“Most employers think that employees follow common sense,” says Perez. “They don’t, because it is usually based on past life experiences. Unless you have the training programs, the administrative controls and the physical controls machine guarding, proper guard rails, ladders in good conditions, etc. employees will make mistakes because they don’t know what to do or the equipment will fail when you rely on it the most.”
Smart Business spoke with Perez about how conducting mock OSHA audits can be a potent safety control mechanism that controls loss and reduces risk.
What programs can be put in place to help control loss?
A good starting point is the mock OSHA audit because those are the minimum standards. That’s because that is what outside regulators would focus on after an employee compliant or serious injury or fatality. In California, if you have a serious injury such as an amputation, fatality or loss of consciousness, an employer is required to call within eight hours. When they, OSHA, come in, they look at your written and physical controls. Usually, the physical hazards are where they get you the biggest penalties and that’s something that you can’t get insurance for; that’s something that comes out of your pocket.
How does the mock audit work?
I give the company a list of written programs I want to look at, then I come in and we sit together in the conference room and interview different people that oversee the programs such as OSHA compliance, employee training, chemical safety and others. From there, you do a physical audit and see if what you say you do in writing is actually being done in the facility. Are the employees aware of the training? You ask questions like, ‘What would you do if you came across a spill? Where would you go if you need an eye wash?’ And so on. You try to match up what they say in writing with the physical environment and employee practices, and you want to break it down by each program.
If you’re looking at forklift safety, you interview the forklift operators. If you’re looking at lock out/tag out, [a rule that says if there’s a problem you shut down the machine where the problem occurred] you interview the mechanics and employees that are authorized to perform lock out/tag out about the machines they use within their respective departments.
What components are usually covered in mock audits and written controls?
The injury and illness prevention program is a good starting point. That covers company policy, the code of safe practices, which is key because those are the training rules you review with employees. Also, active investigation procedures, disciplinary action rules, etc., everything that’s part of your basic safety program.
In addition, if they use strong chemicals that employees have to breathe in, use or mix, you look at the respiratory and hazard communication program. If they operate machines and do repairs on-site, you’ll need to look at the lock out/tag out program. And you should review the forklift safety program <\m> you are required to train your forklift operators every three years. After that, if you have a noisy environment, look at the hearing conservation program.
How does this apply to services companies?
Usually, when you have ergonomic problems in the office, real estate setting or bank, it’s usually a data entry clerk or someone who is doing the exact same job all day long.
For example, a large parcel company that I worked for had a big location with about 1,000 employees who take in calls and process checks for COD deliveries. They would do data entry all day long with their right hand. The employees’ supervisor would bring them another stack of checks. One of the things that we recommended was instead of bringing them another stack of checks, let them get up, walk 50 feet, stretch a little and let them pick up their stack of checks and walk back.
That was a natural break in their workday. As opposed to having the work brought to you, you got up, stretched out, got some blood circulating to you legs, stretched out your wrists a little.
How often should these mock audits be completed?
One every quarter is a good starting point. Then, throughout the quarter, do a different training program so [employees] are not getting slammed with ‘This is what you did wrong.’ Combine it with a positive. After a year of doing four mock OSHA audits, a business should be ready to run their own program.
When it comes to safety, you don’t want to be a cop, you want to be more like a coach. You want the supervisors to evolve and become more like a coach and a guardian of their group and not so much a cop.
Ed Perez is vice president of risk management at Sander A. Kessler & Associates, a property and casualty insurance and employee benefits firm. Reach him at (310) 309-2304 or through the company’s Web site at www.sanderdessler.com