The current economic climate has made it necessary for many companies to change the roles of their employees.
Often, this results in company safety responsibilities falling to an employee who may not have much experience in managing and implementing a safety program. This, coupled with a new enforcement-oriented posture from the Occupational Safety and Health Administration (OSHA), can result in a deficiency gap between OSHA compliance and the safety conditions that actually exist in a company, says Brad Swinehart, senior safety consultant at Sequent, Safety & Risk Reduction.
“This enforcement-oriented position is based on recent changes to the OSHA administrative penalty structure — changes that could result in increased fines, especially to employers in high-hazard industries,” says Swinehart. “If your facility does not already have a formal safety and health program, it can be overwhelming to put together a plan to achieve OSHA compliance, especially if you don’t have experience in developing or implementing a health and safety program.”
Smart Business spoke with Swinehart about the steps to take to put you on the road to OSHA compliance and provide a safer workplace for your employees.
What is the first step toward OSHA compliance?
First, conduct and document some form of safety training on a monthly basis.
Many people have the idea that safety training involves spending multiple hours in a conference room watching videos or reading handouts which, to many people, is not the most interesting way to spend their time. But this does not need to be the case. Safety training can consist of a variety of more interactive methods such as:
- Pre-shift toolbox talks require just 10 to 15 minutes and can be used to address a recent workplace safety issue or possibly a hazard associated with a task that may be completed during that shift.
- Hands-on training, such as lockout/tagout procedures, is helpful for those adult learners who learn by doing as opposed to watching videos or reading handouts.
- New hire orientation training is a great opportunity to establish basic safety expectations. Once an employee arrives in his or her department, the supervisor may provide training around specific safety topics.
Proper documentation is another important component of safety training. For every training-related exercise you conduct, provide a sign-in sheet for all employees in attendance. This critical documentation serves as a record of what safety topics have been covered for the year as well as who completed the training.
The method you choose to conduct the training is entirely up to you. However, training success should be judged by effectiveness, not merely by making sure that every employee attends.
Comprehension of training may be measured by using written tests, hands-on demonstration of the task or a combination of both. Some OSHA regulations outline the preferred types of testing to be applied to measure comprehension and verify competency.
What is the next step?
The second step toward OSHA compliance is the implementation of a safety management system. The recommended approach is to use a process based on the ANSI Z10 standards: ‘Plan, Do, Check, Act.’
- Plan: Identify the goals you hope to accomplish.
- Do: Implement your plan to achieve your goals.
- Check: Make sure that your goals were fully accomplished.
- Act: For any goals that were not achieved, take action.
This process is designed to be an iterative process for continuous improvement to your overall safety program. The implementation of a safety management system essentially involves looking for OSHA deficiencies and establishing a means and target date to resolve those deficiencies.
Developing a proper plan can be overwhelming, but it doesn’t need to be. First, identify your goals through an audit of the facility, equipment and observation of employee behaviors. Once these three areas of the audit process have been completed, prioritize the list based on level of risk.
Then develop a plan for how to best mitigate the hazards or behaviors, using administrative and engineering controls, as well as personal protective equipment. During this phase of the plan, it is important to involve all levels of employees which, in most cases, leads to a better, more comprehensive solution.
How can you increase the chances of success?
In order for a process of continuous improvement to be successful, it is important to clearly define the roles and responsibilities of employees, managers and executives. This allows a business to understand who is responsible for what level of the safety program.
In addition, a corrective action log should be developed and maintained to document the actions needed in order to implement the program. This log should identify the task, person(s) responsible for completion and an anticipated completion date. This log is critical for tracking task completion and for identifying accountability of responsible parties.
Once your plan has been developed and implemented, conduct ongoing audits and reviews to determine the effectiveness of the plan. These may consist of employee interviews, observation of tasks being completed, and audits of equipment and facilities.
The data collected from the audits and reviews can then be analyzed to determine the level of success of the plan and of your overall safety program. When deficiencies are found, review your plan and make necessary adjustments in training, policies or equipment to achieve the required results.
Following these steps will provide the tools necessary for the development and implementation of a successful safety program.
Brad Swinehart is a senior safety consultant with Sequent, Safety & Risk Reduction. Reach him at (888) 456-3627 or [email protected].
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