Safety Program Reviews: Prepare Now, Save Later

Eighty percent of workers are unable to complete safety and hazard reports. Safety starts at the top and at the individual, but flows through the entire organization. What’s your safety IQ?

Facts:

• Studies show that corporate policies and procedures for safety programs in the workplace are written above the literacy level of the average worker to comprehend and understand.
• Younger generation workers have a clear fear of reporting work-related mishaps and concerns, due to being the newbies, and not sure of what the result will be in their keeping their jobs.
• Twenty years ago, it was easier to tell what was or was not a work-related injury because most of the workplace injuries that led to disability were traumatic incidents.

The last quarter/first quarters of each year are hectic times for most U.S. businesses. They are closing out our current year results, and at the same time setting budgets and goals for the coming year. It’s been the same sequence for decades—“We always do it this way.”

One document required to be submitted and posted by federal statutes is your OSHA 300 work-related injuries and illnesses report. Employers with more than 10 employees and whose establishments are not classified as a partially exempt industry must record using OSHA Forms 300, 300A and 301. (Partially exempt industries include establishments in specific low hazard retail, service, finance, insurance or real estate industries.) Employers who are required to keep Form 300, the injury and illness log, must post Form 300A, the summary of work-related injuries and illnesses, in a workplace every year from Feb. 1 to April 30. Current and former employees, or their representatives, have the right to access injury and illness records.

As a printer, when do you look at your safety programs and measure performance?

Although most OSHA standards only require the business to update policies when things change, we don’t always recognize those changes when they happen. For this reason, there should be a pre-planned review time for all the safety rules in your organization. Just as we encourage annual health checkups for our employees, an annual review of the safety program just makes good sense.

Start by reading the safety plan and your “right to know” procedures. Pay particular attention to the responsible persons named in the plans and make sure they are still the best ones to handle the job. Hand-written changes are acceptable, but the plan should be retyped when the changes start to clutter the document. Put a revision date on the new plan and keep the old one for at least seven years (just like any other business records).

Next, make sure you have documentation that shows all staff members have received initial safety training. Don’t forget the part-time and seasonal employees in this review. For many work functions, occupational training is necessary—make sure that all certificates are current, and log the expiration dates for future reference, too. (This is also a good time to update your HR files for such things as valid driver’s licenses and social security cards.)

Employee turnover rates: Statistics say that the higher the turnover, the higher the incidence rate. What do you do to properly train and integrate new employees into your workplace safety and production programs?

Set aside time for a short safety review training session. Don’t forget to keep a record of what was discussed and who attended. There are seven or more common programs that OSHA requires annual refresher training. If you have not conducted these in the past 11 months, now is a good time to get them on your calendars. OSHA fines can be up to $500 per individual if not current on refresher training.

Typical topics covered include: electrical safety, lock out/tag out, slips-trips-falls, welding safety, ladder safety, fire safety/extinguishers, machine guarding and maintenance, PPE, respiratory, right-to-know, back injury/safe lifting, bloodborne pathogens.

Also, remember that since OSHA standards require employees to receive fire safety refresher training on an annual basis, it’s also a great time to reemphasize some of the rules that the staff has been less than diligent in following.

Now’s a great time to give the labeling program a boost, too. Take a look at the labels on all your secondary chemical containers and replace those that are missing or not readable. If you have not developed a GHS compliance plan, now is the perfect time to do so.

Take a walk around the building, inside and out. Look for any new safety hazards and any old ones that need additional attention. This periodic physical review of the practice shows that you take safety seriously and that you try very hard to prevent problems before they start.

Finally, keep a record of the review; coordinate findings with your safety committee and responsible management personnel. Set a plan of action with defined dates for completion, then ensure tasks have been completed and signed off with dates. Let your employees know of findings—ask for feedback and suggestions. Many significant cost-saving ideas have come from employees because they see things from a hands-on perspective.

Most small businesses know what they should be doing, but don’t have the tools or experience on how to go about doing it. Below is a suggested outline of a typical year-end annual review program.

An annual business health and safety audit is recommended for all businesses. The employer must have arrangements for monitoring and review of employee well-being and safety measures.

The objectives of this annual review are:

1. Review of health and safety system, identification of areas of low/non compliance.
2. Identification of employee training needs to create a safer working environment.
3. Assessment of key hazards within the workplace, which will require a risk assessment.
4. Effectiveness of existing audits and management controls.
5. Recommendation for improvement actions for senior management team.

The health and safety annual audit is divided into the following sections:

1. General policy and organization;
2. Work operations and physical arrangements to be considered;
3. Physical plant and workplace considerations;
4. Other hazards;
5. Emergencies;
6. Communication;
7. Training;
8. Supervision;
9. Records, logs and audit checks—documentation and retention procedures;
10. Consideration of general risks identified during risk assessment;
11. General observations; and
12. Fire precautions and observations.

This annual health and safety audit should be supplemented as appropriate by the assessment checklists available for specific hazardous issues. If individual hazards are identified, these should be recorded and assessed on a hazard risk assessment form. All actions that are required as a result of the audit should be recorded and monitored on the health and safety annual audit action plan.

In conclusion, performing year-end analysis and performance reviews of your safety plan and procedures can significantly impact your bottom line. Make safety part of your key closing activities for 2013, won’t you please?

About the Author
Dale Rothenberger has more than 20 years of experience in business transformation and program process management. He is available for consultation and can be reached at d.rothenberger@zeemedrdg.com or at (484) 239-6925.