A big thanks to Mel Manuel Rosas of Pin Point Safety for his comments and input into the following post.
Workplace safety 101: Lessons Learned in Safety Management
Ensuring a safe workplace is a challenge that is made more difficult by staff turnover and constrained resources. In this post, I hope to help pinpoint some of the key items that will help your organization ensure that it is prepared for OSHA inspection. This post will be the basis of my HR.com presentation next week on May 12th. Register here!
The short answer to ‘What you need to do to be ready for an OSHA Audit’ is to follow the full Federal Code and any differences your state might have. Twenty-three states have standards above and beyond what the Federal government requires. Of course, that strategy is not terribly helpful. In reality, your company should start with written safety policies that are approved by management. However, far too many companies stop there – leading to problems with OSHA inspectors.
Not only must you have policies, but they must also be implemented and staff must be up- to- date on their requirements. Each employee must demonstrate to an OSHA inspector that they are aware of what they must to do remain safe based on their role at the company. This includes everything from materials handling and personal protective equipment to confined space permits and lockout tagout procedures. The key for ensuring this level of knowledge is twofold: education and verification.
Education comes in the form of regular training and retraining sessions. These training sessions need to take place for both new and long-term employees and contractors. It is essential that you keep records of who participated in the training, who gave it and when it too place. You can use an online system such as Nimonik to manage this or you can keep the records on your own with Word and Excel files.
When an OSHA inspector does come to your site, you want to ensure that your staff is ready. An OSHA inspector will typically follow your production line, from materials receiving to the shipping of the final product. They will attempt to ensure that all staff and all processes are up-to-speed on their requirements. The only way to ensure that level of knowledge is regular inspections of your location and its staff. Of course, you can use our Audit tool from Nimonik, but this can also be done with pen and paper. The essential part is that you actually use checklists and other tools to keep your staff on their toes.
In terms of testing material, you can use off-the-shelf checklists such as the ones offered by Nimonik. But, a far better solution is to use your own internally-developed checklist. This will force your staff to be involved in the process and invest their knowledge in the company for use by other staff and even for themselves. Your Safety Manager should take time with each person at your location to have them put down on paper all of their knowledge about the safety procedures related to their work tasks. They should indicate the risks involved and list items that they themselves watch out for and that other employees should know about, too. The persons transmitting their knowledge should pretend that someone else needs to replace them tomorrow due to a staff change. Ultimately, this is a Job Hazard Analysis, but since that term can be scary, the best way to frame it is often as a simple explanation of what a job entails and what it requires to stay safe.
When you use these checklists in the field and you find an issue that is amiss , it is essential that you take action. Not only should the direct person at fault be offered assistance to improve the work – through training or another activity – but the staff member’s superiors also need to be informed and made responsible. Demonstration of responsibility is a key element for OSHA inspectors. Your management is as responsible for any safety violations as is the lowest person on the totem-pole, ultimately it is the CEO’s responsibility that all staff members are working in a safe and compliant manner; and management cannot offload that responsibility down the ladder.
The Federal government has a VPP program that companies can adopt to demonstrate proactive safety programs. It is not rocket science. A safe company is one that has fully involved employees and a safety culture that are constantly transmitting the best practices and improving the work environment. Again, using safety tools to signal opportunities for improvement can be done with Nimonik or with a simple Excel and Email system. The key is information gathering and then information transmission.
We hope these tips help you prepare for your next OSHA Inspection and you stay off the below average DART list which currently contains has over 9,000 locations in the United States. Do not hesitate to contact Nimonik for more information, and please come to our Webinar on May 12th to learn more!