How does your Safety Program Stack up?
A well-managed company may have an effective safety program that is integrated into the
company's policy and procedures. Another company may have an encompassing safety
program that outlines every last job in detail. Which is the best? It is my opinion that both are
the best for the company that uses the program. When OSHA initiates an inspection and a
citation is issued the common employer's response is that the worker acted on their own and
disregarded company rules. When OSHA issues a citation based on an employee act, they
usually have a checklist that outlines the following items.
- Employee Experience. If the worker does not have documented proof of experience and
training the employee's action cannot be used as evidence that the employee acted on
their own volition
- Employer Safety Program. If any parts of the safety program are missing, the
employee is assumed to have acted under the direction or lack of direction of the
- Employer Safety Program Enforcement. OSHA looks for the steps taken by the
employer to enforce the safety rules. Many times they want to see a specific rule that
was broken. "Act safely" "Safety First" for example will not cover a worker who
should be wearing a hard hat, but is not. "Hard hats Required on all job sites" will
- What is the employees' knowledge of the rule's violation? OSHA can ask workers to
tell them what the Safety rules are. The language spoken on the job site is considered,
safety rules must be understood as well as distributed.
- How are safety rules enforced, what happens when there are violations? You will need
to show that your safety program has been enforced. That someone has been advised
that they have broken the rules. You will have to prove that the worker knew that they
could be fired if they were caught disobeying a safety rule.
- The final item on the check list item is the Independent Employee act exemption. If the
person breaking a safety rule is a supervisor then the company is not able to claim
independent employee action. Does anyone who is in charge ever bend or break safety
rules? OSHA will determine if the person observed breaking the safety rule was a lead
person or supervisor. If they are any part of the management team, then there is no
excuse, the fine can be fully applied.
My question is, "Does your particular safety program address the above items?". When you
have meetings or worker training sessions are you documenting the training? Is the right
information effectively communicated to your people.
Check your management program for all the italicized items. If you can get a perfect score, I
believe that you have evidence of an effective safety program. Otherwise, you may want to
improve the safety management at your company. For help, check out the recommended
safety program from the web site http:\\www.dnacih.com under the Safety Info section, and
look at the links page for other agencies and associations that can help you with your safety
program. The links page will help you find the regulations that affect you.