Kevin Lindley, Loss Control Consultant, FRSA-SIF
Work safe. Drive safe. Be safe. What does it all mean? Is the translation of “safe” lost in just another phrase we carelessly throw out there when we speak to one another; or, is it a heeding of caution, warning that the world is indeed not safe and that we need to keep our mind focused on our actions so that we can be part of the cure of an unsafe situation? Safety in a company begins with management, who must set goals and commit the resources to achieve those goals. Safety is achieved only when management and employees work together to identify workplace hazards and actively participate to prevent or control them through a safety program.
A safety program is not just a 3-ring binder with printed pages sitting on a shelf in an office. It’s a document that provides the written words of what the company and its employees’ rules of conduct are. The program should be accurate, up-to date, known, reviewed, put into action and most importantly, enforced. A good safety program is focused on identification and assessment of hazards in the workplace to control or prevent them.
The safety program of a company is a vital document to be kept on file and referenced when there is confusion or when an issue arises. The document should include company policies regarding all aspects of office, road, and site safety, as well as employee expectations and disciplinary action for those who do not follow the rules. The safety program should be fully reviewed, updated annually and adjusted when new safety issues arise. Once reviewed, any modifications, additions added, or removals made should be noted and distributed to all employees.
Job site-specific literature produced such as a Job Hazard Analysis (JHA), Activity Hazard Analysis (AHA), Fall Protection Plan, Hazard Assessment Plan, Hazard Communication Plan and all Safety Data Sheets (SDS) should also be kept available on file. In new construction, many times the general contractor or owner’s representative will request a copy of the documents they require in addition to the above noted documents; copies of their forms should also be kept. When a site-specific document is created, review the document with the foreman or crew leader prior to mobilizing on the site. In unique site conditions, a documented site visit may also be required.
Additional documentation should also be examined and maintained. Supporting documentation for any scheduled training, including the sign-in roster of those who attended, the material covered or discussed as well as copies of any certifications issued should be kept on file. When employees are issued certifications, it is a good idea to record and track the certifications so that they can be updated prior to expiration. Employee training programs must be evaluated and consistently improved upon. Always remember, if it’s not documented, it’s like it never happened.
All activities involved with the new-hire process should also be documented and signed by both the new-hire individual as well as the employee who provided the documents, tools/equipment, training, and/or presentation included in the process. New-hire employees should be instructed and trained prior to being sent into the field to work, regardless of their prior work history. Never assume, simply based upon their reported experience, that they know or have been shown how to do things to your company standards or
expectations. It is a good idea to pair experienced employees with the new-hire employee and keep a close eye on their performance as the new-hire employee is often more likely to be injured or cause damage on the job.
Field management, such as supervisor, foreman and lead man, should have a higher level of safety training and knowledge than those under them. They must be competent in any situation they encounter, including disciplinary action toward other employees. If they do not personally possess the knowledge of all situations, they should have a trusted and good advisor available to them for reference or confirmation. Their focus should not be solely dedicated to production in the field; they must also be a company safety representative for those around them. When an unsafe situation is observed, it is their responsibility to immediately address the issue and have it resolved prior to allowing the work to resume. They should also be held accountable for their actions and conduct
themselves as an example in the field for others.
Another key component of a company’s safety program is the OSHA 300 logs. Companies with 10 or more employees are required to keep a record of serious work-related injuries and illnesses on the OSHA Form 300, 300A and 301 logs. Based upon the number of employees, the OSHA Form 300A is required to be submitted to OSHA on an annual basis using the Injury Tracking Application (ITA) online. Just a reminder; 2017s OSHA Form 300A is due on or prior to July 1, 2018. Also, employers must report any employee fatality directly to OSHA within 8 hours, and any amputation, loss of eye, or hospitalization of an employee within 24 hours. This report may be made over the phone or online. The OSHA Form 300A (Summary of related injuries and illnesses) is required
to be posted in a visible location at the place of business from February 1 through April 30 each year.
All employees of a company, from administrative to field workers, need to be aware of the company safety policies and follow them. If they do not follow the policies, the rules must be enforced. Failing to enforce the policies could makes them void in the eyes of OSHA and other government entities. When creating disciplinary actions for employees, companies should be cautioned to create a fair and balanced procedure to address the violations such as a three-strike policy. An example of this would be a written warning on the first offense, retraining on the second offense and possible termination on the third violation.
When looking at your company’s safety, many aspects are taken into consideration. The most visible aspect at first glance is the compliance of the individual employee; however, after further investigation, the full view of the safety “Culture” in a company includes much more. Starting with management, processes, behaviors and full management support, creating a “Safety Culture” is a practical goal which is fully obtainable.