ComplianceOctober 19, 2020

Developing an OSHA compliant workplace safety program

You can use OSHA requirements as a guide to developing and implementing a safety program for your workplace. For a program to be effective, you need to analyze your work site and involve your employees in the process.

The first step to establishing an effective safety program for your workplace is to become knowledgeable regarding what your requirements as an employer are under the Occupational Safety and Health Act. Once you know what your requirements are for purposes of OSHA, you can use those requirements to help you set up a workplace safety program.

Your plan should consider your company's immediate needs and provide for on-going, long-lasting worker protection. Once your plan is designed, it is important to follow through and use it in the workplace. You will then have a program to anticipate, identify, and eliminate conditions or practices that could result in injuries and illnesses.

If you have difficulty in deciding where to begin, checking with your state consultation program (or the services of a private consultant) will get you the assistance you need. A consultant will survey your workplace for existing or potential hazards. Then, if you request it, he or she will determine what you need to make your safety and health program effective. The consultant will work with you to develop a plan for making these improvements and to establish procedures for making sure that your program stays effective.

Tip: Since the passage of the Americans with Disabilities Act, there are several complex issues within the broad scope of safety planning. In the event that you feel you have a conflict between the laws (for example, your safety program appears to prohibit you from making certain accommodations for a disabled worker), seek advice from an experienced attorney or consultant.

The process to develop a workplace safety program will require analyzing your workplace and is likely to involve your employees in the creation. Basically, you need to concern yourself with the types of accidents and health hazard exposures that could happen in your workplace. Because each workplace is unique, your program will differ from that of your neighbor or competitor.

Analyzing your work site

It is your responsibility to know what you have in your workplace that could hurt your workers. Work site analysis is a group of processes that helps you make sure that you know what you need to keep your workers safe. You may need help in getting started with these processes. You can call on your state OSHA Consultation Program or employ private consultants for this help.

Gather specific facts about your situation. Before you make any changes in your safety and health operations, you will want to gather as much information as possible about the current conditions at your workplace and about business practices that are already part of your safety and health program. This information can help you identify any workplace problems and see what's involved in solving them.

The assessment of your workplace should be conducted by the person responsible for the safety and health program and/or a professional safety and health consultant.

  • Request a consultation visit covering both safety and health to get a full survey of the hazards that exist in your workplace and those that could develop.
  • Establish a system, such as vendor consultations, to get expert help when you make changes and to be sure that the changes are not introducing new hazards into your workplace. Also, find ways, such as through trade groups, to keep current on newly recognized hazards in your industry.
  • Make a commitment to look carefully at each type of job done in your workplace from time to time, taking it apart step-by-step to see if there are any hidden hazards in the equipment or procedures. Some initial instructions from a consultant may be necessary.
  • Set up a system of checking to make sure that your hazard controls haven't failed and that new hazards haven't appeared. This is usually done by routine self-inspections.
  • Provide a way for your employees to let you know when they see things that look harmful to them and encourage them to use the process.
  • Learn how to do a thorough investigation when things do go wrong and someone gets sick or hurt. This will help you find ways to prevent recurrences.
  • If you've been in business for a while, take the time to look back over several years of injury or illness experience to identify patterns that can lead to more effective prevention. Thereafter, periodically look back over several months of experience to determine if any new patterns are developing.

Fulfilling your work site safety requirements

After you complete a work site analysis, act on your assessment by fulfilling the requirements you discover. Once you know what your hazards and potential hazards are, you are ready to put in place the systems that prevent or control those hazards. Your state or private consultant can help you do this. Whenever possible, you will want to eliminate those hazards. Sometimes that can be done through substitution of a less toxic material or through engineering controls that can be built in. When you cannot eliminate hazards, systems should be set up to control them.

Here are some actions to take:

  • Set up safe work procedures, based on the analysis of the hazards in your employees' jobs, and make sure that employees understand the job procedures and follow them. This may be easier if employees are involved in the analysis that results in those procedures.
  • Be ready, if necessary, to enforce the rules for safe work procedures by asking your employees to help you set up a disciplinary system that will be fair and understood by everyone.
  • Where necessary to protect your employees, provide, at your own cost, personal protective equipment (PPE) according to published standards and be sure that your employees know why they need it, how to use it, and how to maintain it.
  • Provide for regular equipment maintenance to prevent breakdowns that can create hazards.
  • Plan for emergencies, including fire and natural disasters, and drill everyone frequently so that if the real thing happens, everyone will know what to do, even under stressful conditions.
  • You must ensure the ready availability of medical personnel for advice and consultation on matters of employee health. This does not mean that you must provide health care. But if health problems develop in your workplace, you are expected to get medical help to treat them and their causes.

In order to successfully fulfill the above requirements, consider the following:

  • Have an emergency medical procedure for handling injuries, transporting ill or injured workers, and notifying medical facilities with a minimum of confusion. Posting emergency numbers is a good idea.
  • Survey the medical facilities near your place of business and make arrangements for them to handle routine and emergency cases. Cooperative agreements could possibly be made with nearby plants that have medical personnel or facilities on-site.
  • If your business is remote from medical facilities, you are required to ensure that a person or persons be adequately trained and available to render first aid. Adequate first aid supplies must be readily available for emergency use. Arrangements for this training can be made through your local Red Cross chapter, your insurance carriers, your local safety council, and others.

Engaging employees in the workplace safety process

The beginning steps of safety programs usually start with a clean-up effort to get employees engaged in the process. Poor housekeeping is a major contributor to low morale and sloppy work in general, even though it is not usually the cause of major accidents. Most safety action programs start with an intensive cleanup campaign in all areas of business to get the attention of the staff.

Get everyone involved and impress upon them exactly what it is that you want to do to make your workplace safer, more healthful, and more efficient. Consider a cleanup for the entire facility.

To start the cleanup:

  • get rid of rubbish that has collected
  • make sure that proper containers are provided
  • see that flammables are properly stored
  • make sure that exits are not blocked
  • if necessary, mark aisles and passageways
  • ensure the adequacy of lighting

Tip: You may be able to recycle some of your refuse. Your green effort will be rewarded if you can get cash for your recycling and use the proceeds to fund the safety committee's reward program.

At all times, demonstrate your personal concern for employee safety and health and the priority you place on them in your workplace. Your policy must be clearly set. Only you can show its importance through your own actions.

As the owner, your attitude toward job safety and health will be reflected by your employees' behavior. If you are not interested in preventing employee injury and illness, nobody else is likely to be.

Demonstrate to your employees the depth of your commitment by involving them in planning and carrying out your efforts. If you seriously involve your employees in identifying and resolving safety and health problems, they are more likely to commit their insights and energy to achieve the goals and objectives of your program.

If you have at least a few employees, consider forming a safety committee. This can assist you in starting a program and will help maintain interest in the program once it is operating. Committees can be an excellent way of communicating safety and health information. If you have few employees, consider rotating them so that all can have an active part in the safety and health programming.

Here are some actions to take:

  • Post your own policy on the importance of worker safety and health next to the OSHA workplace poster where all employees can see it.
  • Hold meetings with all of your employees to communicate that policy to them and to discuss your objectives for safety and health for the rest of the year. If appropriate, consider an annual safety meeting to showcase activities and recognize achievement.
  • Make sure that you, and any managers or supervisors, follow all safety requirements that employees must follow, even if you are only in their area briefly. If, for instance, you require a hard hat, safety glasses, or safety shoes in an area, wear them yourself when you're in that area.
  • Use your employees' knowledge and help them buy into the program by having them make inspections, hold safety training, and help to investigate accidents.
  • Make clear assignments of responsibility for every part of the program that you develop and make certain that everyone understands them. The more people involved, the better.
  • Take time, at least annually, to review what you have accomplished against what you set as your objectives and decide if you need new objectives or program revisions to get where you want to be.
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