Safety: It's More than a Company Slogan

Kevin Lindley, FRSA Self Insurer’s Fund Safety Consultant

I always find it distasteful to use the slogan “Safety First.” I cringe every time I hear someone say it. It’s a phrase that some contractors often fall back on concerning their safety policies. We must do more than simply give our workers equipment and tell them to “be safe” every day.

OSHA has been extremely busy during the first quarter of 2024. There have been record site inspections completed on both residential and commercial jobsites. Since the Orlando office opened two years ago, there are increasingly more Compliance Officers present and more are being hired. With that initiative, every contractor is encouraged to ensure their documentation and records are up to date regarding their safety policies and procedures.

In the roofing industry, OSHA’s primary focus is always fall protection. Falls continue to be the leading cause of work-related injuries and fatalities and currently OSHA has a special emphasis directive focusing on fall protection. Although fall protection is the primary safety concern, OSHA looks beyond fall protection policies and procedures and has begun to scrutinize every aspect of the company’s exposures and liabilities during the course of an investigation.

Let’s review what documents OSHA has typically requested of a contractor immediately following a site inspection by a Compliance Officer. They include:

• training records
• company safety program
• safety meetings and trainings
• site inspections
• disciplinary action policy and records of action taken
• OSHA 300, OSHA 300A log and OSHA 301 forms for the past three years
• fall protection plan for the jobsite
• list of employees by position and any certifications.

In reviewing many safety and loss control programs, OSHA will note that the document should be reviewed and updated accordingly on an annual basis. Many of the programs also clearly identify the topics (fall protection, ladder safety, hazard communication, GHS/SDS, PPE, electrical) that all employees must be trained on, annually, as well as new hires before being sent into the field to work.

I cannot stress this enough – ALL TRAINING MUST BE DOCUMENTED – otherwise, OSHA does not consider it to have been completed. Review your programs and coordinate training or establish a schedule for the year to have the training completed.

Document annual harness inspections by field personnel. There are many forms available online to download and print at no cost which will help you document training. Harnesses are identified by the serial number printed on the label of the harness, not the user.

In roofing we use a lot of equipment, ladders and machinery. All equipment should be inspected on an annual basis (or more frequently) and that inspection also documented. Damaged equipment must be either repaired by a competent person or properly disposed of or destroyed.

Companies need to take safety seriously – safety shouldn’t be just another slogan or a sign on the wall. Safety is a constant necessity and should be taken into consideration in all work activities. OSHA compliance should not be the primary goal for updating policies or training workers. The goal of safety is to make the company and workforce better and to ensure that the potential for accidents or injuries on the job is decreased or eliminated.

FRSA members have access to over 250 free Toolbox Talk documents in the Members Login section of the website, www.floridaroof.com. Download and incorporate them into your own safety program.

FRM

Access to workers’ comp coverage is available to all FRSA members. To find out if you qualify for FRSA-SIF workers’ comp insurance, please contact Alexis at 800-767-3772, ext. 206 or email alexis@frsasif.com. To learn more about the FRSA Self Insurers Fund, please visit www.frsasif.com.