If you run a small business, sometimes it is hard to keep up with all the rules and regulations. However, there are some very basic elements that must be implemented into a management system. One example is Occupational Safety and Health Administration’s (OSHA’s) Proposed 'I2P2' Rule. According to OSHA, the proposed rule will “require employers to develop and implement a program that minimizes worker exposure to safety and health hazards.”
No one really knows what the proposed rule will look like, but we can usually make a good guess. So, to help with some these Safety program elements, OSHA’s "Safety and Health Program Management Guidelines", published on January 26, 1989 provides some limited guidance that you can follow.
In many of the voluntary programs, OSHA outlines five elements that will help you to create a successful management system. From my standpoint, although management and employee participation is complementary and forms the core of an effective safety and health program, I want to make sure that there is a clear and distinct difference between management of the operation and employee participation. It will be easier to implement a management system if you understand what OSHA is considering a model system and then expand on the model to fit the organization. The following are the core elements of an effective management system:
- Management leadership
- Employee participation
- Hazard identification and assessment
- Hazard prevention and control
- Information and training
- Evaluation of program effectiveness
An effective management system addresses work-related hazards, including those potential hazards that could result from a change in workplace conditions or practices. In addition, it addresses hazards that are not regulatory driven by nature. The best advice is to not wait for an inspection or a workplace injury to occur before workplace hazards are addressed. If you do not already have a plan in place, then you should immediately create a plan for identifying and correcting hazards, and then implement the elements of the plan. The key is to have employees participate in the development and implementation of the plan.
It is a good practice to implement and maintain a management system that provides systematic policies, procedures, and practices that are adequate to protect employees from safety hazards. In other words, an effective system identifies provisions for the systematic identification, evaluation, and prevention or control of workplace hazards, specific job hazards, and potential hazards that may arise from foreseeable conditions.
No matter if a safety program is in writing or not is less important than how effective it is implemented, managed, and practiced. It should be obvious that as the size of the workplace, the number of employees, or the complexity of an operation increases, the need for written guidance will increase. The program should help to make sure that there is clear communication to all employees with consistent application of policies and procedures.
Management leadership from the top down is the most important part of any process. "Lip service”, is not going to work and does not demonstrate commitment. Management demonstrates this commitment by providing the motivating force and the needed resources by including at least the following:
· Establishing the roles and responsibilities for managers, supervisors, and employees at all levels of the organization and holding each level accountable for carrying out their assigned responsibilities.
· Providing managers, supervisors, and employees with the authority, access to relevant information, training, and resources needed to carry out their responsibilities.
· Identifying at least one manager, supervisor, or employee to receive and respond to reports about safety conditions and, where appropriate, to initiate corrective action.
Just to make it clear, demonstration means “do as I do” and not “do as I say.” This is an important concept, no matter what you are tying to accomplish, always “walk-the-walk, and talk-the-talk”. If you say that you are going to do something, do it!
Employee participation provides the means for employees to develop and/or express their commitment to themselves and/or their fellow employees. Therefore, in any successful system, employees should be provided an opportunity to participate in establishing, implementing, and evaluating the safety system. To fulfill and enhance employee participation, management should implement some form of the following elements:
- Regularly communicating with all employees concerning safety matters.
- Providing employees with access to information relevant to the safety system.
- Providing ways for employees to become involved in hazard identification and assessment, prioritizing hazards, safety training, and management system evaluation.
- Establishing procedures where employees can report work-related hazards promptly and ways they can make recommendations about appropriate solutions to control the hazards identified.
- Providing prompt responses to reports and recommendations.
It is important to remember that under an effective safety system, management encourages and supports employees to report safety hazards and making recommendations about associated hazard, or participating in the corrective actions for hazard as noted.
A practical hazard analysis of the work environment involves a variety of elements to identify existing hazards and conditions as well as areas subject to change that might create new hazards. Using management techniques coupled with employee participation and continually analyzing the work environment to anticipate and develop programs to help prevent harmful occurrences will help to identify hazards. The following elements are recommended to help identify existing and potential hazards:
- Conducting a baseline workplace assessment, updating assessments periodically, and allowing employees to participate in the assessments.
- Analyzing planned and/or new facilities, process materials, and equipment.
- Developing routine job hazards analyses and training employees on the hazards noted.
- Assessing risk factors of ergonomics applications to employee’s tasks.
- Conducting regular site safety inspections so that new or previously missed hazards are identified and corrected.
- Providing a reliable system for employees to notify management about conditions that appear hazardous and to receive timely and appropriate responses. This system utilizes employee insight and experience in safety and allows employee concerns to be addressed. And the most important, the employee should be encouraged to use this system without fear of reprisal.
- Investigating injuries, "near misses," and loss producing events so that their causes and means of prevention can be identified.
- Analyzing injury trends to identify patterns with common causes so that they can be reviewed and prevented
Hazards that employees are exposed should systematically be identified and evaluated. This evaluation can be accomplished by assessing compliance with the following activities and reviewing safety information for example:
- The establishment's injury experience.
- The OSHA 300 logs
- Workers' compensation claims (Employers First Report of Injury)
- Nurse and/or first aid logs
- Results of any medical screening/surveillance
- Employee safety complaints and reports
- Environmental and biological exposure data
- Information from prior workplace safety inspections
- Material Safety Data Sheets (MSDS’s)
- Results of employee safety perception surveys
- Safety manuals
- Safety warnings provided by equipment manufacturers and chemical supplier
- Information about safety provided by trade associations or professional safety organizations
- Results of prior incidents and investigations
- Evaluating new equipment, materials, and processes for hazards before they are introduced into the workplace
- Assessing the severity of identified hazards and ranking those that cannot be corrected immediately according to their severity
It is also important to evaluate other regulatory requirements that may impose additional and specific requirements for hazard identification and assessment.
Effective planning and design of the workplace or job task can help to prevent hazards. Where it is not feasible to eliminate hazards, action plans should be implemented that can help to control unsafe conditions.
Elimination or control should be accomplished in a timely manner once a hazard or potential hazards are identified. The following are some suggested measures:
- Using engineering techniques where feasible and appropriate
- Establishing safe work practices and procedures that could be understood and followed by all affected employees
- Providing personal protective equipment (PPE) when engineering controls are not feasible
- Using administrative controls. For example, reducing the duration of exposure
- Maintaining the facility and equipment to prevent equipment breakdowns
- Planning and preparing for emergencies and conducting training including emergency drills, as needed, ensuring that proper responses to emergencies will be "second nature" for all employees involved
- Establishing a medical surveillance program that includes handling first aid cases onsite and off-site at a nearby physician and/or emergency medical care to help reduce the risk of any injury that may occur
Once identified, an action plan should be developed to help solve the issues or can be used to come into compliance with applicable requirements. These plans can include setting priorities and deadlines and tracking progress in controlling hazards.
Training is an important part of any program to ensure that all employees understand the requirements of the safety programs and potential hazards of the operation. This training should address the roles and responsibilities of both the management and the employees. It will be most effective when combined with other training about performance requirements and/or job practices. The complexity depends on the size and the nature of the hazards and potential hazards present. The following information and training should be provided to all levels:
- The nature of the hazards and how to recognize them
- The means to control these hazards
- The protective measures that can be used to prevent and/or minimize exposure to hazards
- The provisions of applicable requirements
Anyone who has responsibilities for the information and training should be provided the level of training necessary to carry out their safety responsibilities.
The following provides a brief explanation for some specific-level training. You should review your operation and expand on the brief summary.
Employee training programs should be designed to ensure that all employees understand and are aware of the hazards that they may be exposed and the proper methods for avoiding such hazards.
Management must be trained to understand the key role they play in safety and to enable them to carry out their job duties effectively as follows:
- Analyzing of the work under their supervision to anticipate and identify potential hazards
- Maintaining physical protection in their work areas
- Reinforcing employee training on the nature of potential hazards associated with their work and on protective measures. The reinforcement is done through continual performance feedback and, as necessary, through enforcement of safe work practices
- Understanding their roles and responsibilities
Note that some compliance standards impose additional, more specific requirements for information, training, and education. Make sure that you read specific training requirements.
Evaluation of Program Effectiveness
The management system should be evaluated to ensure that it is effective and appropriate to specific workplace conditions. The system should be revised in a timely manner to correct any deficiencies as identified by any program evaluation. It is important that system elements be reviewed at least annually to evaluate their success in meeting the goals and objectives so that deficiencies can be identified and the program and/or the objectives can be revised when they do not meet the goal of an effective safety process.
The key to developing a management system is to provide visible top management involvement in implementing and sustaining the management system so that all employees understand that management’s commitment is serious.
Resources: OSHA’s "Safety and Health Program Management Guidelines", published on January 26, 1989
"Developing an Effective Safety Culture: A Leadership Approach" by James Roughton