Your Business and OSHA by Sylvia Daves

In the U.S. thousands of workers die each year in workplace accidents.

Hundreds of thousands suffer injuries.

The Occupational Health and Safety Administration, OSHA, has been

established to coordinate government efforts to improve workplace

safety.

OSHA is responsible for: safety analyses and studies; training program

efforts; and regulation development and enforcement.

Most states have individual OSHA programs. These programs must have

standards and enforcement that meets or exceeds Federal OSHA standards.

Another facet of occupational safety and health is Hazard Communication. The

federal government has strict standards for hazard communication including

program development, employee training, and documentation of both

the program and training.

WORKPLACE SAFETY

The Occupational Safety and Health Act was passed by congress in 1970. The

purpose was to "assure so far as possible every working man and woman

in the nation safe and healthful working conditions and to preserve

our human resources."

The Occupational Health and Safety Administration (OSHA) is part of

the U.S. Department of Labor.

The act established the National Institute for Occupational Safety

and Health (NIOSH) as the research arm of OSHA. NIOSH is part of

the Department of Health and Human Services.

In 1989, OSHA issued recommended guidelines for effective management

and protection of worker safety and health. These guidelines are

found in the Federal Register (54 FR (18):3094- 3916, January 26,

1989).

Federal OSHA states that

"Employers are advised and encouraged to institute and maintain in

their establishments a program that provides adequate systematic policies,

procedures, and practices that protect their employees from, and allow

them to recognize, job-related safety and health hazards.

"An effective program includes provisions for the systematic identification,

evaluation, and prevention or control of general workplace hazards,

specific job hazards, and potential hazards that may arise from foreseeable

conditions."

The key facets of a program are:

Management commitment

Employee involvement

Worksite analysis

Hazard prevention and control

Employee training

MANUALS

All employers should have a written safety and hazard program. OSHA

and Workers' Compensation Insurers are requiring written programs.

Weeks or months of time can be spent documenting a comprehensive program,

writing all the necessary procedures, designing and typesetting the

required forms, etc.

But, there are shortcuts. Some insurance companies offer guidelines

on preparing a safety program. There are literally hundreds of independent

safety consultants who prepare manuals for client companies.

These services usually run in the thousands

of dollars. Best's Safety Directory (available from the A.M. Best

Company Oldwick NJ 08858) is a good source of names of safety consultants.

One of the easiest ways to get a written workplace safety and hazard

communication program is offered by System Interface Consultants,

Inc. (SIC is at 865 Via de La Paz, Pacific Palisades, CA 90272. They

can be reached at (310) 454-5316). SIC offers an Individualized Workplace

Safety and Hazard Communication Manual. It is over 100 pages of procedures,

forms and postings to provide the backbone of a company's Workplace

Safety and Hazard Communication program.

Each manual is individualized and typeset with the company name on

each page and throughout the text. Dozens of forms are included to

help document a comprehensive safety program.

SIC's individualized manuals are in four parts -

The manual itself is fifteen chapters defining purpose, authority,

and responsibility for program initiation and maintenance. Specific

chapters deal with hazardous materials, equipment, procedures and

processes. There are chapters on workplace safety communication and

safety committee.

The second part is forms. There are twenty forms for documenting

the program; employee training, suggestions, and recognition, and

hazard identification and correction.

There are corrective action forms, report forms, and a Material Safety

Data Sheet request form. Lots of forms! Each one is individually

printed with the company name.

The third section is supplementary material including required posters

and a safety survey checklist.

The fourth section provides specific information on individual state

workplace safety and hazard communication requirements.

INDIVIDUAL STATE PLANS

Employers located in an OSHA-approved State-plan state must comply

with the workplace safety requirements of that state.

OSHA-approved state plans are required to be "at least as effective"

as the Federal rule but may differ in some respects.

The states with OSHA-approved state plans are:

Alaska, Arizona, California, Connecticut, Hawaii, Indiana, Iowa, Kentucky,

Maryland, Michigan, Minnesota, Nevada, New Mexico, New York, North

Carolina, Oregon, Puerto Rico, South Carolina, Tennessee, Utah, Vermont,

Virginia, Virgin Islands, Washington, and Wyoming.

OSHA wants the states to match their seven-fold increase in penalties.

VOLUNTARY SAFETY AND HEALTH PROGRAM MANAGEMENT GUIDELINES

The Occupational Safety and Health Administration (OSHA) has issued

voluntary program management guidelines to encourage employers to

do more than just comply with regulations to prevent occupational

injuries and illnesses.

Although compliance with the law, including specific OSHA standards,

is an important objective, an effective program looks beyond specific

requirements of law to address all hazards. It seeks to prevent injuries

and illnesses, whether or not compliance is at issue.

The language in these guidelines is general so that it may be broadly

applied in general industry, shipyards, marine terminals, and longshoring

activities regardless of the size, nature, or complexity of operations. Construction

activities are not covered by this guideline because they are already

covered under OSHA's construction standards.

The guidelines, a distillation of successfully applied safety and

health management practices, are advocated by safety and health professionals

and consultants representing corporations, professional associations,

and labor unions.

The extent to which a program is described in writing is less important

than how effective it is in practice. As the size of a worksite or

the complexity of a hazardous operation increases, however, the need

for written guidance increases to ensure clear communication of policies

and priorities and consistent and fair application of rules.

Major elements of an effective occupational safety and health program

include:

Management Commitment and Employee Involvement.

* A worksite policy on safe and healthful work and working conditions

clearly stated so that all personnel with responsibility at the site

and personnel at other locations with responsibility for the site

understand the priority of safety and health protection in relation

to other organizational values.

* A clear goal for the safety and health program and objectives for

meeting that goal so that all members of the organization understand

the results desired and the measures planned for achieving them.

* Top management involvement in implementing the program so that

all will understand that management's commitment is serious.

* Employee involvement in the structure and operation of the program

and in decisions that affect their safety and health, to make full

use of their insight and energy.

* Assignment of responsibilities for all aspects of the program,

so that managers, supervisors, and employees in all parts of the organization

know what performance is expected of them.

* Provision of adequate authority and resources to responsible parties,

so that assigned responsibilities can be met.

* Holding managers, supervisors, and employees accountable for meeting

their responsibilities, so that essential tasks will be performed.

* Annual reviews of program operations to evaluate their success

in meeting the goal and objectives, so that deficiencies can be identified

and the program and/or the objectives can be revised when the goal

and objectives are not met.

Worksite Analysis.

* Identification of all hazards by conducting baseline worksite surveys

for safety and health and periodic comprehensive update surveys. Also

included would be an analysis of planned and new facilities, processes,

materials, and equipment; and another of routine job hazards.

* Regular site safety and health inspections, so that new or previously

missed hazards and failures in hazard controls are identified.

* A reliable system to encourage employees, without fear of reprisal,

to notify management personnel about conditions that appear hazardous

and to receive timely and appropriate responses.

* Investigation of accidents and "near miss" incidents, so that their

causes and means for prevention are identified.

* Analysis of injury and illness trends over extended periods so

that patterns with common causes can be identified and prevented.

Hazard Prevention and Control.

* Procedures that ensure that all current and potential hazards are

corrected in a timely manner through engineering techniques where

appropriate, safe work practices understood and followed by all parties;

provision of personal protective equipment; and administrative controls,

such as reducing the duration of exposure.

Safety and Health Training.

* Ensure that all employees understand the hazards to which they

may be exposed and how to prevent harm to themselves and others.

* Ensure that supervisors and managers understand their responsibilities

and the reasons for them so they can carry out their responsibilities

effectively.

*****

Sylvia Daves is Vice President of System Interface Consultants, Inc.

She manages user support operations.

You can reach Sylvia at (310) 454-5316

Back 14.05.2006.