662 HAZWOPER for General Site Workers III

"Foreseeable" Hazards

Another important question to ask about the nature of a hazard relates to whether it was "foreseeable." Safety managers should address the question of foreseeability during the root cause analysis phase of an accident investigation. A hazard for which OSHA issues a citation must be reasonably foreseeable. All the factors which could cause a hazard do not need to be present in the same place at the same time to prove foreseeability of the hazard (an explosion need not be imminent). For example:

• If combustible gas and oxygen are present in sufficient quantities in a confined area to cause an explosion if ignited but no ignition source is present or could be present, no OSHA violation would exist.
• If an ignition source is available at the workplace and the employer has not taken sufficient safety precautions to preclude its use in the confined area, then a foreseeable hazard may exist.

It is necessary to establish the reasonable foreseeability of the general workplace hazard, rather than the hazard which led to the accident. For example:

• A titanium dust fire may have spread from one room to another only because an open can of gasoline was in the second room. An employee who usually worked in both rooms was burned in the second room from the gasoline. The presence of gasoline in the second room may be a rare occurrence. It is not necessary to prove a fire in both rooms was reasonably foreseeable. It is necessary only to prove the fire hazard, in this case, due to the presence of titanium dust, was reasonably foreseeable.

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