:

1. In the UKIRT control room
2. In the UKIRT Hilo Office #12
   
3.  In the JCMT control room
4.  Site Safety Advisor's copy
5.  Chairman of the Site Safety Committee's copy
6.  Head of Administration's copy
7. In the Library 1-copy
8.  In the JAC Office at Hale Pohaku

Controlled copies are clearly labelled as such on the spine of the binder. All other hard copies should be regarded as temporary only - for the definitive version, check a controlled copy or the WWW.

5. annual STFC SHE (Safety, Health and Environmental) Management Improvement Plan

6. the Hazard Communication Program (right-to-know);

7. the Site Safety Committee;

14. disciplinary action where necessary against staff who do not comply with JAC's policies and procedures as laid down in this manual. The normal disciplinary procedures, as set out in STFC and RCUH conditions, will be used;

15. routine inspections of first aid equipment and lifting equipment carried out by the Site Safety Advisor or under his control.

B. Health and Safety Orientation of New Employees 

All new employees will receive a health and safety orientation designed to enable their active participation in JAC health and safety programs. The information provided to new employees will promote their awareness and understanding of the possible hazards at work, as well as the methods to be used to control such hazards.
 

2. Responsibilities 

1. Supervisor

1. Ensures that the JAC HR document The Supervisor's Orientation Checklist for New Employees is completed as instructed.

2. Ensures the employee is enrolled in the appropriate programs (e.g., first aid/CPR, and training sessions) and obtains and uses the equipment necessary to perform his/her job according to JAC health and safety policies (e.g., protective clothing, safety glasses, shoes, hard hats, and government drivers licenses).

3. Discusses and, when appropriate, demonstrates safety practices and equipment (e.g. TSS/Work Leader safety procedures, specific lockout/tagout procedures, safety harness, and eyewash) in the area(s) assigned.

4. Explains pertinent JAC health and safety policies, via the JAC Safety Manual
   

5. Explains use of special equipment and/or facilities.

6. Ensures that the employee attends required health and safety training.

7. Agency Staff; being staff employed directly by the Agencies (STFC, NRC, NWO) and resident within the JAC: The immediate supervisor and the sponsor will ensure that all health and safety requirements are explained to and understood by the agency staff.

2. Site Safety Advisor

Coordinates and conducts training sessions for new employees (e.g., Introduction to Health and Safety at JAC).

3. Administration Department

1. Explains employee's rights, benefits including the "Employee Assistant Program" and JAC requirements in the event of occupational injury or illness.

2. Notifies the Site Safety Advisor of arrival of new employees.

C. Safety Training Plan 

1. Policy.

General safety training will be made available to all employees and specific training plans will be developed to suit the needs of all individuals subject to special or unusual hazards.

2. Responsibilities

1. Supervisor

2. Employee

1. Regularly checks their safety training record and works with their supervisor to schedule their required safety training.
2.    Participates in the safety training program(s) as required. 
   

3. Site Safety Advisor

Schedules safety training courses as requested by staff and/or supervisors.

3. General

1. The Site Safety Advisor conducts and schedules various health and safety training programs ranging from short videos to longer courses. Topics covered include first aid, cardiopulmonary resuscitation (CPR), fire extinguisher use, forklift safety and lockout/tagout.
2. Training provided by the Site Safety Advisor is not intended to replace the supervisors' responsibility for ensuring that employees are properly trained to perform assigned tasks.

4. Safety Training

The frequency of training is determined by the employee's supervisor taking into account Federal and State regulatory requirements.  The current requirements for any employee can be found in the JAC Internal Web.

D. Injury/Illness Reporting and Investigation 

1. Policy and Purpose

Any work related injuries or illnesses involving occupational death; every non-fatal occupational illness; and those non-fatal occupational injuries which involve one or more of the following must be reported to the Site Safety Advisor and the employee's supervisor.

• loss of consciousness
• days away from work
• restricted work activity or job transfer
• medical treatment beyond first aid, or
  
• near misses in which injury was avoided only by good fortune
  

The following, taken from OSHA's  An Overview: Recording Work-Related Injuries and Illnesses, must also be recorded and reported to the Site Safety Advisor and employee's supervisor:

You must also record work-related injuries and illnesses that are significant (as defined below) or meet any of the additional criteria listed below.

You must record any significant work-related injury or illness that is diagnosed by a physician or other licensed health care professional.  You must record any work-related case involving cancer, chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum.  See 29 CFR 1904-7.

What are the additional criteria?
You must record the following conditions when they are work-related:

• any needlestick injury or cut from a sharp object that is contaminated with another person's blood or other potentially infectious material;
• any case requiring an employee to be medically removed under the requirements of an OSHA health standard;
• any Standard Threshold Shift (STS) in hearing (i.e., cases involving any average hearing loss of 10 dB or more in either ear); and
• tuberculosis infection as evidenced by a positive skin test or diagnosis by a physician or other licensed health care professional after exposure to a known case of active tuberculosis.

Whenever an accident occurs involving: loss of life; or injury to three or more employees requiring inpatient hospitalization; or property damage in excess of $25,000, then the Head of Administration or Designated Official shall report the accident by telephone (1-800-468-4644, ext. 9102 or 808-586-9102) or in person to OSHA in the quickest possible manner but in no case shall the time exceed 8 hours. The report shall include all known circumstances of the accident, the establishment name, location of incident, the number of fatalities or hospitalized employees, the extent of any injuries, the time of the incident, contact person and phone number, and the amount of property damage. Additional reports, in writing or otherwise, may be required by the director of OSHA. This requirement applies to each such fatality or hospitalization of three or more employees which occurs within 30 days of an incident.

Exception: If the employer does not learn of a reportable incident at the time it occurs, the employer shall make the report within eight hours of the time the incident is reported.

Any other incidents in which remedial action could improve safety should be reported to the Site Safety Advisor or the employee's supervisor.

2. Responsibilities

a.      Employee

Reports the incident to the Site Safety Advisor and their supervisor within 6 hours of its occurrence.
 

b.     Supervisor

i.        Promptly informs the Head of Administration of the accident.

ii.      Obtains witness statements and assists in accident investigation efforts.

iii.    Completes the Research Corporation of the University of Hawaii (RCUH) Supervisor's Report of Industrial Injury & Accident Investigation form and submit it to the JAC Human Resource Associate in sufficient time to allow it to be reported to RCUH within 24 hours of the incident.

c.     Site Safety Advisor

i.      Insures that all injury/illness reporting forms are completed.

ii.     Reports major incidents involving STFC staff to the STFC Safety Advisor using the UK RIDDOR regulations as a guide.

iii. Reports all safety incidents to STFC using their SHE  (Safety Health and Environment) web reporting system.

d.     Safety Committee Chairman

 Initiates and conducts accident and incident investigations if required.

e.      Administration Department

1. Reports incidents to OSHA or HIOSH (Hawaii Occupational Safety and Health) if required. (One or more fatalities, hospitalization of three or more employees, or property damage in excess of $25,000 must be reported within eight hours.) 
2. Maintains injury and illness statistics and prepares summary reports as required by the Occupational Safety and Health Administration (OSHA), U.S. Department of Labor.

3. Investigation and Review

1. Review the human techniques or actions and uses of equipment or instrumentation involved in the accident.
2. Investigate the circumstances and underlying factors leading to the accident.
3. Identify methods or actions to prevent similar accidental events.
4. The committee will neither assign responsibility nor recommend any disciplinary action.
5. Depending on the level and nature of the findings , some measures may be implemented immediately whereas others may be considered by the Safety Committee. In the former, the Director will be notified and in the latter, recommendations will be made to him.
6. Findings on recommendations will be reported to the STFC Safety Advisor where deemed applicable.
   

E. Risk Assessment 

1. Policy

Three forms of risk assessment are routinely carried out at JAC. The regular safety tours are an "area assessment" of all our work areas. In addition, where non-routine tasks are to be performed, a risk assessment (job assessment) is carried out first by the relevant supervisor with support from the Site Safety Advisor. The third form of risk assessment covers VDT operators, and the Site Safety Advisor has special forms for that purpose.

2. Responsibilities

a.      Employee

Alerts supervisor to situation where a risk assessment may be required. Participates in performing risk assessments, and carry out the required actions.
 

b.     Supervisor

Initiates risk assessments where required, for example in situations where work practices will change or in areas where existing risks have come to light. Ensures that the findings of the risk assessment are acted upon and appropriate equipment is provided.
 

c.     Site Safety Advisor

Assists supervisor in completing risk assessments.  Issues assessment control number to supervisor.

3. STFC Risk Assessment (Standard) Form

4. Guide to filling out the form

The risk assessment number (allocated by the Site Safety Advisor) is of the form "telescope- number- year", e.g. UKIRT-3-1997"

The object of the exercise is to prevent accidents happening by identifying those things about which it might later be said "we should have thought of that". The Site Safety Advisor can give assistance in filling out the form.

A guide to filling out the "Risk Assessment (Standard)" form is available via this link:

http://www.shepublic.stfc.ac.uk/Codes/STFC/SC06%20Risk%20Management/SC6%20Appendix%205a.aspx

F. Relevant Legislation and JAC Policies

1. The Federal law

The underlying legislation for safety in the USA is the Occupational Safety and Health Act of 1970, as amended in 2002. This Act established an Occupational Safety and Health Administration (OSHA), whose job it is to interpret and police the Act. The key part of the Act is Section 5:

"Sec 5.

(a) Each employer -

(1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees;

(2) shall comply with occupational safety and health standards promulgated under this Act.

(b) Each employee shall comply with the occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct."

This is very similar in spirit to the UK Health & Safety at Work Act of 1974.

While section 5 of the OSH Act is sufficient in principle to ensure the safety of staff in the workplace, it would be very hard to enforce without detailed interpretation. This detail is provided in the various Standards that OSHA produces, which are embodied in 29 CFR (which means the Code of Federal Regulations number 29). 29 CFR has many parts, numbered rather haphazardly. Chief among these, as they apply to JAC, is 29 CFR part 1910, also known as "Federal OSHA".

29 CFR 1910 is a substantial book and gives a lot of detail in some areas, less so in others. In order to help people who are trying to obey the standards, there is also a substantial body of written responses to queries from the public on points of interpretation. These take the form of whole letters, and of "frequently asked question" (FAQ) documents.

All of the OSHA standards, the written interpretations, and the whole of the 1970 Act can be found on OSHA's web site at www.osha.gov.

2. Hawaii State Law

The 1970 OSH Act also allowed for States to set up their own standards (effectively, therefore, their own versions of 29 CFR), and Hawaii chose to do so. The standards are available at:
http://hiosh.hawaii.gov/

3. Applicability of Law from staff members' own countries

Many members of staff at JAC are not US citizens. For UK citizens the UK health and safety laws do not apply in the US.  It is however, STFC's policy to harmonize the requirements of UK and US health and safety legislation and where reasonably practicable, to adopt the more stringent requirements.

JAC's policy is to apply the provisions of US law, plus those of UK law where they are known to be more strict and where it is reasonably practicable to do so. 

G.  Role of Designated Official

The JAC has a position entitled "Designated Official" and various references to this position are contained in this manual.  The Designated Official has overarching responsibility for the management actions and decisions that need to be taken in the event of emergencies or unforeseen incidents such as fires, earthquakes or serious injury/death to personnel.  They shall also be the point of contact for the police/media in the event of a major incident involving the JAC, its staff or its facilities.

The position is normally held by the Director JAC. In his absence off-island, another member of the Senior Management Team (SMT) will be named as the Designated Official.  All changes of the Designated Official are notified to staff by email, and are also held at

http://wiki.jach.hawaii.edu/staff_wiki-bin/wiki/JAC_Designated_Official

H. Authorised Equipment Operators 

The following equipment is to be used by authorised operators only. A list of the currently authorised operators is in Addendum 1. Operational use of the telescopes also requires certification (see Chapter 10 Section C)

1. Forklift
2. All Jib Hoists (JCMT, UKIRT & Hilo)
3. JCMT Genie Aerial Work Platform
4. JCMT Manbasket
5. JCMT Overhead Crane
6. JCMT Starlift
7. JCMT Starlift - Lift and Park Only
8. JCMT Emergency Roof and Door Winch
9. JCMT SCUBA-2 Platform Lift
   
10. UKIRT Dome Crane
11. Exposed Live Parts Between 30V and 150V
12. Hilo Vehicle Lift
13. UKIRT Lift-a- Loft Scissors Manlift
14. UKIRT Hyster Forklift
15. UKIRT Hyster Forklift - Relocate and Park
    
16. Genie Z-45/22 Articulating Boom Lift

I. Safety Policies for JAC Staff Working Elsewhere 

JAC Safety guidelines have been carefully drawn up with the aim of ensuring that staff work in a safe manner without excessive requirements - going to another site does not change any of the premises upon which the guidelines are based and in particular does not give any sort of "holiday from risk". Staff should therefore abide by local safety policy and/or JAC policy, whichever is more stringent.