OSHA regulations and standards apply to virtually every industry. In some cases only a few standards (such as Exit Routes and Recording/Reporting Occupational Injuries and Illnesses) apply. On the other hand, many industries are heavily regulated (think construction, manufacturing, laboratories, and biotech companies).
Most companies do their best to develop the industrial hygiene and safety programs that OSHA requires. Large companies with dedicated health and safety professionals have an advantage in this arena. Mid- and small-sized companies are often hindered by limited health and safety budgets and a lack of skilled resources. Very small companies are often uninformed about the OSHA regulations, overwhelmed by all that they have to do, and simply don’t know where to start.
Has your company established and implemented health and safety programs that are required of them? How do they stack up? Are they considered “best in class”? Read on to learn about 5 common industrial hygiene and safety program shortfalls.1. You have too few – or too many – programs. The process of determining which programs apply to your workplace is not always straightforward. Read the scope and/or application section of the OSHA Standard in order to understand which regulations apply. These sections sometimes include exclusions that require careful consideration. Think twice before you say that your company is “grandfathered” out of a regulation. These clauses are few and far between.
Secondly, don’t be too quick to incorporate a program that doesn’t apply to your site. For example, many companies develop and implement a Bloodborne Pathogen Program even though they are not required to do so. Remember that OSHA will hold you accountable for any program that you have in place – including those that don’t apply to your company. Think twice before you take on more than you have to.2. Your written programs lack necessary information. More often than not, we see written programs that merely repeat the regulation. This regurgitation of the OSHA Standard is unnecessary and sends the regulator who is reviewing your program a strong signal that he/she should dig deeper. Your written program should be customized to your facility and explain how you comply with the OSHA requirements (example, “lockout-tagout equipment is located in the central control room”, “completed confined space permits are retained by the safety coordinator”).
Background and educational information should be kept out of the program document and instead be incorporated into the employee training session. Remember, when it comes to written programs, less is more. Lengthy documents are confusing at best and damning at worst. Finally, don’t forget to periodically review your health and safety documents and update them as needed.3. You have poor recordkeeping and records management. Did you know that OSHA mandates that certain records be kept for specific time periods? For example, most fire extinguisher and fire alarm records must be retained for a period of 5 years. Medical and exposure monitoring records generally need to be retained for 30 years or longer.
You may decide to keep records that aren’t required by OSHA. For example, some companies use a written inspection checklist to comply with OSHA’s requirement to examine powered industrial trucks at least daily. A close reading of OSHA’s Powered Industrial Truck Standard reveals that a written checklist is not required. When you’re deciding what health and safety records you need remember the saying “if it isn’t written down, it didn’t happen”.4. Your training program is inadequate. Let’s start with the trainer – he/she must be qualified, competent, and know the subject matter inside and out. Trainers that simply show slides and respond to questions with vague answers will quickly discredit you and your program. Remember to verify that the training sessions include all the information that OSHA requires.
And finally, make sure that your workers understand the information that is presented to them. Are you using words and terms that they understand? Do any of them need a translator? Do you evaluate them at the completion of the training session in order to determine that they understood the material and can incorporate the health and safety requirements into their jobs?5. There is no safety accountability. Do you hold your workers accountable for their safety behavior? What happens if they disregard your company’s safety policies, practices, and procedures? Do you recognize and/or reward positive safety behavior?
Your reactions to negative and positive behaviors sends a very strong message to your workers. A failure to address negative safety behavior signals apathy or even approval on your part. Conversely, acknowledging desired safety behaviors sends a strong positive message to your worker which will promote continued good behavior.
It’s important to highlight that a lack of safety accountability can get you – the supervisor or manager – in hot water. Let’s say a worker of yours is blinded because he/she did not wear the safety glasses that your company requires. An OSHA investigation ensues. Telling OSHA that “it’s the employee’s fault, we have a safety glasses policy and he/she ignored it” will be of limited help. On the other hand, if you show OSHA documentation that you counseled and/or disciplined the employee on more than one occasion when you observed him/her not wearing their safety glasses you are demonstrating that you hold your employees accountable for their safety behaviors.
Do any of the shortfalls described above sound familiar? Have you implemented all of the written industrial hygiene and safety programs that apply to your company? Are you sure you’ve identified all of the regulations and standards that apply?
Cashins & Associates, Inc. can help you no matter where you are in your safety and health compliance journey. We can identify the regulations that apply to your company, develop written programs, deliver regulatory-required training and more! Click on the link to submit your request. We look forward to hearing from you!