Safety Program Review and Assessment
The main purpose of establishing a Safety Program Review and Assurance program is to identify and prioritize areas for continuous improvement. Although certain programs are required to be periodically reviewed to comply with OSHA standards, the various types of assessments, surveys, inspections, and interviews do not exist to check a box. They provide insight into the effectiveness of your safety programs and information on how we might improve upon what we have in place.
By proactively assessing our programs, we identify risks before events occur or before outside assessments identify these risks for us. This allows the Company to demonstrate proactive management of the program. In turn, taking these actions helps build confidence with stakeholders, management, and outside regulatory agencies.
Depending on what specific written safety programs apply to your company, most require an annual review or an annual training refresher. A partial list is below:
- Lockout/Tagout – Review of written energy control procedures AND observations of authorized employees performing LOTO
- OSHA 300 Log posting (Feb 1 to April 30)
- Hearing Conservation – Annual audiograms for employees, hearing conservation training
- Bloodborne Pathogens – Exposure Control Plan review and update
- Process Safety Management – Operating Procedures
- HAZWOPER – Annual refresher training
- Crane and Hoisting – Annual inspection by a Qualified Person
- Respiratory Protection – Annual medical questionnaire, Employee Fit Testing
- Portable Fire Extinguishers – Annual Inspection/certification & Employee Training
- Asbestos Program – Annual Awareness Training/retraining
- Lead Program – Annual Awareness Training/retraining
The goals of the program review and assurance system are to:
- Ensure that ES&H systems are effective, improving over time, complying with their guiding regulations, and properly implemented the company
- Identify and manage issues on a risk-based, graded-approach
- Identify trends and resolve deficiencies
- Monitor the effectiveness of controls and work performance
- Promote continuous improvement
- Communicate performance to key stakeholders and provide them with information to make informed management decisions
Program self-assessments are subject matter expert (SME)-driven reviews and assessments of the programs under their management. The SME may be from the EHS Department or a team of knowledgeable and experienced individuals in the program area (i.e., a maintenance electrician assessing the Electrical Safety Program).
Although SME-driven, program assessments should be a collaborative effort with feedback and input from affected stakeholders. The goal of the program assessment is to determine the following:
- Do programs meet compliance requirements?
- Are effective controls in place and used?
- Is there active and effective communication between EHS and stakeholders?
- Are employees following requirements even when EHS or management is not looking?
Inspection Records and Audit Reports
Accurate inspection records are important. They serve as evidence of the inspection program, provide documentation of necessary corrective actions, and provide a follow-up method to ensure completion. One of the easiest methods to record an inspection is to use a checklist.
You can find checklists in the Safesite template database. You can also build your own templates and tailor them to suit your individual requirements and upload them to your Safesite account.
Checklists have several advantages. However, they don’t work as a replacement for inspections. They are no substitute for informed employees performing a careful observation of the workplace.
The use of checklists is especially helpful during periodic inspections of particular equipment. Qualified persons should inspect such items as conveyors, hoists, cranes, fire extinguishers, sprinkler systems, scaffolding, and ladders on a compliance-based schedule.
You can use preventive maintenance software to schedule these types of programmed periodic inspections and operational readiness checks. However, any means of ensuring that equipment is checked on a schedule that is in accordance with manufacturers and OSHA requirements are adequate.
You should create a summary report to discuss the program audited, the purpose and scope of the audit, audit team members, information and documents reviewed, and number of interviews or other data collected.
A comparison of findings with the requirements of the written program (i.e., a Gap Analysis) can then describe both areas for improvement and areas that comply with the requirements. Finally, generate a list of corrective actions, with a responsible person or group assigned and estimated completion date.
Manage findings from self-assessments in accordance with the company’s Corrective Action Tracking or Issues Management process.
Observations and opportunities for improvement made by the audit team need to be evaluated and ranked for resolution. Some are simple and straightforward and will be initiated and completed by the SME directly with little guidance. Others may be complex, interfacing with other programs across multiple organizations and requiring significant resources to resolve. These issues will be shared with management and risk-ranked. Management will make decisions about actions to take and monitor high-priority issues to completion.
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