How to Build Communication and Recordkeeping Best Practices into Your Safety Program

Every worker needs to have the latest relevant safety information before they clock-in. For that to happen, safety communications need to do more than exist: they need to be effective. 

Effective safety communications within an organization must flow in both directions, from management to employees and from the “shop floor” to management. 

In Part 4 of our Ultimate Guide to Safety Management Systems series, Dave Paoletta shows you what it takes to build communication and recordkeeping directly into your safety system.

Are you new to the series? Go back and read Part 1, Part 2, and Part 3.

How to Achieve Effective Safety Communication

Implementing a safety management program depends on employee involvement and acceptance. As a result, you must make an effort to inform workers of any expectations, explain why you need the program or procedure, and share how it will benefit the organization. In other words, successful workplace safety communication relies on frequent and meaningful interactions.

The effectiveness of  management and the Safety Department communication depends on several factors:

1. Credibility. Studies show employee perceptions of management’s sincerity and credibility influence the attitude change produced by management messaging. In other words, if the employees feel they are being “sold” something that may be good for the company but isn’t also good for them, they will likely ignore it. Avoid implementing poorly conceived programs and procedures, pursuing frequent policy or process changes, and making unkept promises. These management behaviors destroy credibility, and communication will suffer.
2. Attractiveness. In communications, “attractiveness” is defined as how comfortable the message receiver feels with the message-sender. We are more likely to listen and respond to a message from someone we think is “like us” and has our best interest in mind. As above, if the workers feel that management is not considering the worker, they are less likely to act on the safety information.
3. Power. Although management has the authority to enforce policies and procedures through oversight and progressive discipline, you will find framing compliance with new rules as necessary to maintain a safe and efficient workplace is a better approach. The absence of management follow-up on new “requirements” or rules will often lead to a lack of employee acceptance.

Ultimately, effective safety messages depend on worker perceptions, such as: 

1. Is management as interested in my safety as they say?
2. Is my supervisor really enough like me to be believable or so different as not to be trusted?
3. Is my supervisor’s power over me real? Must I comply with safety rules? (Ref: Safety Management: A Human Approach, Third Edition. Petersen, Dan. American Society of Safety Engineers, 2001. P. 174)

An Introduction to Safety Communication Techniques

The following sections contain some examples of safety communications techniques used by various U.S. industries.

Publications and Bulletins

The most basic form of safety communications is written (and emailed) materials such as: 

• safety bulletins
• lessons learned communications
• upcoming training classes, 
• new safety initiatives or team events 

Written material posted on bulletin boards, in cafeterias, restrooms, and other gathering areas is useful in plants where most of the workforce don’t regularly access a computer during the working day. All written material must use clear fonts and colors, and the content kept brief and to the point. Posted written material should also be current and updated frequently. Out-of-date and non-applicable posts lead employees to ignore all subsequent postings as they associate these communications with being generally outdated.

Employee Safety Team or Committee

Safety Committees or Safety Teams are powerful communication and hazard recognition tools. However, they can just as easily be a complete waste of time and effort.  The key to success is to train and orient team members and support them to yield concrete results in the workplace. The team charter must focus on the target of finding and controlling hazards.  Key advantages of the Safety Team approach to hazard recognition and control are:

1. Pooling the group’s experience and expertise. The collective experience, together with the opportunity to brainstorm problems, results in developing practical and innovative solutions.
2. Opportunity for groups of people to work together in committee meetings results in improved communications and a personal understanding of the challenges faced by different workgroups.
3. The committee’s recommendations, especially on controversial issues, are usually accepted more positively by others in the organization.

Here are a few points to keep in mind when creating a safety committee. Membership Composition 

• The number of participants depends upon the number of employees. 
• The committee must have an equal number of employer-selected and employee-elected (or volunteer) members.
• The leader should select members from all parts of the organization.
• Membership should be for a specified term and rotate (so members stay fresh). 

Membership Requirements 

• Election of a chairperson. 
• Serve a minimum of one year, when possible. 
• Be trained in hazard identification (see link below).
• Be trained in communication skills for team-members. 
• Be trained in incident investigation principles and know how to apply them.
• Receive safety committee meeting minutes. 
• Represent the major activities of the Operational Units/company divisions 

Duties 

• Meet monthly. 
• If employees mostly do low hazard work, then the safety committee may meet quarterly. 
• Meetings must occur on company time and be performed via a conference call, if necessary. 
• Keep a record of each meeting for three years, including:
  •  Meeting date
  • Attendees’ names
  • Name of the person who will follow up on the recommendations
  • All other committee reports, evaluations, and recommendations.
  • Safety and health issues discussed; include hazards involving tools, equipment, the work environment, and work practices.
  • Recommendations for correcting hazards and reasonable deadlines for management to respond.

Safety Committee Goals: 

• Establish a system for employees to report hazards and suggest corrective actions.
• Establish a procedure for reviewing inspection reports and recommending corrective actions.
• Evaluate all incident investigations and recommend how to prevent a recurrence.
• Make safety committee meeting minutes available for all employees to review.
• Recommend ways to strengthen your Operational Unit’s overall safety effort.

How and When to Use Safety Incentives and Rewards

The research on the effectiveness of safety campaigns and initiatives shows a limited impact in many cases. 

Instead, creating a coordinated communications strategy to announce a new program or approach is useful for capturing the workforce’s attention and build interest.

Additionally, if the initiative changes an established way of doing something or seems to affect a real or perceived employee benefit, it’s imperative to carefully plan the roll-out. For a change that might be controversial, you should include all stakeholders in the planning phase. Employee concerns and feedback gathered and dealt with before the rollout. If your program doesn’t take employee feedback on board, the initiative is probably doomed to failure.  Some other rules of thumb are below:

• Define a specific problem or issue for the effort to address. Don’t launch a safety campaign just because you think the safety department needs attention.
• Always get approval from senior management and written agreement on goals, methods, budget, and duration of the safety initiative before proceeding.
• Always involve Union stewards (if applicable), supervisors, and workgroup leaders to design, plan, and implement safety campaigns.
• Minimize the number of safety campaigns/initiatives per year — the fewer, the better!
• Define the goals and key success metrics for each campaign/initiative to gauge its effectiveness.
• End campaigns or initiatives when you meet the goal or if the campaign proves ineffective. In other words, don’t keep beating a dead horse.

Properly designed and implemented safety campaigns that address real issues that employees accept and buy-in are great tools for communicating needed process changes to employees.  However, safety campaigns don’t take the place of regular two-way communication of safe work practices, hazard reporting, or collaborative problem-solving. These practices are the keys to building and maintaining effective safety programs over the long term.

Incentive Programs

The goal of most safety incentive programs is to promote safe work behaviors by offering a tangible reward for employees who deliver the desired outcome.  The idea that workers modify their behavior in desirable ways to receive positive reinforcement or a reward seems to be common sense. Additionally, “Operant Conditioning” has been studied and written about by scholars of human behavior like Edward Thorndike, John Watson, and B. F. Skinner for decades. 

Unfortunately, although the science underlying the work is well-founded, incentive programs’ effects on worker safety have not been directly established.  Before implementing an organization’s incentive and reward program, management should ask what the real goal is.

Too often, incentive programs are a reaction to poor safety performance, as indicated by unacceptably high injury and incident rates. Other times, incentive programs exist to address employee dissatisfaction and inadequate corporate or safety culture.

Incentive programs are not standalone tools for improving company culture, employee/management relations, or driving incident and injury reduction. Rather, incentives may be a useful part of a broader strategy to engage workers in the safety program or highlight a specific program or procedure change.

OSHA does not require employers to offer safety incentive programs as part of their safety program management system. It warns against programs that offer high-value incentives that might deter reporting, so workers don’t lose a prize. Avoid programs that reward employees for avoiding injuries or achieving a certain number of “injury-free days’. These programs lead to peer pressure because they are group-based. If one person is injured, everybody loses the reward. Instead, design your incentive program to reward specific behaviors that are easily observable and deemed beneficial to working safely or complying with safe work procedures. 

Below are nine tips for designing an effective safety incentive program:

1. The behaviors required to receive an award are well-defined and achievable.
2. Everyone who meets the behavioral standard should receive a reward.
3. It would be best to avoid penalizing groups for failure by an individual unless they can control the individual’s performance.
4. It’s better for many people to get small rewards than for one person to get a large reward.
5. Do not reward one group at the expense of another.
6. Progress towards awards should be monitored and publicly posted.
7. The rewards should be displayable and represent safety achievement.
8. Reward programs should have defined time limits and be started, stopped, and changed frequently. 
9. After concluding a safety incentive program, perform a review (“hotwash” or after-action session) to determine if it met the stated objectives and what lessons will inform future efforts.

If designed and implemented thoughtfully, safety incentive and reward programs can be a useful part of the management-employee safety communication process and promote a positive atmosphere towards safety in the organization.  Beware of “off the rack” or commercial incentive programs that claim fantastic results at other companies. Instead, evaluate them based on the guidance above and your specific objectives for the incentive program before buying.

How to Get Started with Recordkeeping

Proper recordkeeping is vital for the Safety Management System because it enables meaningful assessments, allows for long-term trend analysis, and verifies compliance with regulatory standards.

The organization must segregate and manage records from the various EHS activities with the degree of rigor appropriate for each. For example, meticulously filing First Aid Kit inventory and inspection sheets is equivalent to saving all of your receipts for donuts; it’s neither required nor cost-effective. It only creates more paperwork.

Other records, such as exposure test data or personnel exposure monitoring results, should be treated more formally. You must maintain the appropriate level of confidentiality around any document containing Personal Identifiable Data or PII. 

The US Department of Labor defines PII as:

Any representation of information that permits the identity of an individual to whom the information applies to be reasonably inferred by either direct or indirect means. Further, PII is defined as information: (i) that directly identifies an individual (e.g., name, address, social security number or other identifying number or code, telephone number, email address, etc.) or (ii) by which an agency intends to identify specific individuals in conjunction with other data elements, i.e., indirect identification. (These data elements may include a combination of gender, race, birth date, geographic indicator, and other descriptors). Additionally, information permitting the physical or online contacting of a specific individual is the same as personally identifiable information. This information can be maintained in either paper, electronic, or other media. 

Any document or record containing PII must remain in a locked file or encrypted computer database. Access should stay on a need to know basis. Typically, the Human Resource Department maintains the information, given they have the most training and experience in safeguarding PII. The EHS Office can maintain less sensitive records, such as safety training records, facility/shop/laboratory inspections records, incident investigations, and corrective action reports. Chemical Safety Data Sheets (SDS), air sampling and exposure monitoring data and reports, not containing PII, shall also be maintained by the EHS Department. 

Below are some examples of records and their maintenance requirements:

• Maintain medical records for each employee for the duration of employment plus 30 years unless a specific standard requires a different retention period. These include chemical Safety Data Sheets, Records of Bloodborne pathogen exposure incidents, respiratory protection medical evaluations and fit tests, and any chemical exposure testing records. Some medical records, such as audiometric test results and PPE training records, only need to be kept for the duration of an individual’s employment.
• Retain the annual OSHA-300 Log, Annual Injury and Illness Summary, and incident Report Forms (either OSHA’s or your state’s equivalent) for at least five years.
• Maintain safety training records for at least three years, but it is wise to keep them for each individual for the duration of employment.
• Keep noise monitoring (area monitoring, not personnel monitoring) records for at least two years, and
• Hold on to Lockout Tagout program inspections and canceled Confined Space Entry Permits for one year. However, it is wise to keep the LOTO evaluations for the duration of employment.

The Safety Management Program should include written guidelines for document and records management to comply with the above. To be effective, you should also design it to:

• Be located and accessed by more than one person. Often, a company is left not knowing where the records are or how to access them when a vital member of the HR or EHS team retires or leaves the company! Digitizing your documents and records is a simple way to keep them secure and accessible.
• Be accessible and in a format that can be transferred to a regulatory authority such as OSHA or the EPA within 24 hours if requested during an inspection.
• Be comprehensive enough (especially training records) to determine the training’s content and quality after the fact.
• Incident investigation records should also contain corrective actions and proof of completion of any corrective actions.

You Don’t Have a Safety Program if You Don’t Have Communication

Every single safety program demands communication and recordkeeping components. Without these, you stand no chance of success or compliance.

The good news is that there are many tools at your disposal, so with some research and ingenuity, you have what you need to build a safety communication program that truly speaks to your team.

That’s a wrap on our Ultimate Guide to Safety Management System series. Are you ready to get your program up and running? Let Safesite be your partner. Check out our always-free features, or get in touch to schedule a personal walkthrough of the app.