By Roger M. Paveza, CRIS; Vista Safety Consulting

A “successful” safety management system can mean several things; however, the first thing I always look to ask is if your program is truly effective or have you just been lucky?  By consistently following the below cornerstones of safety, it can lead you down the path for a successful safety management program, OSHA compliance, and injury prevention. One study of small employers found that workers’ compensation claims fell dramatically after adopting programs similar to those described in these recommended practices.

Another potential benefit can be when employers are faced with possible OSHA violations and are looking to shift blame to an unruly employee – typically referred to as the “unpreventable employee misconduct” defense.  In rudimentary explanation, an employer is not relieved of responsibility simply because an employee did not follow the rules. In order to even attempt to assert this defense effectively, an employer would have to show complete effectiveness (i.e. consistent documentation) with all below cornerstones.

Safety Programming / Health & Safety Manual

The blueprint of your safety management system starts with your health and safety manual. As several OSHA regulations require a “written safety program/plan,” ensure that policies and work rules contain clear, specific requirements and prohibitions designed to prevent unsafe conditions and violations of applicable OSHA standards. Some key ingredients for a successful Health & Safety Manual include

• Ensuring that the right people are involved and have a voice in the polices.
• Being industry and company specific. Ensure that the programs apply to your exposures.
• Having a qualified safety director or other professional review safety policies on an annual basis or whenever there are important safety-related developments in the industry.  

Communication / Safety Training

Many standards promulgated by OSHA explicitly require the employer to train (or instruct, or communicate, or inform…) employees in the safety and health aspects of their jobs. Other OSHA standards make it the employer’s responsibility to limit certain job assignments to employees who are “certified”, “competent”, or “qualified” – meaning that they have had special previous training, in or out of the workplace.  Also, the term “designated” personnel means selected or assigned by the employer or the employer’s representative as being qualified to perform specific duties. Therefore, ensuring that employees read safety manuals, conducting periodic training for employees, and periodically reviewing work rules (and documenting all of these actions) can help establish adequate communication. 

Here are some simple points to consider to ensure your next safety training is effective: 

1. Action.  Action and interactivity will ensure responses from your audience.  Your audience can’t fall asleep if they are moving around.  You’ll also gain a higher retention from something that is different from the conference room or trailer.  Consider training in the field…remember how much fun field trips were in grade school.  
2. 7-Minute Rule.  90% of workers say they regularly daydream during meetings. Adult attention span is about 20 minutes; however, most people can sit and listen to someone else talk for only about 7 minutes before their minds begin to drift off.  Therefore, trainers should be willing to do whatever it takes to keep their listeners on their mental toes. Pre-program your presentation with ways to surprise your listeners into engaging their minds every 5 to 7 minutes. Keeping your audience guessing “What are they going to do next?” is an effective way to hold their attention.
3. Relevance.  Mix cause and effect stories into your training session and use examples from your own workplace. Show your audience why they should care. If employees are willing, have them tell personal stories of incidents that occurred close to them. This tool helps to minimize the “it can’t happen to me” theory.
4. Humor.  Use humor to get and keep people engaged. Intersperse your presentation with jokes, funny pictures, or video clips. You can probably develop a ‘safety moral’ for just about any funny picture or video clip that comes across your desk.  
5. Credibility.  Credibility is the most important aspect of a successful training program. Make sure you’re prepared. People do not want to learn from experts, they want to learn from people with expertise. Also, keep in mind that a good trainer is also a good listener.

Self-Assessment / Job-Site Evaluations 

One of the most overlooked OSHA regulations is under the subpart “General Safety and Health Provisions” where 29 CFR 1926.20(b)(2) states, “Such programs shall provide for frequent and regular inspections of the job sites, materials, and equipment to be made by competent persons designated by the employers.” As self-assessment may be a painful experience, the failure to identify or recognize hazards that are present is one of the “root causes” of workplace injuries, illnesses, and incidents. A critical element of any effective safety and health program is a proactive, ongoing process to identify and assess such hazards.  

However, the follow-up/corrective action should not be ignored either. OSHA will refrain from issuing a citation for a violative condition that an employer has discovered through a voluntary self-audit and has corrected prior to the initiation of an inspection (or a related accident, illness, or injury that triggers the inspection), if the employer also has taken appropriate steps to prevent the recurrence of the condition. In situations in which the corrective steps have not been completed at the time of the inspection, OSHA will treat the voluntary self-audit report as evidence of good faith, not as evidence of a willful violation, provided that the employer has responded promptly with appropriate corrective action to the violative conditions identified in the audit. Accordingly, if the employer is responding in good faith and in a timely manner to correct a violative condition discovered in a voluntary self-audit, and OSHA detects the condition during an inspection, OSHA will not use the report as evidence of willfulness. A timely, good faith response includes promptly taking diligent steps to correct the violative condition, while providing effective interim employee protection, as necessary.

Accountability / Discipline

Rounding out the aforementioned cornerstones is accountability. I always say, albeit facetiously, that 99% of my clients have a discipline program and 99.9% don’t effectively enforce the one they have. Having a working discipline program is a critical component to an effective safety system. Used in the right way, a discipline program

• establishes an organization’s commitment to safety by enforcing the rules and procedures designed to keep people safe,
• encourages employees to always be vigilant about following safety protocols, especially when engaging in high-risk tasks such as working at heights, in confined spaces, and in excavations, and 
• protects leaders by ensuring follow-through on every rule violation.

About the Author:

Roger M. Paveza, CRIS is President of Vista Safety Consulting and frequently partners with the AssuredPartners team to provide professional and technical advice to the construction industry sector.  He utilizes his knowledge in all aspects of health and safety and risk management to deliver innovative solutions and cost-effective measures for managing clients’ risk.  Questions can be sent to asa@assuredpartners.com