Who Needs New Year’s Resolutions?

OSHA DRAFT S-H Program Cover-1Most of us do the same thing on New Year’s — Make resolutions we don’t keep:

  • Lose weight
  • Eat more vegetables
  • Get organized

Sound familiar?

And yet, these resolutions are important. If they weren’t, we wouldn’t waste time even thinking about them. So, we set up the goals even if we aren’t sure we can reach them because, as we all know, there are only so many hours in a day.

You know another goal that’s important? Knowing that everyone goes home today. You’ve heard me talk about it before — it is something I feel strongly about. It’s why I support the OSHA mission of assuring safe workplaces, even though at times I may disagree with some of the requirements. Fortunately, the safety goal can be reached. Really!

How? OSHA is working on updating its Safety & Health Program Management Guidelines. To use OSHA’s own words: “…the new guidelines build on the previous version, as well as lessons learned from successful approaches and best practices under two OSHA programs — Voluntary Protection Program (VPP) and Safety and Health Achievement Recognition Program (SHARP), and similar industry and international initiatives such as ANSI/AIHA Z10 and OSHA 18001.”

I know it’s a mouthful, but it’s a great mouthful. It shows that OSHA is not working in a vacuum, but instead is using the experience of what did and did not work to update guidelines meant to make the job site safer for everyone. What does this mean for you? More realistic guidelines. More realistic guidelines are easier to understand and implement. It means that you can develop a Safety & Health program that makes sense and works for you. (See how reaching that safety goal is already starting to look easier?)

The updated guide will, obviously, overlap with some existing OSHA guidelines (as seems to be the case with many OSHA rules and regulations). It will also help you “comply with existing standards.1” Fortunately, the guideline appendix contains a list of General Industry and Construction standards that fit together. While not comprehensive, it does provide a good starting point and again, make writing your Safety & Health plan that much easier.

So how does this not-yet-published guideline help you plan for safety in 2016? Simple! Review the draft document and use it as a guide to create your 2016 Safety & Health Program. The guideline is relatively short for a government publication and stands at 44 pages at the time of this writing. You can access it at the link above or from the LeadSMART website at www.leadsmarttraining.com/osha. The link is right at the top of the page.

If you’ve never written a S&H Program before, you may be wondering where to start. Well, the publication helps you there, too. As part of the Introduction, it contains the section “How to Use the Guidelines” and the final document will include several tools such as a handy checklist in the appendix. (Like I said earlier, this goal is starting to look easier and easier, right?)

But let’s be honest: You’re busy and may not have time to review the document. You barely have time to write your 2016 Safety & Health Program much less implement it. That’s why I’ve highlight important features of the guidelines to get you started.

The draft document covers 7 major areas OSHA calls Core Elements. Each of those elements talk about what to focus on to help ensure a safe work environment. Let’s review. (Much of the information below is pulled directly from the guidelines so you can feel comfortable that it’s coming from the “horse’s mouth.”)

Management Leadership

Management provides the leadership, vision, and resources needed to implement an effective safety and health program. Management leadership means that business owners, CEOs, managers, and supervisors at all levels:

  • Lead by example and establishes employee safety and health as a top priority.
  • Sets expectations of the program and employees (communicate!).
  • Ensures resources are available to implement safety and health initiatives appropriately.

Worker Participation

Workers generally know the most about their jobs and potential hazards. A S&H Program will be ineffective without meaningful participation of workers and (if applicable) their representatives in creating and executing the program. Worker participation means that all workers, including contractors, subcontractors, and temporary staffing agency workers: I recommend using your S&H program as a measuring tool for your subcontractors.

  • Emulate the example of management leadership by participating in the program.
  • Report violations (without fear of repercussion).
  • Be able to provide input for all levels of the program.

Hazard Identification & Assessment

A proactive, ongoing process to identify and assess hazards in order to fix them is a core element of any effective safety and health program. Failure to identify or recognize hazards is frequently one of the “root causes” of workplace injuries, illnesses, and incidents and indicates that the safety and health program is ineffective. Hazard assessment can lead to opportunities to improve program performance.

  • Recognize that this is an ongoing process and periodic inspections are necessary to ensure existing hazards are removed and new hazards are identified.
  • Identify any injury trends to address underlying hazards.
  • Create a corrective action plan for identified hazards.
  • Ensure there is a plan for emergencies.

Hazard Prevention & Control

Effective controls protect workers from workplace hazards generally; prevent injuries, illnesses, and incidents; minimize or eliminate safety and health risks; and help employers provide workers with safe and healthy working conditions. The processes described here will help you prevent and control the hazards you identified in the previous section of these guidelines. Hazard prevention and control means:

  • Investigate and select hazard controls that are feasible and effective for the situation.
  • Write, communicate to the organization, and implement a hazard control plan.
  • Evaluate, evaluate, evaluate, and adjust as necessary.

Education & Training

Workers who know about workplace hazards and the measures in place to control them can work more safely and be more productive.

  • Communicate all aspects of the program to employees frequently to include discussion and feedback to ensure it is understood at all levels.
  • Train employees who will implement specific hazard controls or other processes.
  • Train employees on their responsibilities as part of the Safety & Health plan as well as how to identify hazards.

Program Evaluation & Improvement

Periodically step back and evaluate what works and what does not, and whether you are on track to achieve your program goals. Evaluate the program initially to verify that it has been implemented as intended and on a regular basis once it is established. Whenever you identify opportunities to improve the program, make adjustments, and monitor how well it performs as a result. Share the results of your monitoring and evaluation within the workplace to help drive further improvement.

  • As with hazard identification and assessment, evaluating the program itself is an ongoing process and needs to be done periodically.
  • Ensure the program is actually implemented and that management and employees are involved.
  • Evaluate the efficacy of the program and make corrections/improvements where needed.

Coordination & Communication on Multi-employer Worksites

Does this Core Element even apply to you? Unless you NEVER accept other employers’ workers at your job site (i.e., plumbers, electricians, mechanics, any type of subcontractor) and your own staff is NEVER assigned to a job site controlled by someone else, then this section will apply to you.

  • Ensure the subcontractors are trained about the safety and health program on site.
  • Make the subs comfortable with communicating back, not only with questions, but with identified potential hazards.

There is considerably more information in the guidelines than the high level review above. Do your best to make the time to become familiar with the new guidelines to ensure you create the right, and best, safety and health program for your company. You may ask yourself, why go to all this effort? Because I know that just like me, you want everyone to go home today and every day.

And, if you like making your 2¢ known, OSHA is taking comments on the new guidelines until February 15, 2016. To make a comment, go to: https://www.osha.gov/shpmguidelines/index.html.

One last point I’d like to make: My OSHA instructor taught me that my Safety & Health Program should say what you do and then do what is said. Pretty basic, but easy to forget in the mad rush of daily life. However, that is also why a “canned” or off-the-shelf plan probably won’t work for you unless you take the time to customize. You need to make sure your S&H Program fits the unique needs of your business and how you run things. Otherwise, it will be difficult to follow or hold anyone to the standard you are trying to set.

So that’s it! Now you’re ready to meet your New Year’s safety resolution, right? I know that you can reach that goal and that you’ll find it’s easier than you think. There are lots of resources out there to help you create the plan that works for you.

Speaking of resources, we at LeadSMART are here to help. If you have a question on your Safety & Health program, a site situation or even an upcoming project, feel free to contact the LeadSMART Training Solutions office and ask for me, Peter. Our help is free of charge and we are not EPA or OSHA agents so we welcome you to speak freely. Located in Southern New Hampshire and covering CT, MA, ME, NH, and VT, you can also email me at peter@leadsmarttraining.com.

Stay Healthy, folks.

Peter & the LeadSMART Team

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